Our mystery-shopping reviews of the offshore casinos Donbet, Rolletto, and other illegally operating casinos found frictionless onboarding and deposits from the EU and UK—despite the brands lacking local permissions. Both brands are operated by the Santeda network, with payment flows routed via Santeda International Limited (Cyprus) and the gateway UtPay (utpay.io). In multiple tests, Revolut appeared as a checkout option—raising serious questions given UK/EU rules on unlicensed gambling and Revolut’s own public policies. We call on players and insiders to share evidence of Revolut’s involvement in illegal gambling payments.
Key Points
- Operators & structure: Donbet and Rolletto are operated by Santeda International B.V. (Curaçao); Santeda International Limited (Cyprus) acts as payment agent (Source: m.donbet.com, Rolletto.com)
- Payment orchestration: Deposits presented UtPay gateway flows; UtPay markets a merchant widget supporting cards, Apple/Google Pay and crypto (Source: utpay.io)
- Revolut at checkout: In FinTelegram’s test deposits (Sept–Oct 2025), Revolut/“Revolut Pay” surfaced as a payment method via UtPay on both brands.
- Policy clash: UK law (Gambling Act 2005, s.33) criminalises offering facilities for gambling to GB customers without a UKGC licence; payment blocking is flagged as a core tool (Source: Legislation.gov.uk).
- Revolut’s own stance: Revolut advertises a Gambling Block and says some countries require it to block transactions to illegal operators (Source: Revolut).
- Regulatory backdrop: Revolut obtained a UK banking licence with restrictions in July 2024 and remains under close scrutiny while exiting “mobilisation” (Source: The Guardian).
- Wider ecosystem risk: Major payment rails have previously been found processing illegal-site transactions, underscoring gaps in merchant vetting and orchestration (Source: The Guardian).
Short Narrative

Our investigators registered and deposited at Donbet and Rolletto from multiple EU and UK IPs with no effective geoblocking or jurisdictional gating. Corporate footprints indicate that Santeda International B.V. (Curaçao) operates both brands, with Santeda International Limited (Cyprus) identified as a payment agent in brand documentation. Checkout paths surfaced UtPay, a gateway that embeds a widget for multiple payment types. In these flows, we encountered Revolut/“Revolut Pay” as an available option and successfully completed deposits during our tests.
That matters: under UK law, providing gambling facilities to GB consumers without a UK Gambling Commission (UKGC) licence is a criminal offence (s.33). UKGC guidance emphasises payment blocking as a key disruption tool. Revolut, for its part, markets a Gambling Block feature and explicitly notes that in some European countries it must block transfers to illegal operators. The appearance of Revolut payments at unlicensed casinos, therefore, collides with both legal expectations and Revolut’s public controls.
Extended Analysis

- Operator facts: Donbet and Rolletto name Santeda International B.V. as operator under Curaçao eGaming; Donbet/Rolletto materials and a MyStake/Donbet affiliate PDF place Santeda International Limited (Cyprus) in the payment chain. The Cyprus register confirms Santeda International Limited (HE406761) (Source: i-cyprus.com).
- Gateway layer (UtPay): UtPay publicly offers a plug-in widget and multi-rail acceptance—exactly the sort of payment orchestration layer that can route high-risk traffic across card schemes, APMs and crypto (Source: utpay.i).
- Revolut exposure: Revolut Pay is a one-click online checkout method available to Revolut and non-Revolut customers. If that button appears on an unlicensed operator accessible in the UK or restricted EU markets, Revolut and its acquiring partners face exposure under AML/CFT and consumer-protection regimes, as well as reputational risk—especially while the firm transitions from a restricted UK banking licence to full permissions (Sourcde: Financial Times).
- Ecosystem lesson: Prior reporting shows even major card networks have been used on illegal sites, often via third-party payment tools. That amplifies the obligation on wallets, acquirers, PSPs and orchestration vendors to enforce geofencing, merchant KYC, and jurisdictional blacklists (Source: The Guardian).
Actionable Insight
- For regulators: Examine merchant onboarding and transaction-level controls at Revolut and UtPay for gambling MCCs/merchant IDs linked to Santeda-operated sites. Cross-reference with UKGC and EU national blacklists (Source: Gambling Commission).
- For Revolut & partners: Review checkout placements where Revolut Pay is exposed on unlicensed operators; align with the firm’s “local requirements” blocking policy; perform retrospective remediation and SARs where warranted (Source: Revolut).
- For consumers/victims: If you deposited to Donbet/Rolletto with Revolut, retain evidence (screenshots, receipts, Revolut statements, merchant descriptors, UtPay widget IDs) and file complaints with your national regulator and card/wallet provider.
Call for Information (Whistle42)
Were you offered Revolut as a payment option at Donbet, Rolletto, or other unlicensed casinos? Are you a current/former Revolut, acquirer, or UtPay insider with knowledge of merchant onboarding or blocking lists? We want to hear from you. Share artefacts (checkout screenshots, payment confirmations, merchant descriptors, emails/chat logs) via Whistle42—confidentially and securely.




