SoftSwiss Update: RevDuck Network Reveals a Coordinated “Corporate Shell Game” and Affilka-Driven Illegal Casino Operations

A recent whistleblower submission to Scam-Or Project sheds new light on how the RevDuck affiliate network—operating the casino brands Holyluck, Trueluck, and Kokobet—allegedly deploys rotating Costa Rican shell companies while relying on SoftSwiss’s Affilka platform to continue targeting Dutch players in defiance of KSA enforcement actions.

The evidence reinforces Scam-Or Project’s findings from January 24, which outlined SoftSwiss’s role as a centralized technology and payment infrastructure provider that enables offshore casino groups to obscure Ultimate Beneficial Owners (UBOs), bypass regulatory barriers, and continue monetizing restricted EU markets through corporate layering and geo-evasion techniques.

Key Findings at a Glance

• Whistleblower allegation: RevDuck-operated casinos systematically rotate Costa Rican “Sociedad de Responsabilidad Limitada” (SRL) entities depending on visitor geography, while SoftSwiss tooling supports a sustained compliance evasion strategy.
• KSA enforcement reference: The Dutch regulator Kansspelautoriteit (KSA) issued a penalty payment order (last onder dwangsom) against the operator of Booms.bet, with a maximum financial exposure of €840,000.
• Regulatory footprint overlap: Trueluck.com lists “SOCIEDAD DE RESPONSABILIDAD LIMITADA” Reg. No. 3-102-903325 in its footer—the same Costa Rican registration number cited by KSA in the Booms.bet enforcement action, linked to Sapphire Summit SRL.
• Observed geo-redirects: Accessing Holyluck.com resulted in redirection to Holyluck2.com, where Gem Limitada (Costa Rica) appears as the disclosed operator.
• Market targeting indicators: RevDuck’s own promotional materials include testimonials positioning “TrueLuck Casino” as focused on the Dutch market and “powered by RevDuck Partners.”
• SoftSwiss platform context: “Affilka by SOFTSWISS” advertises integrated payment and affiliate-management capabilities. SoftSwiss also references an MGA B2B authorization pathway through Stable Aggregator Limited.

The RevDuck Model: Corporate Layering and Geo-Based Evasion

Following Scam-Or Project’s January 24, 2026 investigation into SoftSwiss’s alleged function as an unlicensed payment and technology hub for offshore casino clusters, a whistleblower dossier has now validated those conclusions through a detailed analysis of the RevDuck affiliate network.

According to the submission, RevDuck employs a classic “corporate shell game” by rotating Costa Rican legal entities to complicate oversight by regulators, banks, and payment processors.

When Holyluck.com is accessed from a Dutch IP address, users are redirected to Holyluck2.com, which identifies Gem Limitada (Costa Rica) as the operator. In contrast, non-Dutch visitors are shown Zephyr Holding Sociedad de Responsabilidad Limitada (Costa Rica, registration 3-102-926727). Earlier versions of the platform—such as Holyluck.com/de—referenced Yakadea Sociedad de Responsabilidad Limitada, demonstrating a recurring pattern of entity substitution.

This structure closely mirrors that of Booms.bet, which was fined €840,000 by KSA in January 2026. In that case, the regulator identified the operator as a Costa Rican SRL with registration number 3-102-903325—the same registration number now appearing in Trueluck Casino disclosures. The entity behind both cases: Sapphire Summit SRL.

SoftSwiss and Affilka: The Operational Backbone

Multiple affiliate-industry sources confirm that RevDuck operates on the Affilka platform provided by SoftSwiss. Affilka functions as the core system for affiliate tracking, reporting, and commission payments and is marketed as part of SoftSwiss’s integrated ecosystem, alongside its casino platform, game aggregator, and payment orchestration layer.

The Affilka website (www.affilka.com) states that the product originated as a SoftSwiss division and is now operated as a standalone brand by Zellero Limited, registered in Cyprus (https://affilka.com/privacy-policy/).

Public statements by RevDuck suggest involvement that goes beyond passive affiliate marketing. In a June 2025 post on the Affiliate Guard Dog forum titled “Online Casino Kansspelautoriteit: A System Designed to Fail,” the official RevDuck account wrote:
“For example, a typical offshore project from RevDuck, which does not have a KSA license, offers…”

This phrasing implies operational ownership and control over unlicensed casino projects, rather than mere third-party promotion.

