Indemo Review

A Promising Model with Critical Caveats

Update 2025-07-07: An earlier version incorrectly stated that Tamarindo does not publish audited financials. Indemo also informed us that their June 2025 funding round went from ‘committed’ to ‘completed’. We also received updated AUM data that increases the number from €10.5 million to €12 million. The updated review now reflects those points.

Editor's Note: This analysis uses the latest public data as of July 4th, 2025, including platform responses and verified ownership structures. It is for informational purposes only and isn’t tailored investment advice.

Executive Summary

Indemo offers a 50/50 profit-share on Spanish non-performing loan (NPL) recoveries, showing strong early returns (25% IRR on €1.5 million completed deals). Operating under MiFID II regulation, the platform recently improved governance by switching from an affiliated servicer (Atlan) to the independent Taurus Ibérica. Despite these positives, a critical structural flaw - the potential for undisclosed servicer changes to an affiliated entity - and the lack of a secondary market present significant investor watch points.

Key Highlights

• Profit-Share: 50/50 profit-share after all costs.
• Returns: 25.3% average IRR on 8 completed deals (€1.5 million principal).
• Liquidity: No secondary market; no fixed repayment date.
• Structurally Genuine Cashback: The platform’s profit-share model ensures 4% cashback campaigns* are a direct boost to returns, unable to be offset by lower interest rates.
• Servicer: Currently uses independent servicer Taurus Ibérica.
• Governance Risk: 2025 prospectus removes specific servicer naming, allowing future substitution without public disclosure.

Investment Stance

Indemo is currently investable, particularly during cashback campaigns, for those comfortable with NPL risks and illiquidity. The fair profit-share and independent servicing offer a reasonable risk-adjusted opportunity. However, investors should limit exposure until Indemo demonstrates commitment to transparency regarding servicer selection and delivers a functional secondary market.

The Investment Proposition

Indemo is a Latvian investment firm (MiFID II licence 06.06.08.824/547, supervised by Latvijas Banka) that co-finances Spanish non-performing mortgage loans. The marketing pitch is seductive: target ~15% returns backed by real estate.  

Operational Model

1. Spanish banks unload delinquent mortgages at ≈60% of face value.
2. Tamarindo Vector S.L. (director: Ilja Hagins; owner: Alexander Nazarov) buys the debt. [BORME 9 May 2019]
3. Tamarindo lists the claims as "Notes" on Indemo.
4. Investors commit funds, refinancing Tamarindo so it can buy the next batch.
5. Taurus Ibérica (independent servicer) handles legal recovery and asset sale.
6. Net proceeds are split 50/50 between Tamarindo and investors after all costs.

Operational Constraints

• No monthly cash-flow; capital locked until resolution. 
• No secondary market yet. Your money really is stuck till maturity.

“Loan Originator”: Tamarindo

Unlike a traditional P2P loan originator that underwrites and issues new loans to borrowers, Tamarindo operates as a specialized distressed debt investor. Its process begins where a traditional loan ends: after a borrower has defaulted. Tamarindo sources and acquires portfolios of existing non-performing loans (NPLs) from Spanish banks, typically at a deep discount to their original value. It then packages these debt claims into individual investable securities (Notes), effectively acting as the deal supplier for the Indemo platform.

This model is fundamentally different from standard P2P lending. Instead of funding a new loan in exchange for a fixed interest rate, investors are refinancing Tamarindo’s acquisition of an existing bad debt. The return is not a predictable interest payment but a 50% share of the potential profit realized upon successful recovery.

Servicer: Taurus Ibérica

Servicer sounds quite gentle. They’re not. They are the collection agency. They are the investor's legal and financial muscle, hired to do one thing: turn a defaulted loan back into cash.

Taurus operates under a limited power of attorney, giving it full legal standing to negotiate, litigate, and sell. Tool-kit: (i) cash-for-keys deals, (ii) negotiated restructurings, (iii) full court enforcement culminating in a judicial auction. Because servicer fees rank senior to investor principal in the waterfall, their efficiency and cost-discipline dictate your eventual IRR.

Taurus Ibérica is a significant player in Spanish NPLs, with 15+ years of experience, extensive real estate data, and over 80,000 sales completed. Its scale and independence provide substantial operational depth. However, that very scale might be why the prospectus notes no backup servicer, indicating a single point of failure if Taurus Ibérica were to falter.

