Rillpay SRL is a Costa Rica-based crypto wallet infrastructure provider and on-ramp aggregator. It serves as a primary “Layer 1” gateway for offshore casinos (e.g., Dama N.V. group), routing fiat deposits through a secondary layer of EU-based VASPs like Kryptonim. Due to its role in masking gambling transactions as digital asset purchases, Rillpay is rated as High Risk.

R42 Risk Signal

• Traffic Light: 🔴 High Risk (Red)

• Confidence Grade: Confirmed (Technical analysis of payment cascades + Merchant integration logs)

• Rationale: Rillpay is a key enabler of “fake bank deposits.” It allows unlicensed casinos to access SEPA and credit card rails by obfuscating the transaction’s purpose through multiple crypto-conversion layers.

Key Data Table

What the Company Does

Rillpay provides a “Widget-as-a-Service” for crypto on-ramping. In practice, it is a payment orchestrator that sits between an online casino’s cashier and the global banking system. When a player clicks “Deposit,” Rillpay identifies the best “Layer 2” processor (like Kryptonim) to handle the fiat-to-crypto conversion, ensuring the deposit bypasses gambling-specific blocks.

Regulatory & Legal Framework

• Costa Rican Registration: Registered under SUGEF Article 15 bis. This registration is primarily for AML reporting and does not constitute a “license” to provide financial services in the EU.

• EU Regulatory Gap: Rillpay operates in Europe without MiCA authorization by claiming it is merely a “software provider” to authorized EU VASPs.

Ownership, Founders, Executives

The group maintains a low public profile. Management typically consists of technical architects with backgrounds in high-risk payment gateways. Investigative links suggest shared technical infrastructure with the Daxchain ecosystem.

Corporate Structure & Related Entities

Rillpay SRL functions as the “Offshore Licensing Shield.” It manages the high-risk merchant relationships, while its “partners” (like Kryptonim in Poland) handle the regulated fiat-to-crypto settlement.

Products, Integrations & Technical Footprint

Rillpay’s primary product is a non-custodial wallet API and a Smart Checkout Widget. Technical logs show it frequently “cascades” payments—if one processor fails, Rillpay automatically shifts the transaction to another “Layer 2” provider.

Merchant / Customer Footprint

Concentrated in the Dama N.V. and Hollycorn N.V. casino groups. Key merchant brands include LuckyWins, Neon54, Winning.io, and Casinoly.

Complaints, Allegations, Enforcement, Litigation

• Consumer Fraud Allegations: Players have reported being unable to charge back deposits because Rillpay/Kryptonim characterize the transaction as a “completed crypto purchase” rather than a gambling deposit.

• Compliance Bypass: Alleged to facilitate transactions for Polish VASPs in violation of those entities’ own internal AML policies regarding iGaming.

Risk Factors & Red Flags

• Layered Obfuscation: The use of two or more entities to process a single deposit is a classic red flag for “Transaction Laundering.”

• Jurisdictional Risk: Costa Rica is a known haven for VASPs seeking to avoid the scrutiny of the EBA or ESMA.

Merchant Due-Diligence Checklist

• [ ] Is the “Checkout” URL a rillpay.co subdomain? (Result: ALERT).

• [ ] Does the transaction descriptor on the bank statement match the casino name? (Result: NO – typically ‘Crypto Purchase’).

• [ ] Is the merchant licensed in the player’s jurisdiction? (Result: NO).

Evidence Box (References)

• SUGEF Costa Rica – VASP Registry

• FinTelegram: The Rillpay Connections

• Due Diligence Hub – Rillpay Entry

Update Log (Evergreen)

• Feb 2026: RatEx42 confirms Rillpay as the Layer 1 provider for LuckyWins. Signal set to RED.

Call for Information (Whistle42)

Are you a developer at Rillpay or a merchant who has been “offboarded” by regulated banks? We are looking for internal routing tables and fee structures. Report anonymously at Whistle42.com.