BaFin Warns on DAO1 as German Nationals Promote Unauthorized Crypto Trading
German regulator BaFin issued a consumer warning on October 2, 2025, about DAO1, a product offering automated trading of crypto assets using bots. The regulator found that Apertum Holding Limited was an affiliated company and that the services were unauthorized in Germany under the European Union's Markets in Crypto-Assets regulation.
The warning targeted Dennis Loos and Dirc Zahlmann, two German nationals who were promoting DAO1 in Germany through webinars and social media. They had been named in a Texas State Securities Board Emergency Cease and Desist Order in March 2025 for allegedly offering unregistered securities and making material misstatements.
The operation became predominantly German after the warning was issued, with 62% of traffic coming from Germany by November 2025. BaFin's warning stated that where a provider operates without necessary permission, contracts may be invalid, and protections attaching to regulated financial services do not apply.