Financial Overview (2024)

Indemo publishes audited financials, an essential transparency measure for any platform.

• Assets Under Management: €12 million (July 2025), up from €2 million 1 year ago.
• Registered Investors: 10,000+.
• Active Portfolio: 80+ funded debts, 190 Notes listed.
• 2024 Revenue: €386,000.
• 2024 Net Loss: €682,000.
• Cash Position: €425,000 (December 2024).
• Monthly Burn Rate: €50,000.

These metrics reflect a typical startup growth phase, with significant cash burn supporting rapid AUM expansion.

Returns & Cost Structure: A Double-Edged Sword

Indemo reports an average 25.3% p.a. return, but this is based on a shallow pool of just eight completed deals - too small to validate the model's scalability. The real story isn't the headline number; it's the structure behind it.

Investors receive a 50/50 split of net profit, but only after gross recoveries are reduced by a gauntlet of fees:

• Legal & Court Fees: Estimated at ~3%.
• Servicing & Administrative Fees: Projected at 4-7%.
• Platform Fee: A fixed 5% cut of the gross recovery.

This profit-share model presents a double-edged sword. On one hand, quick resolutions can generate the outsized IRRs Indemo has shown in its early deals. Furthermore, because there is no underlying interest rate to manipulate, any cashback offer (currently 4%*) is a genuine, non-recoupable yield enhancement. Because Indemo can't manipulate loan rates to claw it back, any cashback percentage can be taken at face value.

On the other hand, the model's success hinges on a triad of factors: sale price, total costs, and time. Duration is the silent killer of IRR. With no late fees or penalty interest, doubling the duration simply halves the return. This exposes the model's most significant risk: the potential for investor losses even on a profitable asset sale. Because all costs are paid before investors see their principal returned, a long and expensive recovery can obliterate the entire profit margin and even eat into the initial investment.

Payment Waterfall: Where the Money Flows

The order in which proceeds are distributed is non-negotiable and dictates investor risk. The Base Prospectus (Conditions 7–11) outlines this exact payout waterfall. Every euro from a settlement or auction follows this order:

1. Tax Authorities: Latvian & Spanish taxes.
2. Indemo: Fixed platform fee.
3. Servicer / Issuer: Day-to-day servicing costs.
4. Legal & Enforcement: All out-of-pocket costs (lawyers, courts, etc.).
5. Backup Servicer: Contingency remuneration (if appointed).
6. Noteholders: Return of capital (Debt Price refinanced).
7. Noteholders: Performance-Linked Interest (50% of remainder).
8. Tamarindo: Remaining 50% profit.

Crucially, investor principal (step 6) is only returned after all operational costs and fees (steps 1-5) are fully settled.

Key Risks

Indemo presents a number of key risks. Many of these are execution risks where Indemo's interests align directly with yours - meaning they succeed when you do. That’s a reassuring factor in a space where some platforms seem designed to extract fees regardless of investor outcomes. However, certain structural and governance issues warrant particular attention. These risks are real, yet generally manageable for those comfortable with early-stage alternative lending platforms. The primary concerns include:

Servicer Substitution & Conflict of Interest

Past Problem: Until recently, asset management was handled by Atlan Advance, led by Ilja Hagins (Indemo's majority shareholder). Atlan charged administrative and legal fees before investor profit-share, creating a conflict of interest where Hagins could potentially inflate costs. This conflict was not explicitly listed in the prospectus under "Conflicts of Interest."

Current State: Indemo switched to independent servicer Taurus Ibérica, a positive development that removes the immediate conflict. Taurus operates independently and charges standard market fees. Revesta Soluciones, another company founded by Hagins, currently provides back-office services to Tamarindo, paid from Tamarindo's profit share, not gross recovery funds.

Future Risk: The 2025 prospectus removed specific servicer naming, allowing future servicer substitutions without public disclosure. This creates a loophole for appointing an affiliated servicer. Revesta Soluciones describes itself as an NPL servicer, and Indemo's statements ("at present does not function as a servicer," "over time, this could result in other professional servicing partners joining alongside or replacing existing ones like Taurus") strongly suggest it could become a servicer.

