Contiant as an Open Banking Intermediary: How Bulgarian Middleware Channels Illegal Casino Payments via Yapily

Compliance Review Date: December 16, 2025

This article examines the operational role of Contiant Ltd, a Bulgaria-registered technology company that has positioned itself as an Open Banking intermediary for offshore gambling operators. Available evidence shows that Contiant plays a central role in routing payment flows from restricted jurisdictions—particularly the Netherlands—into illegal online casinos by utilizing the regulated Open Banking framework of Yapily Connect UAB.

1. Contiant Ltd: Corporate Setup and Declared Function

Contiant Ltd promotes its services as Open Banking solutions tailored to industries with elevated regulatory risk, including iGaming, Forex, and Crypto-related businesses.

Company background

• Legal name: Contiant Ltd
• Registration number: UIC / Tax No. 207006641
• Jurisdiction: Bulgaria
• Registered location: Sofia

There is no indication that Contiant holds an independent payment or electronic money license. Instead, its legal documentation consistently frames the company as a technical facilitator, responsible for software integration, payment interfaces, and implementation services. The execution of payments and access to customer funds are fully delegated to licensed third-party providers.

2. Yapily’s Role as the Licensed Payment Executor

A defining feature of Contiant’s operating model is its reliance on Yapily, a regulated Open Banking provider active in the UK and Lithuania.

Payment flow mechanics

When a user makes a deposit at an offshore casino such as Winning.io using Contiant’s payment option:

• The transaction is initiated on paywith.contiant.com
• The interface clearly states that the service is powered by Yapily
• The actual Payment Initiation Service (PIS) is performed by Yapily Connect UAB, authorized by the Bank of Lithuania
• The user must approve the payment through their own bank or fintech application

In this structure, Contiant never directly touches the funds but acts as the front-end access layer to Yapily’s regulated infrastructure.

3. Compliance Gap Created by Technical Intermediation

By positioning itself as a purely technical intermediary, Contiant creates a separation between licensed payment rails and illegal casino operators. While Yapily does not contract directly with offshore gambling platforms, its infrastructure is nonetheless used to settle transactions that represent gambling deposits to unlicensed operators.

The scale and consistency of these flows suggest more than isolated misuse. Either partner oversight mechanisms are ineffective, or high-risk activity is being tolerated through reliance on Contiant as a buffer layer.

4. Traffic Data and High-Risk Market Focus

Traffic analysis indicates that Contiant’s services are almost exclusively aligned with offshore gambling traffic.

Key observations

• Referral traffic: Virtually all inbound visits to paywith.contiant.com originate from unlicensed casino brands, including Winning.io, LuckyWins, Skyhills, Epicbet, Shakebet, and WBetz
• Geographic origin: Over 95% of users are located in the Netherlands, a market subject to strict enforcement by the Dutch gambling regulator (KSA)
• Bank connections: Outgoing links frequently lead to ING, Rabobank, Revolut, and KBC, confirming the facilitation of direct bank-to-casino payments

This traffic composition shows that Contiant is not serving a broad Open Banking customer base but rather a narrow, high-risk gambling segment.

5. Individuals Associated with Contiant

Publicly available records identify the following individuals as founders and executives of Contiant:

• Ivo Dimitrov — Co-Founder and Chief Executive Officer
• Dimitar Kostov — Co-Founder and Chief Technology Officer
• George Matev — Co-Founder and Partner

6. Revolut and the “Open Banking Game” Structure

The transaction model commonly described as the “Open Banking Game” illustrates how Revolut’s Open Banking APIs are ultimately used to fund illegal gambling deposits without Revolut having a direct contractual relationship with offshore casinos.

Layered payment chain

1. Offshore casino integrates Contiant
2. Contiant routes transactions through Yapily Connect UAB
3. Yapily connects to oba.revolut.com
4. Funds are debited from the player’s Revolut account

Documented player journeys

Test transactions conducted with Winning.io show users selecting instant banking or Revolut, followed by redirection to paywith.contiant.com, presentation of a Yapily authorization screen, and final payment approval within the Revolut environment. Similar flows have been identified for LuckyWins and other casinos using Contiant. A broader breakdown of Winning.io’s payment infrastructure, including its use of layered intermediaries and shadow banking techniques, has been documented in a separate investigation by Scam-Or Project.

7. Risk Assessment and Regulatory Implications

This layered setup allows regulated institutions to process payment volumes economically linked to illegal gambling while maintaining contractual distance from the operators themselves.

However, from an AML/CTF and transaction-monitoring perspective:

• Revolut remains responsible for oversight of outgoing payments and API access,
• Yapily bears responsibility for partner governance and risk monitoring,
• Contiant operates as the enabling technical intermediary.

The combination of persistent high-volume transactions, casino-exclusive traffic, and concentration in a prohibited market such as the Netherlands constitutes a clear high-risk profile that would normally justify enhanced due diligence, counterparty restrictions, or termination.

Summary Overview: Contiant Ltd

Whistleblower Information

Are you employed by Yapily, Contiant, or a connected payment provider? Do you have insight into onboarding procedures, monitoring practices, or risk reviews related to offshore casino clients?

Information can be submitted securely and confidentially via the Scam-Or Project whistleblower section.