The new generation of FinTechs in the high-risk segment typically works with a group of companies across different regulatory regimes and jurisdictions. Each company of the respective FinTech group is focused on a special task. Among these companies, there is regularly a licensed company and one or more unlicensed companies. The licensed company regularly refers to itself as an online bank or payment services provider (PSP). The unlicensed companies usually operate as API-based payment processing platforms (PPP) in the ecosphere of the licensed company. Those new FinTech groups with their fragmented corporate structures, cross-company services, and multi-jurisdictional approach actually constitute a massive challenge for regulators. In many cases, the only relationship between these differently branded FinTechs and their respective services is their beneficial owner. Today we present our review on the Naspay & BigWallet FinTech group.
Introducing Naspay and BigWallet
We came across the Naspay & BigWallet group in connection with broker and crypto-scams. For example, the illegal crypto broker FX Crypto Club has integrated Naspay (see FinTelegram report here) as a payment services provider. One of the scams operating entity was registered as a merchant with them. Apparently, the FinTech group is operated by Denis Kazakov and comprises the following entities and brands:
|Individual & entity||associated brands||Jurisdiction||Description|
|N.A. Naspay Limited||Naspay (www.naspay.com)||Cyprus||unlicensed operating entity behind Payment Processor Platform NasPay Cashier platform|
|Silvergate Technologies Limited||BigWallet Payments (www.bigwpay.com)||Cyprus||licensed operating entity behind the Payment Services Provider (PSP) BigWallet Payments|
|Silvergate LT UAB||BigWallet (www.bigwallet.com)||Lithuania||licensed operating entity behind Online Bank BigWallet|
|Deniz Kazakov||Naspay, BigWallet Payments||Cyprus||CEO and founder of BigWallet Payments and NasPay (LinkedIn profile)|
|Rati Tchelidze||BigWallet, BigWallet Payments||Lithuania||Director Silvergate LT UAB and Silvergate Technologies Ltd|
|Alexander Ketishvili||BigWallet, BigWallet Payments||Georgia||Former Director Silvergate LT UAB, Director Silvergate Technologies Ltd, currently CIO TBI Bank in Georgia|
The Naspay & BigWallet group apparently works with the “FinTech Pattern”, i.e. with their service portfolio diversified over several brands and legal entities in different jurisdictions. The two Silvergate companies in Lithuania and Cyprus are e-money service providers licensed in Cyprus and Lithuania respectively. While Naspay is a provider of Naspay Cashier with the corresponding processing platform, BigWallet Payments presents itself as a PSP and BigWallet as a Lithuanian online bank.
According to his LinkedIn profile, the former CEO of BigWallet Payments Alexander Ketishvili currently works as Chief Information Officer with the Georgian TBI Bank. Before joining the BigWallet group, Ketishvili worked for several other Georgian banks. Hence, it may be assumed that the BigWallet group is well-connected with Georgian banks.
In our review, we found that when registering with BigWallet (www.bigwallet.com) to set up an account, the Ondata UAB, a company registered in Lithuania is involved in the KYC process. As a potential new client, you have to accept that the personal data is provided to this Ondata. Upon successfully completed registration, we received the usual confirmation email. The verification required after registration is done via the now common face and passport pictures taken via the camera on the computer. We assume (but do not know) that Ondata works with face recognition and AI algorithms.
The registration at BigWallet Payments, on the other hand, is somewhat different. We applied for a merchant account and had to submit a respective merchant pre-check form. However, we were not asked for an email address or phone number or any other contact information. After submitting the online form, we received a message on the website that the BigWallet Payments team would contact us. How will this work if we did not leave any contact information? We are curious and will report back. That’s a strange process flaw for a company that claims to be a fast-growing PSP.