A Singapore court has convicted James Henry “Henry” O’Sullivan and Rajaratnam Shanmugaratnam (“Shan”) for falsifying escrow confirmations used to validate Wirecard’s alleged Asian third-party business. The verdict undercuts core defense narratives in Munich and strengthens prosecutors’ case that the “escrowed cash” and TPB never existed. Key Points Verdicts: District Judge Kow Keng Siong found Shanmugaratnam guilty on 13 counts of falsification; O’Sullivan guilty on 5 counts for abetment (letters issued 2016–2018). Sentencing set for November; max penalty up to 10 years’ jail and/or fine (Source: CNA). Amounts & Targets: Letters falsely claimed >€1.1bn held in escrow for Wirecard AG, WCUKI, and Cardsystems, and were sent to EY auditors in Germany/Ireland (Source: singaporelawwatch.sg). Roles: O’Sullivan—close associate of fugitive Jan Marsalek—instigated several letters; Shanmugaratnam signed on Citadelle Corporate Services letterhead (Source: CNA). German Trial Context: In Munich, Markus Braun, Oliver Bellenhaus, and former chief accountant Stephan von Erffa stand trial; Marsalek remains at large (Source: Reuters). Civil/related rulings: Munich court also ordered Braun and two others to pay damages over loans to a Singapore company linked to O’Sullivan, tying threads between cases (Source: Reuters). Short Narrative The Singapore case targeted the paperwork that propped up Wirecard’s supposed Asian “third-party business” (TPB): a chain of balance confirmation letters asserting massive escrow balances at Citadelle. The court concluded those letters were fabrications, with O’Sullivan orchestrating and Shanmugaratnam executing. Prosecutors showed the letters were crafted to mislead Wirecard’s auditors and corporate entities about non-existent funds, directly striking at the credibility of the TPB story line. Extended Legal Analysis 1) Elements proven in Singapore: The convictions establish intentional falsification of escrow confirmations—documents routinely relied upon by auditors and lenders. The court credited extensive email/Telegram trails and rejected defenses premised on “account hacks” or innocence of purpose. This is not a technical breach; it is a finding of fraudulent misrepresentation in the core mechanism that “verified” TPB cash. 2) Evidentiary spillover to Munich: German courts are not bound by foreign criminal verdicts, but these findings are highly persuasive corroboration: They align with the prosecution thesis in Munich that TPB never existed and that audit confirmations were engineered illusions (Source: ft.com). They dovetail with Munich civil findings on unjustifiable loans to a Singapore vehicle connected to O’Sullivan, showing a consistent cross-jurisdictional pattern around the TPB narrative. They weaken any remaining defense argument that audit-trail irregularities were misunderstandings rather than deliberate deception. 3) Witness dynamics: In Munich, Bellenhaus (ex-Dubai head) is a key witness after his release from custody; the Singapore verdicts buttress his account of a constructed TPB overseen by Marsalek, with O’Sullivan as a facilitator. The chain from Dubai (operational claims) → Singapore (escrow confirmations) → Munich (group accounts) becomes more coherent for the court. 4) Impact on individual defendants: Markus Braun: While some counts were trimmed to speed the mammoth trial, core charges on 2016–2018 accounts and bank fraud remain. The Singapore convictions increase the probative weight against the credibility of TPB cash lines in those years. Stephan von Erffa (chief accountant): As the numbers owner, any assertion of good-faith reliance on confirmations looks harder to sustain when a court abroad has now criminally condemned the very confirmations. Jan Marsalek: The verdicts further document his central role in directing the confirmations; they are likely to fuel mutual legal assistance steps and keep the Interpol notice warm. Call for Information FinTelegram invites insiders from Citadelle, Wirecard Singapore/ Dubai, WCUKI, and connected PSPs to share documents on escrow arrangements, audit interactions, and intercompany loans—securely via Whistle42.com. Share Information via Whistle42

