Holyluck Payment Trail: Whistleblower Links Card Deposits to SENDS via TAS Link Infrastructure

A whistleblower dossier reviewed by Scam-Or Project indicates that deposits made to the unlicensed offshore casino Holyluck were routed through a multi-layered payment structure. This chain allegedly includes checkout.agpayer.com, a PayLink node associated with TAS Link in Ukraine, and Smartflow Payments Limited — the UK-based electronic money institution operating under the SENDS brand and authorized by the FCA.

The dossier contains screenshots, transaction records, and supporting correspondence. Below is a structured breakdown of the findings and their implications.

Key Findings

• Holyluck Casino Network
  The operation appears to be linked to Costa Rica-registered Gem Limitada, using multiple domains such as holyluck.com, holyluck2.com, and holyluck3.com.
• Identified Acquirer
  Newly reviewed communication shows TAS Link directing the complainant to SENDS / Smartflow Payments Limited as the acquiring institution.
• MCC 5816 in Transaction Data
  Card transaction evidence includes:
• London GBR descriptor
• ECOM transaction type
• Tokenization enabled
• Merchant Category Code 5816
  This supports allegations of potential miscoding.
• Quicko as Payout Channel
  A separate screenshot references quickowallet TarnowskieGo POL, reinforcing claims that Quicko sp. z o.o. handled payouts.
• Regulatory Context
• Smartflow Payments Limited is FCA-authorized (FRN 900873)
• Companies House lists Alona Shevtsova as the person with significant control
• Ukrainian authorities have previously sanctioned Shevtsova in connection with a UAH 5 billion miscoding case involving illegal casinos
• Multi-Domain Infrastructure
  The use of multiple Holyluck domains suggests a networked merchant setup rather than isolated payment activity.

The Acquirer Becomes Visible

A critical development in this case is the identification of the acquiring party.

An email reviewed by Scam-Or Project shows that TAS Link LLC informed the complainant that the case had been escalated to the acquirer and advised contacting [email protected] for further inquiries. This shifts the narrative from a theoretical routing chain to a clearly identified UK-regulated EMI — Smartflow Payments Limited (SENDS).

Public records confirm:

• Authorization under FCA regulations
• Registration as an Electronic Money Institution
• Control by Alona Shevtsova

This significantly strengthens the evidentiary structure of the case.

Transaction Evidence Overview

The whistleblower dossier includes the following transaction indicators:

• Debit transaction: 50.00 EUR
• Descriptor: London GBR
• Type: ECOM
• Tokenization: Yes
• MCC: 5816

Additional evidence includes:

• Payout reference linked to Quicko in Poland
• TAS Link communication identifying SENDS as acquirer

Taken together, these elements establish a structured payment chain:

Deposit → Routing → Acquiring → Payout

Why MCC 5816 Raises Concerns

The appearance of MCC 5816 is central to compliance concerns.

The whistleblower claims that gambling-related transactions were presented as lower-risk digital goods. According to Mastercard guidelines:

• Gambling and digital goods fall under distinct MCC categories
• Acquirers must assign accurate MCC codes

If the transaction data reflects actual processing, this may indicate MCC masking or miscoding, rather than a simple classification error.

Summary Table: Alleged Payment Chain

TAS Link’s Role Clarified

Earlier evidence pointed to TAS Link as part of the routing infrastructure. New documentation refines this role.

TAS Link:

• Operates PayLink, an e-commerce payment platform
• Supports card payments, Apple Pay, Google Pay, and transfers
• Acts as a Mastercard Member Service Provider and Visa Third Party Agent

While not confirmed as the acquirer, TAS Link demonstrated the ability to identify the acquiring institution — and explicitly named SENDS. This positions TAS Link as a confirmed intermediary in the transaction chain (source).

Smartflow, SENDS, and Alona Shevtsova

Records from Companies House confirm that Smartflow Payments Limited is active and controlled by Alona Shevtsova.

Additional context:

• SENDS publicly states FCA authorization (FRN 900873)
• Ukrainian authorities have linked Shevtsova to a large-scale miscoding case
• The Economic Security Bureau of Ukraine alleged use of fake transaction descriptions to disguise gambling flows
• The National Bank of Ukraine revoked IBOX Bank’s license due to AML/CFT violations

This background adds regulatory weight to the current case (source).

The Quicko Connection

The payout side of the transaction appears linked to Quicko sp. z o.o.

Supporting facts:

• Screenshot reference: quickowallet TarnowskieGo POL
• Polish regulator KNF revoked Quicko’s authorization on 21 January 2026
• Decision included immediate enforcement and required operational wind-down by 30 April 2026

This strengthens the claim that Quicko functioned as a payout endpoint within the payment flow.

Conclusion

The Holyluck dossier presents a detailed and structured view of a cross-border payment chain involving:

• A gambling-facing merchant network
• Routing infrastructure (agpayer + PayLink)
• A UK-regulated acquirer (SENDS / Smartflow Payments Limited)
• A Polish payout provider (Quicko)

While the available evidence does not prove deliberate misconduct by any specific party, it highlights a non-random, multi-jurisdictional payment architecture. Such structures are commonly associated with:

• Merchant category manipulation
• Transaction laundering risks
• Fragmented compliance oversight

The involvement of regulated entities and previously sanctioned individuals increases the importance of regulatory scrutiny.

Read more on checkout.agpayer.com and other anonymous payment gateways here.

Ongoing Investigation & Whistleblower Appeal

Scam-Or Project continues to examine whether the Holyluck case represents an isolated incident or part of a broader processing pattern.

Individuals with relevant information — including insiders, compliance professionals, payment operators, and merchants — are encouraged to submit evidence via the Scam-Or Project whistleblower section.

Relevant areas of interest include:

• SENDS / Smartflow Payments Limited
• TAS Link / PayLink infrastructure
• checkout.agpayer.com
• Quicko payment flows
• MCC 5816-coded transactions linked to gambling

Further updates will follow as additional evidence emerges.