Tag: outsourcing risk

SENDS, GANGA PAY, and the Compliance Question: Why a Licensed UK EMI’s Web-Licensing Structure Deserves Scrutiny

FCA Payment Contributor -
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.