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

Smartflow Payments Limited, operating under the brand SENDS, is a UK FCA-regulated Electronic Money Institution (EMI). Despite its regulated status, the entity is categorized as highly restricted due to its Ultimate Beneficial Owner (UBO), Alona Shevtsova, being officially sanctioned by Ukraine’s National Security and Defense Council (NSDC). Recent intelligence reveals a sophisticated corporate obfuscation strategy: the platform’s intellectual property, domain, and technology have been shifted to a separate shell company (GANGA PAY LTD) immediately following the sanctions against the UBO. The company is heavily implicated as a payment facilitator in a massive UAH 5 billion money laundering network tied to the illegal online casino segment.

R42 Risk Signal

🔴 RED (Severe Risk) | Confidence Grade: High

Explanation: Assigned a RED signal due to direct, verifiable sanctions exposure and active corporate obfuscation. The UBO is subject to a 10-year asset freeze. The separation of the FCA-regulated entity (Smartflow) from the technological and IP holding entity (Ganga Pay Ltd) via a post-sanctions “licensing agreement” is a textbook asset-shielding tactic designed to protect operational infrastructure from regulatory seizure. Active law enforcement investigations (ESBU) further compound the severe risk.

Key Data Table

• Brand Name(s): SENDS

• Primary Domain: sends.co

• FCA Regulated Entity: Smartflow Payments Limited (f.k.a. Electronic Payment Solutions Ltd, UK Co. 11070048)

• IP/Technology Holding Entity: GANGA PAY LTD (UK Co. 14867993)

• Jurisdiction of Incorporation: United Kingdom

• Registered Address (Smartflow): 11 Garden Court, Tewin Road, Welwyn Garden City, Herts, England, AL7 1BH

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

• Regulatory Status: Authorised EMI (FCA FRN: 900873)

• Ultimate Beneficial Owner (UBO): Alona Shevtsova (Ukraine)

• Proxy/Nominee Director (Ganga Pay): Anna Borodenko (Ukraine)

Operational Overview

SENDS operates as a digital payment service provider marketing to B2B and B2C clients, including startups, freelancers, and e-commerce merchants. Its core offerings include multi-currency business and personal accounts with dedicated IBANs, cross-border payments via SEPA and SWIFT, mass payout capabilities, and virtual Mastercard debit cards. They also offer internet acquiring services with integrations for Apple Pay, Google Pay, Visa, and Mastercard.

Regulatory Framework

Smartflow Payments Limited is regulated in the United Kingdom by the Financial Conduct Authority (FCA) as an Authorised Electronic Money Institution. However, the operational reality circumvents this framework: the actual software, website, and branding are owned by GANGA PAY LTD, an unregulated shell entity. This “Software as a Service” (SaaS) arrangement technically distances the regulated EMI from the platform’s proprietary data and infrastructure, creating a significant regulatory blind spot.

Ownership & Executives

• Alona Shevtsova: Ultimate Beneficial Owner (>75% shares of Smartflow), active Director, and CEO. Founder of the associated “LEO” payment network.

• Anastasiia Pervushyna: Director and MLRO (Smartflow).

• Zinaida Berezovskaya

• Anna Borodenko: Director and PSC of GANGA PAY LTD (assessed as a proxy/nominee for the Shevtsova network).

Corporate Structure

The corporate architecture is explicitly designed for compartmentalization:

• The Regulated Shell: Smartflow Payments Limited holds the FCA license and the banking rails.

• The Asset Safe Haven: GANGA PAY LTD owns the sends.co domain, the website, and the underlying platform technology.

• The Trigger Event: SENDS operates under a Software License Agreement dated May 1, 2025. This date is highly suspicious, occurring mere days after the UBO and the Smartflow legal entity (under its former name) were sanctioned and subjected to asset freezes by the Ukraine NSDC in April 2025. This indicates an emergency restructuring to ring-fence the platform’s technology from regulatory seizure.