Former Austrian Chancellor Sebastian Kurz, now an emblem of elite networking and rapid accumulation of wealth in the post-political sphere, has parlayed his influence into millions through a combination of consulting, investment, and high-stakes tech entrepreneurship. Recent financial disclosures confirm that SK Management GmbH, Kurz’s Vienna-domiciled consulting firm, raked in €2.38 million in profit in its third year—a staggering sum for any consulting business, but especially for a company founded immediately after Kurz’s abrupt political exit amidst corruption allegations. This cashflow is meticulously reported in Austria, and the company now employs a staff of ten, specializing in advising global technology firms and providing geopolitical strategy, with a strong focus on the Middle East and high-level connections to former political allies based in Vienna. Just The Tip of The Iceberg Yet SK Management is only the tip of the iceberg. The true engine behind Kurz’s newfound wealth and international cachet is his pivotal role as co-founder (and roughly 15%-20% shareholder) of Dream Security, the Israeli cybersecurity startup that has exploded in both value and public profile. Founded in early 2023 in partnership with ex-NSO Group CEO Shalev Hulio and cyber expert Gil Dolev, Dream Security specializes in AI-driven cyber defense for governments and critical infrastructure, boasting offices in Tel Aviv, Vienna, and Abu Dhabi. In the past year alone, the company secured an additional $100 million in investment, catapulting its valuation to $1.1 billion and annual revenue to $130 million, largely from national government contracts. Kurz’s role is more than financial—he is Dream’s public face in Europe, leveraging connections from his chancellorship to open doors on the continent for a firm otherwise rooted in Israel’s intelligence ecosystem. It is no coincidence that Dream stands at the crossroads of lucrative cyber defense and international intrigue; its CEO’s NSO Group legacy and the firm’s focus on national infrastructure raise profound questions about surveillance, security, and Kurz’s true role in shaping the company’s strategy and client relationships. These activities have been lauded by some as visionary and derided by others as opportunistic, especially as they coincide with his ongoing legal difficulties in Austria related to perjury and public corruption—allegations he continues to contest. The Peter Thiel Connection Kurz’s American ambitions are equally notable. Peter Thiel, the controversial PayPal co-founder and Silicon Valley kingmaker, hired him as a global strategist for Thiel Capital not long after his resignation. Kurz’s move to California, with rumors of remuneration dwarfing his chancellor’s salary, underscores his access to U.S. power networks. Thiel, known for aggressive investments in tech and a philosophy of disruption, clearly sees value in Kurz’s European connections and crisis-management experience. Their working relationship, forged amidst mutual admiration and political overlap, invites scrutiny into how Kurz’s European knowledge may be leveraged to benefit Thiel’s global ventures, including interests tangential to cybersecurity and data analytics. The scope and velocity of Sebastian Kurz’s post-political business empire raise critical questions. Who benefits from his geopolitical consulting and cybersecurity ventures, and at what cost to public accountability and transparency? Call 4 Information FinTelegram urges whistleblowers and insiders—whether in Austria, the Middle East, or Silicon Valley—to come forward with any information pertaining to SK Management, Dream Security, or Kurz’s international dealings. Only through full transparency can the ties between offshore capital, state secrets, and political influence be brought into the light. Share Information via Whistle42.

