Illegal gambling

20Bet’s Presence in the German Gambling Market and Questions Around Revolut’s Payment Processing

By Tom Morris - December 25, 2025 No comments 3 mins read

Overview of the Allegations

A recent report published by RatEx42 examines potential compliance and regulatory issues connected to the online gambling brand 20Bet and its activities targeting players in Germany.
The analysis raises concerns about possible breaches of EU gambling law, anti-money-laundering (AML) standards, and Germany’s Interstate Treaty on Gambling (GlüStV). It also reviews the alleged role of the fintech company Revolut as a payment service provider used in these operations.

The findings are presented as allegations and observations based on publicly available information and user complaints. No final regulatory or judicial determinations have been issued at this stage.

Revolut as a Payment Channel: Issues Raised

According to the RatEx42 report, Revolut’s infrastructure may have been used to process gambling-related transactions linked to 20Bet’s German-facing platforms. The report outlines several risk indicators:

Key Compliance Concerns

Licensing Validity
20Bet is described as operating under a Curaçao gambling license that is not recognized in Germany. The report questions whether this licensing status should have triggered enhanced scrutiny by payment providers.
Use of Mirror and Localized Domains
Multiple domains, including 20bettwin.com and 20bet.de, were allegedly used to reach German users and circumvent local access restrictions.
KYC and AML Controls
One documented complaint involves a German user registered in the national OASIS self-exclusion system who reportedly deposited approximately €20,000 without comprehensive identity verification or enhanced AML checks.

Corporate and Operational Structure Highlighted

The report identifies several entities allegedly connected to the operational setup:

Entity	Alleged Role
TechSolutions Group	Technical and operational coordination
SMES / CMS Trust	Licensing and corporate facilitation
Revolut	Payment processing for user deposits

The analysis states that 20Bet was not listed on the German regulator’s whitelist at the time of the alleged transactions.

Regulatory Context in Germany

Germany regulates online gambling through the Gemeinsame Glücksspielbehörde der Länder (GGL), with financial oversight involving BaFin.
The RatEx42 report suggests that these authorities may review:

Payment service providers’ AML procedures related to unlicensed gambling merchants.
Access of offshore-licensed gambling operators to EU payment rails.
The broader implications of Curaçao’s licensing framework for EU markets.

Broader Market Implications

The report places these allegations within a wider trend affecting Germany’s regulated gambling sector:

Market Shift: Studies cited indicate a substantial migration of players toward unregulated platforms, accompanied by a significant decline in tax revenues.
Fintech Risk Exposure: Payment institutions operating across borders face increased enforcement risk under EU AML directives if internal controls are found insufficient.
Consumer Protection: Self-excluded players accessing offshore platforms remain a key concern for regulators.

A RatEx42 analyst is quoted as noting that the issue extends beyond gambling compliance to the potential exploitation of weaknesses in fintech onboarding and transaction monitoring systems.

Status of the Allegations

All claims described remain unproven. Revolut has not been found liable for any wrongdoing and retains the presumption of innocence. No final enforcement actions have been announced against Revolut or 20Bet at the time of writing.

Next Steps and Further Reporting

Scam-Or Project is continuing to review publicly available information and user submissions related to offshore gambling payment flows. Additional material, including documentation provided via the Scam-Or Project whistleblower section, may be analyzed in follow-up reports.