Whistleblower evidence reviewed by FinTelegram indicates that casino deposits may pass through a layered redirect chain before reaching the Paysolo open-banking gateway. The observed flow — Pagagate → Impaya.online → Aceiro.online → openbanking.paysolo.net — suggests that Impaya and Aceiro may function as intermediate routing or masking layers between casino-facing payment gateways and the open-banking execution stack involving Paysolo, Pellopay, Yapily and Revolut.
Key Findings
- The observed video/screenshot evidence shows a sequential redirect flow:
pagagate.com→impaya.online→aceiro.online→openbanking.paysolo.net. - Impaya publicly presents itself as an e-commerce payment-solutions provider offering online payment systems and customised payment technology.
- Impaya identifies NewTech Mobile SIA as its EU representative, registration number 40103709254, at Skanstes str 7 k1, Riga, Latvia.
- LinkedIn profiles connect Sergejs Roslikovs to Impaya and NewTech, with Roslikovs described as CEO of IMPAYA Payment System and CEO of NewTech SIA.
- Aceiro appears in the live payment path, but public-source corporate attribution is not yet confirmed. It should be treated as a technical routing/domain lead.
- The downstream Paysolo layer is not merely theoretical: Paysolo markets itself as a EUR–crypto bridge and virtual IBAN provider, including SEPA/SWIFT rails and crypto conversion.
- The Pellopay layer appears later in the payment consent text, while Pellopay publicly describes API-based payment integration, payment traceability, settlements, bank transfers, digital wallets and support for methods including Revolut.
The Observed Flow
Based on the whistleblower video and screenshots, the payment journey appears to move through the following sequence:
Casino deposit page → Pagagate → Impaya.online → Aceiro.online → openbanking.paysolo.net → Pellopay/Yapily consent layer → bank selection, including Revolut EU
This is a materially important finding. It shows that before the player even reaches the Paysolo open-banking page, there may already be two additional routing layers — Impaya and Aceiro — sitting between the casino-facing gateway and the open-banking interface.
Why Impaya And Aceiro Matter
We also found Aceira.online and Paysolo in the open banking payment rails of other casino and sports betting sites that operate without the proper license through payment agents in Cyprus. Betify is another example. As such, this payment rail setup involving Aceira and Impaya, centered around Paysolo, is common in this high-risk segment.
Impaya and Aceiro appear to operate in the pre-Paysolo layer. Their role is not visibly explained to the user. In the screenshots, both domains display generic “Payment processing … Please wait, your payment is being processed” pages.
That makes them important for compliance analysis because they may perform one or more of the following functions:
| Possible Function | Compliance Relevance |
|---|---|
| Redirect orchestration | Breaks visibility of the original merchant journey |
| Payment-session handling | May generate or preserve order/payment tokens |
| Gateway masking | May separate casino brand from bank-facing payment layer |
| Risk-routing logic | Could select Paysolo/open banking depending on player country or bank |
| Merchant abstraction | Makes it harder to identify who the merchant of record is |
Impaya.online and Aceiro.online appear in the observed payment path between casino-facing gateways and Paysolo’s open-banking interface.
The New Architecture: A Layered Casino Payment Stack
The working Rail Atlas model now becomes more precise:
Offshore casinos
↓
Pagagate / Urbenics
↓
Impaya.online
↓
Aceiro.online
↓
openbanking.paysolo.net
↓
Pellopay Finance LTD
↓
Yapily Connect
↓
Revolut / other banks
This is not a conventional payment chain. It is a composable payment stack in which each layer may be operated by a different entity, hosted under a different domain, and subject to different regulatory visibility.
Compliance Analysis
1. The “Processing Page” Pattern
Both Impaya and Aceiro appear as neutral processing screens. Such pages can be legitimate in ordinary payment orchestration. But in a high-risk gambling context, they can also reduce transparency by preventing the user, bank, or investigator from seeing the full merchant chain at once.
The question is not whether a processing page is illegal. The question is whether the processing page is used to strip context before the transaction reaches open banking.
2. Impaya’s Public Positioning
Impaya publicly describes itself as a payment-solutions provider offering scalable, secure online payment systems and customised solutions. Its LinkedIn profile similarly presents Impaya as a “full-package solution” with legal support and online payment technology.
That public positioning fits the role seen in the payment flow: Impaya may be providing gateway or orchestration technology. However, FinTelegram should request confirmation before making any definitive statement about its contractual role.
3. NewTech Mobile And The Latvian Link
The whistleblower identified NewTech Mobile SIA as Impaya’s EU representative. Public search results for Impaya confirm NewTech Mobile SIA, registration number 40103709254, as the EU representative shown on Impaya’s own site.
This is relevant because it gives regulators and counterparties a concrete EU contact point for questions about the observed casino-payment routing.
