Revolut, Open Banking & Offshore Casino Payments: Player Evidence Raises Fresh Compliance Questions

A customer communication reviewed by Scam-Or Project raises a significant compliance concern involving Revolut. The key issue: was a client initially informed that Mastercard chargebacks had been processed and finalized, only for Revolut later to acknowledge that no such chargebacks had ever been initiated?

Set against the backdrop of ongoing investigations into illegal offshore casino payment infrastructures, this case highlights a broader structural risk. It questions whether Revolut’s safeguards are sufficiently effective when gambling-related payments are routed through open banking providers, intermediary layers, and masked transaction descriptors.

Key Findings

• A reviewed customer exchange suggests Revolut first indicated that disputes had been submitted via Mastercard and resolved, but later admitted no chargebacks were ever filed and cases were closed internally.
• Revolut states it may block illegal gambling transactions where legally required and offers an optional “gambling block,” though this feature is disabled by default and depends on correct transaction identification.
• Revolut Business explicitly lists “gambling and quasi-cash merchants” as unsupported industries, increasing sensitivity around repeated exposure to such transactions.
• Revolut’s UK personal terms do not impose a universal ban on gambling for adults; restrictions mainly target illegal use, with specific MCC-based controls applied to accounts aged 16–17.
• The European Banking Authority (EBA) highlights elevated ML/TF risks in payment institutions, especially in sectors such as gambling and crypto, particularly where intermediaries and cross-border structures are involved.
• The Dutch regulator Ksa has confirmed it can issue binding directives to payment providers to block illegal gambling transactions, reinforcing regulatory scrutiny over payment rails.

The Player Evidence: Why It Matters

Scam-Or Project reviewed screenshots of communication between a player and Revolut regarding disputed casino-related transactions.

Initially, Revolut support reportedly stated that:

• disputes had been submitted via Mastercard,
• appropriate dispute categories were used,
• intermediary descriptors were considered,
• final outcomes had already been reached,
• and no further escalation (such as pre-arbitration) was possible.

The player then requested standard chargeback documentation, including:

• chargeback reference numbers and ARNs,
• dispute reason codes,
• submission timestamps,
• second presentment status,
• pre-arbitration details,
• and confirmation of review by Mastercard or the acquiring bank.

Following this, Revolut support allegedly clarified that:

• no chargebacks had been submitted,
• disputes were handled internally,
• and the Mastercard chargeback process had never been initiated.

This distinction is critical. A rejected scheme chargeback and a case never submitted to the scheme represent fundamentally different procedural realities and customer rights.

Revolut’s Public Position on Gambling

Revolut’s publicly available materials present a nuanced stance:

Consumer Accounts

• Optional “gambling block” can restrict gambling-related card payments.
• The feature is disabled by default upon account creation.
• Blocking depends on identifying transactions as gambling-related.
• In certain jurisdictions, Revolut enforces regulatory blacklists of illegal operators.

UK Terms

• No blanket ban on gambling for adult users.
• General prohibition applies only to illegal activities.
• MCC-based restrictions are explicitly applied to accounts for users aged 16–17.

Business Accounts

• Revolut Business prohibits cooperation with gambling and quasi-cash merchants.

Conclusion: Revolut recognizes gambling as a high-risk sector, but its controls rely heavily on transaction classification, merchant identification, and regulatory triggers—leaving gaps where payments are structurally obscured.

Why Open Banking Increases Risk

The risk landscape becomes more complex with open banking.

Revolut Bank UAB, licensed in Lithuania, provides:

• card payment execution,
• acquiring services,
• money remittance,
• payment initiation,
• account information services.

At the same time:

• Yapily Connect UAB is regulated by the Bank of Lithuania as a payment initiation provider and offers iGaming-related solutions.
• Perspecteev was identified by ACPR as an early licensed PSD2 provider for account information and payment initiation.

Risk Structure

A typical transaction chain may look like:

1. User interacts with a casino interface
2. Payment is routed via an open-banking provider
3. Bank processes a payment request with an intermediary descriptor
4. The true gambling destination is fragmented or obscured

This layered architecture creates opacity and complicates compliance monitoring—exactly the type of structure regulators consider high-risk.

Descriptor Masking and Transaction Laundering Risk

Revolut’s reliance on MCC classification—especially noted in restrictions for younger users—reveals a structural limitation.

Potential obfuscation techniques include:

• non-gambling MCC codes,
• generic payment gateway descriptors,
• substitute payees,
• marketplace-style transaction wrappers,
• open banking flows lacking merchant transparency.

Examples cited in the complaint include descriptors such as:

• MBM Ramp
• BlueOC
• Sknvrs
• TransferOp Payment Gateway Ltd

These may conceal the actual gambling nature of transactions, affecting both dispute handling and fraud classification.

Regulatory Perspective and Enforcement Risk

Revolut has already faced regulatory scrutiny:

• The Bank of Lithuania fined Revolut Bank UAB €3.5 million on 4 April 2025 for AML/CFT violations.
• Previous warnings and enforcement measures have also been recorded.

The EBA’s 2023 findings highlight:

• increased ML/TF risks in payment institutions,
• higher exposure to gambling clients,
• risks from intermediaries and cross-border structures,
• weaknesses in transaction monitoring and governance.

Key Questions Regulators May Ask

The Dutch Ksa’s enforcement powers confirm that payment providers are now central enforcement targets—not peripheral actors.

Potential Regulatory Consequences

Revolut could face scrutiny from:

• The Bank of Lithuania and EU supervisory bodies
• The European Central Bank (ECB) structures
• UK regulators such as the FCA and PRA
• National gambling regulators

The primary concern is not necessarily direct onboarding of illegal casinos, but indirect facilitation through complex payment chains.

From a regulatory standpoint, indirect exposure does not mitigate risk—it intensifies expectations for robust controls.

Scam-Or Project Preliminary Assessment

Based on available evidence, Scam-Or Project concludes:

Revolut’s exposure to offshore casino payments appears systemic rather than incidental. The issue lies in the convergence of:

• illegal gambling operators,
• open banking facilitators,
• intermediary payment descriptors,
• fragmented transaction chains,
• cross-border structures,
• and dispute handling inconsistencies.

If customers were informed that chargebacks were processed when they were not, this raises concerns not only about communication practices but also about whether underlying transaction risks were adequately assessed.

Call for Whistleblowers

If you have used Revolut in connection with offshore casinos or suspect irregularities in transaction handling, Scam-Or Project invites you to share information via the Scam-Or Project website.

We are particularly interested in:

• communications describing disputed gambling transactions,
• transaction records involving open banking providers or generic descriptors,
• cases where chargebacks were claimed to be rejected but never initiated,
• repeated deposits linked to casino payment chains despite existing controls.

Confidential submissions may help determine whether this is a customer support issue, a structural descriptor problem, or a broader compliance gap within a major European fintech ecosystem.