Executive Summary Bitcoin pushed to a fresh all-time high around $125k over the weekend and is consolidating just below it today (Mon, 6 Oct 2025, Europe/Vienna). The move caps a year of powerful spot-ETF-driven demand and shrinking new supply after the Apr 20, 2024 halving (block 840,000). Compared with Oct 2017 and Oct 2021, today’s backdrop features deeper institutional rails (U.S. spot ETFs) and clearer regulation (EU MiCA in force), which should moderate—but not eliminate—post-peak drawdowns. Opportunities Structural demand via U.S. spot ETFs: The SEC’s Jan 10, 2024 approvals opened a persistent, brokerage-native buy channel; recent reports cite multi-billion weekly net inflows around the new highs (Source: sec.gov). Programmed supply squeeze: Issuance halved from 6.25 to 3.125 BTC per block on Apr 20, 2024, mechanically reducing sell pressure from miners (Source: Wikipedia). Regulatory normalization (EU): MiCA has entered application (stablecoin rules since 30 Jun 2024; CASP/issuer regime 30 Dec 2024), improving institutional comfort and market conduct (Source: amf-france.org). Risks Cycle reflexivity & precedent: After the 2016 and 2020 halvings, BTC peaked within ~12–18 months and then fell 70–80% in the following bear phases (2018 and 2022). Macro shocks or ETF outflows could re-create deep drawdowns (Source: CoinDesk). Miner economics & fee volatility: Post-halving, miners rely more on fees (boosted at times by Ordinals/Runes activity), which are cyclical and can amplify network-wide liquidity swings (Source: Investopedia). Policy/market-liquidity shocks: 2025 already delivered double-digit monthly selloffs; political or rate-path surprises can quickly unwind momentum (Source: The Guardian). Market Impact (Oct 2025 vs Oct 2021 vs Oct 2017) Oct 2017 (post-2016 halving): Retail-led melt-up into Dec 2017 near $20k, followed by a brutal 2018 crash (~70–80%). No ETF access, minimal institutional rails (Source: Reuters). Oct 2021 (post-2020 halving): Futures-based ETF (BITO) launched in Oct, catalyzing a run toward Nov 2021’s ~$69k ATH before the 2022 bear. Institutional interest rose, but no spot ETF (Source: Reuters) Oct 2025 (post-2024 halving): Spot ETF era + friendlier U.S. policy tone + EU MiCA in force. New ATH ~$125k with meaningful ETF inflows amid macro uncertainty (safe-haven/debasement trade narrative). Regulatory Context United States: SEC approved 11 spot Bitcoin ETPs on Jan 10, 2024, transforming access for RIAs and traditional portfolios. European Union: MiCA now applicable (stablecoins from Jun 30, 2024; remaining provisions Dec 30, 2024), with licensing of CASPs underway—raising baseline standards for custody, market abuse, and disclosures. Actionable Takeaways Position sizing for volatility: Treat 30–50% pullbacks as baseline risk even in an up-cycle; pre-commit add levels rather than chase strength. Use the rails: Prefer spot-ETF wrappers where mandates require it; monitor net-flow momentum as a leading indicator for trend health (Source: MarketWatch). Diversify drivers: Pair BTC exposure with liquid rates hedges or gold if your thesis leans on the “debasement trade” (Source: MarketWatch). Watch miners: Track hashrate/fee mix and public-miner margins; stress in mining often leads broader market weakness (Source: Cointelegraph). Hypothesis: Will the “post-halving crash” repeat? Base case (>50% probability): This cycle peaks later and sees shallower downside than 2018/2022 because spot-ETF demand + MiCA clarity create steadier bid/participation. Expect cyclical drawdowns of 30–50%, not an 80% collapse—unless we see a regulatory shock, major ETF outflows, or a systemic exchange failure. Tail risk (<25%): a policy/credit/liquidity event triggers a >60% drawdown reminiscent of prior cycles. Share Information via Whistle42 Executive Summary Bitcoin pushed to a fresh all-time high around $125k over the weekend and is consolidating just below it today (Mon, 6 Oct 2025, Europe/Vienna). The move caps a year of powerful spot-ETF-driven demand and shrinking new supply after the Apr 20, 2024 halving (block 840,000). Compared with Oct 2017 and Oct 2021, today’s backdrop features deeper institutional rails (U.S. spot ETFs) and clearer regulation (EU MiCA in force), which should moderate—but not eliminate—post-peak drawdowns. amf-france.org+3Reuters+3MarketWatch+3 Opportunities Structural demand via U.S. spot ETFs: The SEC’s Jan 10, 2024 approvals opened a persistent, brokerage-native buy channel; recent reports cite multi-billion weekly net inflows around the new highs. sec.gov+1 Programmed supply squeeze: Issuance halved from 6.25 to 3.125 BTC per block on