Damex Uncovered: Inside Europe’s Fintech Star

Few start-ups have repositioned themselves as rapidly and ambitiously within the European fintech and crypto regulatory landscape as Damex. Established in Gibraltar in 2017 under the name Digital Asset Management Ltd (“DAM”), the company was originally founded to assist clients in buying, managing, sending and storing digital assets in a regulated environment.

According to its official website, the firm was co-founded by Sam Buxton, Thomas Johnson, Jeremy King, Scott McKim and Philip Vasquez. The company states that each of these individuals continues to play a strategic role in its operations. Mr Buxton is now Chairman, Mr McKim is Chief Operations Officer, Mr Vasquez is Chief Legal Officer, Mr Johnson is Operations Director and Mr King is Chief Investment Officer.

Damex’s senior leadership team also includes Kriya Patel (Chief Executive Officer), Pete Burgess (Chief Commercial Officer), Alexandra Carreras (Chief Financial Officer), Miguel Ortega (Chief Marketing Officer), Ricardo Abunassar (Chief Technology Officer), Erwin Gerritsen (Chief Product Officer) and Carol Molina (Chief Executive Officer for the Americas). Each brings specific expertise in regulatory technology, digital payments and business development across both crypto and traditional finance sectors.

This executive structure reflects Damex’s evolving identity as a cross-jurisdictional payments firm, positioning itself at the intersection of compliance, blockchain infrastructure and international fintech. According to the Damex teams page a total of 36 people are employed (that already includes interns and assistant’s as well).

Public records held by Gibraltar Companies House indicate relatively modest financial activity during the early years. By 2024, Damex was actively marketing itself as a “borderless payments ecosystem” operating across several jurisdictions, including Gibraltar, Malta, Lithuania, the Isle of Man and Spain. This expanding footprint has drawn attention from industry stakeholders and regulators. Our seven-part investigation will examine the company’s trajectory, corporate structure, regulatory compliance and key partnerships.

From crypto brokerage to regulated payments network

Archived promotional materials and public disclosures show that Damex initially offered crypto acquisition and custody services tailored for high-net-worth individuals. Clients could transfer fiat currencies to Damex’s accounts in Gibraltar, with the company facilitating the purchase and transfer of cryptocurrencies such as bitcoin and ether. This service model was developed under Gibraltar’s Distributed Ledger Technology (DLT) regulatory framework introduced in 2018.

Over time, Damex expanded into fiat onboarding, payment services, card issuance and its own retail platform. The company obtained an electronic money institution (EMI) licence in Lithuania in 2023 and a Class 3 Virtual Financial Assets (VFA) Service Provider licence in Malta in 2024. Each authorisation widened Damex’s market reach and brought additional jurisdiction-specific obligations, including requirements for capital adequacy, local staffing and compliance oversight.

Ownership structure and legal entities

Public records and company disclosures show that Damex Group’s holding structure is anchored in Gibraltar, with The Experience Holding Limited registered as the parent company. Operating under this umbrella, Damex has several subsidiaries across different jurisdictions, including:

• Digital Asset Management Ltd (Gibraltar)
• Damex Digital Ltd (Malta)
• Damex.io UAB (Lithuania)
• Damex IOM Limited (Isle of Man)
• Damex Managementspain SL

Each entity is subject to its respective national legal and regulatory framework and, based on official filings, has its own board of directors. Various individuals from Damex’s executive team hold senior or governance roles across more than one subsidiary.

As of 2025, Sam Buxton is Chairman of Damex and Scott McKim is Chief Operations Officer. Mr McKim is listed in certain regulatory roles within the group’s Gibraltar operations. Philip Vasquez, a barrister admitted in Gibraltar, is Chief Legal Officer and plays a central role in group-level legal and governance matters.

In Malta, Dr Justine Scerri Herrera is recorded as a director of Damex Digital Ltd. She is also affiliated with MK Fintech Partners Ltd, which provides registered office services to the formerly Malta-licensed VFA entity through their role as a representative of Michael Kyprianou Law Firm and the Maltese CSP Michael Kyprianou Services Ltd. These connections will be explored in the Malta-specific instalment of this series, alongside the MFSA’s guidance on substance and outsourcing requirements.

