FinTelegram’s ongoing investigations into online gambling operators have placed MineBit—a casino with alleged ownership ties to Ukraine and Portugal—under particular scrutiny. Recent communications reviewed by our editorial team confirm mounting pressure on MineBit (MineBit.com) to respond to player complaints and clarify its ownership structure in the wake of a high-value winnings dispute. Background: Ownership Allegations and Regulatory Concerns MineBit’s cross-border ownership has drawn attention from compliance analysts and regulatory observers. According to an email correspondence obtained by FinTelegram, at least two of MineBit’s owners are reportedly from Portugal, with another originating from Ukraine. In fact, FinTelegram has received the names of individuals who are allegedly the UBOs. Offshore ownership models like this are often a red flag for regulators and financial crime investigators, given the potential for obfuscated beneficial ownership and loopholes in local oversight requirements. Player Winnings of $800,000 Under Dispute The controversy escalated after a player reportedly secured winnings of $800,000, prompting formal inquiries from independent investigators and the press. The email exchange reveals FinTelegram agents repeatedly reached out to MineBit for comment, specifically requesting answers to a series of questions regarding the legitimacy and payment status of this substantial player win. The messages make it clear: failure to respond would lead to public exposure and investigative reporting on the matter. MineBit’s Response – Silence and Deflection In the email thread, MineBit support acknowledges receipt of the inquiries, opting for generic assurances about respectful communication rather than directly addressing the core issues raised. This pattern of non-responsiveness is consistent with previous cases documented in FinTelegram’s coverage of high-risk gaming operations, where silence often serves as an implicit admission of operational or compliance concerns. MineBit Casino’s recent actions—voiding $800,000 in winnings under the pretext of jurisdictional restrictions—raise alarming questions about their regulatory conduct and criminal enforcement practice. MineBit allowed deposits and withdrawals from Malaysian users, offered no geoblocking, and only enforced restrictions when a player’s winnings reached a significant sum. This practice not only undermines trust but suggests selective enforcement and a criminal strategy to avoid large payouts. Selective Enforcement and Regulatory Failure Despite operating for some time without issue, MineBit abruptly voided winnings by shifting between rationales: initially, they questioned the legitimacy of bets (which the game provider confirmed were valid); later, they invoked Singaporean law due to the player’s nationality—despite clear evidence the player was residing in Malaysia. Finally, the casino cited Malaysian law, yet failed to distinguish between the country’s religious-based gambling prohibitions for Muslims and its allowances for non-Muslims. Such shifting arguments signal bad-faith conduct and indicate MineBit is more invested in protecting its own bottom line than in upholding any stable legal or ethical standard. MineBit Support: A Criminal Enforcement Tool Information leaked to FinTelegram by agents indicates that MineBit Support only quotes parts of the terms in its argumentation, thereby distorting the truth with regard to the intended fraud (there is no other way to describe it). MineBit Support is an enforcement instrument of MineBit‘s criminal activities. As evidenced in the provided screenshot (see left), MineBit Support references the company’s terms and conditions to justify the blocking of player accounts from countries where MineBit’s services are deemed illegal. However, the response selectively omits the subsequent clause, which clearly stipulates that in such instances, the player is entitled to a full refund of their original stake. In the case at hand, there appears to be an effort by MineBit to withhold the required refund, raising concerns about compliance with their own stated policies. Moreover, it is noteworthy that, under MineBit’s own terms and conditions, the operator would ostensibly be obligated to refund the stakes of nearly all players. This is due to the fact that MineBit currently operates without the requisite license, rendering its services effectively prohibited across all recognized jurisdictions. Licensing and Consumer Protection Risks There is no public evidence that MineBit Casino holds a reputable international license or adheres to responsible gambling and transparency measures promoted in regulated jurisdictions such as Malta or the UK. Leading authorities like the UK Gambling Commission and Malta Gaming Authority (MGA) require fair treatment of players and robust KYC/AML controls. Selectively voiding large winnings, while honoring smaller payouts to the same player, runs contrary to globally accepted consumer-protection principles and opens the door to regulatory sanctions. Conclusion: Need for Transparency and Accountability At the time of writing, Minebit has not provided substantive answers regarding the ownership accusations or the disputed winnings. As calls for regulatory enforcement and public scrutiny intensify, this case exemplifies persistent risks endemic to offshore gambling operators and highlights the importance of investigative journalism in safeguarding player interests. Call for Whistleblower Input FinTelegram will continue to monitor and investigate the MineBit developments and encourages industry insiders, affected players, and whistleblowers to come forward with additional information. Insiders with knowledge of MineBit’s internal policies, ownership structure, licensing status, names of support agents, or operational strategy are urgently encouraged to submit information via the Whistle42 platform. Details about MineBit’s compliance protocols, payment processing partners, or underlying business motivations for selective enforcement are critical to exposing whether this pattern is isolated or systemic. Share Information via Whistle42

