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.
Fresh whistleblower intelligence suggests that the Holyluck payment trail was not an isolated event. FinTelegram has reviewed new SENDS communications and new UK merchant entities linked to digital-goods storefronts that may have functioned as front-end payment layers for offshore gambling flows. The emerging picture points to a broader merchant cluster, not a single disputed transaction.