Why the Web-Licensing Structure of a UK EMI Requires Closer Examination

A recent review by Scam-Or Project of the SENDS / Smartflow structure has revealed an additional layer that deepens existing compliance concerns around the UK-based EMI. Several SENDS website pages explicitly state that the platform is owned by GANGA PAY LTD and is only used by Smartflow Payments Limited under a Software License Agreement dated 01/05/2025.

While GANGA PAY is an active UK-registered entity, its Companies House profile identifies it as an IT and web-services business—not an FCA-authorised payment institution. At the same time, Smartflow’s 2024 financials indicate rapid expansion in acquiring revenues, while whistleblower materials continue to associate SENDS with merchant networks allegedly linked to offshore casino payment flows.

Although this structure does not constitute proof of misconduct, when viewed alongside the public background of Alona Shevtsova, references to ESBU investigations, and the recent appointment of a Ukrainian controller at GANGA PAY, it raises substantial questions around outsourcing, governance, and AML risk exposure.

Key Findings

• Website Ownership Structure
  SENDS’ official pages confirm that the platform is owned by GANGA PAY LTD, with Smartflow Payments Limited operating it under a licensing agreement dated 01/05/2025.
• GANGA PAY’s Business Profile
  According to Companies House, GANGA PAY operates under SIC classifications related to:
• IT consultancy
• Data processing and hosting
• Web portals
• Advertising services
  It is not listed as a regulated EMI.
• Change of Control at GANGA PAY
  Anna Borodenko, a Ukrainian national residing in Ukraine, became director on 13 February 2026. Prior directors resigned in October 2024 and February 2026.
• Smartflow’s Financial Expansion
  2024 financial highlights:
• Turnover: €23,969,696
• Net profit: €1,473,734
• Cash reserves: €7,074,469
• Merchant liabilities: €11,301,172
  Revenue is overwhelmingly driven by acquiring fees (€23,933,239), with minimal contribution from e-money operations.
• Ownership and Background Context
  Alona Shevtsova is listed as the sole active PSC of Smartflow (75%+ ownership). Public ESBU disclosures describe a scheme involving illegal casino payments using miscoding and multiple controlled entities.

What the GANGA PAY Licensing Structure Implies

The licensing arrangement effectively separates the regulated EMI (Smartflow) from the digital interface used by customers. According to SENDS disclosures:

• GANGA PAY owns the website and underlying infrastructure
• Smartflow operates it under license

Such arrangements are not uncommon in fintech. However, the key compliance issue lies in functional control:

Critical Compliance Considerations

• Who controls onboarding and customer journeys?
• Where are transaction monitoring and AML controls executed?
• Who owns and processes regulated data flows?

If core operational functions are handled by a non-regulated entity, the EMI must still demonstrate:

• Full regulatory control
• Audit rights and oversight
• Operational resilience
• Accountability to the FCA

This turns the structure into a governance and outsourcing risk issue, not merely a technical setup.

Risk Classification

The cyberfinance rating platform RatEx42 has classified SENDS as:

RED – Critical Risk

This rating is based on:

• Alleged involvement in payment flows linked to illegal casinos
• Limited transparency in governance
• Questionable compliance processes

Who Is Anna Borodenko?

Public information on Anna Borodenko remains limited. Verified data shows:

• Ukrainian nationality
• Residence: Ukraine
• Appointed director of GANGA PAY on 13 February 2026

There is no widely documented track record linking her to regulated payments institutions. While this alone proves nothing, within an already sensitive structure it increases the importance of:

• Source-of-funds verification
• Business rationale for ownership change
• Governance transparency

Governance History of GANGA PAY

Frequent changes in control are not inherently improper but represent a relevant governance signal.

Smartflow’s 2024 Growth and Risk Implications

Smartflow’s rapid growth significantly alters its risk profile:

• Revenue increased from €7.7M (2023) to €23.97M (2024)
• Business model heavily reliant on merchant acquiring
• €11.3M owed to merchants

This is no longer a marginal operator. It is a scaled acquiring platform, meaning:

• Control over onboarding and merchant flows becomes critical
• Any ambiguity in infrastructure ownership becomes a material AML concern

The Shevtsova Context

The ownership structure adds further sensitivity:

• Alona Shevtsova holds 75%+ control of Smartflow (Scam-Or Project Report)
• Public ESBU materials reference illegal casino fund flows via miscoding schemes

While no direct link is proven between Smartflow and such activity, the broader context increases regulatory scrutiny.

Additionally:

• Smartflow transferred money-transfer activities from IFX Payments Limited to PayrNet Limited (May 2025)
• Financial statements reference reliance on licensed payment software

This reinforces dependency on external infrastructure and partnerships.

Compliance Assessment

Key Issue: Functional Boundary

The central compliance question is not whether GANGA PAY is regulated, but:

Where does regulated activity end, and outsourced technology begin?

Two Possible Scenarios

Ownership and Control Concerns

• Smartflow controlled by Alona Shevtsova (75%+)
• GANGA PAY controlled by Anna Borodenko (since Feb 2026)
• Documented turnover in GANGA PAY leadership

This combination creates a heightened-risk structure, requiring scrutiny of:

• Ownership links
• Source of funds
• Operational dependencies
• Regulatory disclosures

Sanctions & Investigation Context

• Smartflow / SENDS and Alona Shevtsova appear in OpenSanctions-related screening contexts
• Shevtsova is publicly linked to Ukrainian sanctions and ESBU investigations

While inclusion does not establish wrongdoing, it is a material compliance signal requiring:

• Enhanced due diligence
• Close monitoring of related-party structures
• Review of merchant-acquiring exposure

Key Compliance Questions

Regulators and counterparties should focus on:

1. What exactly is licensed by GANGA PAY to Smartflow?
2. Does GANGA PAY influence onboarding, merchant acquisition, or data flows?
3. Was the FCA notified about this outsourcing arrangement?
4. What due diligence was conducted when Anna Borodenko assumed control?
5. Are all regulated decisions (AML, MCC classification, monitoring) fully controlled by Smartflow?

Summary Table

Whistleblower Call

Scam-Or Project invites insiders, former employees, auditors, compliance professionals, and partners with knowledge related to:

• Smartflow Payments Limited / SENDS
• GANGA PAY LTD
• Anna Borodenko
• Alona Shevtsova
• Merchant onboarding systems
• Payment infrastructure and licensing arrangements

to submit information via the Scam-Or Project whistleblower section.

Priority Materials

• Software License Agreement (01/05/2025)
• Documentation of licensed infrastructure
• Merchant onboarding and MCC classification records
• AML and transaction-monitoring data
• Governance and ownership records related to February 2026 control changes