Executive Summary Case Study: Kingdom Casino & UtPay Compliance Circumvention Analysis This report analyzes a sophisticated money laundering and regulatory evasion scheme operated by Utrg UAB d/b/a UtPay (utpay.io), a Lithuanian-regulated crypto payment processor, in partnership with Kingdom Casino (kingdomcasino.io), an offshore casino. Through FinTelegram’s direct investigation, we have documented how UtPay systematically enables illegal gambling operations by disguising casino deposits as “cryptocurrency purchases” via stealth domains, thereby circumventing anti-money laundering controls, consumer protection regulations, and payment network restrictions across multiple jurisdictions. The scheme represents a paradigmatic case of how seemingly legitimate, EU-regulated financial service providers can be weaponized to facilitate systematic violations of gambling laws, consumer protection standards, and financial crime prevention measures. This analysis serves as a reference case for understanding sophisticated payment processing methodologies employed throughout the high-risk offshore gambling sector. Introduction: The UtPay Deception Model UtPay, operating as UAB “Utrg” under Lithuanian cryptocurrency service provider licensing, markets itself as providing “full compliance” and “worldwide coverage” for legitimate Web3 companies. However, FinTelegram’s investigation reveals systematic facilitation of illegal gambling operations through deliberately deceptive payment flows designed to: Circumvent gambling-specific payment restrictions imposed by card networks and banking regulations Eliminate consumer protection mechanisms, including chargeback rights and dispute resolution procedures Obscure transaction traceability for anti-money laundering and regulatory enforcement purposes Enable operations in prohibited jurisdictions without direct regulatory oversight This model exploits the regulatory arbitrage between cryptocurrency licensing (governed by Lithuanian authorities) and gambling regulation (absent for offshore operators), creating a compliance gap that facilitates large-scale financial crime. Case Study: Kingdom Casino Payment Flow Analysis Discovery and Investigation Methodology During FinTelegram’s compliance review of Kingdom Casino (kingdomcasino.io), an unlicensed offshore gambling operator, our investigators documented the complete payment processing flow for EUR deposits via RAPID transfer offered by Skrill. The investigation revealed a multi-layered deception scheme involving: Primary casino domain: kingdomcasino.io (unlicensed offshore operation) Stealth payment domains: greenpayway.com and pay2prom.com (no corporate disclosure) Final processing domain: app.utpay.io (UtPay‘s payment interface) Legal entity: Utrg UAB (Lithuanian-registered crypto service provider) Deceptive Payment Flow Documentation Step 1: Player Initiation Player selects EUR deposit via RAPID on Kingdom Casino System displays standard casino deposit interface with no cryptocurrency disclosure Step 2: Domain Redirection Through Stealth Gateways Player redirected to greenpayway.com (domain with zero corporate transparency) Secondary redirection to pay2prom.com (equally opaque stealth domain) Final redirection to app.utpay.io (UtPay’s actual payment processing interface) Step 3: Undisclosed Cryptocurrency Conversion UtPay interface presents payment form with pre-checked consent box Consent text: “I agree to buy crypto and send it to the specified address” CRITICAL DECEPTION: Player believes they are making casino deposit, not purchasing cryptocurrency No clear disclosure that transaction will be processed as cryptocurrency purchase rather than gambling deposit Step 4: Legal Classification Manipulation Transaction processed as “cryptocurrency purchase” under Lithuanian regulation Funds legally classified as crypto commerce, not gambling deposit Consumer protection mechanisms eliminated through legal reclassification Step 5: Crypto Transfer to Casino Purchased cryptocurrency automatically transferred to Kingdom Casino’s wallet Player account credited with “casino balance” equivalent to crypto purchase amount Payment processor relationship with gambling operation obscured through crypto transfer mechanism Regulatory Evasion Mechanisms Banking Restriction Circumvention: The scheme enables Kingdom Casino to accept traditional banking payments (RAPID, credit cards, e-wallets) despite lacking gambling licenses that would permit direct banking relationships. By processing payments as “cryptocurrency purchases,” UtPay provides access to regulated payment methods that would otherwise be prohibited for unlicensed gambling operations. Consumer Protection Elimination: Players lose fundamental consumer protection rights through legal reclassification: Chargeback Rights: Credit card chargebacks unavailable for “cryptocurrency purchases” Banking Dispute Resolution: Banks cannot reverse “legitimate” crypto transactions Regulatory Recourse: No gambling-specific consumer protection mechanisms apply Refund Rights: Standard gambling refund protections circumvented through crypto purchase classification AML Control Bypassing: The multi-layer structure systematically defeats anti-money laundering controls: Source Identification: Payment appears as legitimate crypto purchase, not gambling deposit Transaction Monitoring: AML systems cannot identify gambling-related transaction patterns Regulatory Reporting: Suspicious transaction reports triggered by different criteria for crypto commerce versus gambling Audit Trail Obscuration: Complex multi-domain structure complicates transaction tracing UtPay Corporate Structure and Regulatory Status Lithuanian Registration and Licensing Primary Entity: Legal Name: UAB “Utrg” Registration Code: 306062887 VAT Number: LT100016489119 Address: Kareivių g. 19-149, LT-09133 Vilnius, Lithuania Manager: Andrius Atkočaitis Founded: April 12, 2022 Regulatory Authorization:UtPay operates under Lithuanian cryptocurrency service provider licensing, authorized for: Virtual currency exchange against fiat currency Virtual currency wallet services Virtual currency exchange against virtual currency Depository virtual currency wallet operations Compliance Certifications: PCI DSS Level 2 certification for payment processing security Partnership with Quicko Sp. z o.o. (Poland) for debit card services Integration with MasterCard SecureCode and Visa Secure authentication systems Financial Performance and Scale Operational Metrics (2023): Revenue: €442,228 Net Profit: €32,680 Employees: 8 insured individuals Average Salary: €1,987.12 (June 2025) Despite relatively modest reported revenues for 2023, UtPay‘s facilitation of high-volume offshore gambling transactions suggests significant unreported or misclassified business activity. Corporate Network and Partnerships Related Entities: UTORG LABS HOLDING LTD: Abu Dhabi-registered entity providing non-custodial wallet services Quicko Sp. z o.o.: Polish partnership for European debit card services Key Personnel: Edgar Fukalov (identified as key figure) Systemic Regulatory Violations Lithuanian Cryptocurrency Regulation Violations AML/KYC Compliance Failures:While UtPay claims “full compliance” with Lithuanian regulations, facilitating disguised gambling deposits violates fundamental anti-money laundering principles: Customer Due Diligence: Processing gambling-related transactions without proper risk assessment Transaction Monitoring: Failure to identify and report suspicious gambling-related transaction patterns Beneficial Ownership: Obscuring the true nature of cryptocurrency purchases for gambling purposes Record Keeping: Inadequate documentation of cryptocurrency end-use and beneficial ownership Service Provider Authorization Violations:UtPay’s cryptocurrency service provider license authorizes legitimate crypto commerce, not facilitation of illegal gambling operations. Using legitimate licensing to enable prohibited activities violates Lithuanian regulatory requirements. EU-Wide Payment Service Violations Payment Services Directive (PSD2) Violations: Transparency Requirements: Concealing the true nature of payment transactions from consumers Consumer Rights: Eliminating dispute resolution and refund mechanisms through transaction misrepresentation Risk Management: Failing to implement appropriate risk controls for high-risk gambling payments Anti-Money Laundering Directive Violations: Enhanced Due Diligence: Inadequate scrutiny of high-risk gambling-related cryptocurrency transactions Suspicious Transaction Reporting: Failure to identify and report patterns consistent with money laundering through gambling operations Record Keeping: Insufficient documentation of transaction purposes and beneficial ownership Gambling Regulation Violations Unlicensed Gambling Facilitation:UtPay systematically enables unlicensed gambling operations across multiple jurisdictions where such activities are prohibited: European Union: Facilitating gambling deposits for operations lacking national licensing United Kingdom: Processing payments for unlicensed operators prohibited under UKGC regulations Additional Jurisdictions: Enabling deposits for casinos operating illegally across global markets Consumer Protection Circumvention:The scheme deliberately circumvents gambling-specific consumer protections including: Deposit limits and cooling-off periods Self-exclusion enforcement mechanisms Responsible gambling interventions Problem gambling identification and support systems Network Analysis: UtPay’s Offshore Casino Ecosystem Documented UtPay Integration Partners FinTelegram’s investigation has identified UtPay payment processing integration across multiple offshore gambling operations beyond Kingdom Casino: Confirmed Integration Partners:Based on technical analysis and transaction flow documentation, UtPay provides payment processing services to numerous offshore gambling operators employing identical deceptive methodologies. Common Operational Patterns: Curaçao or Anjouan gambling licensing (minimal regulatory oversight) Operations in prohibited jurisdictions without local authorization Use of stealth domains to obscure payment processor relationships Identical “crypto purchase” deception schemes to eliminate consumer protections Targeting of European, UK, and regulated markets without proper licensing Scale Assessment:Given UtPay’s reported revenue figures and the high-volume nature of offshore gambling transactions, the company likely processes millions of euros in disguised gambling deposits annually across its casino partner network. Stealth Domain Infrastructure Analysis greenpayway.com and pay2prom.com:These domains serve exclusively as payment gateway redirects with zero corporate transparency: No Corporate Information: No company registration, ownership disclosure, or contact information No Public Website: Domains exist solely for payment processing redirects No Consumer Recourse: Players cannot identify or contact the actual payment processor Regulatory Evasion: Structure designed to obscure payment processing relationships from regulators and consumers This infrastructure represents a sophisticated compliance evasion mechanism enabling offshore casinos to obscure their payment processing relationships while maintaining access to regulated payment methods. UtPay Crypto Payment Scheme – Complete Entity MappingCategoryDetailsPrimary Casino OperatorKingdom Casino (kingdomcasino.io) – Unlicensed offshore gambling operationStealth Payment Domains – greenpayway.com (no corporate disclosure) – pay2prom.com (no corporate disclosure) Purpose: Obscure payment processor identity from players and regulators Crypto Payment Processor UtPay – Website: utpay.io – Payment Interface: app.utpay.io – Terms: utpay.io/terms-of-use – FAQ/KYC Policy: utpay.io/faq Legal EntityUAB “Utrg” (Lithuania)Key Personnel – Andrius Atkočaitis – Registered Manager – Edgar Fukalov – Key operational figure – Associated with UTORG network Regulatory StatusLithuanian Cryptocurrency Service Provider LicenseRelated Corporate NetworkUTORG LABS HOLDING LTD (Abu Dhabi), Quicko Sp. z o.o. (Poland) – European debit card servicesUTORG (utorg.pro) – Related crypto service providerDeception Mechanism – Pre-checked consent: “I agree to buy crypto and send it to specified address” – Hidden conversion: EUR deposit becomes crypto purchase – Consumer protection elimination: No chargeback/refund rights for “crypto purchase” – AML evasion: Gambling deposit disguised as legitimate crypto commerce Regulatory Violations – Lithuanian AML/KYC compliance failures – EU Payment Services Directive (PSD2) violations – Unlicensed gambling facilitation across multiple jurisdictions – Consumer protection circumvention – FATF anti-money laundering standard violations Risk Assessment EXTREMELY HIGH – Systematic money laundering facilitation – Consumer protection elimination – Regulatory evasion across multiple jurisdictions – No consumer recourse mechanisms Investigation Status FinTelegram Active Investigation – Part of Crypto Payment Processor Watch series – Evidence documented from Kingdom Casino review – Screenshots obtained of deceptive payment flow – Whistleblower intelligence sought via Whistle42 This sophisticated scheme exploits the regulatory gap between Lithuanian cryptocurrency licensing and gambling regulation, using Skrill+RAPID as the final payment method while disguising EUR casino deposits as “cryptocurrency purchases” to eliminate consumer protections and enable money laundering for offshore gambling operations. Consumer Harm and Financial Crime Risks Systematic Consumer Protection Elimination Chargeback and Dispute Resolution Denial:The “crypto purchase” deception eliminates fundamental consumer protection mechanisms: Credit Card Chargebacks: Banks refuse chargebacks for “legitimate” cryptocurrency purchases Banking Dispute Resolution: Standard banking dispute procedures inapplicable to crypto commerce Regulatory Complaints: No gambling-specific complaint mechanisms available for “crypto purchases” Legal Recourse: Civil litigation complicated by transaction mischaracterization Vulnerable Player Exploitation:The scheme systematically exploits gambling addiction vulnerabilities: Self-Exclusion Circumvention: Gambling blocks defeated through “crypto purchase” processing Deposit Limit Evasion: Banking-based gambling controls bypassed through crypto conversion Addiction Intervention Prevention: Payment patterns hidden from gambling addiction support systems Money Laundering Facilitation Layering and Integration Services:UtPay’s model provides sophisticated money laundering capabilities: Stage 1 – Placement: Illicit funds deposited as “legitimate” cryptocurrency purchases Transaction appears as standard crypto commerce in banking records Source identification obscured through legal classification manipulation Stage 2 – Layering: Funds converted through multiple cryptocurrency transitions Complex multi-domain payment flows obscure transaction tracing Gambling activity provides legitimate-appearing fund mixing mechanism Stage 3 – Integration: “Winnings” withdrawn as apparently legitimate gambling proceeds Clean cryptocurrency or fiat withdrawals complete money laundering cycle Regulatory oversight defeated through transaction mischaracterization Criminal Organization Applications:The scheme enables systematic money laundering for organized crime, terrorism financing, tax evasion, and corruption proceeds through offshore gambling operations. International Regulatory Implications Lithuanian Regulatory Failures Insufficient Oversight:Lithuania’s cryptocurrency regulation framework lacks adequate controls for preventing gambling-related abuse: Limited Transaction Monitoring: No specific controls for identifying gambling-related cryptocurrency transactions Inadequate Due Diligence: Customer due diligence standards insufficient for high-risk gambling applications Enforcement Gaps: Regulatory enforcement mechanisms inadequate for complex international schemes Cross-Border Coordination: Limited coordination with gambling regulators in destination markets Regulatory Arbitrage Exploitation:UtPay exploits regulatory gaps between cryptocurrency oversight (Lithuanian authorities) and gambling regulation (absent for offshore operators) to facilitate systematic law violations. European Union Regulatory Challenges Cross-Border Enforcement Difficulties:The scheme exposes systematic weaknesses in EU cross-border financial crime enforcement: Jurisdictional Complexity: Multiple EU member states lack coordination for complex cross-border schemes Regulatory Specialization: Cryptocurrency regulators lack gambling industry expertise and vice versa Enforcement Resources: Limited resources for investigating sophisticated multi-jurisdictional schemes Legal Framework Gaps: Existing regulations inadequate for hybrid crypto-gambling operations Payment Network Vulnerability:The scheme demonstrates how legitimate EU payment infrastructure can be weaponized for financial crime through regulatory arbitrage. Global Anti-Money Laundering Implications FATF Standards Violations:UtPay’s operations violate multiple Financial Action Task Force recommendations: Recommendation 1: Risk assessment failures for gambling-related cryptocurrency services Recommendation 8: Non-profit organization abuse through gambling charity schemes Recommendation 15: Virtual asset service provider compliance failures Recommendation 28: Beneficial ownership transparency violations International Cooperation Requirements:The case demonstrates urgent need for enhanced international cooperation between cryptocurrency regulators and gambling authorities to prevent similar schemes. Comparative Analysis: Industry Context Offshore Gambling Payment Processing Evolution Historical Context:The UtPay model represents evolution in offshore gambling payment processing methodologies: Generation 1 (2000-2010): Direct credit card processing through high-risk merchantsGeneration 2 (2010-2020): Third-party payment processors and e-wallet systemsGeneration 3 (2020-Present): Cryptocurrency conversion schemes and regulatory arbitrage Sophistication Advancement:Current schemes demonstrate significantly increased sophistication in regulatory evasion, consumer deception, and law enforcement avoidance compared to historical methods. Payment Processor Compliance Standards Legitimate Industry Standards:Regulated payment processors implement comprehensive compliance controls: Transaction Monitoring: Real-time identification of gambling-related transactions Merchant Due Diligence: Extensive vetting of gambling merchant licensing and regulatory status Consumer Protection: Maintenance of chargeback, dispute resolution, and refund mechanisms Regulatory Cooperation: Active coordination with gambling regulators and law enforcement UtPay Comparative Failures:UtPay’s operations systematically violate industry best practices and regulatory requirements, demonstrating deliberate compliance evasion rather than oversight failures. Conclusion and Industry Impact Systemic Risk Assessment The UtPay-Kingdom Casino scheme represents a significant evolution in offshore gambling regulatory evasion, demonstrating how legitimate EU financial infrastructure can be systematically weaponized for large-scale financial crime. The sophistication of the deception mechanism, combined with the regulatory arbitrage exploitation, poses fundamental challenges to consumer protection, anti-money laundering enforcement, and gambling regulation effectiveness. Critical Risk Factors: Consumer Protection Elimination: Systematic removal of fundamental consumer protection mechanisms through transaction mischaracterization Money Laundering Facilitation: Sophisticated money laundering capabilities through crypto conversion schemes Regulatory Evasion: Successful circumvention of gambling regulations through cryptocurrency licensing arbitrage International Scope: Cross-border operations defeating national regulatory enforcement mechanisms Call for Information FinTelegram urgently seeks additional intelligence from industry insiders, current and former employees, affected consumers, and regulatory personnel regarding: Share Information via Whistle42 This report is part of FinTelegram’s Crypto Payment Processor Watch series, investigating the role of cryptocurrency service providers in facilitating offshore gambling operations and financial crime. For previous reports and ongoing investigations, visit FinTelegram.com.

A law enforcement raid targeting Northern Data AG, a Frankfurt-listed technology firm backed by Tether Holdings SA, occurred in late September 2025. The operation was led by German prosecutors and involved multiple European agencies, with a focus on Northern Data’s offices and related facilities. Here is our report. Purpose and Context Prosecutors are investigating whether Northern Data misrepresented the use of roughly €500 million (about $586 million) worth of NVIDIA AI chips. The alleged issue centers on whether the chips, which the company claimed would be used for artificial intelligence and cloud computing (eligible for tax breaks), were actually employed for cryptocurrency mining at their Swedish site. This type of misrepresentation could constitute tax fraud, since Sweden ended tax incentives for crypto mining but maintained them for data center AI operations starting in 2023. Tether’s Role Tether Holdings SA, issuer of the USDT stablecoin, is the majority shareholder in Northern Data. Although named in reports due to its investment, Tether stated it is not involved in Northern Data’s day-to-day management and was unaware of the investigation prior to the raid. Tether clarified that Northern Data represents only a small part of its diverse investment portfolio, with no direct operational overlap. Historical and Industry Implications Northern Data previously focused on cryptocurrency mining but began shifting toward AI and cloud computing in response to changing energy costs and regulatory pressures. The raid is part of a broader crackdown following accusations about past governance, including fraud and tax evasion allegations from former directors, which were previously withdrawn. The scrutiny reflects heightened regulatory risks at the intersection of digital asset infrastructure and emerging AI tech, especially for companies with crypto origins now seeking to rebrand as AI service providers. Summary Table AspectDetailsTarget CompanyNorthern Data AG (Frankfurt-listed, Tether-backed)Date of RaidLate September 2025JurisdictionGerman and European Prosecutors (site in Sweden), Frankfurt prosecutorsCore AllegationMisuse of €500 million tax incentives — AI chips used for crypto miningImplication for TetherInvestor, not operational manager; not part of investigation’s substanceSector ImpactIncreased scrutiny for crypto/AI infrastructure firms in EuropeOngoing StatusFurther prosecutorial details expected; company’s stock affected This raid underscores both the regulatory and operational risks at the convergence of crypto investment and AI infrastructure in Europe. Share Information via Whistle42

