KYCoin Compliance Briefing: Utility Token Scheme Inside Luxembourg’s Olky Group Under Regulatory Spotlight

Early-stage utility token linked to a licensed payment institution amid allegations of casino-related transaction facilitation

1. Overview

KYCoin (ticker: KYC) is an early-generation utility token issued by NUN-TECH SA, an IT services company registered in Luxembourg and embedded within the broader Olky Group ecosystem.

Originally launched in 2021 on a private ledger and later migrated to the Polygon network (Ethereum layer 2), KYCoin is designed as an internal access and utility token for:

• KYC verification services

• Payment order routing

• Transaction processing within the Olky Group’s payment and crypto-asset environment

The token is closely integrated with Olky Payment Service Provider SA, a licensed payment institution supervised by Luxembourg’s Commission de Surveillance du Secteur Financier (CSSF) under authorization no. 47/13. Both NUN-TECH SA and Olky Payment Service Provider SA have operated from the same Luxembourg address, raising questions around the degree of operational separation and corporate independence.

Separate intelligence inputs suggest that the Olky Group infrastructure may be used to support illegal casino operations, which, if accurate, heightens regulatory risk given the group’s focus on high-risk verticals such as crypto and Web3 services.

2. Corporate Structure and Ownership Profile

2.1 NUN-TECH SA

• Jurisdiction: Luxembourg

• Incorporation: April 2017

• Registered capital: €35,392

• Headcount: Approx. 1–10 employees

• Trade register number: B214016

• Registered address: 7A rue de Turi, L-3378 Livange, Luxembourg

• Branch office: 48 Quai du Lazaret, Marseille, France

NUN-TECH SA is presented in corporate materials as part of the Olky Group, but publicly available information does not fully clarify its exact ownership chain, ultimate beneficial ownership, or internal governance arrangements.

2.2 Olky Payment Service Provider SA

• Legal form: Société anonyme

• Trade register number: B165776

• Registered capital: €2,271,111.00

• Incorporation: January 2012

• License: Payment institution license 47/13, granted by Luxembourg’s Ministry of Finance in 2013

Olky Payment Service Provider SA initially operated from 7A rue de Turi, L-3378 Livange and later relocated to 1 Op de Leemen, L-5846 Fentange. Both locations appear to be business-park style shared office facilities.

2.3 Olky Group Composition

The Olky Group is described as a multi-entity structure comprising:

• OlkyPay – payment services

• OlkyPass – KYC identity solution

• Algoreg – KYC/AML technology

• OlkyWallet – crypto-asset services

• OlkyRent – SaaS / technology services

According to corporate claims, the group:

• Employs 100+ staff across Luxembourg and France

• Has processed more than €8 billion in transactions by 2024

Franck Rouayroux is presented as CEO of both Olky Group and OlkyPay. Karima Lachgar also appears in management roles across several group entities, suggesting a tightly integrated management structure.

3. KYCoin Token: Role, Use Cases and Technical Setup

KYCoin is marketed as a utility token used to access and pay for services inside the NUN-TECH / Olky environment. Its core functions include:

3.1 OlkyPass KYC Passport

A digital identity solution branded as OlkyPass, reportedly powered by Algoreg technology, allows customers to undergo Know Your Customer (KYC) checks once and then reuse the resulting “KYC passport” across participating Olky partners.

Key features include:

• Document capture and verification

• Screening for adverse media

• Risk scoring and profiling

• Streamlined onboarding for regulated institutions

3.2 Bank Identity and Alias Management

KYCoin is associated with a bank identity mapping service, enabling users to:

• Link payment accounts to aliases such as

• Email addresses

• Phone numbers

• QR codes

• Simplify payment routing inside the Olky network

3.3 Payment Order Routing

Transfers of KYCoin between participants are used as part of a payment order routing mechanism, where:

• KYCoin movement reflects underlying fiat or crypto-asset payment instructions

• Transactions occur inside a closed or semi-closed partner ecosystem integrating regulated and crypto-related services

3.4 Technical Characteristics

• Initial deployment: 2021 on a private ledger

• Migration: Subsequently moved to Polygon, an Ethereum layer-2 network

• Standard: ERC-20 compatible token

Olky’s promotional materials emphasize “ultra-fast” value transfers within a “limited network” of partners subject to KYC controls. From a regulatory perspective, this raises questions about whether KYCoin functions more as an internal settlement instrument than as a standard, open-market utility token.