Apr 20, 2024, mechanically reducing sell pressure from miners. Wikipedia Regulatory normalization (EU): MiCA has entered application (stablecoin rules since 30 Jun 2024; CASP/issuer regime 30 Dec 2024), improving institutional comfort and market conduct. amf-france.org Risks Cycle reflexivity & precedent: After the 2016 and 2020 halvings, BTC peaked within ~12–18 months and then fell 70–80% in the following bear phases (2018 and 2022). Macro shocks or ETF outflows could re-create deep drawdowns. CoinDesk+1 Miner economics & fee volatility: Post-halving, miners rely more on fees (boosted at times by Ordinals/Runes activity), which are cyclical and can amplify network-wide liquidity swings. Investopedia+1 Policy/market-liquidity shocks: 2025 already delivered double-digit monthly selloffs; political or rate-path surprises can quickly unwind momentum. The Guardian Market Impact (Oct 2025 vs Oct 2021 vs Oct 2017) Oct 2017 (post-2016 halving): Retail-led melt-up into Dec 2017 near $20k, followed by a brutal 2018 crash (~70–80%). No ETF access, minimal institutional rails. Reuters Oct 2021 (post-2020 halving): Futures-based ETF (BITO) launched in Oct, catalyzing a run toward Nov 2021’s ~$69k ATH before the 2022 bear. Institutional interest rose, but no spot ETF. Reuters+1 Oct 2025 (post-2024 halving): Spot ETF era + friendlier U.S. policy tone + EU MiCA in force. New ATH ~$125k with meaningful ETF inflows amid macro uncertainty (safe-haven/debasement trade narrative). Reuters+1 Regulatory Context United States: SEC approved 11 spot Bitcoin ETPs on Jan 10, 2024, transforming access for RIAs and traditional portfolios. sec.gov+1 European Union: MiCA now applicable (stablecoins from Jun 30, 2024; remaining provisions Dec 30, 2024), with licensing of CASPs underway—raising baseline standards for custody, market abuse, and disclosures. amf-france.org+1 Actionable Takeaways Position sizing for volatility: Treat 30–50% pullbacks as baseline risk even in an up-cycle; pre-commit add levels rather than chase strength. Use the rails: Prefer spot-ETF wrappers where mandates require it; monitor net-flow momentum as a leading indicator for trend health. MarketWatch Diversify drivers: Pair BTC exposure with liquid rates hedges or gold if your thesis leans on the “debasement trade.” MarketWatch Watch miners: Track hashrate/fee mix and public-miner margins; stress in mining often leads broader market weakness. Cointelegraph+1 Hypothesis: Will the “post-halving crash” repeat? Base case (>50% probability): This cycle peaks later and sees shallower downside than 2018/2022 because spot-ETF demand + MiCA clarity create steadier bid/participation. Expect cyclical drawdowns of 30–50%, not an 80% collapse—unless we see a regulatory shock, major ETF outflows, or a systemic exchange failure. Tail risk (<25%): a policy/credit/liquidity event triggers a >60% drawdown reminiscent of prior cycles.

Our mystery-shopping reviews of the offshore casinos Donbet, Rolletto, and other illegally operating casinos found frictionless onboarding and deposits from the EU and UK—despite the brands lacking local permissions. Both brands are operated by the Santeda network, with payment flows routed via Santeda International Limited (Cyprus) and the gateway UtPay (utpay.io). In multiple tests, Revolut appeared as a checkout option—raising serious questions given UK/EU rules on unlicensed gambling and Revolut’s own public policies. We call on players and insiders to share evidence of Revolut’s involvement in illegal gambling payments. Key Points Operators & structure: Donbet and Rolletto are operated by Santeda International B.V. (Curaçao); Santeda International Limited (Cyprus) acts as payment agent (Source: m.donbet.com, Rolletto.com) Payment orchestration: Deposits presented UtPay gateway flows; UtPay markets a merchant widget supporting cards, Apple/Google Pay and crypto (Source: utpay.io) Revolut at checkout: In FinTelegram’s test deposits (Sept–Oct 2025), Revolut/“Revolut Pay” surfaced as a payment method via UtPay on both brands. Policy clash: UK law (Gambling Act 2005, s.33) criminalises offering facilities for gambling to GB customers without a UKGC licence; payment blocking is flagged as a core tool (Source: Legislation.gov.uk). Revolut’s own stance: Revolut advertises a Gambling Block and says some countries require it to block transactions to illegal operators (Source: Revolut). Regulatory backdrop: Revolut obtained a UK banking licence with restrictions in July 2024 and remains under close scrutiny while exiting “mobilisation” (Source: The Guardian). Wider ecosystem risk: Major payment rails have previously