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The Soft2bet Files: How Better Governance Could Have Changed the Story

An assessment of the corporate, payments and compliance failures highlighted by the 2026 investigation

The Soft2bet Files: How Better Governance Could Have Changed the Story

An assessment of the corporate, payments and compliance failures highlighted by the 2026 investigation
by
September 2026
In July 2026, Investigate Europe published a year-long cross-border investigation into Soft2bet – a Cyprus-based iGaming company that had built a public reputation around licensed operations, compliance awards and its position as a B2B technology provider.

The investigation presented a very different picture.

According to the report, alongside 11 legitimately licensed brands was a network of more than 145 unlicensed casino brands targeting Germany, Spain, Austria and the United Kingdom – markets in which the relevant operations did not hold domestic authorisation. The investigation estimated that the network generated approximately €600 million between May 2020 and May 2024.

It also reported that licensed and unlicensed operations shared personnel, technology and payment infrastructure, while funds moved through Cypriot corporate entities connected to Soft2bet founder Uri Poliavich.

Soft2bet disputed the investigation's interpretation, arguing that the entities involved were separate corporate structures. The central legal question, therefore, is not whether different companies existed on paper – but whether those companies were sufficiently independent in practice.

In this article:

The numbers and key facts behind the investigation

The investigation reported:

  • More than 145 unlicensed casino brands, primarily targeting Germany, Spain, Austria and the UK.
  • Approximately €600 million generated through the network between May 2020 and May 2024.
  • More than seven million visits from German IP addresses during Q4 2024.
  • Approximately 50,000 player claims in Germany and Austria by 2025.
  • A €5 million Spanish regulatory fine against Rabidi N.V., which the article says remained unpaid.
  • More than €700 million processed through three regulated payment institutions identified in the investigation.
  • Approximately 30 million visits from unlicensed casino sites through the internal payment gateway Pgway during a six-month period.
  • More than 60 allegedly fraudulent copyright complaints were used in attempts to remove reporting from search results.

These figures illustrate the extent to which allegedly unlicensed activity was intertwined with a wider corporate and commercial ecosystem.

Mistakes Soft2Bet made and lessons from them

The most important lesson from the case is that corporate separation only works when it is real.

1. Too many connections led back to the same individual

The investigation identified Poliavich as UBO, director, or beneficial controller across multiple entities. Among those named were Outono Ltd, Araxio Development N.V., and other companies within the wider structure.

That created a straightforward investigative path.

Once investigators connected the different companies, brands and jurisdictions, the corporate structure ultimately led back to the same individual.

A group can contain dozens of legally separate companies and still present a unified regulatory risk if ownership, management and control remain closely connected.
Rikk commentary:
Building all the businesses under the same name poses significant risks for both the UBO and the businesses. You need to maintain proper protection for your business against your private issues, and protect yourself from business issues, especially in this sphere. Also keep in mind that in Cyprus, for a few euros, you can obtain full information about the entity, its owners, and the history of share transfers. So, if the operator is operating in complex markets, they need to consider this.

2. Brand ownership created another public trail

The investigation also examined trademarks associated with brands including Wazamba and Rabona.

Trademark registers are public. They can therefore provide investigators with a relatively simple route from a consumer-facing brand to the company that owns its intellectual property – and potentially from that company to the wider corporate group.

This illustrates a broader point: compliance analysis does not begin with confidential banking records. Public corporate registers, trademark databases, licensing records, sponsorship announcements and employment information can collectively reveal how a group operates.
Rikk commentary:
When you register ™ for the brand that operates from offshore casinos in complicated markets - everyone can find information about this. Usually operators use offshore jurisdictions with closed registers to minimize the risk.

3. Payment processing became a major point of exposure

One of the most serious allegations concerned payment processing.

The investigation reported that Pgway, an internal payment gateway associated with the network, processed deposits for unlicensed casino sites using merchant codes belonging to unrelated businesses. The examples reportedly included businesses such as a Nigerian cake-decoration company, a Zambian camera retailer and a Cypriot content agency.

The investigation further reported that three regulated payment institutions processed more than €700 million through the arrangement.

