SENDS / Smartflow Payments Limited: Compliance Concerns, Sanctions Exposure, and Corporate Structuring Risks

DAREX Classification

DAREX Tier: Not applicable (applies only to digital asset service providers)

Overview

Smartflow Payments Limited, operating under the SENDS brand, is an FCA-authorized Electronic Money Institution (EMI) in the United Kingdom. Despite its regulated status, the entity is assessed as high-risk due to its ownership and structural setup.

The Ultimate Beneficial Owner (UBO), Alona Shevtsova, has been sanctioned by Ukraine’s National Security and Defense Council (NSDC). Following these sanctions, new intelligence indicates that core assets — including intellectual property, domain ownership, and platform technology — were transferred to a separate entity, GANGA PAY LTD.

This restructuring coincides with allegations linking the group to a UAH 5 billion money laundering scheme associated with illegal online gambling operations.

R42 Risk Signal

Rationale:
The RED classification reflects:

• Direct exposure to sanctions affecting the UBO
• Evidence of deliberate corporate restructuring post-sanctions
• Ongoing criminal investigations
• Separation of regulated and operational assets through licensing

The arrangement between Smartflow and GANGA PAY LTD appears consistent with asset protection strategies aimed at limiting regulatory enforcement reach.

Key Entity Data

Operational Model

SENDS provides payment services for both individuals and businesses, including:

• Multi-currency accounts with IBANs
• SEPA and SWIFT transfers
• Mass payout solutions
• Virtual Mastercard debit cards
• Online acquiring (Apple Pay, Google Pay, Visa, Mastercard integrations)

Its services target freelancers, startups, and e-commerce merchants.

Regulatory Structure vs. Operational Reality

Although Smartflow Payments Limited holds FCA authorization, the platform’s actual infrastructure is controlled by GANGA PAY LTD, which is not regulated.

This setup introduces a critical compliance gap:

• The licensed EMI does not directly own its core technology
• Platform operations rely on a Software License Agreement (May 1, 2025)
• Ownership of data, systems, and user interface sits outside the regulated perimeter

This creates a regulatory blind spot, limiting supervisory visibility.

Ownership and Management

• Alona Shevtsova – UBO (>75%), CEO, Director; founder of the LEO payment network
• Anastasiia Pervushyna – Director, MLRO (Smartflow)
• Zinaida Berezovskaya – Associated executive
• Anna Borodenko – Director and PSC of GANGA PAY LTD (identified as nominee/proxy)

Corporate Architecture

The structure demonstrates deliberate segmentation:

1. Regulated Layer

• Smartflow Payments Limited
• Holds FCA license and access to banking infrastructure

2. Asset & Technology Layer

• GANGA PAY LTD
• Owns domain, platform, and IP

3. Trigger Event (Critical Timeline)

• April 2025: UBO and Smartflow sanctioned by Ukraine NSDC
• May 1, 2025: Software License Agreement activated

This timing strongly suggests an urgent restructuring designed to isolate key assets from sanctions enforcement.

Technical and Network Links

The SENDS platform functions as an intermediary between banking systems and digital merchants.

Notably:

• GANGA PAY LTD is listed as seller for the “Official shop of the LEO team”
• This creates a direct operational link to the LEO payment system, previously shut down over similar allegations involving illegal gambling transactions

Merchant Exposure

Although publicly positioned for standard business use, investigations indicate involvement in high-risk sectors:

• Offshore gambling platforms
• Unlicensed betting operators
• Eastern European markets

A key concern is merchant miscoding, potentially used to disguise gambling-related transactions and bypass AML controls.

Enforcement and Investigations

Sanctions (April 2025)

• Imposed by Ukraine’s NSDC
• Targeted Alona Shevtsova and Electronic Payment Solutions Ltd (now Smartflow)
• Included 10-year asset freeze

Criminal Investigation

• Conducted by Ukraine’s Economic Security Bureau (ESBU)
• Focus on:
• SENDS network
• LEO payment system
• Alleged UAH 5 billion laundering operation

Detentions

• Polish authorities reportedly detained Iryna Tsyhanok, identified as a key figure in the network

Major Red Flags

• Post-sanction restructuring of core assets
• Sanctioned UBO with long-term asset freeze
• Use of virtual office address (Shelton Street, London)
• Reliance on nominee directors
• Allegations of transaction miscoding
• Direct link to LEO, a previously exposed payment system

Risk Assessment & Engagement Considerations

Before working with SENDS or any affiliated entities, counterparties should consider the following:

1. Legal Exposure Review
   Evaluate whether cooperation could conflict with sanctions imposed on the UBO.
2. Contractual Transparency
   Request full, unredacted copies of the Software License Agreement dated May 1, 2025, to clarify control over infrastructure and data.
3. Regulatory Status Check
   Verify the current FCA authorization (FRN: 900873) and review any recent supervisory actions or notices.
4. Investigation Exposure Analysis
   Assess potential risks linked to ongoing ESBU investigations and examine ties to the LEO payment network.

Update Log

• April 9, 2026: Major update — added GANGA PAY LTD structure, licensing timeline, and LEO network links
• April 9, 2026: Initial profile published following sanctions and investigation findings

Whistleblower Call

Do you have information about:

• The licensing agreement between Smartflow Payments Limited and GANGA PAY LTD?
• The role of Anna Borodenko within this structure?

Submit documents, contracts, or insider insights securely via the Scam-Or Project whistleblower section.