FinTelegram’s ongoing Rail Atlas investigation has identified a recurring pattern behind offshore casino payments targeting EU users: anonymous gateway layers route transactions into regulated Open Banking providers—including Yapily, Perspecteev (SaltEdge ecosystem), and now Powens—before reaching bank endpoints such as Revolut. This interim report shifts the focus from casino operators to the licensed infrastructure that executes the payments, raising key regulatory questions about transparency, merchant due diligence, and AML controls.
Key Findings
- Multiple offshore casinos tested by FinTelegram show a consistent multi-layered payment architecture.
- Anonymous gateway domains such as Pagagate, Urbenics, and Supergateway act as intake and routing layers.
- A second layer of routing/payment orchestration includes entities such as Impaya, Aceiro, PayOp, and Paysolo/Pellopay.
- The final execution layer consistently involves regulated Open Banking providers, notably:
- Yapily (UK/LT regulated AISP/PISP)
- Perspecteev / SaltEdge ecosystem (Lithuania-linked Open Banking infrastructure)
- Powens (France, ACPR-regulated payment institution, CIB 16948)
- These providers initiate payments toward bank endpoints such as Revolut (
oba.revolut.com). - The structure suggests a systematic payment-routing model rather than isolated incidents.
- The setup creates a potential AML and regulatory visibility gap, where banks process payments without full upstream merchant context.
Read our Revolut Rail Atlas reports here.
Executive Summary
FinTelegram’s Rail Atlas investigation has reached a critical phase. Across multiple independent cases—GoldenBet, Paysolo/Pellopay flows, Impaya/Aceiro routing layers, and now Luckzie—one pattern repeatedly emerges:
Offshore casinos do not process payments directly.
They rely on a layered infrastructure that ultimately depends on regulated Open Banking providers.
This interim report identifies three such providers—Yapily, Perspecteev, and Powens—as key chokepoints within the Revolut payment rails ecosystem. While the upstream layers remain opaque and fragmented, the downstream Open Banking layer is licensed, supervised, and therefore within regulatory reach.
The Standard Rail Atlas Model
Based on multiple payment simulations and user-submitted evidence, FinTelegram defines the following canonical payment flow:
Casino Front-End
↓
Anonymous Gateway Layer
(Pagagate / Urbenics / Supergateway)
↓
Routing / Orchestration Layer
(Impaya / Aceiro / PayOp / Paysolo / Pellopay)
↓
Regulated Open Banking Provider
(Yapily / Perspecteev / Powens)
↓
Bank Endpoint
(Revolut / EU Bank)This model explains how transactions originating from offshore casino environments are transformed into seemingly legitimate Open Banking payment requests.
The Regulated Layer: Key Entities
Yapily
Yapily is a well-established Open Banking provider offering payment initiation and account access services across Europe. It has been observed in multiple casino payment flows, including:
- Paysolo / Pellopay routing stacks
- Bilderlings-based Open Banking flows (e.g., GoldenBet)
Role in Rail Atlas:
Payment initiation service provider (PISP), enabling bank connections and user authentication.
Key Question:
What level of merchant context is available to Yapily when initiating payments?
Perspecteev / SaltEdge Ecosystem
Perspecteev operates within the SaltEdge Open Banking ecosystem and has been identified in earlier FinTelegram investigations involving casino payment flows.
Role in Rail Atlas:
Aggregation and payment initiation within Open Banking environments.
Observation:
Repeated presence in high-risk routing stacks suggests systematic use in certain gateway infrastructures.
Key Question:
How are high-risk merchant flows identified and filtered within the SaltEdge ecosystem?
Read our Perpecteev reports here.
Powens (Newly Identified)
Powens is a French payment institution regulated by the ACPR (Autorité de Contrôle Prudentiel et de Résolution) under registration number CIB 16948. It provides Open Banking and Open Finance services, including:
- Payment initiation
- Account aggregation
- Financial data access
Powens was identified in the Luckzie payment flow:
Luckzie → Supergateway → PayOp → Powens → Revolut
Significance:
Powens represents the first major Western European regulated payment institution identified within the Rail Atlas.
Key Question:
Is Powens aware that its services are being invoked within casino deposit flows targeting EU users?
The Unregulated / Grey Infrastructure Layer
In contrast to the regulated entities, the upstream layers remain largely opaque:
| Layer | Entities | Characteristics |
|---|---|---|
| Anonymous Gateways | Pagagate, Urbenics, Supergateway | Minimal transparency, identical UI patterns, routing behavior |
| Routing Layer | Impaya, Aceiro, PayOp, Paysolo/Pellopay | Payment orchestration, dynamic routing, fragmented oversight |
Key Insight:
The unregulated layer obscures the origin of the transaction.
The regulated layer executes it.
This separation is central to understanding the compliance risks.
Regulatory and Compliance Implications
1. PSD2 / Open Banking Transparency Gap
Open Banking payments are user-authorized but often decoupled from full merchant visibility.
Risk:
Banks may approve payments based on authentication alone, without understanding that the transaction originates from an offshore casino.
2. AML / Transaction Monitoring Challenges
Observed flows suggest that the merchant may appear as:
- PayOp / Transferop
- Powens payment request
- Other intermediary entities
Rather than the actual casino operator.
Potential Outcome:
Transaction laundering through Open Banking rails.
3. Gambling Regulation Conflicts
Jurisdictions such as Germany and the Netherlands impose strict rules on:
- Unlicensed gambling operators
- Payment facilitation for such operators
Key Issue:
Are regulated Open Banking providers indirectly facilitating payments that may be prohibited under national gambling laws?
Accountability Framework
The Rail Atlas identifies three levels of potential accountability:
A. Open Banking Providers (Yapily, Powens, Perspecteev)
- Merchant due diligence procedures
- Use-case restrictions (e.g., gambling)
- Transaction monitoring and risk controls
B. Banking Layer (e.g., Revolut)
- Visibility into upstream transaction context
- Classification of Open Banking payments
- Detection of repeated high-risk flows
C. Regulators
- ACPR (France – Powens)
- Bank of Lithuania (Yapily, Perspecteev ecosystem links)
- FCA (UK oversight where applicable)
Key Questions
To Open Banking Providers
- Do you have visibility into the original merchant (casino operator)?
- Do you restrict or monitor gambling-related payment flows?
- What AML controls apply to payment initiation requests from third-party gateways?
To Revolut and Other Banks
- What merchant information is visible at the point of authorization?
- Are Open Banking payments classified by risk category?
- Are repeated flows from specific providers monitored?
Conclusion
FinTelegram’s interim findings suggest that offshore casino payment processing is not random or fragmented. Instead, it relies on a structured, multi-layered system culminating in regulated Open Banking providers.
The critical shift is this:
The focus is no longer on the casinos themselves—but on the licensed infrastructure that enables their payment rails.
This raises fundamental regulatory questions about transparency, due diligence, and the role of Open Banking providers within high-risk payment ecosystems.
Whistle42 Call
FinTelegram invites insiders, payment professionals, compliance officers, and affected players to submit confidential information via the Whistle42 platform.
We are particularly interested in:
- Merchant onboarding documents
- Open Banking integration logs
- Payment-routing configurations
- AML alerts and internal risk assessments
- Additional casino payment flows involving Yapily, Powens, or Perspecteev
