Unlimint EU Ltd d/b/a Unlimit is an e-money institution regulated by the Bank of Cyprus and headquartered in Limassol. Unlimit is one of the payment facilitators of 22Betgo (website), an online casino and gambling platform operated by TechSolutions Group N.V. with a license in Curacao. The SEPA transfers of 22Betgo players are processed via Unlimit. Our review found a strange development we would like to discuss.
The Questionable Approach
We understand that the correct recipient must be named in bank transfers under money laundering rules in Europe. This is part of the EU Funds Transfer Regulation, which aims to prevent the abuse of funds transfers for terrorist financing and money laundering purposes. The regulation requires payment service providers, such as banks and money transmitters, to send complete (and correct) information about the payer and the payee with each transfer of funds.
Players who deposit at 22Betgo via SEPA bank transfer are directed to the Unlimit website to receive the payment instructions. Unlimit asks the players to make their deposits to the bank account of Unlimint PSP FZ-LLC, a company in the United Arab Emirates. Players, therefore, have no bank receipt to prove that they have made a deposit to place bets on 22Betgo. The actual recipient’s name, 22Betgo, does not appear in the transfer. Unlimit can only assign this payment to Bet22go using the unique reference number. This makes chargebacks request much more complicated, if not impossible.
Specifically, payment instruction tells the user to deposit to the account of Unlimint PSP FZ-LLC at Unlimint EU Ltd in Cyprus with the IBAN CY28902000010000020101008731.
According to its Media Kit, Unlimit, founded in 2009 by Kirill Evstratov, has over 500 employees in 16 offices across 5 continents. The company’s main offices would be located in London, Frankfurt, Singapore, São Paulo, Hong Kong and Mexico. Cyprus is not mentioned!
Unlimit Key Data
| Trading name | Unlimit Unlimint PayCard |
| Domain | www.unlimit.com |
| Legal entity | Unlimint EU Ltd |
| Jurisdiction | Cyprus |
| Authorization | E-Money Institution regulated by Bank of Cyprus |
| Related individuals | Kirill Evstratov Danils Kass Pavel Maksimov Vitalii Merkulov Kristaps Zips Irene Skrynova Nadja Ivanova |
| PayRate42 rating | Orange (PR42 profile) |
Share Information
We would like to know more about this approach by Unlimit and 22Betgo. Why is a company in UAB specified as the recipient for a SEPA transfer to an online casino or online sports betting platform? Why is the actual recipient not specified and concealed?
Please post your answers in the comments or via our whistleblower system, Whistle42.