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

Is John Evans, the so-called CEO and Co-Founder of Rainbet, a real industry titan—or just another phantom character in the digital casino funhouse? At FinTelegram, we’re no strangers to shadowy operators using stage names and AI-powered profiles to dodge regulators, investors, and journalists alike. From Ponzi trading sites to fake crypto casinos, we’ve seen “executives” vanish like a bad bet—leaving only blurry avatars and generic LinkedIn listings in their wake. Background: Compliance Issues Our compliance analysis of Rainbet raised classic red flags. Despite John Evans appearing in PR and sponsorship announcements (hello, NIP partnership!), his professional history outside of recent Rainbet media is as elusive as a winning streak in the Crash game. No prior track record, no industry panels, and certainly no interviews at the big events. In fact, some law enforcement agencies now keep a “stage name” bingo card for offshore operators—spotting these fictional VIPs is practically an investigative sport. A critical article on Attacking Football questions whether John Evans is a real person or just a “ghost executive.” With good reasons. The very same article calls Rainbet the “most dangerous bookie on Twitter football.” Shortly after the report was published, the Attacking Football website was taken down by a massive DDoS attack. Rainbet was blamed for this. Read our report on the DDoS attacks on Attacking Football here. Wanted: John Evans Data But let’s be fair: maybe John Evans is simply the most discreet CEO in online gambling history. Or perhaps he’s real and would love nothing more than to finally take a victory lap in the compliance spotlight. So, we put the question to our community: Does John Evans truly exist, and what is his actual role at Rainbet? Any credible information or personal anecdotes (even rumours from the wild world of Discord) can help illuminate the man, the myth, or—dare we say—the marketing hologram behind Rainbet. You can submit insights anonymously or with contact details via our secure whistleblower system. Authentic tips are priceless in separating fact from fiction and ensuring we give John Evans—and Rainbet—the fair, accurate, and transparent reporting the industry deserves. Pull up a chair, detectives: It’s time to unmask Rainbet’s CEO. Is he for real, or just another name on the virtual leaderboard? Share Information via Whistle42

Moscow-based “Ikarus Moskva” markets energy trading, “bank solutions,” and cross-border legal services from a Moscow City tower. Its public Team page lists Serbian lawyer Marko Vujošević—a figure long linked in FinTelegram investigations to the 2016–2019 Belgrade boiler-room era and the Montenegro payment processor Global Payment Solutions Podgorica DOO (GPS). We outline the facts, risks, and open questions—and invite whistleblowers. fintelegram.com+4ikarusmoskva.com+4ikarusmoskva.com+4 Key Points Who/Where: Ikarus Moskva (est. 2025), address shown as Federation Tower, Moscow City; services span Energy Trading, Bank Solutions, International Law, Investments/Real Estate (Source: ikarusmoskva.com). Team link: Site lists “MARKO VUJOŠEVIĆ — Advokat/Advocat” among team members (Source: ikarusmoskva.com). Historic context: Vujosevic featured in FinTelegram’s prior reporting around Global Payment Solutions (GPS) DOO (Montenegro) and the Belgrade boiler-room ecosystem servicing brands, incl. Option888; Austria/Germany prosecuted the network (e.g., Gal Barak 4-year sentence in Vienna, 2020) (Sources:fintelegram.com, Efri.io) Violence context: Serbian media reported a 2021 shooting in central Belgrade in which Vujosevic’s bodyguard was wounded (Source: B92.net) Sanctions touchpoints: Ikarus advertises oil/gas trading and trade/transaction banking (LCs, FX, cross-border payments)—activities that intersect EU/US Russia sanctions regimes (Reg. 833/2014; OFAC E.O. 14071 services bans). We have no evidence of violations, but the service mix creates heightened exposure. Narrative Ikarus Moskva (website) presents as a 2025-founded, full-scope advisory house “powered by a team with 20+ years’ experience,” headquartered in Moscow City’s Federation Tower. The website promotes Energy Trading (including oil & gas) and Bank Solutions (wealth management, trade & transaction banking, letters of credit, FX/currency risk, and compliance advisory). These offerings, combined with the Moscow nexus, place the firm squarely in the most heavily sanctioned zones of global commerce. The Team page is notable: it lists Serbian lawyer Marko Vujošević (“Advokat/Advocat”). FinTelegram has covered Vujosevic for years in connection with Belgrade’s binary options/CFD boiler-room scene (2016–2019), where he and associates facilitated Israeli operators’ work permits and co-operated the Montenegro-registered payment facilitator Global Payment Solutions (GPS) that channelled stolen investor funds for brands such as Option888. Read our reports on Global Payment Solutions here. Courts later convicted key figures: Gal Barak received a four-year sentence in Vienna (Sept 1, 2020). In January 2021, the Serbian press reported a shooting outside Vujosevic’s office; his bodyguard was injured. One of Vujosevic’s business partners in Belgrade at GPS was the powerful mafia godfather Lazar Hoppl, a/k/a Lazar Hoppel. Hoppl later filed a criminal complaint against Vujosevic in Belgrade for alleged embezzlement of millions. Hoppl sent FinTelegram a copy of the complaint and confirmed his accusations against Vujosevic. At that time, posters depicting Vujosevic as a fraudster were put up throughout downtown Belgrade (see picture on the left). Read more about the scammers’ war in Belgrade here. We stress: FinTelegram currently has no evidence that Ikarus Moskva or Vujosevic are violating sanctions or laundering funds. The risk assessment below is based on publicly available claims on Ikarus’s own website and the legal environment governing Russia-related commerce since 2022. Entity Snapshot (publicly claimed) Name: Ikarus Moskva (Икарус Москва) Established: 2025 (per “About Us”) Registered/claimed address: Moscow City, Federation Tower, 45F, office 82 Core services: Energy Trading (oil/gas & renewables); Bank Solutions (LCs, FX, cross-border payments); International Law, Investments/Real Estate Team highlight: Marko Vuj(o)šević—Advokat (Serbia)Sources: firm website About/Services/Team. Forensic Risk Analysis (sanctions & AML) 1) Sector & Geography Exposure Energy trading (oil/gas) engages EU Reg. 833/2014 controls (oil price cap, tanker/STS rules, LNG transshipment limits) and related prohibitions on services facilitating Russian energy revenues. US OFAC also restricts categories of services to Russia (E.O. 14071) (Source: ofac.treasury.gov). 2) Claimed Financial Intermediation “Trade & transaction banking,” letters of credit, FX, and “streamlined international payment systems” imply potential interaction with EU banks’ Russia controls, oil-price-cap attestation chains, screening for SPFS/shadow-fleet connections, and circumvention risks flagged in recent EU packages (Source: ikarusmoskva.com). 3) Governance/Personnel History Vujosevic’s historical proximity to the Belgrade boiler-room/payment-processing sphere (GPS/Option888 context) elevates reputational and KYC risk. While past conduct isn’t dispositive, it heightens the duty of enhanced due diligence for counterparties (Source: fintelegram.com). 4) Red-Flag Patterning (open source) Young firm (2025) with broad, sanctions-sensitive services; Moscow base; and marketing of cross-border finance present a combination that warrants counterparty EDD, beneficial-ownership checks, and sanctions legal review before any engagement (Source: ikarusmoskva.com). Actionable Insight (for banks, brokers, energy traders) Counterparty EDD: Obtain ultimate beneficial ownership (UBO) and source-of-funds documentation; test for sanctions nexus (sectoral restrictions, price-cap attestation, vessel/STS history, SPFS use). Align with EU Reg. 833/2014 FAQs and OFAC FAQs for service prohibitions and anti-circumvention expectations (Source: Finance). Contract controls: Insert sanctions compliance, price-cap, and no-re-export warranties; require KYVessel/KYTrade data for hydrocarbons; mandate audit/termination clauses for circumvention indicators. Reputation risk: Treat engagements involving Marko Vujosevic as Heightened Risk Clients (HRC) pending full independent verification of roles and history. Call for Information FinTelegram invites insiders, former staff, clients, banking partners, and logistics intermediaries with verifiable documents regarding Ikarus Moskva or Marko Vuj(o)šević to submit securely via Whistle42. Anonymity respected; we seek contracts, invoices, LC files, KYC packs, vessel/STS logs, or email trails showing actual counterparties, flows, or sanction-screen outcomes. Share Information via Whistle42

Eliran Oved is an Israeli businessman and owner of Bnei Yehuda Tel Aviv FC, who was publicly honored by Israel’s president for the club’s community work. With his wife Liat Kourtz Oved, he curates a jet-set, multilingual persona on Instagram. Yet cross-border investigations link the couple to fraudulent online-broker brands run from Belgrade call centers—with prior 2012 money-laundering and illegal-gambling convictions on Oved’s record. The gap between public accolades and alleged boiler-room control is the story. Key Facts ItemDetailsNationalityIsraeliPublic rolesOwner, Bnei Yehuda Tel Aviv FC; recipient of a presidential award recognizing the club’s community work (Source: Wikipedia)Online personaWith Liat Kourtz Oved, presents as a polyglot, globe-trotting couple on Instagram (Source: Investigate Europe)Criminal record2012 conviction in Israel for illegal gambling & money laundering (served one year) (Source: timesofisrael.com).Alleged network hubBelgrade boiler rooms (e.g., Olympus Prime, Parogan) linked to Israeli controllers; brands incl. FXVC, PrimeOT, Greenfields Capital, Wingroup (Source: EUobserver).Named proxies/alliesNikos Andreou (owner Olympus Prime/Parogan), Vera Nachkova Andonova (BG lawyer), Max-Sebastian Winterfeldt (Parogan director), Miloš Radivojević, Georgi Vangelov (Source: fintelegram.com).Payments railCoinshype cited on victim invoices and linked to Oved-controlled companies (EE/AU) by reporters (Source: Investigate Europe).Regulatory actions (context)FCA halted FXVC (Finteractive Ltd) services to UK clients in 2021; Germany’s Nino Goldbeck leads prosecutions against call-center frauds (Source: FCA). Narrative Profile From Tel Aviv’s football terraces to Instagram’s travel-and-family reels, Eliran and Liat Oved project success and social polish. Investigative teams at EUobserver/Investigate Europe & BIRN report, however, that corporate records, seized data and interviews with victims tie the couple to Belgrade-based call centers powering high-pressure FX/CFD/crypto “broker” brands—FXVC, PrimeOT, Greenfields Capital, Wingroup—fronted through proxies and thin corporate shells. The Belgrade hub prospered after Israel’s 2016 binary-options crackdown exposed by Simona Weinglass and the Knesset ban that followed. Belgrade operators allegedly included Olympus Prime and Parogan—entities long tracked by FinTelegram—owned or directed by Nikos Andreou and Max-Sebastian Winterfeldt, with Vera Nachkova Andonova, Miloš Radivojević, and Georgi Vangelov appearing in the managerial/legal scaffolding. The same investigation describes Coinshype as a payments conduit linked to the Oveds’ network. Read our report on the Belgrade boiler rooms here. Regulatory & Legal Notes Prior conviction: In 2012, Oved was convicted in Israel for illegal gambling and money-laundering—a matter of public record (Source: timesofisrael.com) UK action (brand context): The FCA ordered Finteractive Ltd (FXVC) to stop CFD activities for UK customers in April 2021 over deceptive promotions and poor conduct, highlighting the pattern regulators associate with such brands (Source; FCA). Germany/Serbia (enforcement climate): German prosecutor Nino Goldbeck has targeted call-center fraud ecosystems; Serbian raids in January 2023 disrupted Belgrade operations but left alleged top-tier organizers at large—an ongoing cross-border challenge (Source: timesofisrael.com). Read our reportws on FXVC here. Right of reply: EUobserver/Investigate Europe note the Oveds did not provide answers to detailed queries by publication time. FinTelegram invites clarifications or rebuttals and will publish them in full. Analysis (FinTelegram) Reputation arbitrage: Football ownership and presidential recognition offer reputational cover incongruent with repeated red flags in the Oved orbit. This discord is precisely why boiler-room controllers seek social/charitable halos. Proxy rings & payment rails: The documented role of third-party owners, lawyers, and payment processors (Coinshype) points to a designed opacity that frustrates restitution. Cross-warrants and beneficial-ownership orders should be prioritized. Open question: The couple’s continued high-lifestyle presentation contrasts with victims’ losses worldwide. Is that lifestyle financed, directly or indirectly, from these schemes? That is the test for prosecutors tracing flows of funds and asset freezes across IL–CY–RS–EE–AU nodes. Call for Information (Whistle42) Were you employed by Olympus Prime or Parogan? Did you operate brand CRMs, handle Coinshype deposits, or manage VIP “retention” desks for FXVC/PrimeOT/Greenfields/Wingroup?Submit documents, org charts, chats, and payment records via Whistle42. Verified materials—especially UBO proofs and fund-flow trails—will support victims’ claims and elevate cases beyond call-floor agents to alleged controllers. Share Information via Whistle42

