A new whistleblower submission to FinTelegram reveals how the RevDuck network—operating Holyluck, Trueluck, and Kokobet under rotating Costa Rican shell companies—uses SoftSwiss’s Affilka platform to systematically target the Netherlands despite KSA sanctions. The case confirms FinTelegram’s January 24 findings that SoftSwiss functions as a central technology and payment hub enabling offshore operators to evade regulators and mask Ultimate Beneficial Owners through dynamic corporate layering.
Key Facts
- Whistleblower claim: RevDuck-operated casinos allegedly rotate Costa Rican “SRL” entities by geo/location, and SoftSwiss tooling enables a “cat-and-mouse” compliance evasion model.
- KSA enforcement reference: The Dutch regulator (Kansspelautoriteit) issued a penalty payment order (last onder dwangsom) against an operator behind Booms.bet, with a maximum exposure of €840,000.
- Live footprint match: On Trueluck.com, the footer states rights belong to “SOCIEDAD DE RESPONSABILIDAD LIMITADA” Reg. No. 3-102-903325—the same registration number referenced by KSA for Booms.bet. It’s connected to Sapphire Summit SRL.
- Geo/redirect behavior observed: Holyluck.com redirected us to Holyluck2.com, which displays Gem Limitada (Costa Rica) as the owner in the footer.
- RevDuck market targeting signals: RevDuck’s own site includes testimonials describing “TrueLuck Casino” as committed to the Dutch market and “powered by Revduck Partners.”
- SoftSwiss capability context: “Affilka by SOFTSWISS” markets built-in payment processing features; SoftSwiss also publicly references an MGA B2B authorisation path via Stable Aggregator Limited.
The RevDuck Pattern: Shell Game & Geo-Evasion
Following FinTelegram’s January 24, 2026, report documenting SoftSwiss’s alleged role as an unlicensed payment hub for illegal casino networks, a detailed whistleblower dossier has confirmed these findings through analysis of the RevDuck affiliate network and its brands Holyluck, Trueluck, and Kokobet.
The submission describes a textbook “shell game” in which RevDuck rotates Costa Rican front entities to confuse regulators and payment processors. When accessing holyluck.com from a Dutch IP address, users are redirected to the mirror domain holyluck2.com, which displays ownership by Gem Limitada (Costa Rica), while international visitors see Zephyr Holding Sociedad de Responsabilidad Limitada (Costa Rica, registration 3-102-926727). Earlier iterations of the site (e.g. the German version Holyluck.com/de) cited Yakadea Sociedad de Responsabilidad Limitada, illustrating systematic entity rotation.[whistleblower submission]
This corporate layering technique directly mirrors the structure of Booms.bet, which was fined €840,000 by the Dutch gambling regulator KSA in January 2026. KSA identified Booms.bet’s operator as a Costa Rican Sociedad de Responsabilidad Limitada with registration number 3-102-903325—the exact same registration number that appears in Trueluck Casino marketing materials and regulatory disclosures. The name of the company: Sapphire Summit SRL.
SoftSwiss Integration: Affilka as Operational Backbone
Multiple affiliate industry sources confirm that RevDuck operates on the Affilka platform by SoftSwiss, describing it as the program’s core tracking, reporting, and payment infrastructure. Affilka is SoftSwiss’s proprietary affiliate management software, marketed as part of the integrated SoftSwiss ecosystem alongside its casino platform, game aggregator, and payment orchestration layer.
In the “About Us” section of Affilka (www.affilka.com) , you can read that Affilka used to be a division of SoftSwiss but is now operated as a separate brand with its own domain by Zellero Limited, registered in Cyprus.
Public statements by RevDuck reveal operational control beyond mere affiliation. In a June 2025 forum post on Affiliate Guard Dog titled “Online Casino Kansspelautoriteit: A System Designed to Fail,” the official RevDuck account writes (screenshot right): “For example, a typical offshore project from RevDuck, which does not have a KSA license, offers…”—linguistically admitting to originating and controlling the illegal casino offers rather than simply promoting third-party brands.