Technical Footprint

The platform acts as a technological bridge between traditional banking rails and digital merchants. Notably, the technology owner, GANGA PAY LTD, is also listed as the legal seller for the “Official shop of the LEO team” (an e-sports/gaming brand). This directly links the SENDS infrastructure to Shevtsova’s infamous LEO payment system, which was previously shut down for the exact same illegal casino money-laundering typologies currently suspected of SENDS.

Merchant/Customer Footprint

While ostensibly targeting the gig economy, freelancers, and standard e-commerce, investigations indicate a significant, unadvertised footprint in high-risk sectors. Specifically, the SENDS network has been flagged as a primary payment facilitator for offshore and unregulated gambling operators, primarily servicing Eastern European markets via merchant miscoding.

Enforcement/Litigation History

• Sanctions (April 2025): Ukraine’s NSDC imposed 10-year sanctions and asset freezes on Alona Shevtsova and Electronic Payment Solutions Ltd (now Smartflow).

• Criminal Investigations: Ukraine’s Economic Security Bureau (ESBU) is actively investigating Shevtsova, the SENDS network, and the related LEO payment system for suspected involvement in a UAH 5 billion money laundering ring utilizing illegal online casinos.

• Network Detentions: Polish authorities have reportedly detained Iryna Tsyhanok, an alleged key accomplice within the SENDS/Smartflow laundering architecture.

Red Flags

• Post-Sanctions Asset Shielding: The transfer/licensing of core IP to GANGA PAY LTD immediately following the UBO’s sanctioning is a critical evasion indicator.

• Sanctioned Leadership: UBO is actively sanctioned and subject to asset freezes in a major European jurisdiction.

• High-Risk Addresses & Proxies: GANGA PAY LTD utilizes the notorious 71-75 Shelton Street virtual office address and relies on a carousel of proxy directors.

• Merchant Miscoding Allegations: Highly credible allegations of facilitating illegal gambling through intentional transaction miscoding to bypass AML controls.

• The “LEO” Connection: Direct corporate links between the SENDS technology provider and a previously shuttered, disgraced payment network (LEO).

Merchant Due-Diligence Checklist

Before engaging with this entity, partners and correspondent banks should execute the following:

1. Halt Operations pending Legal Review: Assess whether engaging with the SENDS platform constitutes a breach of the UBO’s asset freeze, given that the technology is licensed through a connected shell company.

2. Request the GANGA PAY Licensing Agreement: Demand unredacted copies of the May 1, 2025, Software License Agreement to determine true ownership of operational data and customer funds.

3. Verify the current FCA authorization status of FRN 900873 and check for any recent Supervisory Notices.

4. Conduct Enhanced Due Diligence (EDD) regarding the ongoing ESBU criminal investigations into the LEO and SENDS networks.

Evidence Box (Sources)

• UK Companies House (Smartflow): Smartflow Payments Limited Overview

• UK Companies House (Ganga Pay): GANGA PAY LTD Overview

• SENDS Website Footer: Documents the May 1, 2025, software licensing agreement with Ganga Pay Ltd.

• OpenSanctions: Alona Shevtsova Profile | Smartflow Profile

• Financial Intelligence: FinTelegram / Due Diligence Hub Reports

Update Log

• April 9, 2026: Profile heavily revised. Added intelligence regarding the GANGA PAY LTD asset-shielding structure, the suspicious May 1, 2025 licensing agreement timeline, and the direct technical links to the defunct LEO payment network.

• April 9, 2026: Initial compliance profile created. Triggered by discovery of UBO sanctions and ESBU money laundering investigations.

Whistle42 Call to Action

Do you have inside information regarding the licensing agreement between Smartflow Payments Limited and GANGA PAY LTD? Are you aware of Anna Borodenko’s exact role within the Shevtsova network? Help us map this corporate obfuscation. Submit your evidence, contracts, or internal communications securely and anonymously via the Whistle42 Secure Drop.