been found processing illegal-site transactions, underscoring gaps in merchant vetting and orchestration (Source: The Guardian). Short Narrative Our investigators registered and deposited at Donbet and Rolletto from multiple EU and UK IPs with no effective geoblocking or jurisdictional gating. Corporate footprints indicate that Santeda International B.V. (Curaçao) operates both brands, with Santeda International Limited (Cyprus) identified as a payment agent in brand documentation. Checkout paths surfaced UtPay, a gateway that embeds a widget for multiple payment types. In these flows, we encountered Revolut/“Revolut Pay” as an available option and successfully completed deposits during our tests. That matters: under UK law, providing gambling facilities to GB consumers without a UK Gambling Commission (UKGC) licence is a criminal offence (s.33). UKGC guidance emphasises payment blocking as a key disruption tool. Revolut, for its part, markets a Gambling Block feature and explicitly notes that in some European countries it must block transfers to illegal operators. The appearance of Revolut payments at unlicensed casinos, therefore, collides with both legal expectations and Revolut’s public controls. Extended Analysis Operator facts: Donbet and Rolletto name Santeda International B.V. as operator under Curaçao eGaming; Donbet/Rolletto materials and a MyStake/Donbet affiliate PDF place Santeda International Limited (Cyprus) in the payment chain. The Cyprus register confirms Santeda International Limited (HE406761) (Source: i-cyprus.com). Gateway layer (UtPay): UtPay publicly offers a plug-in widget and multi-rail acceptance—exactly the sort of payment orchestration layer that can route high-risk traffic across card schemes, APMs and crypto (Source: utpay.i). Revolut exposure: Revolut Pay is a one-click online checkout method available to Revolut and non-Revolut customers. If that button appears on an unlicensed operator accessible in the UK or restricted EU markets, Revolut and its acquiring partners face exposure under AML/CFT and consumer-protection regimes, as well as reputational risk—especially while the firm transitions from a restricted UK banking licence to full permissions (Sourcde: Financial Times). Ecosystem lesson: Prior reporting shows even major card networks have been used on illegal sites, often via third-party payment tools. That amplifies the obligation on wallets, acquirers, PSPs and orchestration vendors to enforce geofencing, merchant KYC, and jurisdictional blacklists (Source: The Guardian). Actionable Insight For regulators: Examine merchant onboarding and transaction-level controls at Revolut and UtPay for gambling MCCs/merchant IDs linked to Santeda-operated sites. Cross-reference with UKGC and EU national blacklists (Source: Gambling Commission). For Revolut & partners: Review checkout placements where Revolut Pay is exposed on unlicensed operators; align with the firm’s “local requirements” blocking policy; perform retrospective remediation and SARs where warranted (Source: Revolut). For consumers/victims: If you deposited to Donbet/Rolletto with Revolut, retain evidence (screenshots, receipts, Revolut statements, merchant descriptors, UtPay widget IDs) and file complaints with your national regulator and card/wallet provider. Call for Information (Whistle42) Were you offered Revolut as a payment option at Donbet, Rolletto, or other unlicensed casinos? Are you a current/former Revolut, acquirer, or UtPay insider with knowledge of merchant onboarding or blocking lists? We want to hear from you. Share artefacts (checkout screenshots, payment confirmations, merchant descriptors, emails/chat logs) via Whistle42—confidentially and securely. Share Information via Whistle42

Executive Summary: The Ultimate Regulatory Evasion Machine Santeda International operates the most comprehensive illegal gambling network targeting European consumers, utilizing a sophisticated web of Cyprus-based payment agents, shell licensing structures, and mainstream financial facilitators including Revolut, MiFinity, and major payment processors. Through six identical casino brands and a complex corporate maze spanning Curaçao and Cyprus, Santeda has created an industrial-scale operation that systematically violates gambling laws across the EU and UK while exploiting regulatory arbitrage to evade enforcement. The Santeda Casino Empire: Six Brands, One Criminal Operation Core Casino Brands: MyStake Casino – Sports betting specialist with over 7,000 games VeloBet Casino – Football-focused platform launched 2023 Rolletto Casino – “Mafia-themed” gaming platform DonBet Casino – Operating under fraudulent GTW B.V. licensing facade GoldenBet Casino – Premium gaming platform with 6,000+ slots CosmoBet Casino – Multi-platform gambling operation All six platforms share identical infrastructure, payment systems, customer support, and terms of service, confirming they are functionally the same business operation disguised as separate entities. Corporate Structure: A Masterclass in Beneficial Ownership Concealment Primary Operating Entity Santeda International B.V. Registration: Curaçao Company Number 151296 Address: Abraham Mendez Chumaceiro Boulevard 03, Curaçao Gaming License: OGL/2024/1798/1048 (Curaçao Gaming Authority) Status: Active since 2020 EU Payment Processing Hub Santeda International Limited Registration: Cyprus HE406761 Address: Patrikiou Loumoumpa, 7, Block A, Flat A13, 7560 Pervolia, Larnaca, Cyprus Director: Christos Samaras Role: Primary payment processor for all casino deposits and withdrawals The GTW B.V./CYGTW LTD Licensing Fraud Most egregiously, DonBet operates under a completely fraudulent licensing structure: Claims ownership by: GTW B.V. (Curaçao License OGL/2024/250/0115) Claims payment agent: CYGTW LTD (Cyprus) Reality: All payments processed by Santeda International Limited (Cyprus) This represents deliberate misrepresentation of corporate ownership and regulatory compliance to deceive players and regulators. Payment Processing Network: Mainstream Banks Facilitating Illegal Gambling Primary Payment Facilitators Based on FinTelegram’s review findings and player bank statements: Traditional Banking: Revolut – Processing direct bank transfers and card payments despite Terms of Service prohibiting unlicensed gambling Rapidob – Specialized bank deposit processor for European players Banking Circle – Likely backend processor via Cyprus infrastructure E-Wallet Facilitators: MiFinity – UK/Malta regulated e-wallet facilitating illegal gambling transactions Jeton Bank – Digital wallet processor UtPay – Crypto-fiat bridge processor enabling Revolut deposits The Revolut Compliance Scandal Revolut’s facilitation of Santeda deposits represents one of the most serious compliance failures in European fintech. Despite clear terms prohibiting “illegal gambling transactions” and specific restrictions on unlicensed operators, Revolut continues processing payments to Santeda casinos across restricted jurisdictions. MiFinity’s systematic violation of its own anti-gambling policies is equally damning, with the company’s terms explicitly forbidding “payments to or from persons or entities offering illegal gambling services” while actively facilitating Santeda operations. Regulatory Violations and Criminal Activity Systematic License Evasion FinTelegram’s testing confirmed unrestricted access to all Santeda casinos from: United Kingdom – No UKGC license, direct violations of Gambling Act 2005 Germany – No GGL license, breach of State Treaty on Gambling Netherlands – No KSA license, violation of Gambling Act (Wok) France – No ARJEL license, breach of gambling monopoly laws Multiple EU jurisdictions – Systematic violation of national gambling laws Australia Regulatory Action The Australian Communications and Media Authority (ACMA) has issued formal warnings to Santeda entities for illegal gambling operations, confirming international regulatory scrutiny. Payment Processing Crimes Unlicensed Money Transmission – Santeda International Limited (Cyprus) operates without proper payment services licensing AML Violations – No evidence of adequate customer due diligence or transaction monitoring Bank Fraud – Misrepresenting transaction purposes to mainstream financial institutions Player Harm and Withdrawal Failures Consumer complaints reveal systematic issues: Delayed withdrawals across all Santeda platforms Account restrictions without explanation during withdrawal attempts KYC weaponization to delay legitimate payouts Shared liquidity problems suggesting undercapitalized operations Player testimonials confirm identical stalling tactics across all six casino brands, proving centralized management of customer funds and withdrawal policies. Compliance Violations by Payment Facilitators Revolut’s Regulatory Breach Direct violation of company Terms of Service prohibiting illegal gambling AML compliance failure – Processing payments to unlicensed operators Consumer protection breach – Enabling addiction and financial harm in restricted markets MiFinity’s Systematic Facilitation Breach of FCA/MFSA obligations – UK and Malta regulators require prevention of illegal gambling Terms of Service violations – Explicit prohibition of illegal gambling payments ignored