RevDuck explicitly promotes its brands as “safer offshore alternatives” to KSA-licensed casinos, criticizing the Dutch regulator’s approach and guiding Dutch players to unlicensed sites. This confirms that SoftSwiss, through Affilka, is providing the technical backbone for an operator that openly targets restricted markets and admits to circumventing local gambling regulation.
Systematic Targeting of the Netherlands
Despite standard compliance disclaimers, the RevDuck network actively engineers its infrastructure for Dutch players:
- Trueluck Casino is marketed on Dutch-language portals such as trueluckcasinonl.com and trueluck-app.com as “the best online casino in the Netherlands,” with full Dutch localization and payment methods including Visa, Mastercard, bank transfer, Revolut, and Bitcoin.
- Dutch review sites explicitly acknowledge that Trueluck “does not have a KSA licence” and operates illegally under Dutch law, yet the brand remains accessible to Dutch players.
- The whistleblower notes that Holyluck uses Dutch URL paths such as
/inloggen/(Dutch for “Log In”) and deploys holyluck2.com as a geo-evasion mirror when Dutch connections hit the main domain, indicating deliberate circumvention of KSA ISP blocking measures. - Affiliate marketing materials within the RevDuck network explicitly state that Trueluck is “tailored to Dutch preferences” and “committed to providing the Dutch market,” contradicting claims of passive international availability.
The Netherlands Gambling Authority (KSA) has repeatedly imposed €840,000 fines on offshore operators targeting the Dutch market, including Booms.bet (January 2026), with enforcement actions specifically mentioning Costa Rican Sapphire Summit SRL structures as the typical vehicle for these illegal offers.
Payment Hub Consistency
While the whistleblower submission focuses primarily on corporate layering and regulatory evasion, the known pattern from other SoftSwiss clusters suggests RevDuck brands, based on the Affilka platform with its integrated payment processing, integrate the same payment rails documented in FinTelegram’s January 24 report:
- Affiliate sources list CoinsPaid among RevDuck’s payout methods for affiliates, consistent with SoftSwiss’s documented ownership links to the Dream Finance OÜ crypto payment processor.
- Trueluck’s Dutch-facing pages list Visa/Mastercard, bank transfer, Bitcoin, and Revolut as player payment methods, matching the generic SoftSwiss cashier stack (cards, open banking, crypto) identified across Dama N.V., Hollycorn N.V., Stable Tech N.V., and Novatrix SRL casinos.
The uniformity of payment rails across nominally independent operators powered by SoftSwiss—spanning crypto (CoinsPaid/CryptoProcessing), open banking (Contiant/Yapily), instant banking (Perspecteev/ChainValley), and e-wallets (MiFinity, Jeton)—reinforces the hypothesis that SoftSwiss functions as a centralized payment orchestration hub rather than a pure B2B software supplier.
Compliance Assessment
The RevDuck case materially strengthens FinTelegram’s core thesis: SoftSwiss is not a neutral B2B platform provider but a central technology, affiliate, and payment hub enabling offshore networks to structure, market, and monetize illegal casino offers into regulated EU markets.
Key risk indicators:
- Rotating Costa Rican shell entities (Zephyr, Gem, Sapphire, Yakadea) following the same structural pattern as KSA-sanctioned Booms.bet (Costa Rica SRL 3-102-903325).
- Affilka by SoftSwiss confirmed as the operational platform for RevDuck, linking SoftSwiss directly to unlicensed Dutch-facing operations.
- Explicit admission in public forums that RevDuck runs “offshore projects” and promotes “safer offshore alternatives” to KSA-licensed sites, demonstrating active regulatory circumvention rather than passive market participation.
- Systematic geo-evasion and localization for the Netherlands (Dutch language,
/inloggen/URL paths, mirrors such as holyluck2.com, NL-specific affiliate portals). - Dynamic legal-entity switching based on visitor IP, displaying different Costa Rican companies (Gem vs. Zephyr) to different geographic audiences—a money-laundering technique known as “layering.”