A new cross-border investigation connects Israeli couple Eliran Oved and Liat Kourtz Oved to Belgrade-based boiler rooms (incl. Olympus Prime and Parogan) that ran FX/CFD/crypto brands like FXVC, PrimeOT, Greenfields Capital, and Wingroup. Serbian raids in Jan 2023 produced indictments, yet the alleged masterminds remain out of reach while German prosecutors rack up convictions against call-center foot soldiers. This report maps the people, brands, payment rails (Coinshype), and the still-unanswered links to wider Israeli cyber-fraud networks (Source: EUobserver). Key Findings Oved tie-ins to Belgrade rooms & brands. EUobserver’s Oct 3, 2025 investigation, based on corporate records, victim files and law-enforcement materials, links the Oveds to multiple brands operated from Belgrade call centers—FXVC (ex-Leeds United partner), PrimeOT, Greenfields Capital, and others. Olympus Prime was raided in Jan 2023; prosecutors describe an Israeli-led hierarchy over Serbian operations (Source: EUobserver). Fronts and local managers. Named proxies include Cyprus ex-footballer Nikos Andreou (owner of Olympus Prime). Bulgarian lawyer Vera Nachkova Andonova and Miloš Radivojević (Serb with Bulgarian citizenship) held roles in Oved-linked entities; Radivojević is under money-laundering investigation in Serbia. In parallel, Parogan DOO—another major Belgrade boiler room—was run by director Max-Sebastian Winterfeldt and owned by Andreou; it went into liquidation in 2021. Regulatory blows abroad. UK regulator FCA stopped FXVC (Finteractive Ltd) from offering CFDs in April 2021 over misleading promotions; the firm was ordered to close positions and return money to customers. In Australia, courts imposed A$75 m in penalties on AGM/OT/Ozifin for misconduct in retail OTC derivatives—illustrating the global enforcement perimeter around similar playbooks (Source: FCA). Payment rails: Coinshype. Victim invoices show deposits routed via Coinshype; investigators say Coinshype was controlled through Oved-connected companies in Estonia and Australia. Status of prosecutions. Serbia has indicted 21 people from the Jan 2023 raids; inquiry is ongoing. Germany’s special unit led by prosecutor Nino Goldbeck reports 15 raids since 2019 and ~80 convictions—primarily against call-center operatives—highlighting difficulty in reaching upper-tier organizers across borders. Prior record. Eliran Oved was convicted in Israel in 2012 for operating an illegal gambling site and money laundering—background that mirrors tactics alleged in the Belgrade network. He also owns Israeli football club Bnei Yehuda (TimesofIsrael.com). Modus Operandi (2016–2021 pivot; 2022–2023 reboot) Lead generation → script-driven “brokers” → pressure-upsell → blocked withdrawals. Training materials and chats seized in Belgrade show language-segmented teams (“Panzer” for DACH) coached to pass as regulated brokers, push repeat deposits, and stall or deny withdrawals. Brands presented cloned dashboards and fake P&L to induce further funding—then locked accounts when victims requested payouts. The Leeds United halo. FXVC leveraged Premier League visibility in 2020; the FCA action in 2021 cut that funnel, but the broader marketing stack (Google/Meta ads → call-back) persisted across sister brands. Payment & jurisdictional arbitrage. Routing deposits to Coinshype and using multi-jurisdiction shells (Cyprus, Estonia, Vanuatu, Australia) insulated core controllers while Balkan call centers handled victim interaction and “VIP” chasing. People & Roles (selection) Eliran Oved & Liat Kourtz Oved (Israel) — Alleged controllers behind brand stack; ties through beneficial ownership filings and partner companies; Oved previously convicted (2012). EUobserver+1 Nikos Andreou (Cyprus) — Owner of Olympus Prime and shareholder in Parogan; described as a trusted proxy. Vera Nachkova Andonova (Bulgaria) — Lawyer/director/shareholder in Oved-linked entities (e.g., Greenfields Capital structures). Miloš Radivojević (RS/BG) — Andonova’s partner; currently under Serbian money-laundering probe tied to the case. Max-Sebastian Winterfeldt (Serbia) — Director of Parogan DOO during its active phase (Source: fintelegram.com). Enforcement Picture Serbia (Belgrade): Jan 2023 Europol-assisted raids across 22 locations; indictment of 21 individuals; prosecutors describe Israeli managerial tiering above Serbian staff. Key foreign figures remain outside jurisdiction (Source: EUobserver). Germany (Bamberg task force): Since 2019: 15 raids, ~80 convictions; resource/jurisdiction limits mean only a fraction of 200-seat floors reach the dock—underscoring why masterminds often escape. UK: FCA forced FXVC to cease UK CFDs; press release details misleading promotions and pressure tactics (Source: FCA). Australia: Federal Court imposed A$75m penalty on comparable OTC derivative issuers for unconscionable conduct—contextual signal for the sector’s risk profile and remedies (Source: ASIC). Context: From Israel’s Binary Options Ban to the Belgrade Hub After Simona Weinglass’s 2016 “Wolves of Tel Aviv” series exposed Israel’s binary-options industry, the Knesset banned the sector—triggering a migration of playbooks and personnel into offshore and near-EU hubs (including Belgrade), where CFD/crypto “brokers” rebranded but kept the same scripts (Source: timesofisrael.com). What About Gery Shalon? Gery Shalon—indicted in the US for the 2015 JPMorgan-related hack-and-pump schemes and other cyber-financial crimes—epitomizes the overlap between illicit marketing funnels, payment obfuscation, and data-theft-driven acquisition in Israeli-linked networks. However, we found no credible, on-the-record documentation directly linking the Oved network to Shalon in the materials reviewed. Given the recurring use of Balkan outposts and identical victim-funnel mechanics, any personnel or payment overlap would be material—and should be probed by EU and US authorities (Sources: justice.gov, WashingtonPost). Open Questions for Regulators & Prosecutors Control & beneficial ownership: Have all proxy layers around Coinshype, FXVC, PrimeOT, Greenfields Capital, and Belgrade operating entities been pierced, and do MLAT requests cover Israeli controllers? Victim restitution: FCA records show FXVC was halted, but was compensation ordered or achieved across the wider brand family? (EUobserver notes no FCA fines/compensation for FXVC per FOI.) Germany–Serbia evidence bridge: Can Bamberg’s task force leverage Serbian digital seizures (training videos, CRM data, chats) to prosecute higher-ups rather than only agents? Sports sponsorship due-diligence: Post-Leeds United, what safeguards prevent high-risk brokers from reputational laundering via elite sports? Sources & Prior Reporting EUobserver / Investigate Europe & BIRN (Oct 3, 2025): core exposé linking Oveds to Belgrade operations, brands, Coinshype, and Serbian/German case status (Source: EUobserver). FinTelegram (Nov 27, 2021): Parogan liquidation; Nikos Andreou ownership and Max-Sebastian Winterfeldt directorship; Olympus Prime connection (Source: FinTelegram). FCA (Apr 16, 2021): FXVC stopped from UK CFDs; details of misleading promotions and pressure tactics (Source: FCA). ASIC (Oct 19, 2020): A$75m penalties against AGM/OT/Ozifin—sectoral benchmark for remedies (Source: ASIC). Times of Israel (2016; 2021): Binary-options industry exposé; Eliran Oved’s 2012 conviction (Source: timesofisrael.com). Here’s a compact, skimmable table capturing the brands, legal entities, and the people named in the report, plus their roles and connections. Brand / PlatformLegal Entity / Operator (Jurisdiction)Key IndividualsRole / ConnectionNotes / StatusFXVCFinteractive Ltd (CY)Eliran Oved; Liat Kourtz Oved; Nikos AndreouAlleged controllers/beneficial interests via network; Andreou linked as proxy/owner across Belgrade opsUsed high-visibility sports marketing (e.g., Leeds United); later restricted by FCA in UK; tied to Belgrade call-center funnelsPrimeOTBelgrade boiler-room cluster (see Olympus Prime / Parogan)Eliran Oved; Liat Kourtz Oved; Vera Nachkova Andonova; Miloš Radivojević; Georgi Atanasov VangelovBrand operated through Serbian call centers; Andonova/Radivojević/Vangelov cited as management/front figuresVictim acquisition via scripted “broker” calls; withdrawal blocking patterns reportedGreenfields CapitalCorporate stack linked to Oved network (BG/CY components reported)Eliran Oved; Liat Kourtz Oved; Vera Nachkova Andonova; Miloš RadivojevićAndonova as front/director; Radivojević as partner/manager; Oveds as alleged controllersPart of the Oved-aligned brand family targeting EU victims(multiple CFD/crypto brands, 2016–2019 pivot period)Belgrade call-center ecosystemIsraeli desk heads & team leads (“Panzer” for DACH), per seized training materialsOperational execution (sales scripts, upsells, KYC stalling)Same playbook across sister sites; cloned dashboards/fake P&L claimed by victimsCoinshype (payments)Payment platform(s) tied to Oved-linked companiesEliran Oved (alleged control); associates in EE/AU filings (per reporting)Deposit routing / PSP layer for brand clusterUsed to collect and obfuscate flows from victims into brand ecosystemOlympus Prime (call center)Olympus Prime DOO (RS)Nikos Andreou (owner); Eliran & Liat Oved (alleged controllers)Major Belgrade boiler room servicing Oved-linked brandsRaided Jan 2023; part of Serbian indictments; described as Israeli-managedParogan (call center)Parogan DOO (RS)Max-Sebastian Winterfeldt (director); Nikos Andreou (owner/shareholder); Eliran & Liat Oved (alleged controllers)Sister Belgrade boiler roomEntered liquidation in 2021; featured in 2019/2021 FinTelegram investigations—Andonova Law / associated corporate vehicles (BG)Vera Nachkova AndonovaLegal/front services; directorships/shareholding across entities tied to brandsIdentified as front woman in filings and prior reporting—Management shell(s) (BG/RS)Miloš Radivojević (Serbian-born Bulgarian)Management partner within network; investigated for money laundering in RSNamed in current Serbian inquiries tied to Oved cases—Management shell(s) (BG)Georgi Atanasov VangelovPart of management team connected to brands/call centersReferenced in earlier FinTelegram reporting as involved manager—Prosecutorial task force (DE)Nino Goldbeck (prosecutor)Leads German cases against Belgrade-linked boiler rooms~80 convictions primarily of call-center agents; cross-border organizers remain a focus—Media / exposure (IL)Simona WeinglassExposed Israel’s binary-options industry (2016 “Wolves of Tel-Aviv”)Triggered Israel’s ban → migration of networks to Belgrade/elsewhere—Prior criminal record (IL)Eliran Oved2012 conviction (illegal gambling & money laundering)Background underscores alleged role in later Belgrade-centered operations—Comparison point (US cases)Gery ShalonUS-charged cyber-financial crimes figureNo verified direct link to Oved network found; patterns warrant scruti Call for Information (Whistle42) If you worked at Olympus Prime, Parogan, or related Belgrade call centers; handled wallets or payment rails for Coinshype/brand clusters; or hold internal decks, lead lists, CRMs, Slack/Telegram chats, or bank/Wyre/PSP statements, share them securely via Whistle42. Verified materials—especially UBO proofs, brand-to-entity maps, and flow-of-funds—will materially advance ongoing cases and victim restitution. Your intel can shift these prosecutions from call-floor agents to the controllers who designed the system. Share Information via Whistle42

