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

Impaya operates as a global Payment Service Provider (PSP) heavily focused on the high-risk offshore iGaming, unregulated Forex, and crypto-broker sectors. Orchestrated from Riga, Latvia, but officially shielded behind a Canadian corporate registration, Impaya utilizes a fragmented, multi-jurisdictional shell structure to provide remote fiat onboarding and open banking rails for merchants operating without top-tier European financial licenses.

R42 Risk Signal

🔴 RED: Critical Risk | Confidence Grade: High

Reasoning: Impaya triggers a “Critical Risk” signal under the RatEx42 Risk Rating Methodology due to its explicit targeting of unlicensed financial entities. Marketing materials and active technical integrations (e.g., with white-label broker providers like UTIP and B2Broker) confirm that Impaya aggressively onboards offshore operators without requiring standard European financial licenses. The platform relies on regulatory arbitrage—utilizing a Canadian MSB registration to obscure its primary operations targeting the EU market.

Key Data Table

Operational Overview

Impaya provides end-to-end payment gateway solutions designed specifically to absorb the compliance burden for high-risk merchants. The core operational model features:

• Global Fiat Onramps: Processing Visa, Mastercard, SEPA Direct Debit, Apple Pay, Google Pay, and localized e-wallets across 170+ countries.

• Open Banking Exploitation: Providing open banking API rails that allow high-risk merchants to initiate direct bank-to-bank transfers, bypassing traditional card acquirer scrutiny.

• Remote High-Risk Onboarding: Offering fast-tracked, remote corporate account opening specifically designed for gray-market iGaming operators and unlicensed FX/crypto brokerages.

Regulatory Framework

Impaya exhibits classic regulatory arbitrage. While its core operational team, CEO, and EU representative entity (NewTech Mobile SIA) are based in Latvia, Impaya holds no Electronic Money Institution (EMI) or banking license with the Bank of Latvia or the European Central Bank. Instead, the primary contracting entity is Impaya Payments Ltd. in British Columbia, Canada, leveraging Canadian Money Services Business (MSB) loopholes to process global volumes while dodging strict European capital and auditing standards.

Ownership & Executives

• Sergey Roslikov (CEO & UBO): Identifies himself as the CEO and is based in Riga, Latvia. His physical location tightly binds the actual decision-making and operational center of the company to the Baltics, despite the international corporate facade.

Corporate Structure

The entity utilizes a deliberately fragmented structure to isolate risk and access different regional banking rails:

• Impaya Payments Ltd. (Canada): The primary contracting and shielding entity.

• NewTech Mobile SIA (Latvia): Acts as the boots-on-the-ground EU representative and operational hub.

• Paytech Solutions PTE. LTD. (Singapore): Acts as the APAC access point to route Asian payment methods.

• Impaya Assets OÜ (Estonia): A supplementary Baltic entity, likely utilized for holding or supplementary crypto-asset processing.

Technical Footprint

• White-Label API Gateways: Functions as a deeply embedded checkout solution on offshore platforms.

• Brokerage Integrations: Publicly confirmed integrations with major offshore B2B tech providers like UTIP and B2Broker, systems frequently used to spin up unregulated “burner” brokerages in offshore havens like St. Vincent and the Grenadines (SVG).

Merchant/Customer Footprint

Targeted aggressively at high-risk, unverified, or offshore merchants. Impaya is a frequent exhibitor at major gray-market networking events (e.g., ICE Barcelona iGaming conference) to court offshore casino operators. Their client base is predominantly entities actively avoiding tier-1 regulatory jurisdictions.

Enforcement/Litigation History

There are no direct international sanctions against Impaya or its executives at this time. However, the exact model they deploy—onboarding unlicensed EU-facing brokerages via remote offshore gateways—is heavily scrutinized by ESMA, the FCA, and FinTelegram as a primary conduit for transaction laundering and investor fraud.

Red Flags

• Active Facilitation of Unlicensed Entities: Public marketing bragging that “no Forex license is required” to use their payment gateway.

• Geographic Discrepancy: The CEO and operations are in Latvia, but the contracting entity is strategically placed in Canada.

• High-Risk Tech Partnerships: Embedded into tech stacks (UTIP) known for deploying unregulated boiler-room brokerages.

Merchant Due-Diligence Checklist

• Acquirer Action: Classify as High-Risk/Critical. Require enhanced due diligence (EDD) to verify the ultimate destination of funds routed through Impaya APIs.

• Compliance Protocol: Trace settlement flows specifically from impaya.com nodes to verify if Canadian MSB licenses are being used to passport payments illegally into EU jurisdictions.

• Onboarding Block: Do not utilize Impaya as an intermediary if your platform requires strict adherence to EU AMLD6 or FCA safeguarding rules.

Evidence Box (Sources)

• Impaya Corporate Infrastructure: impaya.com

• UTIP Broker Integration (Unlicensed Forex Focus): utip.org/show_news/impaya

• B2Broker High-Risk Integrations: b2broker.com/news/b2broker-adds-december-updates…

• RatEx42 Risk Rating Methodology: listings.ratex42.com/the-ratex42-risk-rating-methodology/

Update Log

• Profile Created: April 26, 2026.

• Last Status Check: Entities confirmed active; API integrations verified.

Whistle42 Call to Action

Are you an industry insider or former employee with knowledge of Impaya’s European settlement banks, exact processing volumes, or internal KYC/AML override procedures for unlicensed brokers? Submit your intelligence securely and anonymously through the Whistle42 secure drop to assist financial regulators in mapping shadow payment rails.