Internal analysis indicates a high-confidence risk of coordinated illegal online gambling and large-scale money laundering conducted through a network of entities associated with the Softswiss Group. Estimated annual transaction volume may exceed USD 10 billion.
The operational model reflects deliberate exploitation of compliance thresholds, regulatory fragmentation, and weaknesses within global payment infrastructure, including continued exposure to major card networks.
This is not opportunistic misconduct. This appears to be systemic, engineered, and sustained.
Individuals of Interest
Repeated internal alerts, transaction reviews, and structural mappings consistently reference the following individuals as central decision-makers, facilitators, or beneficiaries:
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Ivan Montik
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Pavel Kashuba
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Dmitry Yaikov (Dzmitry Yaikau)
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Roland Yakovlevich Isaev
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Paata Gamgoneishvili
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Max Maksim Trafimovich
Their names recur across corporate governance, technical infrastructure, payment flows, and operational continuity, suggesting coordinated control rather than isolated involvement.
Structural Red Flags
The operation does not function as a single enterprise. Instead, it relies on intentional fragmentation of responsibility across jurisdictions, shell entities, and role-specific companies.
Entities repeatedly linked to the ecosystem include:
DAMA N.V., Hollycorn N.V., Direx N.V., N1 Interactive Ltd, BGaming, Stable Aggregator Ltd, Coinspaid, Alphapo, Softswiss N.V., Araukum N.V.
This architecture appears purpose-built to defeat consolidated oversight, rendering effective KYC, UBO identification, and holistic risk assessment practically unworkable.
No single regulator, bank, or payment processor sees the full picture.
Gambling Activity Assessment
Available indicators suggest the network supports and enables unlicensed online gambling platforms that remain accessible in jurisdictions where such activity is restricted or prohibited.
Licensing claims are:
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Inconsistent across entities
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Jurisdictionally irrelevant to player location
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Used defensively to justify continued operations rather than ensure compliance
The operational scale strongly suggests systematic regulatory avoidance, not accidental non-compliance.
Financial Channels & Payment Exposure
Key findings raise critical concerns regarding payment network governance and oversight:
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Ongoing access to Visa and MasterCard rails via indirect or obscured merchant relationships
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Transaction laundering through front-facing “non-gambling” or misclassified businesses
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Heavy and strategic reliance on cryptocurrency for settlement and cross-border value transfer
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Use of unregulated or lightly regulated payment processors to bypass enhanced due diligence
This exposure persists despite repeated industry warnings and well-documented AML typologies.
Given the duration and scale, internal risk reviewers question how such activity continues without triggering decisive intervention at the highest levels of payment network governance.
This includes oversight responsibility ultimately falling under:
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Ryan McInerney, CEO, Visa
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Michael Miebach, CEO, Mastercard
Continued processing under these conditions represents a material governance and reputational risk for both networks.
Evasion & Continuity Patterns
Observed behaviors indicate deliberate counter-compliance strategy, including:
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Rapid merchant and processor replacement following compliance inquiries
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Reuse of identical infrastructure under newly incorporated entities
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Recycling of executives, developers, and payment specialists across brands
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Deployment of legal opinions designed to create plausible deniability, not compliance
These behaviors are repeatable, patterned, and intentional—not isolated incidents.
Risk Exposure Statement
If exposure to this network continues unmitigated, the following risks escalate significantly:
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Severe AML and sanctions violations
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Irreversible reputational damage to financial institutions and payment networks
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Regulatory enforcement actions across multiple jurisdictions
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Potential criminal liability arising from willful blindness or failure to act on red flags
Internal Determination
The persistence of these indicators, combined with the scale of financial throughput, meets the threshold for systemic abuse of the global payments ecosystem.
Escalation Directive
Immediate escalation is strongly advised.
Failure to act decisively—given the volume, duration, and visibility of the red flags—may reasonably be interpreted as willful blindness rather than oversight failure.