4. Regulatory Environment and Compliance Issues

4.1 Payment Institution License

Olky Payment Service Provider SA:

• Holds payment institution license 47/13 in Luxembourg

• Is supervised by the CSSF

• Is passported throughout the EU and EEA via the ACPR (Autorité de Contrôle Prudentiel et de Résolution) in France

• Is recorded in CSSF registers under Z00000006

This license brings with it obligations relating to capital adequacy, governance, risk management, and AML/CFT compliance.

4.2 Crypto-Asset Services (OlkyWallet)

OlkyWallet is described as being “in the process of authorization” with:

• AMF (Autorité des Marchés Financiers)

• ACPR

as a digital asset service provider. However, public registry checks have not clearly confirmed completed PSAN (Prestataire de Services sur Actifs Numériques) registration, leaving questions about:

• The current operational status of crypto services

• Whether OlkyWallet is fully authorized to provide the crypto-asset services it markets

4.3 KYCoin and MiCA

The status of KYCoin under the EU Markets in Crypto-Assets (MiCA) regulation is not clearly defined.

Key points:

• MiCA entered into force in June 2023, with stablecoin provisions applicable from June 2024.

• It introduces detailed frameworks for:

• Utility tokens

• Asset-referenced tokens

• E-money tokens

Given that KYCoin:

• Was launched before MiCA implementation

• Is now operating in a regulatory environment where MiCA standards apply

it is not yet evident:

• Whether KYCoin has been formally classified under MiCA

• Whether a compliant whitepaper, issuer authorization, and other MiCA-related governance measures are in place

4.4 AML/CFT Obligations and VASP Status

As a token issuer and crypto-related service provider in Luxembourg, NUN-TECH SA would likely fall under:

• Luxembourg’s AML/CFT framework

• Registration or supervision requirements for virtual asset service providers (VASPs)

However:

• NUN-TECH SA could not be reliably identified in public CSSF registers as a licensed or registered crypto-asset entity, which raises questions about:

• The applicable supervisory regime

• How AML/CFT obligations are implemented in practice

5. The Payment Institution – Utility Token Interface

The close connection between NUN-TECH SA (KYCoin issuer) and Olky Payment Service Provider SA (licensed payment institution) merits detailed regulatory review.

Under PSD2 (EU Payment Services Directive), payment institutions must meet robust standards regarding:

• Regulatory capital

• Governance and internal control

• Operational resilience

• Consumer protection

The embedding of a utility token into the payment routing layer introduces several potential issues:

5.1 Capital Requirements

• Does the use of token-mediated routing allow part of the transaction flow to sit outside the conventional balance-sheet treatment of a payment institution?

• Are capital requirements being calculated on the full underlying transaction volume, or only on fiat flows?

5.2 Consumer Protection

• Are KYCoin holders provided with protections equivalent to those afforded to traditional payment service users?

• How are disputes, failed transactions, or fraud cases involving token-layer routing handled?

5.3 Supervisory Scope

• Does the CSSF’s supervision explicitly extend to KYCoin-based transaction flows?

• How are token-layer activities reported and monitored?

5.4 Operational Independence

• To what extent does NUN-TECH SA operate independently from Olky Payment Service Provider SA?

• Is there clear segregation of roles, risk management, and internal controls between token issuance and regulated payment services?

6. Allegations of Casino Facilitation

Intelligence provided to Scam-Or Project indicates that the Olky Group infrastructure may be used to support illegal casino activities. These allegations are particularly sensitive in light of the following:

1. Targeting High-Risk Sectors

• Olky Group explicitly markets its solutions to “high-risk sectors”, including:

• Crypto and Web3 businesses

• Industries reportedly underserved or refused by mainstream banks

2. Online Gambling as a Money Laundering Channel

• Online casino and gambling payment flows have long been recognized by regulators as a significant money laundering risk area.

• Payment intermediaries serving unlicensed or offshore gambling operators frequently attract regulatory enforcement.