RevDuck also openly markets its brands as “safer offshore alternatives” to KSA-licensed casinos, actively criticizing the Dutch regulator and directing Dutch players toward unlicensed platforms. This positions SoftSwiss, via Affilka, as the technology provider supporting a network that explicitly targets restricted jurisdictions.

Active Targeting of the Dutch Market

Despite nominal compliance disclaimers, the RevDuck ecosystem is engineered specifically for Dutch users:

• Trueluck Casino is promoted on Dutch-language portals such as trueluckcasinonl.com and trueluck-app.com as “the best online casino in the Netherlands,” featuring full Dutch localization and payment options including Visa, Mastercard, bank transfer, Revolut, and Bitcoin.
• Dutch review websites acknowledge that Trueluck lacks a KSA license and operates illegally under Dutch law, yet remains accessible to players in the Netherlands.
• Holyluck uses Dutch URL paths such as /inloggen/ and deploys holyluck2.com as a geo-evasion mirror when Dutch connections reach the primary domain.
• Affiliate materials within the RevDuck network explicitly describe Trueluck as “tailored to Dutch preferences” and “committed to serving the Dutch market.”

KSA has repeatedly imposed €840,000 fines on offshore operators targeting the Netherlands, including Booms.bet in January 2026, citing Costa Rican Sapphire Summit SRL structures as a recurring vehicle for illegal offerings.

Payment Infrastructure Consistency

Although the whistleblower submission focuses primarily on corporate structuring and regulatory avoidance, payment patterns associated with SoftSwiss-powered clusters remain consistent:

• Affiliate sources list CoinsPaid as a payout option for RevDuck affiliates, aligning with SoftSwiss’s documented connections to the crypto processor Dream Finance OÜ.
• Trueluck’s Dutch-facing pages advertise Visa, Mastercard, bank transfer, Bitcoin, and Revolut—matching the standard SoftSwiss cashier configuration observed across Dama N.V., Hollycorn N.V., Stable Tech N.V., and Novatrix SRL brands.
• The repetition of identical payment rails—crypto (CoinsPaid/CryptoProcessing), open banking (Contiant/Yapily), instant banking (Perspecteev/ChainValley), and e-wallets (MiFinity, Jeton)—across allegedly independent operators suggests centralized payment orchestration rather than isolated B2B software provision.

Compliance Analysis

The RevDuck case significantly strengthens Scam-Or Project’s central assessment: SoftSwiss does not function as a neutral technology supplier but as a pivotal technology, affiliate, and payment hub enabling offshore casino networks to design, promote, and monetize illegal gambling offers within regulated EU markets.

Key Risk Indicators

• Repeated use of rotating Costa Rican shell entities (Zephyr, Gem, Sapphire, Yakadea) following the same pattern as KSA-sanctioned Booms.bet (SRL 3-102-903325).
• Confirmation that Affilka by SoftSwiss serves as RevDuck’s operational platform.
• Public admissions that RevDuck operates “offshore projects” and promotes alternatives to KSA-licensed casinos.
• Systematic Dutch localization and geo-evasion tactics, including mirror domains and Dutch-language URL structures.
• Dynamic switching of legal entities based on visitor IP—a classic money-laundering technique known as “layering.”

SoftSwiss Network Overview

Conclusion and Call for Evidence

The RevDuck whistleblower submission demonstrates that SoftSwiss, through Affilka and its broader infrastructure, is structurally embedded in the mechanisms enabling illegal offshore casinos to reach Dutch players. The repeated use of Costa Rican Sapphire Summit SRL (3-102-903325) across Booms.bet, Holyluck, and Trueluck highlights a systematic pattern rather than isolated misconduct.

Scam-Or Project is preparing a broader intelligence report examining SoftSwiss’s role as a technology, affiliate, and payment hub for unlicensed casino networks.

We invite submissions from:

• Current or former employees of SoftSwiss, Stable Aggregator Ltd, RevDuck, Holyluck, Trueluck, Kokobet, Booms.bet, or related entities.
• Payment and compliance professionals familiar with SoftSwiss-powered casino payment routing.
• Players who have used CoinsPaid, CryptoProcessing, Contiant, Yapily, Perspecteev, ChainValley, MiFinity, Jeton, or similar processors at SoftSwiss-linked casinos.
• Documentary evidence such as contracts, onboarding files, emails, cashier screenshots, bank details, or crypto wallet data.

Submit securely via the Scam-Or Project whistleblower section.
Verified information will be used to expand ongoing investigations and, where appropriate, shared with regulators and law enforcement authorities.