Coin Sonic UAB, a Lithuanian-registered Virtual Asset Service Provider (VASP), is operating as a payment facilitator for offshore online casinos that appear to breach EU gambling laws. This compliance report examines how Coin Sonic‘s involvement in processing fiat bank deposits for casinos such as SlotsDynamite and SlotsAmigo—both operated by Curacao-based Coco Loco Holdings N.V.—raises serious regulatory and legal concerns.​
Operator and Licensing Overview
SlotsDynamite and SlotsAmigo are crypto-friendly online casinos operating under Curacao eGaming licenses issued to Coco Loco Holdings N.V.. These casinos actively accept players from EU jurisdictions without holding the required national licenses mandated by member states such as Germany, Italy, the Netherlands, and others.
Under EU law and national gambling regulations, operators must obtain licenses from each jurisdiction in which they offer services; a Curacao license does not grant legal market access within the EU.​
Independent testing confirmed that players from various EU regions can register and deposit at these casinos without restrictions, despite local prohibitions on unlicensed operators. This represents a clear violation of applicable national gambling laws across the EU.​
Coin Sonic’s Role and Regulatory Violations
Coin Sonic UAB (company code 306200594) is a Lithuanian private limited company established in December 2022. It operates the crypto exchange platform InstaXchange and is registered as a VASP under Lithuanian law. VASP registration permits activities directly related to virtual assets—such as crypto-to-fiat exchange, crypto custody, and wallet services—but does not authorize the provision of general payment processing or e-money services for non-crypto transactions.​
Our investigation revealed that when players make fiat bank deposits at SlotsDynamite or SlotsAmigo, they are redirected and laundered through multiple domains.
- First, the payment flow passes through secure.omerpayments.com/checkout, then to
- InstaXchange (instaxchange.com), and finally to
- checkout.instantbankpayment.com—a subdomain apparently linked to Yapily, an open banking infrastructure provider.
- Players then select their bank and complete a standard EUR bank transfer directly to Coin Sonic‘s account at Banking Circle’s German branch (IBAN: DE73202208000056199298).​
Crucially, no cryptocurrency is involved in these transactions. Players deposit fiat currency (EUR) that is credited as casino balance for gambling purposes—not exchanged into crypto assets. This activity falls outside the scope of a VASP registration, which is limited to virtual asset services, and instead constitutes payment processing or e-money issuance requiring a Payment Institution (PI) or Electronic Money Institution (EMI) license under EU Directive 2015/2366 (PSD2).​
Coin Sonic UAB does not hold such licenses. By facilitating fiat payments for third-party merchants (illegal casinos), Coin Sonic is operating beyond its regulatory authorization and in potential breach of Lithuanian and EU financial services law.​
Payment Infrastructure and Compliance Gaps
The payment routing involves several intermediaries. Omer Solutions (omerpayments.com) is a high-risk payment gateway explicitly serving industries, including gaming and casinos. Yapily Connect UAB, a Lithuanian-regulated payment institution authorized by the Bank of Lithuania (license LB002045), provides open banking infrastructure but is not itself a payment processor. The use of checkout.instantbankpayment.com—likely a white-label or technical layer—obscures the ultimate beneficiary and complicates compliance tracing.​
Banking Circle, a regulated financial infrastructure provider in Germany and Luxembourg, processes the actual transfers. While Banking Circle itself is licensed, its role as a banking intermediary does not absolve Coin Sonic or the casino operators from compliance obligations. Coin Sonic‘s acceptance of fiat funds on behalf of unlicensed gambling operators implicates the company in facilitating illegal gambling operations across the EU.​
| Entity/Domain | Description/Function | Legal Entity / Owner | Jurisdiction / Registration | Licensing Status |
|---|---|---|---|---|
| SlotsDynamite / slotsdynamite9.com (etc.) | Online crypto/fiat casino (accepts EU players) | Coco Loco Holdings N.V. | Curacao | Curacao eGaming; unlicensed in EU |
| SlotsAmigo | Online casino, sister to SlotsDynamite | Coco Loco Holdings N.V. | Curacao | Curacao eGaming; unlicensed in EU |
| Coin Sonic UAB d/b/a InstaXchange | Crypto exchange & payment facilitator Operator of InstaXchange | Coin Sonic UAB (Reg. code: 306200594) | Lithuania | VASP, not licensed as Payment or EMI |
| instaxchange.com | Crypto exchange platform | Coin Sonic UAB | Lithuania | VASP |
| Omer Payments omerpayments.com & secure.omerpayments.com/checkout | High-risk payment gateway (casino payments) | Omer Solutions | Likely offshore (not clearly disclosed) | No EU payment/EMI license |
| instantbankpayment.com & checkout.instantbankpayment.com | Branded payment checkout (linked to Yapily open banking infrastructure) | Operated in connection with Yapily | UK/Lithuania | Yapily Connect UAB: PI license LT, FCA UK |
| Banking Circle (German branch) | Banking and settlement provider for Coin Sonic payments (IBAN: DE73202208000056199298) | Banking Circle S.A. | Germany / Luxembourg | Fully licensed financial institution |
Legal and Regulatory Implications
Illegal Gambling Operations: SlotsDynamite and SlotsAmigo operate without valid EU member state licenses, making their services illegal in jurisdictions such as Germany, Italy, the Netherlands, Austria, and others. EU member states explicitly require national licenses under the principle of subsidiarity, repeatedly upheld by the European Court of Justice.​
VASP Scope Overreach: Coin Sonic’s VASP registration does not permit general fiat payment processing. The company’s facilitation of non-crypto casino deposits constitutes unauthorized payment services.​
AML/CTF Risks: Processing payments for unlicensed casinos increases exposure to money laundering, terrorist financing, and fraud risks. Coin Sonic’s involvement may breach AML obligations under the EU’s 5th and 6th Anti-Money Laundering Directives and Lithuania’s AML framework.​
Consumer Protection Failures: Players using these casinos lack the protections guaranteed under licensed EU gambling frameworks, including responsible gambling tools, dispute resolution, and fund safeguarding.​
Conclusion and Call for Whistleblowers
Coin Sonic UAB appears to be operating outside the legal boundaries of its VASP registration by processing fiat payments for offshore casinos operating illegally within the EU. This arrangement benefits unlicensed operators while exposing consumers to significant risks and depriving EU member states of regulatory oversight and tax revenue.​
Regulatory authorities in Lithuania, Germany, and across the EU should investigate Coin Sonic‘s payment facilitation activities, assess compliance with payment services and AML laws, and consider enforcement action. Banking Circle and Yapily should also review their indirect involvement in these payment flows.
We call on insiders, whistleblowers, and industry professionals with knowledge of Coin Sonic UAB, InstaXchange, Coco Loco Holdings N.V., or related payment schemes to come forward. Additional documentation, transaction records, internal communications, or evidence of similar arrangements would greatly assist regulatory investigations and public accountability efforts. Contact us confidentially to share information that can help protect consumers and uphold the integrity of EU financial and gambling regulation.