Impact: An affiliated servicer could inflate fees, reducing the profit pool before the 50/50 split. While MiFID II might offer some protection against over-billing, a servicer change without prospectus amendment might escape regulatory radar.

Mitigation: Alexander Nazarov, Tamarindo's owner, would have no incentive to see inflated servicer fees from Hagins-controlled entities, creating a potential counter-balance. Indemo states they plan to announce new servicers but failed to do so when switching to Taurus. This lack of transparency combined with no secondary market means investors cannot exit if a servicer change is made public (or discovered).

The Cash Runway Problem

Indemo faces a typical startup challenge with approximately 8 months of cash runway remaining (based on 2024 financials and recent funding: €159,000 Jan 2025, €150,000 Apr 2025, €120,000 Jun 2025). This raises questions about sustained funding until the platform reaches cash-flow positivity. However, contractual terms, independent servicing, and IFRS derecognition (loans off Tamarindo’s balance sheet) offer some protection against platform bankruptcy affecting investor capital.

Legal Framework Uncertainty

The actual securities sold on Indemo are securities (called "Notes") issued by SPVs (special purpose vehicles). Essentially, each loan is made to a separate "mini-company" (the SPV), shifting the legal battleground from Spain to Latvia.

On paper, the process is designed for investor protection:

1. The Spanish originator, Tamarindo, sells an NPL to a Latvian SPV.
2. Tamarindo uses IFRS accounting standards to declare this a "true sale."
3. This allows the loan to be legally removed from Tamarindo's balance sheet.

However, this accounting entry is essentially Tamarindo's side of the story - a declaration, not a final legal judgment.

The entire structure could be challenged if Tamarindo goes bankrupt. A Spanish administrator, seeking to recover funds for creditors, could argue in a Latvian court that the "true sale" was a sham designed to shield assets.

The core uncertainty is whether Latvian judges, who lack specific, established securitization laws, would find the contractual and accounting evidence sufficient to block such a clawback. Your protection, therefore, hinges on a Latvian court siding with the interpretation of an accounting standard over a bankruptcy administrator’s claim - a scenario that remains legally untested.

Tamarindo's 2023 audited financials (the 2024 report is not yet available) show the company is chiefly financed by a €1.75 million shareholder loan from its sole owner, Alexander Nazarov, maturing in May 2029. For 2023 it booked a modest net profit of €21,768, indicating basic operational viability but thin margins. Under Spain’s Insolvency Act (TRLC), loans from “especially related” parties such as Nazarov are automatically classified as subordinated claims, ranking behind all secured, preferential and ordinary creditors. As a result, Nazarov has little economic incentive to force an insolvency filing that would push his claim to the back of the payout queue.

This alignment could shift materially if Tamarindo were to incur significant debts to independent third-party lenders who do not share Nazarov’s conflict and would rank ahead of him in bankruptcy.

Cross-Contamination Risk (Operational)

The prospectus states that "an event of default under another prospectus can lead to an event of default under this Base Prospectus."

In simple terms, this means there is no "ring-fence" in place (a legal wall that would isolate different investment products from each other, like watertight compartments on a ship). Without this separation, a catastrophic failure in a future Indemo product line could allow creditors to seize assets from the profitable Spanish NPL portfolio to cover the losses.

While this risk is dormant as long as Indemo focuses only on Spanish NPLs, it makes any future expansion a direct threat to existing investors' capital.

Single Point of Failure

Indemo's prospectus candidly states there might be no backup servicer of comparable scale willing to be appointed if Taurus Ibérica fails. This operational dependence on Taurus means any significant disruption could lead to serious recovery delays or principal losses. While Atlan previously managed servicing, its return would reintroduce direct conflicts of interest.

Valuation Methodology

Beyond future sale price, the initial valuation of underlying real estate assets presents a risk regarding accuracy. How are these assets valued at the time of purchase? Indemo uses desktop Automated Valuation Models (AVMs) from Tinsa/Idealista, followed by Taurus's "drive-by" valuations. While these methods assess external condition and market data, they do not account for internal damage. Indemo states values are adjusted downwards based on assumed poor property condition, aiming for conservative Price-to-Value ratios.