KYC/AML failures – No adequate screening of gambling-related transactions Traditional Banking Complicity Every mainstream bank processing Santeda transactions via intermediaries is potentially liable for facilitating illegal gambling and money laundering, as the ultimate beneficiary (Santeda casinos) operates without proper licensing. Key Data Summary Table CategoryDetailsWebsite/Domainmystake.com, velobet.com, rolletto.com, donbet.com, goldenbet.com, cosmobet.comSocial MediaTwitter: @MyStakeCasino, @VeloBetCasino, @RollettoCasino, @DonBetCasinoLegal EntitiesSanteda International B.V. (Curaçao, Reg: 151296)Santeda International Limited (Cyprus, Reg: HE406761)GTW B.V. (Curaçao, Reg: unknown)CYGTW LTD (Cyprus, payment agent)Key IndividualsChristos Samaras (Director, Santeda International Limited Cyprus) Unknown beneficial owners (shell structure)Jurisdictions Curaçao (licensing jurisdiction) Cyprus (EU payment processing hub) EU/UK (illegal target markets) LicensesSanteda International B.V.: OGL/2024/1798/1048 (Curaçao)GTW B.V.: OGL/2024/250/0115 (Curaçao – Donbet facade)Payment ProcessorsPrimary: UtPay, Revolut, MiFinity, Jeton Bank, RapidobHub: Santeda International Limited (Cyprus) – primary processorCasino BrandsMyStake, VeloBet, Rolletto, DonBet, GoldenBet, CosmoBet (6 sister sites, identical operations)Regulatory Issues Australia ACMA warnings (2024) Player withdrawal complaints Unlicensed EU/UK operations Compliance Violations Facilitating illegal gambling in restricted jurisdictions Payment processing without proper licenses Regulatory arbitrage via Cyprus-Curaçao structure Misleading licensing claims (GTW B.V. facade at DonBet) Immediate Enforcement Actions Required FinTelegram suggests coordinated international enforcement: Immediate freezing of all Santeda International Limited (Cyprus) accounts Criminal investigation of Christos Samaras and unknown beneficial owners Revolut license review by UK FCA for systematic compliance failures MiFinity regulatory action by UK FCA and MFSA for illegal gambling facilitation Payment processor sanctions against all entities facilitating Santeda operations ISP blocking of all six casino domains across EU/UK jurisdictions Conclusion: Europe’s Gambling Compliance Crisis The Santeda International network represents the complete breakdown of European gambling regulation and payment system integrity. When mainstream banks like Revolut and regulated e-wallets like MiFinity actively facilitate illegal gambling operations, the entire compliance framework is compromised. This is not merely regulatory arbitrage—it is systematic criminal enterprise exploiting jurisdictional gaps, payment system vulnerabilities, and regulatory enforcement failures to operate industrial-scale illegal gambling across Europe. The fact that six identical casino brands can operate openly, process millions in transactions through mainstream financial institutions, and continue operations despite player complaints and regulatory warnings demonstrates the urgent need for coordinated international enforcement and fundamental reform of cross-border payment oversight. Santeda International is not an isolated case—it is the blueprint for the future of illegal gambling unless immediate action is taken. Whistleblower Call for Critical Intelligence The Santeda network likely encompasses additional undiscovered operations and facilitators. FinTelegram urgently seeks insider information about: Corporate Intelligence Needed: Complete beneficial ownership of Santeda International B.V. and related entities Banking relationships and account details for all Santeda entities Additional casino brands or gambling operations under Santeda control Internal communications regarding regulatory evasion strategies Payment Processing Intelligence: Complete list of payment facilitators beyond those identified Volume and destination of player deposits and casino revenues Money laundering methodologies used to move funds internationally Compliance bypass techniques used with mainstream financial institutions Player and Employee Intelligence: Withdrawal refusal patterns and customer fund seizures Employee testimonials about internal operations and management Marketing strategies targeting restricted jurisdictions Customer database access and data protection violations Submit evidence securely and anonymously via FinTelegram’s whistleblower platform: Whistle42.com Your information is critical to dismantling Europe’s most sophisticated illegal gambling network and protecting consumers from predatory operations enabled by mainstream financial institutions. Share Information via Whistle42