DAXCHAIN OÜ is an Estonian VASP-licensed entity currently serving as a “shadow” fiat payment agent for offshore casinos like WinBay. By utilizing a multi-layered gateway stack and the Tink (VISA) API, it facilitates bank transfers that fall outside its legal crypto-authorization. R42 issues a High Risk signal.

R42 Risk Signal

• Traffic Light: ⚫ High Risk (Black)

• Confidence Grade: Corroborated

• Rationale: The entity is operating as an unlicensed payment processor. Its involvement in an obfuscated “cascade” of gateways to process gambling deposits constitutes a major AML/CFT red flag.

Key Data

What the Company Does

DAXCHAIN acts as a “Fiat Payment Agent” for high-risk offshore casinos. While its license is for crypto services, its actual business involves receiving SEPA transfers from casino players. It sits at the end of a complex technical stack designed to hide the “Gambling” transaction descriptor from the player’s bank.

Regulatory & Legal Framework

• The VASP Loophole: DAXCHAIN uses its Estonian FIU license to open corporate bank accounts, but uses those accounts to process fiat-to-fiat gambling payments—an activity that requires a full Payment Institution (PI) license which they do not hold.

• Tink Exploitation: It utilizes the Tink (VISA subsidiary) API to facilitate bank-to-bank transfers. This misleads the infrastructure provider into believing the transaction is a simple “crypto purchase,” when it is actually a “casino deposit.”

Ownership, Founders, Executives

• UBO: Olegs Bogdanovics, a Latvian national. He is the sole controller.

• Regulatory Record: As of early 2026, the Estonian register has flagged the company with a “deletion notice” potential, suggesting a failure to maintain local substance or compliance filings.

Corporate Structure & Related Entities

• WinBay Casino: Known “Client” merchant.

• Moneyflect / Debitly: Associated technical gateways in the “cascade.”

Products, Integrations & Technical Footprint

The “Shadow Stack” identified: Casino Checkout → payment-gateway.io → moneyflect.com → Debitly.tech → Tink API → DAXCHAIN Bank Account.

Merchant / Customer Footprint

Significant exposure to WinBay (winbay.com) and other unlicensed Curacao-based gambling brands.

Complaints, Allegations, Enforcement, Litigation

• FinTelegram Investigation: Flagged as a key player in the laundering of gambling funds via the SEPA network.

• Unlicensed Activity: Operating a payment service without a PI license is a criminal offense in the EU.

Risk Factors & Red Flags

• Regulatory Misuse: Using a VASP license for fiat processing.

• Cascade Obfuscation: Deliberate hiding of the payment flow.

• License Attrition: Estonian registers showing deletion alerts.

Merchant Due-Diligence Checklist

• [ ] Verify if DAXCHAIN holds a PI license (Result: NO).

• [ ] Alert Tink/VISA to the misuse of their API for offshore gambling.

• [ ] Flag all outgoing transfers to DAXCHAIN bank accounts as “High Risk/Potential Unlicensed Gambling.”

Evidence Box (References)

• [Estonian e-Business Register 2026 – DAXCHAIN OÜ]

• [FinTelegram Intelligence Report: The WinBay Cascade]

• [Tink.com iGaming Compliance Policy]

15) Update Log (Evergreen)

• 2026-02-01: High-Risk alert issued following discovery of unlicensed fiat processing via Tink.

16) Call for Information (Whistle42)

Do you have banking details for DAXCHAIN’s current fiat accounts? Please submit via Whistle42.com.