The presence of overlapping senior roles across different regulated entities is not unusual for fintech groups with a unified operational strategy.

However, such arrangements can prompt legitimate regulatory questions about operational independence, governance controls and the segregation of regulated functions. These aspects will be examined further in parts three and four of this series, with reference to statutory obligations in each jurisdiction.

Revenue channels and business model

Damex does not publish consolidated group accounts. Director reports filed in Gibraltar suggest revenue streams include:

1. Conversion spreads between wholesale crypto markets and retail clients
2. Interchange and processing fees via Modulr Finance B.V. (EU) and Modulr FS Ltd (UK)
3. Ancillary services such as token listings, staking rewards and OTC commissions

The company has stated that it has achieved compound annual growth above 80 percent since 2021, though these figures have not been independently audited by us. Article six will examine Damex’s reliance on Modulr, whose UK filings record continuing operational losses.

Jurisdictional regulation and local substance

Damex operates under multiple regulatory regimes, including:

• Gibraltar’s DLT regulations overseen by the Gibraltar Financial Services Commission
• Lithuania’s e-money regime under the Bank of Lithuania
• Malta’s legal framework is supervised by the Malta Financial Services Authority and the Financial Intelligence Analysis Unit
• Isle of Man’s regime for value-backed tokens following Damex’s acquisition of Blackfridge EX

We are currently not sure what Management services the Spanish company offers and of this imposes additional requirements. But we will be looking into these matters, including those governing marketing and foreign exchange compliance, if they apply. Whether Damex maintains sufficient operational substance in these jurisdictions will be analysed in later articles.

Executive leadership and regulatory roles

Company disclosures and Damex’s own website list the following senior executives:

• Kriya Patel – Chief Executive Officer
• Sam Buxton – Chairman and Co-Founder
• Scott McKim – Chief Operations Officer and Co-Founder
• Philip Vasquez – Chief Legal Officer and Co-Founder
• Thomas Johnson – Operations Director and Co-Founder
• Jeremy King – Chief Investment Officer and Co-Founder

In addition, certain individuals are listed in regulated roles across the group’s licensed subsidiaries:

• Dr Justine Scerri Herrera – Director of Damex Digital Ltd (Malta), affiliated with MK Fintech Partners and Michael Kyprianou Law Firm
• Romanas Ramanauskas – Compliance Officer for Damex.io UAB (Lithuania)
• Grecia Ballard and Nick Maybin – Responsible persons for Damex IOM Limited (Isle of Man) – Both not on the Damex team page.

The allocation of senior positions across multiple entities mirrors Damex’s integrated operating model. While commonplace in cross-border fintech groups, it raises questions about the level of daily jurisdiction-specific oversight, particularly in areas with explicit AML and compliance supervision requirements.

Industry recognition and regulatory context

Damex has appeared in several industry shortlists and has been featured in multiple fintech rankings over recent years. Its website carries client feedback describing positive user experiences, with recurring praise for operational efficiency, accessibility and customer support. As of the time of writing, no public enforcement measures have been issued against Damex by regulators in Malta, Gibraltar, the Isle of Man, Spain or Lithuania.

Nonetheless, the regulatory backdrop remains relevant. The Malta Financial Services Authority (MFSA) and the Bank of Lithuania have each issued sector-wide communications in recent years reminding licence-holders of their statutory duties relating to local substance, governance oversight and outsourcing practices. These reminders are not directed at Damex specifically, but they reinforce the importance of maintaining clear operational structures in cross-border fintech models.

Dependency on Modulr and operational resilience

A significant element of Damex’s fiat settlement capabilities is delivered through its partnership with Modulr, a UK-headquartered Electronic Money Institution (EMI) authorised by the Financial Conduct Authority. Modulr’s European services are delivered via Modulr Finance B.V. in the Netherlands, while UK services are routed through Modulr FS Ltd.

Within the Damex customer experience, this relationship manifests in the provision of white-labelled IBAN accounts linked to the Damex application. In practical terms, Modulr is the regulated entity responsible for safeguarding fiat funds under applicable EMI regulations, while Damex provides the client-facing platform and account management interface.

