Is the Lithuanian VASP Coin Sonic Being Used to Funnel Payments to Illegal Offshore Casinos?

Executive Summary

This compliance brief outlines evidence that Coin Sonic UAB, a Lithuania-registered Virtual Asset Service Provider (VASP), is facilitating fiat deposits for offshore online casinos that target EU residents without the required national licenses. The payment path observed for SlotsDynamite and SlotsAmigo—both operated by Coco Loco Holdings N.V. (Curaçao)—routes customers through several third-party domains before EUR transfers land in Coin Sonic’s account at Banking Circle. Because no crypto is involved, these activities appear to exceed the permissible scope of a VASP registration and may require a Payment Institution (PI) or Electronic Money Institution (EMI) license under PSD2.

Operators and Licensing Posture

• Operators: SlotsDynamite and SlotsAmigo, both linked to Coco Loco Holdings N.V. (Curaçao).

• License relied on: Curaçao eGaming.

• EU market access: EU member states (e.g., Germany, Italy, the Netherlands, and others) require a domestic gambling license for local access. A Curaçao license does not grant EU-wide authorization.

• User experience testing: Players from multiple EU locations can register and deposit with no geo-blocking or license checks, contradicting national prohibitions on unlicensed gambling.

Coin Sonic’s Corporate Profile and Observed Payment Flow

• Company: Coin Sonic UAB (reg. code 306200594), founded Dec 2022 in Lithuania.

• Platform/brand: InstaXchange (instaxchange.com).

• Regulatory status: Registered VASP in Lithuania (crypto exchange / custody / wallet). A VASP registration does not authorize fiat payment processing or e-money issuance for third parties.

Observed Flow for Fiat Casino Deposits (No Crypto Used)

1. Casino cashier redirects to secure.omerpayments.com/checkout.

2. Handoff to InstaXchange (instaxchange.com).

3. Final checkout at checkout.instantbankpayment.com (branded “Instant Bank Payment”), apparently connected to Yapily open-banking rails.

4. Payer selects their bank and initiates a SEPA transfer in EUR directly to Coin Sonic’s account at Banking Circle (German branch; IBAN: DE73202208000056199298).

5. Funds arrive as fiat, credited to the player’s casino balance; no conversion to crypto occurs.

Why this matters: These are fiat acquiring/collection activities for a third-party merchant (the casino) rather than virtual-asset services. Under PSD2 (Directive 2015/2366), such activities generally require PI/EMI authorization. Coin Sonic UAB holds no such license.

Payment Infrastructure and Compliance Gaps

• Omer Solutions (omerpayments.com / secure.omerpayments.com): a high-risk gateway marketing explicitly to verticals such as gaming and casinos. EU payment licensing for the gateway is not clearly disclosed.

• Yapily Connect UAB (Lithuania; license LB002045) and Yapily (UK): provide open-banking connectivity. Open banking acts as a technical initiation layer—it does not itself legalize merchant acquiring where the collector lacks payment licensing.

• instantbankpayment.com / checkout.instantbankpayment.com: branded checkout apparently tied to Yapily infrastructure; this indirection obscures the ultimate beneficiary and complicates traceability.

• Banking Circle S.A. (Germany/Luxembourg): a regulated banking backbone where the Coin Sonic beneficiary account is held. Banking Circle’s licensing does not transfer compliance duties away from Coin Sonic or the casinos.

Entity & Domain Matrix

Legal and Regulatory Analysis

1) Unlicensed Gambling in the EU

• SlotsDynamite and SlotsAmigo solicit EU players without member-state licensing.

• EU courts and regulators uphold the member-state licensing principle; Curaçao authorization is insufficient for EU market access.

2) VASP Scope Overreach

• A Lithuanian VASP registration covers virtual-asset activities (exchange, custody, wallet).

• Collecting fiat for third-party merchants and crediting casino balances is payment acquiring/e-money activity, generally requiring PI/EMI authorization under PSD2.

• Coin Sonic UAB appears to be acting outside its VASP remit.

3) AML/CTF Exposure

• Funding unlicensed casinos heightens ML/TF and fraud risk.

• Potential gaps under the EU 5AMLD/6AMLD and Lithuania’s AML framework include inadequate merchant due diligence, weak transaction monitoring, and deficient source-of-funds controls.

4) Consumer Protection Risks

• Players lack safeguards mandated in licensed EU environments: responsible gambling tools, legally mandated dispute resolution, payout controls, and fund safeguarding.

Transaction-Laundering Pattern (SlotsDynamite ↔ Coin Sonic)

Casino cashier → OmerPayments checkout → InstaXchange → Instant Bank Payment (Yapily-powered) → SEPA to Coin Sonic (Banking Circle IBAN) → Casino balance credited.
No crypto touches the flow; the route functions as masked fiat acquiring.

Conclusions and Next Steps

Finding: Coin Sonic UAB appears to conduct unauthorized fiat payment facilitation for offshore casinos operating illegally within EU jurisdictions. This structure benefits unlicensed operators, sidesteps EU regulatory oversight, and shifts risk to consumers and the wider financial system.

Regulatory recommendations:

• Lithuania (supervising Coin Sonic), Germany (Banking Circle branch), and other EU authorities should review Coin Sonic’s role for possible PSD2 and AML breaches.

• Banking Circle and Yapily should evaluate their indirect exposure and the sufficiency of upstream merchant due diligence in this flow.

Call for information:
Insiders and industry professionals with knowledge of Coin Sonic UAB, InstaXchange, Coco Loco Holdings N.V., or similar payment arrangements are invited to share documentation (e.g., payment instructions, transaction records, internal emails) to support supervisory reviews and protect EU consumers. Confidential submissions are welcome.