Standard Market Risks

Beyond structural risks, investors face general market risks such as real estate market downturns, increased competition, or adverse legislative changes in Spain affecting mortgage recovery. This analysis, however, prioritizes risks unique to Indemo's structure.

Management Team

Indemo's leadership brings concentrated experience from Latvia's financial sector, with notable credentials in regulatory compliance and asset management.

Sergejs Viskovskis (CEO, 5.78% stake) provides strong regulatory credentials from his tenure as Senior Legal Counsel at Mintos (2019-2021) and decade-plus experience at Rietumu Bank in legal and compliance roles.

Pavel Pochtarenko (CRO, 6.19% stake) brings direct asset management experience, having overseen approximately €200 million in assets as Chairman of Rietumu Asset Management.

Daniels Zirjakovs (CTO, 6.19% stake) contributed to building Rietumu Bank's investment services technology infrastructure before joining Indemo.

Ilja Hagins (23.8% stake, largest shareholder) serves as the primary dealmaker, controlling deal supplier Tamarindo and maintaining significant influence over platform direction.

Note: Multiple team members have Rietumu Bank backgrounds. While Rietumu faced money laundering issues in France (2017), none of the current Indemo team seem to have been involved in those operations, and all have undergone regulatory screening.

Key Partners

Tamarindo Vector S.L. supplies 100% of deals, owned by Alexander Nazarov (Cyprus-based retired physicist) and administered by Ilja Hagins. The company shifted from 93% traditional lending (2020) to 88% NPL focus (2024), purchasing debts at 50-65% discounts averaging €150,000.

Taurus Ibérica handles asset management independently, with 15+ years in Spanish NPLs, €500+ million in operations across 120+ branches, and 80K+ sales completed. Their scale and independence provide operational depth, though no backup servicer has been identified.

Governance & Regulatory Compliance

Indemo is actively addressing potential conflicts of interest arising from related-party relationships:

• One non-shareholder director has been appointed.
• A second independent director is planned by end-2025.
• This aims for a balanced board (two founding, two non-founding members). The effectiveness of this structure will depend on these independent directors' demonstrated oversight of related-party transactions.

MiFID II Regulation

Indemo's legitimate MiFID II license provides tangible investor protections, including:

• Up to €20,000 investor compensation for cash balances.
• Segregated fund storage.
• Regular regulatory oversight and mandatory background checks on owners/management.
• Proper disclosure requirements and frameworks for managing conflicts of interest.

However, MiFID II ensures procedural integrity (like building safety codes), but does not guarantee specific investment outcomes or prevent all business model risks. It does not prevent:

• Structural conflicts of interest.
• Deal allocation decisions.
• Cost allocation between related parties.
• Platform-specific business model risks.

Recommendations for Improvement

Key improvements that would significantly enhance Indemo's investment proposition include:

• Launching a functional secondary market promptly.
• Publicly disclosing the servicer for all notes and proactively announcing any changes.
• Providing clear clarification on the role and authority of independent board members in overseeing related-party transactions and outlining specific frameworks for conflict of interest management.

Final Verdict: Promising Model with Critical Caveats

Indemo's profit-share structure effectively aligns interests, making success contingent on operational execution. However, two primary structural concerns demand investor attention:

1. Servicer Substitution Loophole: The ability to change servicers without explicit prospectus disclosure creates a clear risk of value leakage through affiliated servicer appointments and inflated fees. Investors currently lack adequate means to monitor this crucial aspect.
2. Lack of Secondary Market: The absence of a secondary market means investors are illiquid. This prevents them from exiting positions even if critical information, such as a servicer change, comes to light.

While the underlying structure is fundamentally sound, supported by strong partnerships and regulatory oversight, these issues necessitate caution. Indemo’s Cashback campaigns* drastically improve the value proposition since they can’t be offset with lower interest rates. However, prudent investors should limit exposure until Indemo provides clarity on the servicer issue and a secondary market becomes operational, enabling active investment management. Indemo has been forthcoming in responding to inquiries, and addressing these structural concerns would significantly bolster confidence and enhance its long-term investment proposition.

Disclaimer: This analysis focuses on the business model and risk distribution, not personal financial advice. Always verify information with primary sources and consult a qualified financial advisor before making investment decisions.