Thanks for your elaborated response, @DAIICHI.
DARWINS trade at a 10% VaR no matter the underlying strategy's risk. So DARWINS will NOT be affected.
Now, looking into the underlying strategies, I would say there are two options:
A. Traders will increase the amount in their trading accounts (they need more funds to trade the same volumes they are currently trading).
B. Clever traders will launch their DARWINS so they can leverage their trading strategies with investors' capital. This means DARWINS are now even more attractive for traders than they were before ESMA.
Re 100 USD accounts, as far as I know ESMA is not stealing traders' money so they trade smaller amounts, they are only reducing their leverage, so I don't see why you suggest people will trade 100 USD accounts?
Traders will trade at a smaller leverage. DARWINS will remain the same because they ALWAYS trade at a 10% VaR. This sounds like we are all better off this way (market makers are the most negatively affected by this decision and brokers like Darwinex will probably experience a decrease in their volumes in the short term, whereas long term our customers' flow will be probably sounder than it is nowadays).
I hope this clarifies my view!