A Dutch legal-forensic initiative has pushed the illegal-casino debate into a new phase. ITFY Legal has served a detailed forensic cluster report, a Casino Monitor infrastructure report, and a follow-up addendum concerning the HolyLuck-linked casino network on casino operators, payment facilitators, regulators, government agencies and infrastructure providers. The reports draw on FinTelegram’s earlier investigative findings but go deeper into technical infrastructure analysis.
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.
FinTelegram’s Revolut Rail Atlas has identified another regulated Open Banking enabler inside an offshore casino cashier: Powens, a French ACPR-regulated payment institution. In a test of Luckzie Casino, Revolut appeared as a prominent payment option alongside cards and crypto. The observed flow moved from Luckzie to supergateway.net, then to PayOp, then to Powens, and finally to Revolut’s Open Banking API at oba.revolut.com.
FinTelegram’s first Revolut Rail Atlas follow-up zooms in on openbanking.paysolo.net, a payment gateway that appears to sit between anonymous casino-facing gateways and Revolut’s Open Banking API. SimilarWeb screenshots indicate that all referring traffic to openbanking.paysolo.net came from the anonymous payment gateways Pagagate and Urbenics in March 2026.
FinTelegram’s Rail Atlas analysis have repeatedly observed Revolut’s Open Banking endpoint inside layered offshore casino payment flows. The pattern appears to combine anonymous gateways, open-banking intermediaries, and Revolut’s own customer-side payment infrastructure. This does not prove knowing facilitation by Revolut — but it raises serious questions about monitoring and merchant transparency,
In a major blow to Malta-licensed online casinos, the CJEU held that Member States may prohibit certain online gambling services despite foreign EU licences and may attach civil-law consequences, including void contracts and player restitution claims.
FinTelegram’s review of SENDS has uncovered a new structural red flag: the public-facing website of Smartflow Payments Limited, the FCA-authorised EMI behind SENDS, is owned by a separate UK company, GANGA PAY LTD, and used under a software licence. In isolation, that may be a routine outsourcing arrangement. In the context of SENDS’ rapid acquiring growth, Ukrainian control persons on both sides, and ongoing whistleblower allegations around casino-linked merchant flows, it raises a much sharper compliance question.
A new FinTelegram Rail Atlas analysis shows Perspecteev SAS, the French payment institution behind the Bridge brand, appearing in deposit flows linked to offshore casino brands targeting German users — with opaque gateway labels such as “SaferSEPA” sitting between the casino front end and the regulated payment-initiation layer.