DAREX Tier: Not applicable (digital assets service providers only)

Bennupay operates as an unregulated B2B payment orchestration platform utilizing a fragmented corporate structure spanning the UK and Cyprus. Despite facilitating cross-border transactions and onboarding merchants in high-risk sectors (such as online gaming and trading), neither its UK nor its Cyprus entities hold an Electronic Money Institution (EMI) license. The network exhibits several Anti-Money Laundering (AML) red flags, including the use of notorious UK virtual shell addresses, Cypriot proxy directors, offshore Lithuanian banking, and unregulated cryptocurrency (USDC) settlements for merchant fees.

R42 Risk Signal

🟠 ORANGE (Elevated/High Risk) | Confidence Grade: High

Explanation: Assigned an AMBER signal due to severe structural and operational red flags, despite the current absence of direct international sanctions. The rating is driven by regulatory arbitrage: operating a payment gateway for high-risk merchants without an FCA or Central Bank of Cyprus EMI license. The High Confidence Grade is supported by primary corporate registry data across two jurisdictions and verified merchant invoicing proving offshore banking and crypto-asset utilization.

Key Data Table

• Brand Name(s): Bennupay

• Primary Domain: bennupay.io

• UK Legal Entity (Front): BENNU TECH LTD (Company Number: 13817826)

• Cyprus Legal Entity (Operating/Contracting): SREBARS TRADING LTD (Registration Number: HE 395201)

• Registered Address (UK): 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ (High-Risk Virtual Office)

• Registered Address (Cyprus): Stelios Mavrommatis, 60, Agios Dometios, 2364, Nicosia, Cyprus

• Regulatory Status: Unregulated (Registered as software development/trading; No verified EMI/FCA licenses)

• Active Directors / Principals: Jelena Cvetkovic, Snezana Cvetkovic (Cypriot residents)

Operational Overview

Bennupay acts as a payment orchestration layer and cross-border remittance gateway. It provides API checkouts, e-wallet integrations, and credit card processing logic to medium and large-scale merchants. Their own documentation indicates a focus on complex, high-risk merchant categories, including online gaming, e-sports, and digital trading platforms that require multi-currency and cross-border flows.

Regulatory Framework

Bennupay operates entirely outside of standard financial regulatory frameworks. The UK entity (BENNU TECH LTD) is registered under the standard industrial classification for “Business and domestic software development.” This setup allows them to bypass the stringent Anti-Money Laundering (AML) and safeguarding requirements imposed on FCA-Authorised Electronic Money Institutions, operating purely as an unregulated technology vendor while facilitating high-risk financial flows.

Ownership & Executives

• Jelena Cvetkovic: Active Director (UK & Cyprus).

• Snezana Cvetkovic: Active Director and Secretary (Cyprus), Active Director (UK).

• Note: Given the fragmented corporate structure and use of offshore banking, these individuals possess the profile of proxy or nominee directors utilized to shield the Ultimate Beneficial Owners (UBOs).

Corporate Structure

The Bennupay architecture relies on extreme geographical fragmentation to obscure the flow of funds and regulatory jurisdiction:

• The Reputation Layer: A UK-registered company (BENNU TECH LTD) provides a tier-1 geographic veneer.

• The Contracting Layer: A Cyprus-registered company (SREBARS TRADING LTD) executes merchant agreements and handles B2B invoicing.

• The Banking/Settlement Layer: Funds are routed entirely outside the UK and Cyprus. Invoices direct merchants to pay via Lithuanian EMI accounts (Revolut Bank UAB) or via unregulated Ethereum-based stablecoins (USDC).

Technical Footprint

The primary technological footprint is centered around their API gateway hosted at bennupay.io. It routes transactions through various underlying acquiring banks and alternative payment methods, acting as a technical intermediary rather than the merchant of record.

Merchant/Customer Footprint

Bennupay actively targets merchants requiring complex international payment rails, particularly those in sectors frequently rejected by tier-1 banks due to high chargeback rates and laundering risks (gaming, offshore trading, high-risk e-commerce).

Enforcement/Litigation History

Currently, Bennupay, BENNU TECH LTD, and SREBARS TRADING LTD do not appear on major international sanctions lists (OFAC, UK OFSI, EU), nor are there public enforcement actions pending against them. However, their structural typology mirrors that of networks frequently targeted by regulatory crackdowns.

Red Flags

• Unlicensed Operations: Providing financial gateway services without appropriate EMI or Payment Institution (PI) licenses.

• Corporate Fragmentation: Separating the legal front (UK) from the contracting entity (Cyprus).

• High-Risk Addresses: Use of the heavily scrutinized 71-75 Shelton Street virtual office address in London.

• Crypto Settlements: Accepting corporate B2B fees (such as €2,500 MID setup fees) via USDC on the Ethereum blockchain, bypassing traditional correspondent banking oversight.

• Offshore Banking: Utilizing Lithuanian EMIs rather than domestic banking in their jurisdictions of incorporation.

Merchant Due-Diligence Checklist

Partners, acquiring banks, or merchants considering engagement should demand:

1. Proof of Licensing: Request explicit confirmation of their regulatory status regarding the handling of third-party funds.

2. Flow of Funds Diagram: Require a documented flow of funds explaining why UK/Cyprus entities settle funds in Lithuania and via cryptocurrency wallets.

3. UBO Verification: Conduct Enhanced Due Diligence (EDD) to verify if Jelena and Snezana Cvetkovic are the true Ultimate Beneficial Owners or merely proxy directors.

Evidence Box (Sources)

• UK Companies House: BENNU TECH LTD (13817826)

• Cyprus Registrar of Companies: SREBARS TRADING LTD (HE 395201)

• Merchant Intelligence (Invoice): Verified B2B invoice linking Srebars Trading Ltd to the Bennupay brand, requesting payment via Revolut Lithuania and USDC crypto wallets.

Update Log

• April 11, 2026: Initial compliance profile created. Triggered by structural analysis, cross-jurisdictional registry matches, and verified merchant invoicing proving offshore/crypto settlement.

Whistle42 Call to Action

Do you have insight into the Ultimate Beneficial Owners (UBOs) behind Bennupay, BENNU TECH LTD, or SREBARS TRADING LTD? Help us map the true operators behind this fragmented network. Submit internal communications, banking flow details, or acquiring partner lists securely and anonymously via the Whistle42 Secure Drop.