4. Aceiro: The Most Opaque Layer
Aceiro is currently the weakest attribution point. The domain appears in the live payment path, but the public corporate operator is not yet established. That makes it a classic Rail Atlas target: a domain-level routing layer whose ownership, contractual role, and regulatory status require further investigation.
Evidence & Confidence Table
| Entity / Layer | Observed Role | Evidence Type | Confidence |
|---|---|---|---|
| Pagagate.com | Casino-facing gateway / first visible payment hop | Screenshot/video + SimilarWeb context | Corroborated |
| Impaya.online | Payment-processing redirect layer | Screenshot/video | Corroborated |
| Impaya impaya.com | Latvia-based payment solutions provider | Public website and LinkedIn | Confirmed |
| Impaya Payments Ltd | Canadian payment solutions provider | Public information via website | Confirmed |
| Paytech Solutions PTE LTD | Singapore representative for Impaya | Public information via website | Confirmed |
| NewTech Mobile SIA newtech.lv | Impaya EU representative | Impaya public disclosure | Confirmed |
| Sergejs Roslikovs | Impaya CEO | Public professional profiles (LinkedIn) | Confirmed |
| Aceiro.online | Intermediate payment-processing layer | Screenshot/video | Corroborated |
| openbanking.paysolo.net | Paysolo bank-selection layer | Screenshot/video | Confirmed |
| Pellopay Finance LTD | Payment consent / initiation layer | Screenshot/video + public site | Corroborated |
| Yapily Connect UAB | Open-banking connector | Payment footer / public open-banking role | Corroborated |
| Revolut | Bank option / downstream endpoint | Screenshot/video | Confirmed |
Questions To Impaya / NewTech Mobile
- Does Impaya operate or control
impaya.online? - Does Impaya provide cashier, routing, gateway, or payment-processing services to Pagagate, Urbenics, Paysolo, Pellopay, or casino operators?
- What is the relationship between Impaya, NewTech Mobile SIA, Aceiro and Pagagate?
- Does Impaya process or route payments for Luckzie.io, Kingdomcasino.io, Jinxcasino.io, Kingdomcasino6.io, or related casino brands?
- What merchant due diligence is performed for gambling-related clients?
- Does Impaya identify the underlying casino merchant to downstream partners?
- Does NewTech Mobile SIA act as a regulatory representative, technical operator, merchant reseller, or contractual counterparty?
- Has Impaya received complaints or refund requests regarding casino payments?
- Does Impaya support open-banking payment flows via Paysolo, Pellopay or Yapily?
- Who is the merchant of record in the observed €50 casino deposit flow?
Questions To Aceiro
- Who owns and operates
aceiro.online? - Is Aceiro a payment processor, routing domain, white-label gateway, merchant platform, or affiliate technology layer?
- Why does Aceiro appear between Impaya and Paysolo in the observed casino payment journey?
- Does Aceiro maintain transaction logs identifying the original casino merchant?
- Which PSPs, PISPs or open-banking providers does Aceiro connect to?
Regulatory Assessment
The Impaya/Aceiro layer is the point where payment opacity appears to intensify. A player starts in a casino environment, but by the time the journey reaches Paysolo and then Pellopay/Yapily, the origin may be reduced to a technical payment session.
For regulators, this raises three issues:
Merchant transparency: Can the bank or PISP see the original casino brand?
Consumer protection: Does the player understand that the payment may become an open-banking transfer without card-style chargeback rights?
AML/CTF and gambling compliance: Are unlicensed casino payments being routed through payment layers that avoid MCC 7995-style detection?
Conclusion
The Impaya/Aceiro evidence gives FinTelegram’s Rail Atlas a sharper view of the upstream routing layer. Paysolo is the visible open-banking gateway. Pellopay and Yapily appear to sit behind it. But Impaya and Aceiro appear before it, acting as the tunnel between the casino-facing payment gateway and the regulated/open-banking stack.
This is precisely where the compliance risk becomes most serious: the original gambling context may be fragmented before the payment reaches banks such as Revolut.
FinTelegram’s working hypothesis is therefore:
Impaya and Aceiro may function as intermediate routing layers in a multi-hop casino-payment architecture that feeds Paysolo’s open-banking gateway and downstream bank APIs.
This requires direct responses from Impaya, NewTech Mobile, Aceiro, Paysolo, Pellopay, Yapily and Revolut.
Whistle42 Call
FinTelegram invites payment insiders, gateway operators, casino employees, compliance officers, open-banking providers and affected players to submit information confidentially via Whistle42. We are specifically seeking URL logs, redirect chains, merchant contracts, settlement records, payment descriptors, KYC files, correspondence with Impaya/NewTech Mobile, and evidence identifying the operator of Aceiro.
