The crypto payment processor MoonPay has secured a New York Limited Purpose Trust Charter for MoonPay Trust Company, LLC, joining an elite “dual-licensed” club alongside Coinbase, PayPal, Ripple, and NYDIG. The firm now presents itself as a gold-standard infrastructure provider for institutional crypto services. At the same time, FinTelegram and RatEx42 have documented MoonPay’s ongoing technical integration with unlicensed online casinos – and so far, regulators have not publicly sanctioned MoonPay for this specific role.
Key Points
- NYDFS Trust Charter + BitLicense: MoonPay Trust Company, LLC has been authorized by the New York State Department of Financial Services (NYDFS) as a New York Limited Purpose Trust Company (LPTC), allowing it to offer digital-asset custody and OTC trading under banking-style supervision. The firm already holds a BitLicense (June 2025). (Source: prnewswire.com).
- Global Regulatory Footprint: MoonPay highlights registrations in the UK (FCA), Australia, Canada, Italy, Ireland, Jersey and a MiCA crypto-asset service provider authorization in the EU (Source: MoonPay).
- Documented Casino Facilitation: FinTelegram and RatEx42 have repeatedly shown MoonPay as a “buy-crypto” on-ramp embedded in illegal or unlicensed casinos such as Betsolino, MetaWin, Claps Casino, BitStarz and others.
- Texas Enforcement – But Not for Gambling: In 2024, the Texas Banking Commissioner fined MoonPay USA LLC and Moon Pay Limited USD 30,516.30 for engaging in unlicensed money transmission and ordered them to cease until properly licensed. This was a licensing/MTL issue, not a gambling case (Source: dob.texas.gov).
- No Public Gambling-Specific Sanction (So Far): As of 27 November 2025, FinTelegram’s research has not identified any public enforcement action specifically penalising MoonPay for facilitating illegal online gambling, despite its systematic integration in high-risk casinos.
Short Narrative
MoonPay’s press release frames the New York Trust Charter as a milestone in building “regulated financial infrastructure”. A New York Limited Purpose Trust Charter effectively places MoonPay Trust Company, LLC inside the same prudential perimeter used for certain banks and trust companies, with NYDFS as front-line supervisor. The charter allows MoonPay to custody digital assets and run OTC trading desks under one of the most demanding regulatory regimes in the crypto world (Source: prnewswire.com).
Combined with its BitLicense and multi-jurisdictional registrations, MoonPay now presents itself as a bridge between banks, card schemes, stablecoins and blockchains – a regulated “plumbing layer” for the next generation of payments and digital assets.
From a distance, this reads like a compliance success story. Up close, FinTelegram’s case files tell a more uncomfortable story.
Extended Analysis
1. What the Trust Charter Actually Means
Under NYDFS rules, virtual-currency firms can either obtain a BitLicense or a banking-law charter (e.g. limited purpose trust company). A trust charter generally comes with:
- Higher governance and capital expectations than a standalone BitLicense;
- Explicit fiduciary duties around custody;
- Full-scope AML/CTF obligations, including transaction monitoring, SAR-like reporting and robust sanctions controls (Source: Department of Financial Services).
CoinDesk and other outlets underline that MoonPay now joins a very small group of dual-licensed firms – Coinbase, PayPal, Ripple, NYDIG – which NYDFS sees as systemic infrastructure players (Source: coindesk.com).
The press release also hints that this structure could support future stablecoin-style products, subject to separate NYDFS approval, explicitly name-checking the US GENIUS framework as a potential path.
Read our MoonPay reports here.
2. The Unresolved Casino Question
Against this backdrop, FinTelegram and RatEx42 have repeatedly documented MoonPay’s function as a crypto on-ramp for offshore casinos:
- Betsolino: RatEx42 identified MoonPay (and Changelly) as payment facilitators for the illegal Betsolino casino, allowing players to buy crypto by card and push it straight into the casino’s wallets (Source: RatEx42 Listings).
- Systematic Casino Integration: FinTelegram’s Bitcoin.de warning report lists MoonPay among processors that “continue to enable illegal casino operations,” citing integrations with Claps Casino, BitStarz and other offshore operators targeting restricted jurisdictions (Source: FinTelegram).
- MetaWin & Other Crypto Casinos: Our analysis of MoonPay’s acquisition of Meso Network notes that MoonPay’s rails remain deeply embedded in unlicensed crypto-casino ecosystems, including MetaWin, with MoonPay acting as a primary fiat-to-crypto gateway (Source: FinTelegram)
- Buy-Crypto Widgets as De-Facto PSPs: FinTelegram has shown how “Buy Crypto” widgets powered by MoonPay on Roobet, Gamdom and similar sites effectively replace classic gambling PSPs while sidestepping card-scheme MCC restrictions and national gambling controls (Source: FinTelegram).
MoonPay’s own terms of use explicitly prohibit “unlawful gambling” and the use of its services to pay for illegal activities, including illegal gambling or money laundering.
The reality documented in multiple FinTelegram investigations suggests a persistent policy-versus-practice gap.
3. Enforcement to Date
Our research confirms one notable enforcement action:
- Texas (Dec 2024) – Consent order for unlicensed money transmission in connection with fiat and sovereign-backed stablecoin flows, resulting in a USD 30,516.30 penalty and a requirement to obtain a money transmitter licence.
However, as of today we have found no public enforcement decision in which a regulator sanctions MoonPay specifically for facilitating illegal gambling/casino activity. That does not mean there are no confidential supervisory measures – but nothing comparable to the large fines imposed on banks, card schemes or PSPs in gambling cases is visible in the public record.
In other words: MoonPay is now a NYDFS-chartered trust company while its casino integrations, documented across Europe and beyond, have yet to trigger gambling-focused enforcement.
Actionable Insight (for Regulators, Banks, and Partners)
- Regulators should re-evaluate licensed crypto infrastructure providers not just on their own licensing status, but on the nature of their downstream merchants – especially when those merchants are clearly unlicensed casinos in key markets.
- Banks and card schemes partnering with MoonPay for “regulated crypto access” should conduct independent checks on casino integrations, not rely solely on MoonPay’s prohibited-use clauses.
- Institutional counterparties considering MoonPay’s new trust-company services should explicitly address exposure to gambling-related flows in onboarding, risk assessment, and contractual covenants.
The core compliance question is simple: Can a firm credibly market itself as best-in-class regulated infrastructure while continuing to provide de-facto rails for unlicensed gambling?
Call for Information (Whistle42)
FinTelegram will continue to track MoonPay’s regulatory trajectory and its role in the online gambling ecosystem.
We specifically invite:
- Current and former MoonPay employees (compliance, risk, sales, tech);
- Casino operators, affiliates, and PSP partners;
- Banking and card-scheme partners;
- Regulators and supervisory staff with relevant insight
to provide documents, internal communications, and technical integration details regarding MoonPay’s relationships with online casinos and high-risk gaming platforms.
Information can be submitted securely and anonymously via our whistleblower platform Whistle42.