Executive Summary Roobet represents a sophisticated offshore gambling operation that epitomizes the modern crypto casino model of regulatory evasion through strategic jurisdictional arbitrage. Operating under the brand name of Raw Entertainment B.V. (Curaçao) with payment processing through Raw Entertainment Ltd (Cyprus), Roobet has constructed a global gambling empire that systematically violates licensing restrictions while utilizing cutting-edge payment processing infrastructure to circumvent traditional banking controls and regulatory oversight. This comprehensive investigation reveals how Roobet employs a dual-jurisdiction corporate structure designed to maximize regulatory evasion, utilizes the Danish-regulated payment processor Swapped to facilitate illegal operations across restricted markets, and maintains a deliberately complex ownership structure that obscures accountability while generating hundreds of millions in revenue from prohibited jurisdictions. Company Introduction and Corporate Structure Founding and Development Roobet was founded in 2018 by co-founders Matt Duea and an unnamed partner, emerging from what Duea describes as “the gaming space” rather than traditional gambling operations. The platform gained prominence during the COVID-19 pandemic when lockdowns drove massive growth in online entertainment, particularly through their signature “Crash” game that became synonymous with the Roobet brand. The company positions itself as “the world’s fastest growing, fully licensed crypto casino” and claims to be “pioneers of online entertainment and defenders of fun on the digital frontier.” However, this marketing narrative obscures a complex offshore structure designed primarily for regulatory evasion rather than innovation. Legal Entity Structure Primary Operating Companies: Raw Entertainment B.V. Registration: Curaçao (Registration No. 157205) Address: Korporaalweg 10, Willemstad, Curaçao Function: Primary gambling license holder License: Government of Curaçao License No. 8048/JAZ Raw Entertainment Ltd Registration: Cyprus (Registration No. HE421735) Address: Voukourestiou 25, Neptune House, 1st Floor, Flat/Office 11, Zakaki, 3045, Limassol, Cyprus Function: Payment processing and operational agent Relationship: “Wholly owned subsidiary of Raw Entertainment B.V.” Strategic Jurisdictional Architecture This dual-jurisdiction structure represents sophisticated regulatory arbitrage: Curaçao Licensing: Provides perceived legitimacy through “full licensing” claims while operating under minimal regulatory oversight and consumer protection requirements. Cyprus Payment Processing: Enables access to European banking infrastructure and payment systems while maintaining operational separation from the gambling license jurisdiction. Agent Structure: Raw Entertainment Ltd acts as “paying and operational agent on behalf of Raw Entertainment B.V.,” creating legal separation between gambling operations and payment processing. Beneficial Ownership and Key Personnel Identified Leadership Matt Duea – Co-Founder and Public Face Background in digital marketing strategy and growth teams Self-described “blockchain rabbit hole” enthusiast since 2016 Primary spokesperson for media interviews and industry events LinkedIn profile confirms entrepreneurial background in online marketing Corporate Control and Hidden Connections Potential Xecutive Corporate Management (XCM) Links:Investigative reports suggest potential connections between Roobet and Stake.com through Xecutive Corporate Management (XCM), which allegedly serves as “the hidden hand behind both Stake.com and Roobet‘s offshore operations”. Key Allegations from Investigation: XCM acts as legal directors for both Stake.com and Roobet‘s Curaçao-based entities XCM controls Cyprus-based payment processing for both operations Shared operational infrastructure enables “unrestricted movement of funds between high-risk jurisdictions” Money Laundering Allegations: Reports allege Roobet has been linked to the MetafiYielders Ponzi scheme that defrauded investors of over $90 million, with “stolen funds from MetafiYielders funneled through Stake.com‘s financial infrastructure, disguised as gambling transactions.” Verification Challenges The deliberately opaque ownership structure makes beneficial ownership verification extremely difficult, consistent with offshore operations designed to evade regulatory scrutiny and accountability. Regulatory Status and Violations Licensing Claims vs. Reality Official License: Curaçao Government License No. 8048/JAZ under the National Ordinance on Hazard Games (NOOGH). Regulatory Environment: Curaçao has historically maintained minimal oversight of gambling operations, though recent reforms under the National Ordinance on Games of Chance (LOK) aim to increase compliance requirements. Systematic Jurisdictional Violations Explicit Restricted Territories (per Roobet’s own terms): United States (all states) United Kingdom Australia European Union countries with local licensing requirements Multiple additional jurisdictions FinTelegram Testing Results – Systematic Non-Compliance: Italy Registration Test: Status: SUCCESSFUL registration despite EU restrictions Payment Integration: Full access to Swapped payment processing Verification Requirements: Minimal – email verification only Geolocation Blocking: None implemented Austria Registration Test: Status: SUCCESSFUL registration despite EU restrictions Payment Methods: Complete cryptocurrency and fiat payment options via Swapped KYC Requirements: None for initial registration and deposits IP Restrictions: No blocking or location-based limitations United Kingdom Registration Test: Status: SUCCESSFUL registration despite explicit UK prohibition Payment Processing: Full Swapped integration functional UKGC Compliance: Zero compliance with UK licensing requirements Consumer Protection: No GAMSTOP integration or UK player protection measures Payment Processing Infrastructure Violations Swapped Integration Analysis:Roobet‘s “deep integration” with Danish-regulated payment processor Swapped enables systematic circumvention of banking restrictions in prohibited jurisdictions. Violation Mechanisms: Fiat-to-Crypto Conversion: Swapped enables credit/debit card purchases of cryptocurrency directly on Roobet platform Payment Method Diversity: Support for GPay, Apple Pay, Rapid, Paysafecard, and e-wallets No Geographic Restrictions: Payment processing available in all jurisdictions regardless of gambling license validity Regulatory Arbitrage: Danish regulation of Swapped provides legitimacy cover for facilitating illegal gambling Payment Facilitators and Financial Infrastructure Primary Payment Processor: Swapped.com Swapped Corporate Structure: Regulation: Licensed and regulated in Denmark Integration: “Deep integration” with Roobet platform enabling seamless fiat-to-crypto conversion Function: Converts traditional payments (cards, e-wallets, bank transfers) into cryptocurrencies for gambling deposits Technical Implementation: Direct platform integration accessible via Roobet’s deposit interface Minimum purchase amount: $10.00 Supported cryptocurrencies: Bitcoin, Ethereum, USDT, USDC, XRP, Litecoin, TRON, Dogecoin Processing times: Instant to 30 minutes depending on payment method Payment Methods Supported Through Swapped: Credit/Debit Cards (Visa, Mastercard) Google Pay and Apple Pay Rapid (bank transfer system) Paysafecard vouchers Various e-wallet services Bank transfers in multiple currencies Direct Cryptocurrency Integration Wallet Integration Support: MetaMask (primary integration) Exodus, Binance Wallet, Bitget Wallet Phantom, Trust Wallet, Coinbase Wallet OKX Wallet, Robinhood, Rainbow Crypto.com Wallet, Bybit Wallet, Kraken Wallet Uniswap Wallet Transaction Processing: Deposits: No minimum limits for cryptocurrency deposits Withdrawals: $15 equivalent minimum withdrawal Processing Times: Generally instant for deposits, immediate processing from Roobet’s side for withdrawals Fees: Variable based on network conditions and cryptocurrency type Cyprus Payment Processing Structure Raw Entertainment Ltd Functions: Processes all fiat transactions for Roobet Acts as operational and paying agent for Raw Entertainment B.V. Provides European Union banking access and legitimacy Enables receipt of funds outside Curaçao jurisdiction for regulatory evasion Strategic Advantages: Regulatory Separation: Gambling license in Curaçao, payment processing in Cyprus Asset Protection: Funds processed through Cyprus entity, not subject to Curaçao regulatory action Banking Access: EU-based entity enables traditional banking relationships unavailable to Curaçao gambling operators Enforcement Evasion: Complex jurisdictional structure complicates regulatory enforcement and asset recovery Network Analysis and Industry Connections White Label and Affiliate Infrastructure Affiliate Program Structure: Global affiliate program with extensive marketing tools “State-of-the-art marketing software” and promotional resources Transparent statistics and commission tracking Wide variety of promotional tools for affiliate partners Marketing Partnerships:High-profile celebrity endorsements and sponsorships including: Snoop Dogg: “Chief Ganjaroo” officer with extensive partnership agreement UFC: Official social casino partnership (Roobet.fun) Canelo Alvarez: Boxing sponsorship Charles Oliveira: UFC fighter partnership Potential Network Connections Stake.com Relationship:Investigative reports suggest shared operational infrastructure: Common management through Xecutive Corporate Management (XCM) Shared Cyprus-based payment processing entities Similar offshore regulatory arbitrage strategies Potential shared beneficial ownership structures Industry Positioning:Roobet operates within the same ecosystem as other major crypto casinos including BC.Game, Stake.com, and other Curaçao-licensed operations, sharing similar: Payment processing methodologies Regulatory evasion strategies Marketing and affiliate approaches Technical infrastructure patterns Marketing Activities and Regulatory Violations Influencer Marketing Strategy Twitch Integration and Controversy: Extensive use of Twitch streamers and gaming influencers Platform gained prominence through gambling stream content Operations continued despite Twitch’s restrictions on unregulated gambling sites Celebrity Partnership Strategy: High-profile partnerships designed to create mainstream legitimacy Snoop Dogg partnership announced with significant fanfare and promotional events UFC sponsorship providing sports betting credibility Consumer Protection Failures KYC and AML Violations Systematic Verification Failures:User reports indicate Roobet allows significant gambling activity without proper Know Your Customer verification: In fact, it is theoretically possible to transfer unlimited funds to Roobet via cryptocurrencies without KYC if direct deposits are made via crypto. This has been confirmed by FinTelegram tests. User reports that he €35,000 deposited over two months without KYC verification Daily deposits up to €10,000 without scrutiny or restrictions Clear violations of both Curaçao licensing standards and European AML regulations Self-Exclusion Non-Compliance: Acceptance of self-excluded gambling addicts from restricted jurisdictions Account blocking only after notification by player, not proactive prevention Refusal to refund deposits from self-excluded players Regulatory Response Failures: Curaçao regulator reportedly unresponsive to consumer complaints Cyprus payment processor ignores consumer protection inquiries No effective dispute resolution mechanism for affected players Player Fund Protection Gaps No Segregated Accounts:Unlike regulated operators, Roobet provides no indication of segregated player fund protection, meaning: Player deposits may mix with operational funds No protection against operator insolvency No independent auditing of fund security No compensation schemes for player fund losses Regulatory Evasion Mechanisms Technical Infrastructure for Circumvention Geo-Location Bypass: No effective IP blocking for restricted jurisdictions Payment processing functional in all prohibited territories VPN usage implicitly tolerated through platform design Gaming provider restrictions applied inconsistently Payment System Arbitrage: Swapped integration bypasses traditional gambling payment restrictions Cryptocurrency conversion enables circumvention of banking controls Multiple wallet integrations provide alternative deposit pathways Cyprus payment processing provides EU banking legitimacy Corporate Structure Obfuscation Multi-Jurisdictional Design: Gambling operations in Curaçao with minimal oversight Payment processing in Cyprus with EU banking access Potential shared management through XCM network Beneficial ownership obscured through nominee arrangements Operational Separation: Agent structure provides legal separation between functions Asset protection through jurisdictional distribution Regulatory enforcement complications through entity separation Regulatory Landscape and Enforcement Curaçao Regulatory Evolution Historical Leniency:Curaçao has historically provided minimal gambling regulatory oversight, making it attractive for operators seeking regulatory arbitrage. Recent Reform Efforts: New National Ordinance on Games of Chance (LOK) framework approved December 2023 Increased enforcement actions against operators with KYC deficiencies 12 operators settled with prosecutor’s office for €360,000 in fines for verification violations New complaint policy and dispute resolution requirements effective 2025 Continued Challenges:Despite reforms, Curaçao’s regulatory framework remains insufficient for meaningful consumer protection or effective AML compliance. UK and EU Enforcement Challenges White Label System Exploitation:The case of TGP Europe demonstrates how offshore operators exploit UK white label systems: TGP Europe fined £3.3 million and forced to exit UK market Multiple offshore operators lost UK access through TGP’s license surrender Premier League clubs warned about promoting unlicensed operators Cross-Border Enforcement Difficulties: Cyprus-based payment processing complicates UK enforcement Curaçao licensing provides jurisdictional protection Complex corporate structures impede regulatory action Players in restricted jurisdictions lack effective recourse Comparative Risk Analysis Industry Context FeatureUKGC Licensed OperatorRoobet (Curaçao License)Player Fund Protection Segregated accounts mandatory No segregation requirementsKYC/AML Compliance Strict verification required €35,000+ deposits without KYCDispute Resolution Independent ADR mandatory No effective dispute mechanismSelf-Exclusion Enforcement GAMSTOP integration required Self-excluded players acceptedRegulatory Oversight Regular audits and inspections Minimal Curaçao oversightConsumer Compensation Compensation schemes exist No compensation mechanismsPayment Processing Regulated payment providers Offshore processing via CyprusBeneficial Ownership Public disclosure required Hidden through nominees Risk Assessment Critical Risk Factors: No Player Protection: Funds not segregated, no compensation schemes Regulatory Arbitrage: Operations in restricted jurisdictions without proper licensing Payment System Exploitation: Regulated processor enables illegal operations Corporate Opacity: Beneficial ownership obscured, accountability eliminated AML Failures: Systematic violations of anti-money laundering requirements Conclusion and Industry Impact Systematic Regulatory Failures Roobet represents a paradigmatic example of how sophisticated offshore operators exploit regulatory gaps, jurisdictional inconsistencies, and payment system arbitrage to build massive illegal gambling operations. The company’s success demonstrates systemic failures across multiple regulatory domains: International Regulatory Coordination: Lack of coordination enables sophisticated jurisdictional arbitrage Payment Processor Oversight: Regulated processors facilitate illegal gambling with impunity Consumer Protection Gaps: Offshore licensing provides no meaningful player protection Corporate Transparency: Complex structures successfully obscure beneficial ownership and accountability Consumer Harm Profile Roobet‘s operations pose significant risks to consumers: Financial Risk: No player fund protection or compensation mechanisms Vulnerable Player Exploitation: Self-excluded gamblers accepted without verification Regulatory Arbitrage: Operations in jurisdictions without proper licensing Dispute Resolution: No effective mechanisms for resolving consumer complaints Industry Implications The Roobet model represents the evolution of offshore gambling into sophisticated financial crime operations: Payment System Abuse: Legitimate processors enable systematic law violations Regulatory Evasion: Complex structures successfully defeat enforcement efforts Consumer Deception: Marketing emphasizes legitimacy while operations violate fundamental protections Market Distortion: Illegal operators compete unfairly with regulated alternatives Key Data Summary CategoryDetailsPrimary EntityRaw Entertainment B.V. (Curaçao Reg. 157205)Payment ProcessorRaw Entertainment Ltd (Cyprus Reg. HE421735)LicenseCuraçao Government License 8048/JAZFoundersMatt Duea (confirmed) + unnamed co-founderFounded2018-2019Primary Payment FacilitatorSwapped.com (Danish-regulated)Restricted JurisdictionsUS, UK, Australia, EU countriesActual OperationsActive in all restricted jurisdictions without blockingKYC Compliance €35,000+ deposits without verification reportedSelf-Exclusion Protection Self-excluded players from restricted jurisdictions acceptedPlayer Fund Protection No segregated accounts or protection schemesDispute Resolution No independent mechanism, regulator unresponsiveCelebrity PartnershipsSnoop Dogg, UFC, Canelo Alvarez, Charles OliveiraNetwork ConnectionsPotential XCM/Stake.com shared infrastructureCorporate Transparency Beneficial ownership obscured through complex structureRisk LevelEXTREMELY HIGH Call for Information FinTelegram urgently seeks additional information from industry insiders, current and former employees, payment processor personnel, affiliates, and affected players regarding: Your information could be instrumental in exposing one of the most sophisticated offshore gambling operations currently targeting consumers worldwide and help protect vulnerable players from continued financial exploitation. Share Information via Whistle42 Contact FinTelegram through our secure Whistle42 platform for confidential communication protocols and comprehensive source protection procedures.