If accurately established, this is not merely a licensing problem. It raises fundamental questions about merchant due diligence, transaction monitoring, payment transparency and AML controls.

Payment providers are increasingly expected to understand not only the legal entity presenting itself for onboarding, but also the underlying merchant activity, customer journey and jurisdictions being served.
Rikk commentary:
When someone will investigate your operations they will use the main rule “follow the money” so it was super easy to track all the domains of S2B just through technical search of the payment IP’s they used with their own payment gateway. From our search around a year ago it was around 185 domains there. It’s financially profitable to create all the infrastructure on your own but it also creates a huge risk of linking all the entities and activities.

4. The money trail was too closely connected to the principal

The investigation identified approximately €330 million flowing from Cypriot payment entities Tranello and Tilaros to holding companies owned by Poliavich.

It also reported that Soft2bet had identified Tranello to a payment provider as belonging to the Soft2bet group.

This created another potential weakness in the structure: the distance between operating revenue and the ultimate beneficial owner was narrow enough that examining one part of the structure could reveal the broader relationship.
Rikk commentary:
One of the most stupid ideas from our point of view is to receive money through a few connected structures to the UBO from the activity you are potentially not authorized to operate in. You place a target on your head. If you use shelf companies, it will be super easy to track all your money flow.

So in all cases, there are only 2 reasons for it to happen:
  1. Big EGO of the owner
  2. Unprofessional lawyers that support the business

5. Insolvency and asset transfers intensified the risk

According to the investigation, as player recovery claims accumulated, software rights, intellectual property and casino trademarks were transferred to new corporate vehicles. It reported that Araxio Development N.V. and Rabidi N.V. subsequently entered bankruptcy proceedings in Curaçao.

The investigation characterised these developments as part of a broader restructuring that left creditors pursuing companies with limited recoverable assets.

Whether particular transfers ultimately constitute fraudulent conveyance is a matter for the relevant courts and applicable law. But the underlying compliance principle is straightforward: moving assets after a dispute or creditor claim has emerged can create substantially greater legal exposure if the transaction is alleged to have been designed to defeat legitimate claims.
Rikk commentary:
Creditor exposure and insolvency risk should be considered before disputes arise. Do not place all the eggs in one basket, so that in case of trouble you don’t need to move them and expose extra information to the public. There are no limitations on how you can legally structure your business to separate Software, ™, and other IP rights from each other and from operational activity to isolate a risk.

6. Licensed and unlicensed operations cannot safely share the same infrastructure

Former employees cited in the investigation reportedly described licensed and unlicensed businesses operating with shared staff, communications systems, management and payment infrastructure. The B2B technology arm Brainrocket was also reported to have served both sides of the business.

That matters because operational separation is considerably more difficult to establish when the people, systems and money are shared.

A regulator investigating an allegedly unlicensed operation can potentially obtain evidence relating to the licensed operation at the same time. More importantly, shared infrastructure can undermine arguments that supposedly separate companies are genuinely independent.
Rikk commentary:
Where separate regulatory businesses genuinely need to remain separate, the separation must exist operationally as well as legally. Management, technology, payment arrangements, personnel and financial flows should reflect the distinction.
The risk becomes particularly acute where a licensed business operates alongside grey-market activity. Any shared infrastructure can expose the licensed business to questions about the activities of its unlicensed counterpart.

7. Public visibility can become evidence

The investigation also highlighted sponsorships, industry awards, executive interviews and other public-facing activities connected to markets in which affiliated brands were allegedly operating without domestic licences.

Publicity can be commercially valuable, but it also creates evidence.

Sports sponsorships, marketing campaigns and executive statements can establish where a company considers itself to be operating, which markets it is targeting and how it describes its own business.

That can become particularly significant when those public claims conflict with the company's regulatory position.
Rikk commentary:
an operator's public footprint should be consistent with its actual licensing position. From our point of view, all these “sponsorship” activities are more about EGO than about real needs and business profit. It’s an additional stimulus for investigation authorities to check all your skeletons in your closet.

8. Physical presence can eliminate jurisdictional ambiguity

The investigation reported that Soft2bet maintained a physical office in Spain while affiliated brands were allegedly generating unlicensed gambling revenue from Spanish players.

