Revolut and the Offshore Gambling Network: A Growing Compliance Concern

Executive Summary

An independent investigation by the Scam-Or Project into the offshore gambling ecosystem reveals potential regulatory violations involving Revolut.
Tests conducted on unlicensed casinos — Donbet and Rolletto — showed seamless deposits and account setups for users from the EU and UK, despite these platforms lacking any valid local authorizations.

Both casinos are part of the Santeda network, with Santeda International Limited (Cyprus) managing payment processing and UtPay (utpay.io) providing the gateway infrastructure. During several controlled test deposits, Revolut (Revolut Pay) appeared as a live payment option — a red flag under both UK and EU anti-gambling regulations and Revolut’s own compliance policies.

The Scam-Or Project is calling on users and insiders to share evidence related to Revolut’s role in facilitating payments for unlicensed gambling operators.

Key Findings

Investigation Narrative

Independent investigators, whose findings were reviewed by the Scam-Or Project, registered and deposited at Donbet and Rolletto using IPs from various EU and UK regions.
Neither site enforced effective geolocation restrictions, allowing users from prohibited jurisdictions to register and gamble freely.

Public filings reveal that Santeda International B.V. (Curaçao) manages both brands, while Santeda International Limited (Cyprus) operates as the payment handler.
During deposit attempts, payment processing was directed through UtPay, a gateway embedding widgets for various payment channels — including Revolut Pay.

Deposits using Revolut were successfully completed in all test cases, contradicting Revolut’s advertised compliance safeguards and raising questions about its merchant-onboarding protocols.

Legal and Compliance Implications

1. UK Regulatory Conflict

The UK Gambling Commission explicitly prohibits financial institutions from processing payments for unlicensed gambling entities. Section 33 of the Gambling Act 2005 criminalizes this conduct. Revolut’s facilitation of payments to unlicensed brands thus represents a potential breach of UK law and a failure of internal controls.

2. Revolut’s Own Controls

Revolut markets a Gambling Block tool meant to prevent transfers to unauthorized operators. However, our investigation shows that this block does not consistently apply to payments routed via third-party gateways such as UtPay.

3. Broader Ecosystem Risks

History has shown that major card networks and payment intermediaries can inadvertently process illicit transactions when onboarding procedures and geofencing fail.
This pattern underscores the urgent need for PSPs, acquirers, and wallet providers to tighten Know-Your-Merchant (KYM) and jurisdictional screening measures.

Extended Analysis

Operator Structure

• Donbet and Rolletto list Santeda International B.V. (Curaçao eGaming) as the licensed operator.

• Corporate filings identify Santeda International Limited (Cyprus, HE406761) as part of the payment chain.
  (Source: i-cyprus.com)

Payment Gateway: UtPay

• UtPay.io markets a multi-rail checkout widget integrating cards, wallets, and crypto rails.

• Such orchestration layers can obscure risk exposure, allowing high-risk merchants to blend in with compliant traffic.

Revolut’s Exposure

• Revolut Pay serves as a one-click checkout solution for Revolut and non-Revolut customers.

• If Revolut Pay is visible on gambling sites operating illegally in the UK or EU, both Revolut and its acquiring partners face potential liability under AML/CFT and consumer protection frameworks. (Source)

Regulatory Context

Revolut, currently transitioning from a restricted UK banking licence, remains under close scrutiny by regulators for its risk management and customer protection policies.
Engagement with unlicensed gambling operators could hinder its progress toward full UK banking authorisation.

Recommendations & Actions

For Regulators

• Audit Revolut’s and UtPay’s merchant-onboarding and transaction controls for gambling-related MCCs tied to Santeda-linked operators. (Source)

• Cross-reference with UKGC and EU national blacklists. (Source)

For Revolut and Partners

• Conduct an internal review of all checkout placements where Revolut Pay is exposed on unlicensed platforms. (Source)

• Align internal blocking mechanisms with the company’s published compliance commitments.

• Submit Suspicious Activity Reports (SARs) and remediate past exposure where necessary.

For Consumers

If you have used Revolut to deposit funds on Donbet or Rolletto, collect and preserve:

• Screenshots and receipts

• Revolut statements showing merchant descriptors

• UtPay transaction IDs or widget logs

Then, file a complaint with your national gambling regulator and payment provider.

Call for Whistleblowers

Were you offered Revolut as a payment method on Donbet, Rolletto, or other offshore casinos?
Do you work (or have worked) for Revolut, UtPay, or a related acquiring partner with inside knowledge of merchant onboarding or blocking lists?

Submit documentation — including screenshots, confirmation emails, or transaction logs — securely and confidentially via Scam-Or Project website.
Your evidence may help uncover systemic payment compliance failures affecting consumers across Europe.