Instead of answering serious compliance questions, Impaya’s CEO Sergejs Roslikovs responded to FinTelegram’s investigation with sarcasm on LinkedIn — “Thanks for the advertisement :)”. His COO joined the tone, celebrating the attention. Meanwhile, Impaya has not answered FinTelegram’s formal inquiry.
As FinTelegram expands its Rail Atlas investigation into offshore casino payment flows, a new element has emerged: alleged threats by Impaya against a player who raised compliance concerns. Screenshots and video evidence reviewed by FinTelegram show aggressive language, legal threats, and mockery — including emojis — instead of a structured response.
FinTelegram has reviewed a whistleblower report indicating that Germany’s financial watchdog BaFin has registered a case concerning Yapily Connect UAB, the Lithuanian licensed arm of the UK open-banking group Yapily. The allegations are explosive: regulated Pay by Bank infrastructure was allegedly used to process deposits for offshore casino brands targeting German players.
FinTelegram’s review of GoldenBet shows a diversified payment architecture around the Santeda Group: card deposits evidenced through Payabl, wallet deposits showing Santeda International Limited as beneficiary via MiFinity, and an Open Banking rail through Bilderlings → Yapily Connect → Revolut’s Open Banking API. This is no longer a single-PSP complaint story. It is a Rail Atlas case study in how offshore casino operators maintain EU-facing payment continuity
Whistleblower evidence reviewed by FinTelegram indicates that casino deposits may pass through a layered redirect chain before reaching the Paysolo open-banking gateway. The observed flow — Pagagate → Impaya.online → Aceiro.online → openbanking.paysolo.net — suggests that Impaya and Aceiro may function as intermediate routing or masking layers between casino-facing payment gateways and the open-banking execution stack involving Paysolo, Pellopay, Yapily and Revolut.
New whistleblower evidence reviewed by FinTelegram appears to show a Dutch-facing casino deposit flow moving from Kingdomcasino into openbanking.paysolo.net, where users are offered banks including Revolut, Rabobank, N26, SNS Bank and Wise. The payment page itself states that the user agrees to allow “Pellopay Finance LTD partners Yapily Connect” to initiate the payment. The evidence strengthens FinTelegram’s working hypothesis that anonymous gateways, open-banking providers, fiat/crypto bridge operators and Revolut’s Open Banking API may form a layered casino-payment corridor.
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,
A FinTelegram whistleblower submission shows Mega.bet using a Klyme-branded pay-by-bank rail with Immix Solutions Ltd as payee, alongside repeated deposits to a Lithuanian account. The case raises fresh questions about Yapily-linked open-banking rails, offshore-gambling merchant controls, and complaints handling.
A player communication reviewed by FinTelegram raises a serious compliance question for Revolut: did the fintech initially tell a customer that Mastercard chargebacks had been raised and finally decided, only to later admit that no chargebacks had been submitted at all? Against the backdrop of FinTelegram’s long-running investigations into illegal offshore casino payment rails, the case sharpens a broader issue.
Norway’s strict payment ban on unlicensed gambling is being quietly undermined by a new, layered payments stack. Using Revolut as an “entry wallet” and Payoro as a withdrawal hub, offshore casinos and their affiliates appear to have created a de facto alternative banking route for Norwegian players—far from the reach of domestic banks and regulators.
While Revolut proudly celebrates its new status as a licensed UK bank, FinTelegram’s compliance review reveals extensive, ongoing involvement in processing payments for unregulated DeFi brokers and offshore casinos, raising serious AML concerns.
Despite aggressive expansion into strictly regulated European and UK markets, LuckyWins operates entirely without legal authorization, hiding behind a Costa Rican shell. Our latest deposit tests reveal a highly sophisticated payment architecture where Tier-1 European financial institutions—including PPRO, Yapily, and MiFinity—are being weaponized to process illegal gambling funds via open banking exploits and "fake FIAT" crypto on-ramps.