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Compliance Dossier

Compliance Dossier

The Role of Irish-Licensed Zentoria Limited in Supporting NovaForge’s Offshore Casino Network

Recent investigative findings concerning the NovaForge Group and its ACMA-blocked casino brand Spinsy have triggered further disclosures from affected players. Newly obtained documentation suggests that Irish-incorporated Zentoria Limited may be acting as an intermediary payment channel for another NovaForge offshore brand, Robycasino.

According to transaction records shared by a whistleblower, deposits made to Robycasino were recorded on bank statements under the descriptor:

“Spinsopotamia.com Dublin.”

Despite this activity, Zentoria Limited holds an officially recognized Irish Remote Bookmaker’s Licence. The following analysis examines the operational structure, key individuals—Mykhaylo Pavlenko and Alina Vavilova—and the broader compliance implications surrounding Zentoria Limited.

Whistleblower Evidence and Descriptor Analysis

Scam-Or Project continues to analyze payment infrastructures associated with offshore gambling operators. A player impacted by NovaForge Group operations submitted financial statements showing multiple deposits to Robycasino.com.

Instead of displaying the expected merchant reference, the transactions appeared as:

Spinsopotamia.com Dublin

Corporate registry data and domain intelligence confirm that Spinsopotamia.com is connected to Zentoria Limited, an Irish company incorporated on 04 April 2024 and registered in Dublin 4.

This discovery points toward the existence of a structured European payment mechanism that may serve offshore gambling brands through licensed EU infrastructure.

Core Findings

Payment Routing Mechanism

Deposits made to Robycasino are reportedly processed via an Irish merchant account, appearing on bank statements under the descriptor “Spinsopotamia.com Dublin”.

Corporate Entity Identified

Zentoria Limited (Company Number 761150) is formally registered in Ireland and lists gambling and betting activities ([9200]) as its principal business category.

Licensing Status

Zentoria Limited maintains an active Remote Bookmaker’s Licence issued by the Irish Revenue Commissioners.

Responsible Parties

Irish corporate records identify Mykhaylo Pavlenko and Alina Vavilova as directors and decision-makers for Zentoria Limited.

Descriptor Masking Practices

The use of an alternative domain name in billing records suggests potential descriptor substitution—an approach often examined in compliance reviews as a possible form of transaction laundering.

Structural Compliance Assessment

Zentoria Limited presents a dual-layered operational profile. On the surface, it is an Irish-licensed bookmaker with a registered address at:

3rd Floor, Waterloo Exchange, Waterloo Road, Dublin 4, Ireland

Holding a Remote Bookmaker’s Licence enables access to EU banking institutions and merchant acquiring services under recognized regulatory oversight.

However, documentation provided by whistleblowers indicates that Zentoria may not be functioning exclusively as an independent bookmaker. Instead, its licensed merchant infrastructure may be used to process transactions initiated on offshore platforms operated by NovaForge Group.

Alleged Processing Flow

  1. A player deposits funds on Robycasino.
  2. The payment request is redirected to Zentoria Limited’s merchant account.
  3. The transaction appears as “Spinsopotamia.com Dublin”.
  4. The issuing bank processes the payment as an Irish-licensed betting transaction.
  5. Funds are transferred onward within the NovaForge network.

If verified, such routing arrangements would raise compliance concerns under Irish AML regulations and director probity standards.

The Licensed Front-End Model

Global card networks, including Visa and Mastercard, deploy automated controls designed to block transactions to blacklisted offshore gambling operators such as Robycasino or Spinsy.

A licensed EU entity like Zentoria Limited can obtain merchant facilities by presenting its Remote Bookmaker’s Licence and regulatory credentials. Once a merchant account is granted:

  • Transactions are processed under the descriptor of the licensed entity.
  • The offshore casino brand does not appear in the payment record.
  • Automated risk filters may not trigger.

In this configuration, Spinsopotamia.com functions as the visible licensed merchant while backend integrations potentially connect offshore casino platforms to the Irish account.

Transaction Mapping Overview

Phase Operational Description
1 Player deposits funds via Robycasino
2 Payment is routed to Zentoria Limited in Dublin
3 Billing descriptor shows Spinsopotamia.com Dublin
4 Bank authorizes transaction based on Irish licence
5 Funds are distributed within NovaForge’s offshore structure

This layered payment model enables offshore brands to benefit from EU merchant access while distancing the end-user transaction from the original gambling domain.

Corporate Profile: Zentoria Limited

Category Information
Entity Name Zentoria Limited
CRO Number 761150
Incorporation Date 04 April 2024
Registered Address 3rd Floor, Waterloo Exchange, Waterloo Road, Dublin 4, Ireland
Declared Activity [9200] Gambling and Betting Activities
Directors Mykhaylo Pavlenko, Alina Vavilova
Known Descriptor Spinsopotamia.com Dublin
Linked Network NovaForge Group (Robycasino, Spinsy)

Request for Additional Documentation

Scam-Or Project is continuing its review of Zentoria Limited, Mykhaylo Pavlenko, Alina Vavilova, and the broader NovaForge Group payment ecosystem.

Relevant materials may include:

  • Bank statements listing “Spinsopotamia.com” or “Zentoria Ltd.”
  • Internal payment processor documentation.
  • Correspondence between acquiring banks and merchant accounts.
  • Industry insights from payment service providers familiar with the arrangement.

Information can be submitted securely and anonymously through the Scam-Or Project website.

Ongoing cooperation from affected players and industry insiders remains essential in clarifying the structure and compliance standing of cross-border gambling payment networks operating within EU jurisdictions.

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