3. Investigative Focus on Casino Payment Processors

• Scam-Or Project has previously conducted investigative work into payment processors servicing online casino and gambling operators, examining licensing status, payment flows, and risk exposure.

4. Enhanced Obligations in High-Risk Business Lines

• Luxembourg-based payment institutions working with high-risk sectors face heightened AML/CFT expectations and ongoing CSSF monitoring.

5. CSSF Warnings

• The CSSF has issued previous warnings about fraudulent activity misusing the names of legitimate Luxembourg payment institutions, including a public communication involving Olky Payment Service Provider SA in December 2021.

Taken together, these factors suggest that any credible allegations of casino facilitation through the Olky Group framework warrant thorough regulatory investigation.

7. Key Compliance and Risk Indicators

The table below summarizes central attributes of the KYCoin / Olky configuration from a compliance perspective:

8. Regulatory Questions That Remain Open

Several material regulatory questions remain unresolved and require clarification from authorities as well as from the involved entities:

1. MiCA Alignment

• Has KYCoin undergone a formal MiCA assessment as a utility token?

• Does there exist a MiCA-compliant whitepaper and issuer authorization where required?

2. VASP / Crypto Authorization

• Is NUN-TECH SA listed with the CSSF as a virtual asset service provider or equivalent?

• Which specific AML/CFT supervisory framework applies to KYCoin issuance and token-based services?

3. OlkyWallet Registration Status

• Has OlkyWallet completed its PSAN registration and authorization processes with the AMF/ACPR in France?

• Are there limitations on the scope of services it may currently provide?

4. Payment Service Perimeter

• Does KYCoin-based routing amount to a payment service under PSD2 requiring direct authorization, reporting, and oversight?

• Are transactional flows appropriately captured in regulatory reporting?

5. Casino Facilitation and High-Risk Flows

• Have the CSSF or other EU authorities opened inquiries into alleged illegal casino facilitation via Olky infrastructure?

• How are ongoing and historical high-risk flows monitored, documented, and, if necessary, remediated?

9. Conclusion

KYCoin is an early-stage utility token embedded in a hybrid ecosystem of licensed payment services and emerging crypto-asset products. While Olky Payment Service Provider SA holds a legitimate CSSF payment institution license, the model’s dependence on a token layer for core functions, combined with:

• The Olky Group’s strong orientation toward high-risk sectors, and

• Allegations of casino facilitation

means that the KYCoin / Olky construct sits at a point of heightened regulatory interest.

The tight integration between NUN-TECH SA (issuer of KYCoin) and Olky Payment Service Provider SA, reflected in shared addresses, overlapping management, and group branding, raises important questions about:

• The effective regulatory perimeter around token-mediated payment flows

• The sufficiency of consumer protection, transparency, and reporting

• The robustness of AML/CFT controls for both fiat and crypto-asset components

As MiCA and related EU rules move into full effect, models like KYCoin are likely to undergo intensified scrutiny from regulators and possibly from supervisory colleges coordinating oversight across multiple jurisdictions.

10. Whistleblower Information and Call for Intelligence

Scam-Or Project invites insiders and informed stakeholders with direct knowledge of KYCoin, NUN-TECH SA, and the Olky Group to share information through the Scam-Or Project website.

We provide:

• Secure, confidential channels for intelligence submission

• Discussion spaces for affected communities and observers

• The F42 Whistleblower Reward Program, which offers token-based rewards for information deemed materially valuable

Information of Particular Interest

Contributions are especially welcome in the following areas:

• Evidence relating to alleged illegal casino facilitation using Olky or KYCoin infrastructure

• Data or documentation mapping KYCoin transaction flows, counterparties, and partner network structures

• Internal policies, procedures, or communications regarding

• Regulatory compliance

• Risk management

• Treatment of high-risk sectors and gambling-related clients

• Customer complaints, dispute records, chargeback data, or operational incidents involving KYCoin or Olky services

• Any correspondence with regulators (CSSF, AMF, ACPR or others) regarding KYCoin, NUN-TECH, OlkyWallet, or Olky Payment Service Provider

By sharing such information, whistleblowers can help:

• Protect consumers and business users

• Strengthen the integrity of European and global payment channels

• Support regulators in supervising rapidly evolving payment and crypto-asset ecosystems