SoftSwiss Network: Key Data
| Entity | Type | Registration / License | Role | Brands / Connections |
|---|---|---|---|---|
| SoftSwiss / Stable Aggregator Ltd | B2B Platform & Aggregator | Malta: MGA/B2B/942/2022 | Technology hub; casino platform, game aggregation, Affilka affiliate system, payment orchestration | Dama, N1 Interactive, Hollycorn, Stable Tech, Novatrix, RevDuck |
| RevDuck www.revduck.com | Affiliate Network / Operator | Costa Rica (via rotating SRL entities) | “Offshore projects” operator using Affilka; systematic Dutch market targeting | Holyluck, Trueluck, Kokobet |
| Holyluck www.holyluck.com www.holyluckX.com www.holy-luck.org | Offshore Online Casino | Costa Rica: Zephyr Holding SRL (3-102-926727) / Gem Limitada, Yakadea SRL Sapphire Summit SRL UK: Lyntec Limited (geo-switched) | Unlicensed casino targeting Netherlands; geo-evasion via holyluck2.com | RevDuck network |
| Trueluck https://thetrueluck.com | Offshore Online Casino | Costa Rica: Sapphire Summit SRL (3-102-903325) UK: Lyntec Limited | Unlicensed casino; explicit NL marketing; same Costa Rica entity as KSA-fined Booms.bet | RevDuck network |
| Kokobet www.koko.bet | Offshore Online Casino | Costa Rica: 3-102-897762 LTDA | Late 2024 launch; RevDuck network brand | RevDuck network |
| Booms.bet | Online Casino | Costa Rica: Sapphire Summit SRL (3-102-903325) | KSA fine: €840,000 (Jan 2026) for illegal NL operations; same reg. as Trueluck | Independent but structural parallel |
| Affilka www.affilka.com | Affiliate Platform | SoftSwiss Group Cyprus: Zellero Limited | Affiliate management, tracking, reporting; powers RevDuck and 100+ casino brands | RevDuck, N1 Partners, and SoftSwiss client base |
| CoinsPaid / CryptoProcessing | Crypto Payment Processors | Estonia: Dream Finance OÜ (Reg. 14783543, FIU licence FVT000166) | Crypto rails for SoftSwiss casinos; co-founded by SoftSwiss founder Ivan Montik | Dama, Hollycorn, Stable Tech, RevDuck affiliates |
Conclusion and Call for Evidence
The RevDuck whistleblower submission confirms that SoftSwiss, via its Affilka platform and broader ecosystem, is structurally embedded in how illegal offshore casinos reach Dutch players—despite rotating Costa Rican shell companies, geo-evasion mirrors, and public admissions of regulatory circumvention.
The reuse of Costa Rican Sapphire Summit SRL (registration 3-102-903325) by the KSA-fined Booms.bet, HolyLuck, and Trueluck Casino demonstrates that these structures are not isolated incidents but systematic patterns within the SoftSwiss-powered offshore casino ecosystem.
FinTelegram is preparing an expanded intelligence report on SoftSwiss and its role as a technology, affiliate, and payment hub for illegal casino networks. We are calling on insiders, players, and compliance professionals to share additional information:
We are looking for:
- Current or former employees of SoftSwiss, Stable Aggregator Ltd, RevDuck, Holyluck, Trueluck, Kokobet, Booms.bet, or related entities.
- Payment and compliance professionals who have seen routing patterns, merchant setups, or banking relationships involving SoftSwiss-powered casinos.
- Players who have deposited or withdrawn via CoinsPaid, CryptoProcessing, Contiant, Yapily, Perspecteev, ChainValley, MiFinity, Jeton, or other processors at SoftSwiss-powered casinos.
- Documentation, including contracts, emails, onboarding files, cashier screenshots, merchant names, bank accounts, crypto wallets, or evidence of operations in prohibited jurisdictions.
Submit securely via Whistle42
Go to Whistle42 and select the SoftSwiss / payment hub case as your topic. You can upload documents and remain anonymous if you wish. Verified information will be used to expand our ongoing investigation and inform regulators and law enforcement where appropriate.