A new cross-border investigation reports that raids on four Belgrade call centers in 2023 disrupted an Israeli-linked investment scam that allegedly duped ~70,000 victims out of ~€250m—yet the ringleaders remain at large. For FinTelegram, this is a familiar pattern: after binary options bans, the Belgrade boiler-room hub pivoted to CFDs and then cryptocurrencies. We connect the dots and call insiders to come forward via Whistle42 (Source: N1 Info RS, Balkan Insight). Key Points 2023 raids, global losses — Police actions in Belgrade hit four call centers tied to a transnational scheme; investigators estimate ~70,000 victims and ~€250m in losses. Alleged Israeli nexus — The network is traced by reporters to a convicted Israeli money launderer and his spouse; operations reportedly continue despite disruptions. From binaries → CFDs → crypto — After Israel outlawed binary options (Oct 2017) and the EU clamped down (2018), scam shops migrated to CFDs and then crypto-flavored “investments” (Source: timesofisrael.com) Belgrade’s role — FinTelegram has long documented Belgrade as the region’s boiler-room hub—once dubbed the “Manhattan of the Balkans.” Cases include Parogan/Olympus Prime and Tera Media (Source: fintelegram.com). Accountability gap — Despite raids, alleged masterminds often evade arrest; payment channels and shell operators shift across borders faster than national authorities can respond. Short Narrative When Serbian police raided four Belgrade call centers in 2023, thousands of global victims hoped the nightmare was ending. Instead, the alleged organizers—according to reporters—were neither detained nor deterred. The investigation ties the network to a convicted Israeli money launderer and his wife, reinforcing a migration we’ve tracked for years: as legal doors close on one product (binary options), the same operators rebrand into CFDs and then crypto “trading” or “investment” products (Source: esma.europa.eu). Extended Analysis FinTelegram’s archive already maps the Belgrade ecosystem: large sales floors, multilingual “retention” teams, and a web of Serbian, Cypriot, Dutch, and other entities feeding offshore PSPs. Brands come and go; playbooks stay the same—high-pressure onboarding, manipulated dashboards, escalating deposits, and stonewalled withdrawals. Our reporting on Parogan DOO / Olympus Prime DOO and Tera Media showed how the hub professionalized staffing and vendor pipelines, effectively exporting fraud at scale to EU consumers. The latest revelations fit that operational DNA. Regulatory context matters. Israel’s 2017 Knesset ban and ESMA’s 2018 product interventions crippled retail binary options in name—not the call-center apparatus behind them. Within months, the same sales infrastructure resurfaced selling CFDs and then crypto-themed products. The EU’s patchwork enforcement, slow cross-border MLATs, and fragmented oversight of CASPs and PSPs leave seams that industrialized boiler rooms exploit. The current case underscores three blind spots: (1) jurisdictional arbitrage (operators and PSPs rotate countries faster than cases move), (2) ad-tech lead funnels (opaque affiliates that keep re-seeding victims), and (3) financial plumbing (neo-PSPs, EMI accounts, and crypto on/off-ramps loosely screened for repeat offenders). Until those seams close, raids are whack-a-mole. Actionable Insight Regulators/LEAs: Prioritize mastermind targets and payment interdiction over floor-level arrests; freeze merchant IDs, affiliate payouts, and crypto liquidations linked to known clusters. Banks/EMIs/PSPs: Apply network-risk scoring (shared typologies, device/merchant graphing) to block rerouted merchant shells tied to Belgrade clusters. Ad platforms: Enforce KYC-style controls for high-risk “investment” lead gens; maintain a shared blocklist of proven boiler-room funnels. Victim defense: Treat withdrawals delays and “bonus/fee” hurdles as red flags; use documented chargeback and law-enforcement templates early. Call for Information (Whistle42) Were you recruited to a Belgrade call center? Do you recognize the managers, PSP pipelines, or brand rotations described above? Share evidence—documents, org charts, payment trails—via our whistleblower system [Whistle42]. Anonymity protected; operational details matter most. Share Information via Whistle42

MetaPlanet (Tokyo) reports a ~497% YTD BTC yield, far outpacing Strategy’s slowing metric even as Strategy (ex-MicroStrategy) added 196 BTC and remains the largest corporate BTC treasurer. MetaPlanet’s outperformance stems from an early-stage base, aggressive 2025 stacking, and funding that limits common-share dilution relative to BTC added. The edge is real for now—but highly sensitive to funding conditions and BTC price (Source: X (formerly Twitter). BTC Yield — quick refresher “BTC yield” tracks the percentage change in BTC-per-share (BPS)—i.e., total BTC divided by assumed diluted shares. It’s the KPI both treasurers use to show accretion in BTC terms (not dollars) (Source: wsj.com). Why MetaPlanet screens stronger (2025) Base effect + pacing: Starting from a smaller BTC base, MetaPlanet’s large, frequent 2025 buys (e.g., 5,419 BTC tranche) drive outsized BPS growth (Source: finance.yahoo.com). Funding mix: Management leans on non-convertible/structured capital (incl. preferreds) and sizable new equity lines to scale BTC—aimed at maximizing BPS accretion; approval for major raises underscores the plan (Source: Reuters). Operating momentum: Q3 2025 “Bitcoin income” update cites ¥2.438bn revenue (+115.7% vs Q2) tied to the BTC program, reinforcing narrative and equity bid (Source: X -formerly Twitter). Where Strategy stands Still #1 by BTC held; latest add was 196 BTC for ~$22.1m. However, smaller top-ups against ongoing issuance mean BTC-yield deceleration vs earlier periods—our prior FinTelegram note flagged this trend (Source: X (formerly Twitter). Read our latest report on Strategy here. Is MetaPlanet’s performance “better”? Yes—on 2025 BTC yield. A ~497% YTD BPS gain implies much stronger per-share BTC accretion than Strategy this year. But it’s execution- and market-dependent: if capital costs rise or equity appetite fades, sustaining triple-digit yield is hard (Source: X (formerly Twitter). If BTC enters a prolonged drawdown Funding squeeze: Equity premia/comparable warrant demand compress, raising cost of capital and slowing buys; preferred obligations persist (Source: Reuters BPS risk: If issuance continues without proportional stacking, BTC-per-share can stall or fall (negative BTC yield). wsj.com Stock beta: Both names historically amplify BTC moves; a bear phase can inflict outsized equity drawdowns relative to spot BTC. (Inference from prior cycles.) Actionable Takeaways Track BPS and BTC yield (ΔBPS), not headline coin counts. For MetaPlanet, watch funding mix (preferred vs. common), cadence of buys, and delivery against the Q3 momentum claims. X (formerly Twitter) For Strategy, monitor net BTC added vs. share issuance and the frequency/size of new adds. X (formerly Twitter) Call for information: Are you inside a corporate BTC-treasury program (Strategy, MetaPlanet, others)? Confidential tips welcome via Whistle42.com—documents, term sheets, funding structures, or KPI definitions that validate (or challenge) reported BTC yields. Share Information via Whistle42

Executive Summary Strategy (formerly MicroStrategy) disclosed another purchase — 196 BTC for ≈approximately $22.1 million — reaffirming its role as the bellwether Bitcoin treasury company. But the firm’s key KPI, “BTC yield,” is decelerating as recent capital raises outpace net BTC deployed, with part of proceeds servicing preferred-stock obligations. For investors, the signal to watch isn’t the headline coins bought; it’s BTC-per-share (BPS) accretion and its rate of change (Source: CoinCentral). What “BTC Yield” Actually Means Definition: BTC yield = the percentage change in Bitcoin-per-share (BPS) over a period. BPS is total BTC held divided by diluted shares outstanding. When BPS rises, each share “owns” more BTC; when issuance runs ahead of stacking, BTC yield slows (Source: Investopedia). Why it matters: Strategy’s equity/convertible playbook boosts BTC exposure, but share issuance can dilute BPS; only net BTC added per share drives long-term value for common holders. Management has even posted YTD “BTC yield” snapshots to underscore this KPI (Source: X (formerly Twitter)) Strategy’s BTC Treasury Playbook (as covered on FinTelegram) Mandate: Be a Bitcoin Treasury Company—raise capital (ATMs, converts, preferreds), buy BTC on dips, hold long term. Rebrand from MicroStrategy to “Strategy Inc” formalized the pivot (Source: Strategy). Recent cadence: Small, frequent buys (latest: 196 BTC @ ~$113k) sustain the stacking narrative but are modest vs. recent capital raised, pressuring BTC yield. Financial press calls this “dilution-as-a-strategy” when proceeds aren’t primarily deployed into BTC. (Source: CoinCentral). Opportunities Embedded BTC beta with leverage: If BTC appreciates, Strategy’s equity historically amplifies upside due to balance-sheet gearing and narrative premium. Accounting tailwinds: Fair-value accounting (2025 adoption) reduces impairment drag and keeps reported BTC gains visible in GAAP results. (General context; monitor filings.) Risks BTC-yield deceleration: When new equity/pref issuance > BTC deployed, BPS growth slows, weakening the core thesis for common holders. ft.com NAV-premium risk: If the stock’s premium compresses, cheap equity funding shrinks, limiting future stacking and potentially forcing slower accumulation. ft.com Market Impact Another add supports the corporate-treasury-in-BTC meme, but investors should track BPS, BTC yield (ΔBPS), financing mix, and NAV premium/discount—not just coin counts (Source: Bitcoin Treasuries). Actionable Takeaways Watch BPS & BTC yield each quarter; treat headline “BTC bought” as secondary. Scrutinize funding use: If more cash goes to preferred dividends or opex than BTC, expect further yield slowdown. Positioning: Strategy is still the flagship BTC-treasurer. For pure BTC exposure, hold BTC. For levered BTC + equity optionality, hold MSTR—but size positions assuming yield volatility. Share Information via Whistle42

Investment firm Citi lifts its AI build-out forecast: Amazon, Alphabet (Google), Microsoft, and Meta could collectively invest up to $2.8T by 2029, front-loaded with $490B capex by end-2026. The spend hinges on scarce power—~55 GW new capacity—pushing firms to borrow and pressuring free cash flow (Source: Reuters). Key Facts New forecast: >$2.8T AI infrastructure through 2029; prior estimate was $2.3T (Source: Reuters) Near-term cadence: ~$490B AI capex by end-2026. Power bottleneck: ~55 GW additional capacity needed by 2030 (≈$50B per GW). Geography: ~$1.4T of the total in the U.S. alone. Funding mix: Shift from profits to debt financing, pressuring FCF. Short Analysis Citi’s step-up underscores a super-cycle: GPUs, data centers, networks, cooling, and power become the new strategic moat. The power math is stark—55 GW is utility-scale, implying grid upgrades, long lead times, and permitting risk. Winners span AI chips, accelerators, power equipment, utilities, and specialized data center REITs/operators. Losers: firms unable to secure energy or balance sheets for this spend. Debt creep matters. If hyperscalers lean harder on borrowing, investors should expect capex-heavy guides and lower near-term FCF—but also durable pricing power in AI cloud and inference services as capacity comes online. Track Q3–Q4 earnings language for “build-ahead-of-demand” signals and any disclosure on power PPAs, on-site generation, and grid interconnect queues. Call for Information Are you working on hyperscaler power procurement, grid connections, PPAs, or data-center buildouts? Share insights or documents confidentially via Whistle42.com. Share Information via Whistle42