Modulr concluded a USD 108 million Series C funding round, indicating significant institutional backing. However, UK Companies House filings for Modulr FS Ltd show recurring annual losses in the range of EUR 25–30 million. Damex has publicly indicated that alternative arrangements are available in the event of disruption to Modulr’s services, although the identity of those backup providers has not been disclosed. This dependency and the contingency planning around it will be analysed further in part six of this series.

Why this investigation matters?

The final implementation stage of the EU’s Markets in Crypto-Assets Regulation (MiCAR) was set for 30 December 2024, with stablecoin-specific provisions already in effect since June 2024. This regulatory overhaul will impose harmonised licensing, governance, capital and disclosure requirements on crypto-asset service providers across all EU member states.

Damex, with its presence in multiple regulated jurisdictions both within and outside the EU (Carol Molina – Chief Executive Officer for the Americas), occupies a position that could provide first-mover advantages under MiCAR. At the same time, the group’s cross-border dependencies and governance model make it a useful case study for how regulatory harmonisation will affect operational structures. This series aims to map that impact using only primary documents and verifiable public records.

Research methodology

The research underpinning this series draws exclusively on official company registries, public regulatory databases and documentary material sourced from company websites. In June 2025, a questionnaire was sent to Damex representatives, including Dr Justine Scerri Herrera in her capacity as a director of Damex Digital Ltd in Malta and to senior executives Sam Buxton, Scott McKim, Philip Vasquez and Matteo Alessandro. The questions covered governance, compliance staffing, cross-jurisdictional substance and operational dependency on payment partners.

Recipients were asked to respond by 27 June 2025. At the time of publication, no acknowledgement or reply had been received. If Damex or its representatives provide verifiable clarifications or corrections in future, these will be incorporated into subsequent instalments.

A complex and expanding structure

From its origins in Gibraltar as a boutique digital asset brokerage, Damex has developed into a multi-licensed payments and crypto-asset group with regulatory footholds in Gibraltar, Malta, Lithuania, the Isle of Man and Spain. Its leadership team includes both original co-founders and later C-suite appointees, with overlapping roles across multiple jurisdictions.

This model reflects ambition and scale, but also increases the compliance burden and governance risks inherent in cross-border fintech operations. These will become more pronounced as MiCAR and related frameworks take effect, particularly around the areas of local substance and the segregation of regulatory responsibilities.

Areas for further review

This first article sets out Damex’s corporate origins, executive composition and high-level operational model. It also identifies priority areas for deeper review:

• The extent to which the group’s fiat payment infrastructure depends on Modulr and any alternative arrangements.
• The operational footprint and staffing levels in regulated jurisdictions such as Lithuania, Malta and the Isle of Man.
• The governance considerations arising from directors or executives holding roles across multiple group entities and, in Malta’s case, potential links with trustee or corporate service provider arrangements.
• Whether Damex’s current compliance framework meets evolving AML and CTF obligations across Europe.

These are presented as questions grounded in public record, not as allegations. They will be addressed in subsequent parts of this series with reference to statutory requirements and available evidence.

Next steps in the series

Part two will examine Gibraltar, the jurisdiction where Damex was first incorporated and remains domiciled. It will analyse the Distributed Ledger Technology (DLT) regulatory framework, Damex’s licensing history and the degree of supervisory engagement visible in public records.

The later parts will address:

• Lithuania and the single-employee model for Damex.io UAB.
• Malta and the trustee-based licensing structure of Damex Digital Ltd.
• The Isle of Man, Blackfridge EX and stablecoin regulation.
• Damex’s operational reliance on Modulr and related contingency measures.
• A final cross-jurisdictional risk assessment and conclusions.

FAQs

What is Damex and when was it founded?
Damex is a fintech and crypto payments company founded in Gibraltar in 2017, originally under the name Digital Asset Management Ltd.

Who are the founders of Damex?
The company was co-founded by Sam Buxton, Thomas Johnson, Jeremy King, Scott McKim, and Philip Vasquez, all of whom remain in strategic roles.

What services does Damex offer?
Damex provides crypto brokerage, fiat onboarding, payment services, card issuance, and a retail platform across multiple jurisdictions.

Which regulatory licenses does Damex hold?
Damex holds an Electronic Money Institution (EMI) license in Lithuania and a Class 3 Virtual Financial Assets (VFA) Service Provider license in Malta.