Physical infrastructure matters because it can provide regulators with a concrete connection between the operator and the jurisdiction.

An office, employees or other operational infrastructure may make it substantially harder to argue that activity was entirely offshore.

The investigation also reported that Spain's gambling regulator, the DGOJ, imposed a €5 million fine on Rabidi N.V. relating to 25 allegedly illegal casinos.
Rikk commentary:
The main rule for all the business - Don't see off the branch you're sitting on. That means that if you have a local license or you have an office in a particular jurisdiction - don’t even think about working in this geo in an inappropriate way.

Why corporate separation is not enough

The Soft2bet case, as presented by the investigation, illustrates a recurring problem in modern iGaming regulation.

A corporate group can create multiple legal entities, obtain licences in some jurisdictions and operate through different brands. But regulators increasingly examine the substance behind those structures.

  • Who owns the companies?
  • Who manages them?
  • Who employs the staff?
  • Who controls the technology?
  • Who processes the payments?
  • Where does the money ultimately go?
  • Where are the customers located?
  • Where are the people and infrastructure located?
  • And what does the company publicly say about the markets it serves?

When the answers to those questions consistently point toward the same underlying organisation, formal corporate separation may provide little protection from regulatory scrutiny.

The reported Soft2bet structure appears to have suffered precisely from this problem. The investigation did not identify one isolated compliance failure. It described a network in which ownership, brands, payments, personnel, technology, physical presence and public activity repeatedly intersected.

The regulatory environment is changing

The investigation also arrives against a broader shift in European gambling enforcement.

The source highlights CJEU case C-683/24, Spielerschutz Sigma, and an April 2026 opinion from Advocate General Emiliou concerning Malta's Bill 55. The case could have significant consequences for the ability of Malta-licensed operators to resist enforcement of judgments originating in other EU markets.

At the same time, enforcement is increasingly extending beyond operators themselves.
Payment processors, B2B suppliers, game aggregators and affiliates can all become part of the regulatory picture when their services facilitate activity in markets where the underlying operator is not authorised.

The source points to enforcement action involving B2B suppliers in the UK and Ontario as examples of this broader approach.

The implication is significant: licensing is no longer an issue that can be isolated within the operating company. Every participant in the supply chain needs to understand where its products and services are being used and whether the underlying activity is authorised.

Conclusion

For the past year, we at Rikk have been warning clients that sooner or later some of the industry's biggest names would face serious consequences for their approach to restricted markets. We never quite understood why large groups that spoke openly about working in prohibited jurisdictions seemed so unconcerned about the risk. Now Soft2Bet has reportedly cut a large number of staff and hurriedly pulled out of markets where it is alleged to have operated without a licence. It leaves us wondering whether all of this was worth the ego.

The most important lesson from the Soft2bet investigation is not that sophisticated corporate structures are inherently problematic.

It is that legal separation without operational separation creates vulnerability.

A defensible iGaming structure requires more than incorporation documents and licences. It needs consistency between ownership, management, operations, payments, intellectual property, marketing, physical presence and the jurisdictions in which customers are served.
Where those elements tell different stories, investigators have multiple routes into the organisation.

The Soft2bet investigation suggests that the enforcement environment has moved beyond asking whether a particular company holds a licence. The harder question is whether the entire commercial structure behind the activity is consistent with that licence.

For operators, B2B suppliers and payment intermediaries, that is the question their compliance architecture now needs to answer.

If you need offshore infrastructure built from scratch, or want someone to stress-test the setup you already have, get in touch. We'll review how your corporate structure, banking and licensing fit together, find the weak spots before a regulator or payment provider does, and help you keep operating in difficult markets with fewer surprises.

This article is intended for entertainment purposes only and does not constitute legal advice. Regulatory requirements, fees, and timelines are subject to change. Operators should obtain qualified legal counsel before making jurisdictional decisions.
Vladyslav Yarovoi
Vladyslav Yarovoi acts as a managing partner at the esteemed Rikk law firm. With his Master of Law and expertise in a high-risk business, Vladyslav has become an authority on providing legal support for IT businesses; from ensuring their successful launch to making sure they are ready for IPO.
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