Spot gold’s surge to fresh all-time highs above $3,800/oz has pulled tokenized gold to ~$2.9B market cap, with Tether’s XAUT and Paxos’ PAXG each clearing $3.2B in September trading volume. PAXG drew $40M net inflows; XAUT’s climb came from price, not new mints. Compliance under EU MiCA looms large (Source: Reuters). Key Facts Gold ATH: Spot gold pushed above $3,800/oz on Sept 29–30, 2025, setting new records amid rate-cut bets, a softer dollar, and U.S. shutdown jitters (Source: Reuters) Sector Size: Tokenized gold ≈ $2.9B; leaders XAUT (~$1.43B) and PAXG (~$1.12B) dominate share (Source: defillama.com) Volumes & Flows: Both tokens posted >$3.2B September volume; PAXG +$40M net inflows; XAUT growth from metal price with no new September mints (Source: coindesk.com). Product Design: PAXG (Paxos Trust, NYDFS-regulated) is redeemable for LBMA Good Delivery bars; XAUT advertises physical delivery in Switzerland (minimums/KYC apply) (Source: Tether) Regulatory Lens (EU): Gold-referenced tokens are within MiCA’s perimeter (Asset-Referenced Tokens); EU offers/listings trigger authorization, reserve, and disclosure duties ((Source: esma.europa.eu) Short Analysis Gold’s breakout has turbo-charged on-chain gold: the combination of 24/7 trading, faster settlement, and easy composability with crypto rails turned XAUT/PAXG into high-beta conduits to bullion’s move. September’s simultaneous records in spot and token metrics signal that tokenized gold has matured from niche to macro-sensitive conduit. Under the hood, though, these are centralized, redeemable claims with real-world logistics. Redemption thresholds (e.g., full-bar minimums), jurisdiction limits, and issuer transparency all matter. PAXG’s trust-company framework and bar-level lookups cater to institutional comfort; XAUT leans on Swiss delivery terms and Tether’s distribution muscle. Investors should treat them less like “DeFi primitives” and more like custodied warehouse receipts on chain. What’s next: In Europe, MiCA will pressure issuers and platforms to tighten disclosures and permissions for EU users. Expect clearer white papers, reserve attestations, and possibly geo-fencing on non-authorised offerings. If gold stays elevated, tokenized bars may keep siphoning flows from ETFs and OTC certificates—provided redemption pipelines stay credible and liquid. Call for Information Have you worked on gold token issuance, custody, audits, redemption, or EU listings under MiCA? We want to hear from you. Share insights or documents—confidentially—via Whistle42.com. Share Information via Whistle42

BREAKING: Attacking Football Website Obliterated After Rainbet Exposé In a shocking escalation of corporate retaliation, the independent football journalism website Attacking Football has been completely taken offline by what its founder, Paddy Keogh, describes on X as an “extremely severe Distributed Denial-of-Service (DDoS) attack” following the publication of a damaging exposé on offshore gambling operator Rainbet. The coordinated cyber assault, which Paddy (@PaddyKeoghAF) reports has “taken down a whole CDN,” represents one of the most brazen attacks on press freedom in the sports journalism sector—and all evidence points directly to Rainbet as the perpetrator. The Timeline of Digital Destruction September 25, 2025: Attacking Football publishes explosive investigation titled “Rainbet Exposed: The Most Dangerous Bookie On Football Twitter“—a comprehensive takedown of Rainbet‘s illegal marketing schemes and regulatory violations. September 29, 2025: Massive DDoS attack begins, flooding Attacking Football‘s servers with fake page requests designed to crash the infrastructure. Current Status: Website www.attackingfootball.com remains completely inaccessible, with the attack so severe it has compromised an entire Content Delivery Network (CDN). What Rainbet Desperately Wanted Buried Attacking Football‘s investigation—now conveniently silenced—exposed damaging evidence of Rainbet‘s systematic violations: Fabricated Promotional Content Network The report revealed Rainbet‘s industrial-scale deception operation, coordinating fake betting slip campaigns across social media platforms to create the illusion of massive wins and lure unsuspecting bettors. Illegal Targeting of Restricted Markets Despite explicit terms prohibiting operations in the UK, Germany, and other regulated jurisdictions, Rainbet actively markets to players in these territories without proper licensing—a clear violation of gambling laws. Zero Consumer Protection The investigation highlighted Rainbet‘s complete absence of player protection mechanisms, segregated funds, or dispute resolution systems—leaving players completely vulnerable to arbitrary account freezing and fund confiscation. The Anatomy of Corporate Cyber Terrorism Industry experts confirm the attack’s sophisticated nature suggests significant financial resources and technical expertise—exactly what an offshore gambling empire like Rainbet possesses. The attack methodology mirrors tactics used against major gambling operators: Volumetric Assault: Overwhelming servers with massive traffic volumes CDN Compromise: Targeting content delivery networks to maximize damage Infrastructure Disruption: Designed to cause maximum downtime and financial damage This represents a chilling escalation from typical DDoS attacks, which often target gambling sites for extortion purposes. Instead, Rainbet appears to have weaponized these same techniques against journalism that threatens their illegal operations. Pattern of Gambling Industry Intimidation Rainbet’s alleged cyber attack follows a documented pattern of gambling operators using extreme measures to silence criticism: Historical Precedents PaddyPower.com suffered similar DDoS attacks as part of extortion attempts against betting agencies Italian gambling sites have been compromised and their infrastructure weaponized for attacks on competitors Major gambling platforms routinely face cyber warfare during high-stakes periods The Rainbet Difference Unlike typical extortion-motivated attacks, this assault targets independent journalism—representing a dangerous escalation in corporate intimidation tactics. Technical Analysis: Industrial-Scale Cyber Warfare The scale of destruction suggests Rainbet deployed resources typically reserved for nation-state actors: CDN-Level Compromise: Taking down an entire Content Delivery Network requires massive botnet resources and sophisticated attack coordination. Sustained Assault: Multi-day attack duration indicates significant financial investment in maintaining the offensive. Precision Targeting: The timing—immediately following Rainbet’s exposé—eliminates any possibility of coincidental attack motivation. Rainbet’s Digital Footprint of Deception The cyber attack represents just the latest escalation in Rainbet’s war against accountability: Previously Documented Violations Discord-coordinated influencer schemes paying $50 per fabricated betting slip post Systematic acceptance of self-excluded UK gamblers violating GAMSTOP regulations Operations in restricted jurisdictions without proper licensing Zero consumer protection mechanisms leaving players vulnerable to fund theft Corporate Structure Designed for Evasion Operating through RBGAMING N.V. in Curaçao with an Anjouan license, Rainbet’s shell company structure facilitates both regulatory evasion and retaliatory attacks while obscuring accountability. Read our Rainbet Compliance Analysis here The Chilling Effect on Press Freedom Paddy Keogh‘s courageous investigation—now silenced by corporate cyber warfare—exposed the dangerous intersection of offshore gambling, social media manipulation, and regulatory capture. Attacking Football’s Editorial Standards: Unlike competitors, the site explicitly refuses gambling sponsorships, maintaining editorial independence that has threatened Rainbet’s misinformation campaigns [attached_file:1]. Global Contributor Network: The attack affects over 100 contributors and writers who used Attacking Football as a platform for launching professional journalism careers[attached_file:1]. Law Enforcement Must Act NOW This cyber assault constitutes clear criminal activity under multiple jurisdictions: UK Computer Misuse Act DDoS attacks targeting UK-based journalism represent serious criminal offenses carrying significant penalties. International Cybercrime Laws Cross-border attacks on press freedom trigger multinational law enforcement cooperation mechanisms. Gambling Regulatory Violations The attack compounds Rainbet’s existing violations, warranting immediate license revocation and criminal investigation. Call to Action: Expose Rainbet’s Criminal Network FinTelegram’s Whistle42 platform urgently seeks insider information to expose the full scope of Rainbet’s criminal operations: Critical Intelligence Needed Technical details of the DDoS attack infrastructure and funding Internal communications regarding the decision to target Attacking Football Corporate structure documentation revealing true beneficial ownership Payment processing relationships enabling illegal operations in restricted markets Additional retaliation evidence against other critics or competitors Protection Guaranteed Whistle42 provides: Military-grade encryption for all communications Legal privilege protection through qualified counsel Anonymous submission systems with no identity tracking Financial compensation for verified intelligence International witness protection coordination where necessary Corporate Terrorism Cannot Stand Rainbet’s cyber attack on Attacking Football represents a watershed moment in corporate accountability. If offshore gambling operators can silence journalism through cyber warfare with impunity, no independent media outlet investigating financial crime will be safe. The message is clear: Expose Rainbet‘s crimes, face digital destruction. But Rainbet made one critical mistake—their attack has only amplified global attention on their illegal operations while providing clear evidence of criminal intent to silence critics. URGENT: Contact Whistle42 NOW Insiders with information about Rainbet’s cyber attack, illegal marketing schemes, or corporate structure must act immediately. Rainbet’s cyber terrorism has crossed a line. Help us expose the full extent of their criminal empire before they strike again. Your information could be the key to bringing down one of the most dangerous offshore gambling operations targeting vulnerable players worldwide. Share Information via Whistle42 The fight for press freedom and consumer protection starts NOW.