In which countries does Damex operate?
Damex operates in Gibraltar, Malta, Lithuania, the Isle of Man, and Spain, maintaining subsidiaries in each jurisdiction.

Who are the key executives at Damex?
Key executives include Kriya Patel (CEO), Sam Buxton (Chairman), Scott McKim (COO), Philip Vasquez (CLO), and Jeremy King (CIO), among others.

How does Damex manage its fiat payment infrastructure?
Damex relies heavily on Modulr, a UK-authorised EMI, for white-labelled IBAN accounts and fiat settlements, with contingency plans in place.

What are Damex’s main revenue streams?
Revenue comes from crypto conversion spreads, payment processing fees via Modulr, token listings, staking rewards, and OTC commissions.

How does Damex comply with cross-jurisdictional regulations?
Each subsidiary follows local rules, including Gibraltar DLT regulations, Lithuania EMI law, Malta MFSA guidance, and Isle of Man token regulations, with oversight from the executive team.

Why is Damex significant under EU crypto regulations?
Damex’s multi-jurisdictional presence positions it for potential advantages under the EU’s MiCAR framework while highlighting challenges in governance and operational compliance.

Disclaimer

This publication forms part of an ongoing investigative series based on publicly available information and direct correspondence. All references are supported by verifiable evidence from regulatory, governmental or corporate sources. No allegations of misconduct are made.

The individuals and entities mentioned herein were given the opportunity to respond prior to publication. No replies had been received at the time of writing. Should verified corrections be provided in the future, these will be reflected in updated editions. This content is prepared for informational and journalistic purposes in compliance with applicable defamation and media laws in the United Kingdom and European Union.

Sources

1. Gibraltar Companies House – https://www.companieshouse.gi
2. Malta Financial Services Authority (MFSA) – https://www.mfsa.mt
3. Financial Intelligence Analysis Unit (FIAU), Malta – https://fiau.gov.mt
4. Bank of Lithuania – https://www.lb.lt/en
5. Gibraltar Financial Services Commission – https://www.gfsc.gi
6. UK Companies House – Modulr FS Ltd – https://find-and-update.company-information.service.gov.uk/company/09897919
7. Damex website – https://damex.io

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Authorities and contacts for formal complaints or information-sharing

1. Gibraltar (Part 2: DLT compliance and founding jurisdiction) • Gibraltar Financial Services Commission (GFSC) – To report issues concerning Distributed Ledger Technology licensing or regulatory conduct: https://www.gfsc.gi/consumer/submit-a-complaint

2. Lithuania (Part 3: Damex.io UAB and substance requirements) • Bank of Lithuania (Lietuvos Bankas) – For supervision of EMI licences and AML oversight: https://www.lb.lt/en/contacts#contact_form

3. Malta (Part 4: Trustee structure and supervision) • Malta Financial Services Authority (MFSA) – For service provider oversight and fit-and-proper obligations: https://www.mfsa.mt/about-us/contact/ • Financial Intelligence Analysis Unit (FIAU) – For AML, CFT and outsourcing enforcement concerns: https://fiau.gov.mt/contact/

4. Isle of Man (Part 5: Blackfridge EX and stablecoin supervision) • Isle of Man Financial Services Authority – For reporting issues regarding stablecoins, token issuance and financial supervision: https://www.iomfsa.im/complaints/

5. United Kingdom (Part 6: Modulr dependency and safeguarding concerns) • Financial Conduct Authority (FCA) – For EMI supervision, safeguarding failures or third-party reliance risks: https://www.fca.org.uk/contact

6. Europe-wide (cross-border issues relevant to Part 7) • European Banking Authority (EBA) – For passporting, prudential and safeguarding breaches: https://www.eba.europa.eu/about-us/contact-us • European Securities and Markets Authority (ESMA) – For crypto-asset regulations and MiCAR application feedback: https://www.esma.europa.eu/contact-us

7. Optional for whistleblower protection and reporting • Financial Action Task Force (FATF) – For global AML/CFT framework enforcement: https://www.fatf-gafi.org/en/contact.html • International Association of Gaming Regulators (IAGR) – If broader concerns involve payment infrastructure for high-risk verticals: https://iagr.org/contact/