Polish VASP ChainValley as the “Payee” in Offshore Casino Open-Banking Deposits

FinTelegram’s review of the offshore casino Rooli (rooli.com), operated by Curaçao-based Dama N.V., shows a recurring Open Banking pattern: the player’s bank transfer is made to “Chain Valley” as the recipient. In multiple flows, the deposit confirmation screen identifies Chain Valley as payee while the payer is a retail bank (e.g., Revolut, ING). That is not a neutral technicality—it is a compliance chokepoint.

Key Facts

• Illegal casino activities: Rooli is an offshore casino without license or permission to operate in the UK, EU, or in North America.
• Observed Rail: Player chooses Open Banking in Rooli cashier → payment initiation screen → “To: Chain Valley” (payee) → funds leave player’s bank (e.g., Revolut/ING) and land at Chain Valley. (Confirmed by screenshots.)
• Entity: Chain Valley Sp. z o.o. (Warsaw) operates chainvalley.pro; terms identify KRS 0001036419 and Warsaw address.
• Status in Poland: Chain Valley is listed in Poland’s virtual-currency activity register (RDWW-765, entry date 25.05.2023) with services including exchange between “virtual currencies and means of payment” and related intermediation.
• Regulatory reality check: Poland’s Ministry of Finance has explicitly warned that virtual-currency activity in this register is not “licensed or supervised” as a financial licence; oversight is primarily AML/CFT compliance control.
• Operator context: Rooli states payments are processed via Dama N.V. (Curaçao) and places the legal burden on players to assess legality in their jurisdictions.
• Pattern signal: ChainValley previously surfaced in FinTelegram’s Legiano rail investigation (FIAT→USDC “conversion” narrative risk).

Illegal Casino Activities

First, it must be stated plainly: the underlying activity being funded is unlawful in large parts of the market. Rooli—like many Dama-branded casinos—appears to accept players and deposits from multiple EU jurisdictions without holding the required local gambling authorisations. In our review, registration and funding from EU-based banks worked without meaningful friction, while the cashier dynamically surfaced EU languages and bank options tailored to those jurisdictions.

That combination is a strong indicator of active cross-border targeting rather than accidental access. If the gambling offer is not lawfully authorised where the player is located, then the payment rail is not a neutral utility—it becomes an enabler. Payment facilitators and open-banking intermediaries should therefore treat Dama/Rooli exposure as a high-risk, often non-permissible use case and apply refusal and off-boarding controls accordingly.

Yet the operational reality we observe is different: “open banking,” “instant banking,” and crypto on-ramps are increasingly used to route around local licensing, card gambling blocks, and merchant scrutiny—making the regulatory perimeter look optional when it is not.

Short Analysis

1. The compliance issue is the payee. In the Open Banking flow, the recipient of the transfer is Chain Valley—not the casino, not a licensed EU payment institution branded as merchant acquiring, not an e-money wallet with regulated safeguarding disclosures. That means ChainValley functionally sits as a collection account / payment agent for casino deposits (or as a “merchant of record” via a “crypto purchase” wrapper). Either way, this is a high-risk typology for circumventing gambling blocks: bank statements show “Chain Valley,” not “casino.”
2. VASP registration ≠ right to run FIAT payment rails. Under PSD2, payment services in the EU must be provided by authorised/registered payment service providers in scope of the directive. ChainValley’s publicly visible positioning is crypto-service (KYC/AML policy; “buy crypto”; APMs including instant bank transfers). If casino deposits are being routed through a VASP-labeled “crypto purchase,” regulators and banks should treat this as regulatory arbitrage: gambling funding disguised as crypto on-ramp activity.
3. Who should be asking hard questions (now):

• Chain Valley: Who is the ultimate beneficiary of these casino-related transfers? Is ChainValley the merchant of record? Are transfers credited as casino deposits or as crypto buys? What is the settlement path to Dama/its PSP stack?
• Open Banking enablers: Why is a casino cashier initiating payments where the payee is a crypto VASP? What enhanced due diligence is applied for unlicensed/offshore gambling exposure?
• Banks: Why are repeated transfers to “Chain Valley” not treated as potential gambling funding / third-party collection patterns requiring review?

Call for Information

Do you work at ChainValley, an Open Banking provider, a bank risk team, or an offshore casino payment desk—and have documentation on how these “To: Chain Valley” deposits are booked (crypto purchase vs. casino funding), settled, and screened? Send evidence securely via Whistle42.com (screenshots, transaction references, merchant agreements, settlement files, risk rules).