Offshore Casinos – A Deep Dive into the “Fake FIAT” and Polish-Cypriot Payment Architectures!

A follow-up review of SpinFin Casino (operating via SpinFin5.com) reveals a sophisticated evolution in payment routing designed to circumvent EU and UK regulatory oversight. The current infrastructure relies heavily on “Fake FIAT” rails—on-ramping processes where user deposits are instantly converted into cryptocurrencies (primarily USDC) via third-party agents before reaching the operator.

Key shifts include the displacement of Lithuanian payment facilitators by Polish entities (e.g., ChainValley, ARI10) in response to the MiCA crackdown, and the persistent use of Cypriot banking (ISX Financial) for anonymous gateway processing.

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The Payment Rails: Detailed Breakdown

1. The MiFinity & Costa Rican Connection

Our analysis confirms that EU and UK player deposits via MiFinity are routed to 102-945295 SRL, an entity registered in Costa Rica.

• Regulatory Status: Registered with the Tobique Gaming Commission (TGC).
• Compliance Note: The TGC has no legal standing to authorize gambling operations within the EU or UK. This entity functions as the primary “payment agent” and operator node for the SpinFin carousel.

Read our SpinFin PayFac analysis here.

2. Sofort Uber: The Cypriot Gateway Pipeline

The “Sofort Uber” rail is a shell for four anonymously operated gateways that shield the final recipient.

• Gateways: api.PWay.com, debitly.tech, transactionhandler.com, and sofortuberweisung.com.
• Banking Infrastructure: Funds are ultimately settled at ISX Financial EU PLC (Cyprus) via IBAN CY44 9040 0001 0009 7008 3170 1000.
• Insight: Despite regulatory pressure in Cyprus, ISX Financial continues to serve as a hub for these high-risk offshore flows.

3. Bank Transfer: The “Tink-to-Daxchain” On-Ramper

The “Bank Transfer” option is a classic Fake FIAT rail. While the player sees a standard bank interface, the transaction is an immediate purchase of USDC stablecoins.

• On-Ramper: DAXCHAIN OÜ (Estonia).
• Open Banking Provider: Tink (a VISA subsidiary).
• Mechanism: Tink facilitates the FIAT transfer to Daxchain, which then issues crypto to the casino, effectively laundering the nature of the transaction from the player’s bank statement.

4. Revolut & The Polish ARI10 Axis

For Revolut users, the on-ramping is handled by the Polish group ARI10 (operating via Bitcan / Bitcoin Sp. z o.o.).

• Operational Flow: Funds are sent to a transient wallet (0xf79...) and immediately transferred to the operator’s address (0x97b...).
• Compliance Note: The transaction is explicitly labeled as “irreversible,” a hallmark of crypto-based gambling deposits disguised as consumer payments.

5. The “Polish Shift”: ChainValley Replacing utPay

Since late 2025, Lithuanian crypto providers have faced severe pressure due to MiCA implementation. Consequently, utPay has been replaced by ChainValley (Poland).

• Scope: ChainValley now powers the Skrill / Neteller / Rapid Transfer rails.
• Regulatory Context: Poland’s MiCA “grandfathering” period provides a temporary safe haven for these PayFacs to continue servicing illegal offshore operators.
• Fake FIAT Status: Like the Bank Transfer rail, these e-wallet deposits are now converted into crypto-orders via ChainValley before being credited to the casino.

Read our ChainValley reports here.

6. SegoPay & PaySafeCard

The PaySafeCard rail is routed through a series of gateway redirects:

• Path: api.pgway.com → tx.segopay.com → PaySafeCard.
• Provider: SegoPay, a gateway frequently associated with high-risk merchant accounts and offshore gambling.

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PayFac & Agent Summary Table

Payment Rail	Primary PayFac / Agent	Jurisdiction	Role	Compliance Status
MiFinity	102-945295 SRL	Costa Rica	Payment Agent	Unlicensed (TGC only)
Sofort Uber	ISX Financial EU PLC	Cyprus	Settlement Bank	EU Regulated / High-Risk
Bank Transfer	DAXCHAIN OÜ	Estonia	Crypto On-Ramper	VASP / FIU Regulated
Revolut	Bitcan / ARI10	Poland	Crypto On-Ramper	VASP (KNF Registered)
Skrill/Net/Rapid	ChainValley	Poland	Crypto On-Ramper	VASP (Successor to utPay)
PaySafeCard	SegoPay / PGWAY	Various	Gateway	High-Risk Aggregator
ISX Financial EU PLC	Sofort Uber Rail	Cyprus	Settlement Bank	EMI authorized by the Central Bank of Cyprus

Export to Sheets

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Strategic Conclusion

The “SpinFin Model” represents the current gold standard for offshore evasion: moving the regulatory friction point from the casino to regulated crypto on-rampers in jurisdictions like Poland and Estonia. By the time a regulator looks at the transaction, it has already been “cleaned” by its conversion into USDC.

Call for Information

If you have documentation showing (a) the contracting entity behind SpinFin5/SpinFin, (b) merchant-of-record disclosures, (c) wallet destination reuse across other casinos, or (d) bank/EMI accounts linked to these rails, please share it securely via Whistle42.com. Screenshots, email confirmations, and bank descriptors are particularly valuable.

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