VASP “Payment Template:” DAXCHAIN + ChainValley as Fiat Payees Behind Offshore Casino Deposits!

FinTelegram’s Rail Atlas reviews of Stellar-linked offshore casinos show a repeatable payments pattern: players are routed through “open banking” and wallet rails that do not pay the casino directly, but instead pay VASP-registered intermediaries—notably DAXCHAIN (Estonia) and ChainValley (Poland)—that appear to function as fiat collection points. This is not an edge case. It looks like a scalable operating model designed to keep the casino out of the payment line-of-fire.

Key Points

• Multiple casino brands attributed to Stellar show “template-like” repetition in UX and payment architecture, consistent with FinTelegram’s earlier Stellar/Legiano findings.
• Italy’s regulator blocks at least some related domains (including AllySpin and Supabet variants), while operators rotate through domain “mutations,” diluting enforcement at the DNS layer.
• Open-banking flows route users through gateway cascades (per your review) culminating in payees such as DAXCHAIN OÜ (www.daxchain.eu), whose public posture is VASP/virtual-currency activity—not licensed payment institution activity.
• DAXCHAIN’s register data shows presents Olegs Bogdanovics a beneficial owner. It virtual currency license raises the obvious question: why is a VASP the payee for “bank deposits” into offshore casinos?
• ChainValley remains a recurring node: FinTelegram has documented “fake-fiat” deposits where Skrill/Neteller funding is converted into USDC/USDC.e and forwarded to casino wallets—presented to the player as if it were a normal “deposit.”

Read our ChainValley reports here.

Short Narrative

Our latest casino reviews (WinBay, AllySpin, LuckyMax, Spinbara, Supabet) reinforce what the Legiano/Stellar investigations already suggested: offshore casino groups are industrializing “deposit rails” the same way they industrialize domain churn.

The striking part is not just that open-banking is offered—it’s who receives the money. Instead of paying a clearly identified, licensed gambling operator, the flows terminate at intermediaries like DAXCHAIN (Estonia) and ChainValley (Poland). From a compliance perspective, that is a flashing red light: the “merchant of record” layer is being engineered so the casino is one step removed from the payment event.

Extended Analysis: The Regulatory Problem isn’t “Open Banking” — it’s The Payee Design

1) PSD2 doesn’t disappear because the UI says “crypto” or “open banking”

Under PSD2 (Directive (EU) 2015/2366), payment services in the EU are a regulated activity, and authorization/registration is tracked through national competent authorities and consolidated in EU-level registers.

If an entity is functionally acting as a fiat collection agent (receiving consumer bank transfers that fund an offshore casino relationship), the natural questions are:

• Is it authorized/registered as a payment institution or e-money institution for that activity?
• If not, what is the legal characterization of the “payment” the consumer thinks they’re making?

This is exactly where “fake-fiat” architecture becomes useful to operators: if the payment can be framed internally as a purchase of crypto (even if the user experience suggests a casino deposit), the intermediary tries to step out of the PSD2 payment-agent box and into the VASP box.

2) DAXCHAIN: Licensed for Virtual-Currency Activity, Yet Positioned as a Fiat Payee

Public sources indicate DAXCHAIN holds an Estonian FIU virtual currency service authorization (listed with license number FVT000045 in FIU communications).
Separately, Estonia’s business register discloses the company’s ownership/control information (including the beneficial owner name in the register view).

None of that, on its face, answers the PSD2 question: why is a VASP the named recipient in a bank-transfer “deposit” flow that ultimately funds offshore gambling activity? If the true commercial purpose is gambling, routing fiat into a VASP payee looks less like innovation and more like perimeter-hopping.

3) ChainValley: The Repeatable “Fake-Fiat” Conversion Hub

Poland’s virtual-currency activity register lists ChainValley, but Polish authorities have been explicit that entry in the VASP activity register is not equivalent to a financial services license/supervisory approval in the PSD2 sense.

FinTelegram’s Legiano/Stellar reporting already documented how these flows can be structured: “deposit” → embedded crypto purchase (USDC/USDC.e) → automatic transfer to casino wallet, funded via Skrill/Neteller rails—leaving consumers with weaker dispute/chargeback leverage because they technically “received the crypto they ordered.”

In our new Stellar set, ChainValley appears again—paired with classic consumer payment brands (Skrill/Neteller/PaysafeCard) that were never built to be silent feeders into offshore casino stablecoin transfers.

Read our Stellar reports here.

4) The Visa/Tink question: when open banking becomes a gambling rail

We found a cascade that includes Tink in the open-banking confirmation path. Visa publicly confirmed its acquisition of Tink and positions it as a payments/data platform for initiating payments and moving money via APIs.

This creates an uncomfortable but necessary compliance question for the ecosystem:

• If a regulated open-banking stack is initiating payments to VASP payees that are then used to fund unlicensed offshore casinos, what merchant/category screening is actually being enforced?
• Are these payments being treated as “crypto purchases” (and therefore allowed), even when the downstream commercial purpose is gambling?
• If yes, is that a control failure—or a business model?

Actionable Insight: compliance questions that require answers

1. For DAXCHAIN / ChainValley: What is the exact contractual product here—casino deposit, payment facilitation, or crypto purchase/on-ramp? If it’s “crypto purchase,” why is the UX presented as a casino funding method?
2. For open-banking intermediaries (incl. Tink stack participants): What enhanced due diligence is performed when the payee is a VASP that is repeatedly observed in offshore gambling deposit flows?
3. For e-wallet rails (MiFinity pattern): Why do payees like CANAMONEY EXCHANGE LTD / CenturaPay keep appearing in offshore casino cashier flows—what merchant monitoring controls are actually preventing repeat exposure?
4. For regulators & FIUs: Are VASP registrations being used as a backdoor to run de facto payment-agent services for high-risk merchants (illegal gambling, shadow trading)? If so, where is the enforcement line?

Call for Information

If you have internal documentation, merchant onboarding records, payee/descriptor data, settlement account details, wallet clusters, or evidence showing how DAXCHAIN and ChainValley categorize these “deposits” (casino funding vs. crypto purchase), share it securely via Whistle42. We are particularly interested in: (i) merchant-of-record identities; (ii) transaction narratives used for bank compliance; (iii) chargeback/complaints outcomes; (iv) the gateway switching logic between payment-gateway endpoints; and (v) any correspondence with regulators.