Overview of Cross-Border Gambling Operations Associated with the Sisu Group

This document outlines publicly observable corporate registrations, licensing references, and transaction-related elements connected to gambling platforms linked to the Sisu Group, an Estonia-based business group associated with Jan Svendsen, founder of Coolbet. The review focuses on how gambling services are technically and legally organized across multiple jurisdictions and how different entities participate in administrative, operational, and transactional roles.

The content is limited to factual descriptions derived from public records, platform testing, and open-source materials.

Gambling Activity and Market Access

Online gambling services are offered to users through the websites Epicbet.com and ReSpin.com. During access testing, both platforms were reachable from several European jurisdictions where online casino services are subject to national restrictions.

Technical testing conducted on December 16, 2025, confirmed that user registration and cryptocurrency deposits were possible from Austria, Italy, and the United Kingdom, without visible location-based access limitations.

Entity Operating the Gambling Platforms

The operational control of Epicbet.com and ReSpin.com is attributed to Hot Streak Ltd, a company incorporated in Nevis. The entity references a gambling license issued in Anjouan.

A review of publicly available registries in Nevis, Estonia, and Curaçao does not reveal disclosed beneficial ownership links between Hot Streak Ltd and EU-incorporated companies associated with the Sisu Group. As a result, the operator of the gambling platforms is legally distinct from the Estonian corporate entities.

Estonian Corporate Entities

Separate from the operational gambling layer, the Sisu Group maintains several companies registered in Estonia:

• Anya Holdings OÜ
• Sisu Tech OÜ
• Ducks In A Row OÜ

These entities are incorporated within the European Union and fall under Estonian corporate law. Available information positions them within the group’s ownership, administrative, or support structure rather than as licensed gambling operators.

Allocation of Functions Across Jurisdictions

The reviewed structure reflects a functional distribution of activities:

• Corporate ownership, group administration, and strategic management associated with Estonia
• Gambling operations and player-facing activity associated with offshore jurisdictions
• Payment initiation, conversion, and settlement involving third-party service providers

This separation results in different regulatory obligations applying to different components of the overall structure.

Capital Structure and Shareholding

Publicly referenced funding associated with the Sisu Group totals approximately €14 million and is reported to be distributed across multiple investor groups:

• Level Up Entertainment, contributing approximately €9 million, linked to Hans Martin Nakkim, former CEO of ComeOn! and Cherry Spelglädje
• A group of more than 100 individual investors collectively referred to as the “Sisu 100 Network”, contributing approximately €5 million

The available information indicates a dispersed shareholder base without a single publicly identified controlling owner.

Licensing References and Registration Locations

Entities and platforms reviewed in this document reference or rely on several jurisdictions:

• Estonia – corporate incorporation and group-level administration
• Nevis – incorporation of the gambling operator Hot Streak Ltd
• Anjouan – issuance of a gaming license referenced by the operator
• Curaçao – Comeback N.V. mentioned in connection with licensing arrangements

Certain jurisdictions involved do not require public disclosure of beneficial ownership information.

Platform Characteristics

Epicbet.com

• Public launch reported in June 2024
• Game catalogue exceeding 3,000 titles
• Marketing activity includes esports sponsorship involving Ninjas in Pyjamas

ReSpin.com

• Public launch reported on January 9, 2024
• Focus on cryptocurrency-based gambling services
• Displays licensing information similar to that presented on Epicbet.com

Payment and Transaction Services

During platform testing, payment and conversion services were observed to involve the following providers:

• MoonPay, regulated in the United States
• Banxa, regulated in Australia
• Changelly, providing cryptocurrency exchange and API-based transaction functionality

Available payment methods included card payments, Apple Pay, Google Pay, and bank transfers.

Observed Operational Features

At the time of testing and review, the following operational features were noted:

• No visible geographic filtering at the point of user registration
• No mandatory identity verification during initial account creation
• No publicly displayed integration with national self-exclusion systems
• No publicly disclosed information regarding segregation of player funds

These observations are limited to user-facing functionality and publicly accessible disclosures.

Regulatory Context

The structure and operational features described may intersect with regulatory frameworks applicable in various jurisdictions, including:

• EU Payment Services Directive (PSD2)
• EU Anti-Money Laundering Directive
• National gambling regulations in Austria, Italy, United Kingdom, Germany, and France
• Territorial scope provisions related to Estonian corporate licensing
• FATF anti-money laundering standards

Sources and Methodology

This overview is based on open-source intelligence (OSINT), including public corporate registries, platform disclosures, technical access testing, and information published by independent casino review platforms such as CasinoJan, Rodeo Casinos, Casinogamesonnet, Tribuna, GMBLRS, and others.

Where ownership or control information is not publicly available, this absence is recorded as a factual limitation.

Request for Additional Information

To clarify relationships between EU-incorporated entities and offshore gambling operators, Scam-Or Project invites the voluntary submission of relevant documentation from parties with direct knowledge.

Requested materials may include:

• Incorporation and ownership records of Hot Streak Ltd
• Service or management agreements involving Ducks In A Row OÜ
• Internal governance documentation from Anya Holdings OÜ
• Payment processor onboarding and merchant documentation
• Records showing transaction settlement and fund flows
• Cryptocurrency wallet identifiers used for player deposits
• Banking relationship documentation
• Records involving restricted or self-excluded players

Confidential Submission Channel

Information can be provided anonymously through the Scam-Or Project whistleblower section.

The full report, titled “The Sisu Shadow Empire”, consists of 24 pages and is prepared for regulators, compliance professionals, legal advisers, law enforcement bodies, and financial crime analysts.

This overview forms part of Scam-Or Project’s “Crypto Payment Processor Watch” series, which has previously examined Kingdom Casino/UtPay, Rainbet, GamDom, BC.Game, Roobet, and 1xBet.