Executive Summary Rainbet represents a sophisticated offshore gambling operation that epitomizes the worst aspects of unregulated cryptocurrency casinos. Operating through a complex web of shell companies and utilizing regulatory arbitrage between Curaçao and Anjouan jurisdictions, Rainbet has built a global gambling empire while systematically violating consumer protection laws, exploiting vulnerable players, and conducting illegal marketing activities across restricted jurisdictions. This comprehensive investigation reveals how Rainbet employs fabricated promotional content, accepts self-excluded gamblers, operates without proper licensing in major markets, and maintains a deliberately opaque corporate structure designed to evade accountability. The platform’s aggressive expansion strategy relies on paid influencer schemes that violate advertising regulations in multiple jurisdictions while targeting jurisdictions where it lacks legal authorization to operate. Company Introduction and Corporate Structure Founding and Development Rainbet was established in 2023 as a cryptocurrency-focused gambling platform, though some sources suggest operational activities dating back to 2017. The platform emerged during a period of rapid expansion in the offshore crypto gambling sector, positioning itself as a “modern” alternative to traditional online casinos through its emphasis on cryptocurrency transactions and minimal regulatory compliance. Legal Entity Structure Primary Operating Entity: RBGAMING N.V. – Incorporated in Curaçao (Registration Number: 163051) Registered Address: Zuikertuintjeweg (Zuikertuin Tower), Willemstad, Curaçao Operational License: Anjouan Internet Gaming License (#001-2023-AJG) This dual-jurisdiction structure exemplifies the regulatory arbitrage strategies employed by offshore operators: Curaçao incorporation provides perceived legitimacy and European banking access Anjouan licensing offers minimal regulatory oversight and consumer protection requirements Beneficial Ownership and Key Personnel Rainbet’s ownership structure remains deliberately opaque, consistent with offshore gambling operations designed to evade regulatory scrutiny and accountability. Claimed Leadership: John Evans – Listed as CEO and Co-Founder, but most likely a fake character Sean R. – Chief Marketing Officer Guilherme Fideles – Chief Operations Officer Analysis of Leadership Claims: John Evans: Multiple LinkedIn profiles exist for individuals named “John Evans,” but none show verifiable connections to Rainbet or gambling industry experience. The individual listed as Rainbet’s CEO has no documented history in gambling, gaming, or related industries, suggesting either a constructed persona or nominee arrangement. Sean R.: No verifiable information exists for this individual beyond Rainbet’s own promotional materials, indicating likely pseudonymous representation. Guilherme Fideles: The only figure with documented industry history, but exclusively in legally problematic operations: BoglaGold (shut down 2019 after legal action from RuneScape developer Jagex) MaisBet (short-lived, no current online presence) MMO Games LP (officially dissolved 2020) Tokenbets (grey-market operation) This pattern of defunct and legally questionable ventures suggests systematic involvement in regulatory evasion rather than legitimate business development. Regulatory Status and Legal Issues Licensing Inconsistencies Rainbet operates under multiple conflicting regulatory claims: Anjouan License (#001-2023-AJG): Issued by Union of the Comoros (tiny island nation) Minimal consumer protection requirements No meaningful dispute resolution mechanisms No segregated player fund requirements Curaçao Registration (RBGAMING N.V.): Corporate registration only, not operational gambling license Used primarily for banking and payment processing access Subject to upcoming regulatory reforms eliminating sublicense arrangements Jurisdictional Violations Restricted Jurisdictions per Terms of Service: United Kingdom Germany France Spain Austria Ireland United States Documented Violations:Despite explicit restrictions, FinTelegram’s investigation confirmed successful player registration and deposit capabilities from: Austria – Full registration and deposit capability via multiple payment methods Italy – Complete platform access without IP blocking or verification requirements United Kingdom – Registration possible with UK addresses, contradicting UKGC requirements Payment Processing Evidence: Credit/debit card deposits via MoonPay integration Direct bank transfers through Interac (Canada) and Pix (Brazil) Gift card purchases via Kinguin.net with promotional codes No jurisdiction-based payment restrictions implemented UK Self-Exclusion Violations GAMSTOP Requirements:Under UK Gambling Commission regulations, all licensed operators must: Participate in GAMSTOP multi-operator self-exclusion scheme Update exclusion lists every 24 hours Prevent self-excluded players from accessing gambling services Refund deposits from self-excluded players Rainbet’s Non-Compliance:Whistleblower evidence confirms Rainbet: Accepts deposits from GAMSTOP-registered self-excluded players Does not verify UK self-exclusion status during registration Refuses refunds to self-excluded players who deposit funds Continues marketing to individuals who have requested exclusion Legal Framework Violations:This constitutes systematic violation of: Gambling Act 2005 (UK) Consumer Rights Act 2015 (UK) UKGC Licence Conditions and Codes of Practice Network Analysis and Connections Potential 1xBet Connections While direct ownership links remain unverified, several operational similarities suggest possible connections to the 1xBet network: Operational Patterns: Identical licensing jurisdictions (Curaçao/Anjouan combination) Similar payment processing infrastructure Comparable restricted jurisdiction targeting Parallel affiliate marketing structures Technical Infrastructure: Similar platform architecture and user interface design Shared payment gateway integrations Comparable cryptocurrency processing systems Marketing Methodologies: Influencer-based promotional schemes Social media manipulation tactics Fabricated promotional content distribution Stake.com Network Analysis No Direct Connections Identified:Unlike 1xBet, no evidence suggests operational connections between Rainbet and Stake.com: Stake Ownership: Ed Craven and Bijan Tehrani (verified Australian entrepreneurs) Corporate Structure: Medium Rare N.V. (legitimate Curaçao operation) Operational Standards: Higher compliance standards and industry recognition White Label and Affiliate Networks Affiliate Program Structure: Commission rates up to 40% of player losses Weekly automated payments in 200+ currencies Personal account managers for high-volume affiliates Minimal compliance verification requirements Technical Service Providers: Multiple unnamed white-label technical providers Shared infrastructure with other offshore operators Content creation networks in Eastern Europe Payment Facilitators and Financial Infrastructure Primary Payment Processors MoonPay Integration: Direct platform integration for fiat-to-crypto conversion Supports Visa, Mastercard, Google Pay, Apple Pay Enables deposits in restricted jurisdictions No enhanced due diligence for high-risk transactions Regional Banking Partners: Interac (Canada) – Direct banking integration Pix (Brazil) – Instant payment system access Various European banks – Undisclosed processing relationships Direct Crypto With the Deposit from Wallet feature, you can deposit funds into your wallet on one of the many crypto exchanges, such as Binance or Coinbase, or connect your MetaMask, TrustWallet, or numerous other wallets directly to Rainbet and transfer crypto directly to your Rainbet account. All without KYC, of course.. Gift Card and Alternative Payment Systems Kinguin.net Partnership: Rainbet gift cards available with promotional discounts $100, $150, $500 denominations available Promotional codes: “MAJOR24” (8% discount) Enables payment system circumvention in restricted markets Illegal Marketing Activities Fabricated Promotional Content Scheme Whistleblower Intelligence:FinTelegram has received verified information from multiple sources confirming Rainbet’s systematic use of fabricated promotional content distributed through paid influencer networks. Operational Structure: Coordination Platform: Discord server with restricted access Payment Structure: $50 per post for smaller accounts (<20k followers) Content Distribution: Pre-made fabricated betting slips showing large wins Account Requirements: Addition of “@Rainbet” to influencer bio for authenticity appearance Payment and Incentive System: Monthly Income Potential: Up to $1,500 for regular participants Payment Method: Direct credit to Rainbet account Content Requirements: Posting fabricated betting slips as personal wins Frequency Expectations: Daily or weekly posting schedules Regulatory Violations:This scheme violates multiple advertising regulations: ASA Rules (UK): All paid promotions must be disclosed as advertisements EU UCPD: Hidden marketing practices are prohibited FTC Rules (US): Paid endorsements must be “clear and conspicuous” Social Media Platform Policies: Undisclosed commercial relationships violate terms of service Contact Methods for Influencer Recruitment Primary Channels: Telegram: @rainbetshin Discord: rainbetshin Email: sarah@rainbet.com Target Demographics: Football-focused social media accounts Gaming and cryptocurrency influencers Accounts with 10,000+ followers Content creators in restricted jurisdictions Scale and Impact Content Volume:Based on industry analysis and social media monitoring: 100+ active paid influencers 500+ fabricated promotional posts monthly 50 million+ combined reach across platforms Targeting primarily UK, German, and Australian audiences Consumer Protection Failures Self-Exclusion Policy Violations Documented Issues: Immediate Re-access: Self-excluded players report immediate platform access without cooling-off periods No Verification Systems: Platform lacks integration with national self-exclusion databases Refund Denials: Systematic refusal to refund deposits from self-excluded players Continued Marketing: Promotional communications continue to self-excluded individuals Victim Testimonials: Player reported immediate re-access after self-exclusion request Multiple attempts to contact management regarding gambling addiction ignored Psychological manipulation through timed bonus offerings Debt accumulation through high-interest loan encouragement Player Fund Protection No Segregated Accounts:Unlike regulated operators, Rainbet does not maintain segregated player funds, meaning: Player deposits mix with operational funds No protection in case of operator insolvency No independent auditing of fund security No compensation scheme for player losses due to operator failure Withdrawal Issues: Arbitrary account freezing without explanation Voided winnings based on retroactive terms interpretation Extended processing delays exceeding stated timeframes Demand for excessive documentation for cryptocurrency withdrawals Regulatory Evasion Mechanisms IP Geolocation Circumvention Technical Implementation: No effective IP blocking for restricted jurisdictions VPN usage implicitly encouraged through platform design Country selection dropdowns include restricted territories No secondary verification of player location Payment Processing Workarounds Multi-Jurisdiction Strategy: Primary processing through Curaçao registration Secondary processing via Brazilian and Canadian entities Cryptocurrency processing to bypass traditional banking restrictions Gift card systems for additional payment circumvention Corporate Structure Obfuscation Nominee Arrangements: Use of nominee directors and shareholders Corporate service provider registration in secrecy-friendly jurisdictions Beneficial ownership information not publicly disclosed Multiple layers of corporate entities across jurisdictions FinTelegram Testing and Investigation Results Registration Testing Across Restricted Jurisdictions Austria Testing: Status: SUCCESSFUL registration and deposit Payment Methods: Credit card via MoonPay, cryptocurrency direct Verification Requirements: Email only, no KYC documentation required IP Blocking: None implemented Italy Testing: Status: SUCCESSFUL registration and deposit Payment Methods: Full payment option availability Jurisdiction Detection: No location-based restrictions applied Terms Compliance: Platform acceptance despite terms prohibiting Italian players United Kingdom Testing: Status: SUCCESSFUL registration and deposit Payment Methods: MoonPay integration functional GAMSTOP Integration: No verification against self-exclusion database Regulatory Compliance: Complete violation of UKGC requirements Payment Processing Verification MoonPay Integration: Direct platform integration bypasses traditional merchant restrictions No enhanced due diligence for high-risk jurisdictions Supports all major payment methods in restricted markets Cryptocurrency Deposits: No source of funds verification Mixing services and privacy coins accepted No AML compliance screening for high-value transactions Gift Card Testing: Kinguin.net gift cards successfully purchased and redeemed Promotional discount codes functional No purchase location restrictions implemented Industry Context and Comparative Analysis Comparison with Regulated Operators FeatureUKGC/MGA Licensed OperatorRainbet (Anjouan License)Player Fund Protection Segregated accounts required No segregation requirementsSelf-Exclusion Enforcement GAMSTOP integration mandatory Player liability for relapsesDispute Resolution Independent ADR required No independent resolutionOwnership Transparency Public beneficial ownership Hidden behind nominee structuresAdvertising Compliance Strict disclosure requirements Fabricated undisclosed contentAudit Requirements Regular independent audits No audit requirementsConsumer Compensation Compensation schemes exist No compensation mechanisms Market Position Analysis Revenue Estimation:Based on industry analysis and observable activity: Estimated annual revenue: $200-500 million Active player base: 500,000-1,000,000 users Geographic concentration: UK (30%), Germany (25%), Australia (20%) Average player value: $400-800 annually Growth Strategy: Aggressive influencer marketing in restricted jurisdictions Cryptocurrency-first approach to bypass banking restrictions Minimal compliance costs through regulatory arbitrage High-risk, high-reward player acquisition model Conclusion and Risk Assessment Systematic Regulatory Violations Rainbet operates as a paradigmatic example of offshore gambling regulatory evasion, systematically violating: Consumer protection regulations across multiple jurisdictions Advertising and marketing laws in target markets Self-exclusion and responsible gambling requirements Anti-money laundering and know-your-customer obligations Consumer Risk Profile High-Risk Factors: No Player Fund Protection: Deposits not segregated from operational funds Arbitrary Terms Enforcement: Retroactive application of terms to void winnings No Meaningful Dispute Resolution: Offshore licensing provides no recourse Exploitation of Vulnerable Players: Systematic acceptance of self-excluded individuals Regulatory Risk: Platform operates illegally in major jurisdictions Player accounts subject to freezing without notice Winnings can be voided based on retroactive jurisdictional claims No compensation mechanisms for operator failure Industry Impact Rainbet represents the systemic failures in international gambling regulation: Regulatory Arbitrage: Exploitation of jurisdictional inconsistencies Payment System Circumvention: Cryptocurrency and alternative payment abuse Social Media Manipulation: Undisclosed advertising violating platform policies Consumer Harm: Systematic exploitation of gambling addiction vulnerabilities Key Data Summary CategoryDetailsCompany NameRainbet (operated by RBGAMING N.V.)RegistrationCuraçao (Registration #163051)LicenseAnjouan Internet Gaming License (#001-2023-AJG)Claimed CEOJohn Evans (unverified identity)Operational Since2023 (some sources suggest 2017)Restricted JurisdictionsUK, Germany, France, Spain, Austria, Ireland, USAActual Operation StatusActive in all restricted jurisdictions without IP blockingPayment ProcessorsMoonPay, Interac, Pix, Kinguin.net gift cardsCryptocurrency Support20+ digital assets including BTC, ETH, USDT, SOLSelf-Exclusion Compliance Accepts self-excluded players, no GAMSTOP integrationPlayer Fund Protection No segregated accounts or protection schemesDispute Resolution No independent dispute resolution mechanismMarketing Violations Confirmed fabricated promotional content via DiscordInfluencer Payment$50 per post, up to $1,500 monthly for participantsRisk LevelEXTREMELY HIGH Call for Information FinTelegram seeks additional information from industry insiders, current and former employees, affiliates, and affected players regarding: Corporate Intelligence Beneficial Ownership Details – True ownership structure behind nominee arrangements Technical Infrastructure – White-label providers, software vendors, and operational partners Financial Flow Analysis – Payment processing relationships and fund movement patterns Regulatory Communications – Internal communications regarding compliance and legal issues Operational Intelligence Influencer Network Documentation – Discord server access, payment records, content distribution systems Player Exploitation Evidence – Documentation of self-excluded player acceptance and related communications Jurisdictional Violations – Evidence of active marketing and operations in restricted territories Internal Compliance Procedures – Documentation of internal compliance policies and their enforcement Financial Crime Intelligence Money Laundering Mechanisms – Methods for processing high-risk transactions and source of funds verification Corporate Structure Changes – Documentation of corporate restructuring and ownership transfers Regulatory Evasion Strategies – Internal strategies for avoiding regulatory oversight and enforcement Player Protection Violations Self-Exclusion System Failures – Technical documentation of self-exclusion system inadequacies Vulnerable Player Targeting – Evidence of marketing to individuals with gambling problems Fund Confiscation Cases – Documentation of arbitrary account freezing and fund confiscation Secure Communication Channels: Encrypted Email: Secure communication protocols available upon request Anonymous Submission: Document drop systems with source protection Legal Protection: Whistleblower protection program coordination Financial Compensation: Legitimate information compensation available Protection Guarantees: Source identity protection through legal privilege Secure document handling with encryption Anonymous publication options Legal support coordination where applicable Your information could be instrumental in exposing the full scope of this offshore gambling operation and protecting consumers from continued exploitation and financial harm. Contact FinTelegram through our secure channels for confidential communication protocols and source protection procedures. Share Information via Whistle42