Executive Summary:
Recent FinTelegram investigations have revealed that Swapped, a regulated FIAT-to-crypto payment processor, is deeply integrated into the operational infrastructure of GamDom, an offshore online casino operated by Smein Hosting B.V. in Curaçao. Despite Swapped’s terms of service prohibiting illegal gambling, it facilitates EU user deposits for an unlicensed operator. GamDom has already been fined €5 million by the Spanish gambling authority for unauthorized operations. Other crypto onramps such as MoonPay are also prominently featured in the online gambling ecosystem—serving platforms like MetaWin and BC.Game.

The conclusion is stark: Illegal and unauthorized online casinos are rapidly expanding across the EU with the help of crypto infrastructure. National regulators, limited by jurisdiction and technical fragmentation, are largely unable to enforce sanctions effectively. Crypto is not just a neutral payments tool—it is now an enabler of gambling arbitrage at scale.

1) Key Findings from the FinTelegram Reports

• Swapped ↔ GamDom Integration:
  Swapped operates as the FIAT-to-crypto gateway for EU-based users of GamDom. Players can fund their accounts via Swapped, with crypto routed to the casino. The payment flow includes regulated partners like Banking Circle and integrations with Coinbase, Kraken, Binance, or Bybit. This two-step separation between fiat deposits and gambling usage undermines traceability and accountability.
• Contradictory Compliance Position:
  While Swapped’s merchant terms prohibit the facilitation of illegal gambling, the operational reality directly contradicts this. GamDom has no EU license and targets players in restricted jurisdictions. This raises serious questions about Swapped’s risk controls and enforcement of its own compliance framework.
• MoonPay Exposure:
  MoonPay has been repeatedly identified as a preferred payment processor for gambling-related crypto flows. Platforms like MetaWin and BC.Game integrate MoonPay directly into their deposit interfaces, making crypto the default funding route for their gambling operations.

2) Enforcement Snapshot — Spain and EU Focus

• Spain’s Crackdown:
  The DGOJ (Dirección General de Ordenación del Juego) has aggressively penalized unauthorized gambling operations. In 2024–2025 alone, over 14 operators were fined—most receiving €5 million each, with one €10 million case. These also include multi-year bans. GamDom is publicly listed among the offenders. However, payment status and actual deterrence remain unclear.
• Curaçao Context:
  The Curaçao Gaming Authority (CGA) is attempting to clean up its image under external pressure. While it has warned operators and revoked licenses in some cases, the regime remains weak on KYC, payment agent transparency, and cross-border oversight.

3) How Crypto Payments Undermine Regulatory Enforcement

• Jurisdictional Air Gap:
  A user pays fiat to a licensed crypto onramp (e.g. Swapped or MoonPay). The service provider converts it to crypto, which is then sent to an offshore casino. Legally, the payment processor claims to have simply “sold crypto”—not enabled gambling. The gambling event takes place outside their jurisdiction, creating a regulatory blind spot.
• Fragmented Liability Chain:
  Visa, Mastercard, and PSP rules prohibit processing payments for unlicensed gambling. But when payment is split between fiat and crypto, and the processor is not part of the gambling entity, enforcement collapses. This weakens both consumer protection and AML oversight.
• Chargeback Immunity:
  Once fiat is converted to crypto, chargebacks become impossible. Players scammed or misled by offshore casinos face extreme difficulty recovering funds. Payment processors, by design, remain shielded.

4) Compliance Analysis (FinCrime Observer View)

• Swapped:
  By serving GamDom—a casino explicitly fined and banned in multiple EU jurisdictions—Swapped risks regulatory exposure and reputational damage. The mismatch between written terms and operational behavior signals governance failures. The firm is now on the compliance radar.
• MoonPay and Other Onramps:
  These services appear repeatedly in high-risk flows, particularly in gambling, influencer scams, and pseudo‑lotteries. MoonPay’s merchant onboarding and monitoring practices should be scrutinized by regulators and banks alike.
• Authorities Are Outpaced:
  National regulators like Spain’s DGOJ can fine offshore entities, but enforcement stops at the border. There is little to no effective blocking of payments, ad targeting, or app distribution across platforms. The crypto-gambling nexus evolves faster than laws can catch up.

5) Outlook and Policy Recommendations

• Trend Projection:
  Unauthorized gambling operations will continue to scale aggressively using crypto rails. Without coordinated regulatory enforcement targeting the payment processors themselves, enforcement at the operator level will remain ineffective.
• Policy Proposals:
  1. Merchant transparency & classification rules for all CASPs and onramps under MiCA. Gambling exposure must be flagged and geo-blocked.
  2. Joint enforcement frameworks between financial regulators and gambling authorities.
  3. Mandatory disclosures of payment agents and UBOs for any merchant handling crypto-fiat flows.
  4. Platform-level action (ad targeting, app store removals, access blocks) against known gambling facilitators.

Call for Information – Whistle42

Do you have internal documents, chat logs, SOPs, or firsthand knowledge about Swapped, MoonPay, GamDom, or MetaWin and their gambling-related payment structures? We are particularly interested in:

• Internal AML/KYC procedures
• Merchant onboarding practices
• Payment routing setups
• API keys, integration guides, or partnerships with offshore operators
• Workarounds for geo-blocking or compliance filters

➡️ Submit information securely via Whistle42.com. Your identity will be protected. Tipsters may qualify for token-based or legal rewards under our Whistle42 protection framework.