Holyluck Update: New Evidence Points to a Wider SENDS-Centered Merchant Cluster Around Offshore Casino Payments

Charlene Lensburg
Thu, 09 Apr 2026 05:49:18 +0000
Compliance, Gambling Compliance, Illegal gambling, Illegal Payment Services, Asortiz, Digitplaystore, Dota2store, FCA EMI, Gem Limitada, Holyluck, Holyluck2, Holyluck3, Livante, MCC miscoding, Mega.bet, merchant descriptor masking, offshore casino, PayLink, Quicko, SENDS, sk1nzone, Smartflow Payments Limited, TAS Link, Transaction Laundering, Trueluck, UK shell merchants

Fresh whistleblower intelligence suggests that the Holyluck payment trail was not an isolated event. FinTelegram has reviewed new SENDS communications and new UK merchant entities linked to digital-goods storefronts that may have functioned as front-end payment layers for offshore gambling flows. The emerging picture points to a broader merchant cluster, not a single disputed transaction.

New whistleblower material reviewed by FinTelegram strengthens the original Holyluck payment-rail story in two ways. First, it shows what appear to be standardized SENDS support responses telling the complainant that SENDS is only a payment-service provider, that the complainant is “not our client,” and that any refund or chargeback route must go through the merchant or issuing bank.

Second, the whistleblower has identified a growing cluster of UK-incorporated digital-goods fronts — including ASORTIZ LTD and LIVANTE LTD — whose websites present themselves as gaming or digital-goods stores, while the whistleblower alleges they function as cover merchants for gambling-related payment flows. The public record does not yet prove that SENDS knowingly onboarded sham merchants. But the new evidence materially sharpens the question of whether a regulated UK EMI is sitting at the center of a broader merchant-presentation architecture for offshore casino deposits.

Key Findings

The “not our client” line is now documented more clearly. New screenshots reviewed by FinTelegram show SENDS support repeating that it cannot process refunds or chargebacks because the complainant is not SENDS’ client and must instead pursue the merchant or the issuing bank.

The alleged front-merchant layer appears broader. The whistleblower identifies ASORTIZ LTD and LIVANTE LTD, both recently incorporated in the UK, as companies tied to digital-goods storefronts used in the wider payment environment. Companies House shows both are active.

At least two websites openly map to those companies. dota2store.online states in its terms that it is operated by ASORTIZ LTD, while digitplaystore.com states that it is operated by LIVANTE LTD. Both present themselves as digital-goods/game-key sellers.

The wider routing narrative remains consistent with the original case. The earlier chain involving PayLink/TAS Link, SENDS / Smartflow Payments Limited, and a Quicko payout reference still stands as the strongest documented framework from the Holyluck dossier. SENDS publicly states that Smartflow Payments Limited is the regulated entity behind the brand and uses FCA registration number 900873. TAS Link publicly states that it has been NovaPay’s processing partner for more than five years.

The available evidence suggests that Holyluck was not necessarily the merchant presented to the payment system, but that the presented merchant appears to have been acquired through SENDS.

What the New SENDS Screenshots Add

The new screenshots do not reveal a “smoking gun” admission. What they do add is behavioral consistency.

Across the reviewed exchanges, SENDS support tells the complainant that refund requests must be directed to the merchant, that SENDS merely facilitates the transaction, and that the complainant must turn to the card issuer for dispute or chargeback options. In one exchange, SENDS reportedly states outright that the complainant is “not our client.”

That matters because it fits the already documented pattern in the Holyluck case: the consumer-facing gambling activity appears to sit on one side, while the payment-facing response shifts responsibility back to an opaque merchant layer. On its own, this is not proof of complicity. But it is evidence that SENDS was on notice of the complaint and still framed the matter as a merchant-side dispute rather than a potential merchant-misrepresentation or MCC-presentation problem.

One small but noteworthy detail also emerges from the screenshots: the SENDS footer still shows Office 39.18, Level39, One Canada Square, London E14 5AB, while Companies House now shows Smartflow Payments Limited’s registered office as 11 Garden Court, Tewin Road, Welwyn Garden City, changed on 1 December 2025. That may be nothing more than legacy branding or an old template, but it is another indicator that the public-facing and registry-facing layers should be checked carefully.

The New Merchant Cluster: ASORTIZ, LIVANTE, and the “Digital Goods” Layer

The strongest new research lead is the apparent merchant-cluster expansion.

ASORTIZ LTD is an active UK company. Companies House shows Inna Rainova, a Ukrainian national, as director and person with significant control since June 2025. The website dota2store.online states in its terms that it is operated by ASORTIZ LTD and presents itself as a seller of digital products.

LIVANTE LTD is an active UK company registered in Liverpool, with SIC code 63120 – Web portals. Companies House shows Larysa Panaietova, also Ukrainian, as director. The website digitplaystore.com states that it is operated by LIVANTE LTD and markets digital game keys and related products.

That public record does not prove these are sham or “ghost” stores. But it does show that the whistleblower’s named companies are real UK corporates attached to websites that present themselves as low-risk digital-goods businesses — exactly the kind of category that would matter if gambling-related transactions were being presented to payment systems as retail or digital-goods purchases rather than gambling activity.

The additional domain sk1nzone.com appears to market CS2 skins and digital items, but in the quick public record check I reviewed, I did not find a clear operator disclosure equivalent to the ASORTIZ and LIVANTE websites. That makes it a lead, not a verified attribution.

How the Overall Picture Now Looks

The updated picture is more structured than the original Holyluck whistleblower complaint.

At the merchant-facing layer, the Holyluck/TrueLuck/Mega.bet cluster appears to sit in the offshore casino environment, with Holyluck widely described online as operated by Gem Limitada in Costa Rica.

At the payment-presentation layer, the whistleblower now points to multiple UK “digital goods” fronts, including ASORTIZ and LIVANTE, with storefronts such as dota2store.online and digitplaystore.com.

At the processing/routing layer, the earlier case tied the flow to PayLink / TAS Link and then to SENDS / Smartflow Payments Limited as the named acquirer or acquiring-side institution in TAS Link correspondence. TAS Link publicly markets payment-processing capabilities and says it processes for NovaPay. SENDS publicly states that Smartflow Payments Limited is the regulated entity behind the SENDS brand and is FCA-registered under 900873.

At the payout side, the earlier Quicko reference remains notable because Quicko itself publicly said it lost the ability to provide payment services after the Polish KNF revoked its authorization in January 2026.

Compliance Interpretation

The cautious but strong compliance interpretation is this:

The new material does not yet prove that SENDS knowingly operated an illegal-gambling laundering system. It does strengthen the case that SENDS sits inside a recurring complaint pattern involving allegedly mispresented merchants, digital-goods storefronts, and offshore gambling brands. The WhatsApp/email screenshots are especially relevant because they show SENDS not as an unknown background rail, but as an entity already receiving direct complaints and continuing to frame the matter purely as a merchant-side refund dispute.

That is where the regulatory question sharpens. If a regulated EMI is repeatedly named in complaints involving merchant mismatch, descriptor issues, digital-goods fronts, and offshore gambling brands, the issue is no longer just a consumer grievance. It becomes a merchant onboarding, transaction monitoring, MCC accuracy, and suspicious-activity escalation question.

Compliance Award Finalist — While Scrutiny Intensifies

In a development that sharpens the contrast around the Holyluck/SENDS case, SENDS has been officially listed as a finalist in the ICA Compliance Awards Europe 2026 under “Small Compliance Team of the Year (<7 Team Members) – Financial Services.” That shortlist status is now verified by the official ICA finalist page screenshot reviewed by FinTelegram.

The timing is striking. The same UK EMI that is presenting itself as an award-level compliance performer has also been named in whistleblower-backed complaints and FinTelegram reporting concerning digital-goods storefronts, merchant-presentation issues, offshore gambling-facing payment flows, and standardized refusal responses. That does not prove wrongdoing by SENDS, and FinTelegram is not suggesting that an award nomination invalidates a firm’s compliance controls. It does, however, make the underlying questions harder to ignore.

Summary Table

Layer | Entity / Brand | Jurisdiction | Publicly verified role | Investigative significance
Offshore casino layer | Holyluck / Holyluck2 / Holyluck3 | Costa Rica / offshore | Widely described online as operated by Gem Limitada | Underlying gambling-facing activity
Digital-goods front | ASORTIZ LTD / dota2store.online | UK | Active company; website says ASORTIZ operates DOTA2STORE. The Ukrainian national Inna Rainova is the controlling person. | Possible merchant-presentation layer
Digital-goods front | LIVANTE LTD / digitplaystore.com | UK | Active company; website says LIVANTE operates Digitplaystore. Ukrainian national Larysa Panaietova is the controlling person. | Possible merchant-presentation layer
Routing node | PayLink / TAS Link | Ukraine | Public payment-processing infrastructure; NovaPay processing partner | Technical routing role in earlier Holyluck dossier
Acquiring-side EMI | SENDS / Smartflow Payments Limited | UK | Active company; SENDS says Smartflow is regulated entity, FCA 900873 | Central regulated rail under scrutiny
Payout endpoint | Quicko / Quickowallet | Poland | Quicko says it lost ability to provide payment services after KNF action | Relevant payout-side context

Conclusion

The original Holyluck article now looks less like a one-off complaint and more like the first visible slice of a broader merchant-cluster problem.

The new evidence does not conclusively establish willful facilitation by SENDS. But it does show a more scalable structure than before: offshore casino brands on one side, UK digital-goods storefronts in the middle, Ukrainian payment infrastructure in the routing layer, and a UK-regulated EMI sitting in the acquiring-side position while responding to complaints with standardized deflections.

That is already enough to justify a harder second look by compliance teams, card schemes, regulators, and counterparties.

Whistleblower Call

FinTelegram invites insiders, former employees, merchants, acquiring partners, scheme-risk teams, and compliance officers with evidence relating to SENDS / Smartflow Payments Limited, TAS Link / PayLink, ASORTIZ LTD, LIVANTE LTD, dota2store.online, digitplaystore.com, sk1nzone.com, Holyluck, TrueLuck, Mega.bet, or similar MCC- or merchant-presentation anomalies to contact Whistle42 securely.

We are especially interested in:

merchant onboarding files,

MCC assignment records,

descriptor mapping,

SAR/AML escalation files,

correspondence about merchant complaints,

and evidence linking digital-goods fronts to gambling deposits.

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