Compliance Analysis: Swapped’s Deep Integration with GamDom – A Comprehensive Web of Regulatory Violations

Charlene Lensburg
Sat, 13 Sep 2025 06:39:01 +0000
Crypto Compliance, Crypto Payment Processor Watch, Illegal gambling, Illegal Payment Services, ticker, Banking Circle, Binance, Bybit, Coinbase, Gamdom, Kraken, Swapped, Thomas Franklin

The Danish-based crypto payment provider Swapped, co-founded and headed by Thomas Franklin, has established itself not as a mere payment facilitator, but as the central nervous system enabling GamDom’s illegal gambling operations across Europe. Through its sophisticated Swapped Connect platform, the company provides a turnkey solution that transforms regulated crypto exchanges into unwitting accomplices in money laundering and regulatory evasion on an industrial scale.

The Architecture of Illegal Gambling: Swapped Connect’s Seamless Integration

The €5 Million GamDom Fine

A €5 million fine against Smein Hosting B.V. (GamDom) was issued in 2023 by Spain’s Directorate General for the Regulation of Gambling (DGOJ) as part of a sweeping crackdown on unlicensed gambling operators. In the first half of 2023, the DGOJ imposed fines of €5 million each and two-year bans on 14 unlicensed online casinos primarily domiciled in Curaçao, including Smein Hosting B.V.

The penalty was among the harshest measures taken to curb black market gambling exposure in Spain, and highlighted the serious legal and financial risks such operators face across the EU when circumventing licensing and AML requirements.

The Exchange Gateway System

Swapped Connect (accessible via connect.swapped.com) represents one of the most sophisticated compliance evasion mechanisms discovered in the crypto gambling space. The platform directly integrates with major regulated exchanges, including Coinbase, Kraken, Binance, ByBit, and numerous others through three connection methods:

Direct API Integration: Users authorize Swapped to access their exchange accounts directly

API Key Connection: Customers provide API keys allowing Swapped to execute transactions on their behalf

Proxy Connection: Temporary login sessions enabling immediate fund transfers

The Laundering Pipeline

Step 1: Regulatory Bypass
Players access GamDom and initiate deposits through Swapped‘s deeply integrated widget. The system pre-fills wallet addresses and eliminates traditional friction points that would normally trigger compliance scrutiny.

Step 2: Exchange Exploitation
When players deposit via their Coinbase, Kraken, or Binance accounts, the regulated exchanges’ KYC/AML systems see only a legitimate transaction to Swapped—completely blind to the final destination being an illegal casino. This systematically defeats the compliance controls that these regulated entities spent millions implementing.

Step 3: Fiat Integration via Banking Circle
For traditional payment methods, Swapped utilizes Banking Circle S.A. (Luxembourg) with IBAN DE31202208000050484620 to process bank transfers and card payments. This adds another layer of legitimacy while obscuring the ultimate criminal purpose.

Step 4: Seamless Conversion and Delivery
Purchased cryptocurrencies are automatically transferred to GamDom addresses and appear as credits in players’ gambling accounts—completing a transaction that would be impossible through direct channels due to banking and card network restrictions on gambling merchants.

Swapped’s Blatant Terms of Service Violations

Despite Swapped‘s merchant terms explicitly prohibiting “unlicensed gambling activities” and stating that it “does not support merchants operating in prohibited industries, including unlicensed gambling”**, the company has built its entire business model around facilitating exactly these activities.

The Traffic Data Confirms the Casino Engagement

Similarweb analysis reveals that in August 2025, over 8% of Swapped’s referring traffic originated from casinos and sports betting sites—a damning statistic that proves gambling facilitation is not incidental but core to their operations. Additionally, 40% of August 2025 traffic came via Kado.money, the acquired payment processor that Swapped absorbed to expand its illegal gambling reach.

Regulatory Violations and Criminal Liability

Multi-Jurisdictional Money Laundering

United States: Violation of the Unlawful Internet Gambling Enforcement Act (UIGEA), which explicitly prohibits payment processors from facilitating restricted gambling transactions

European Union: Systematic violation of AML directives and national gambling laws across all member states where GamDom operates illegally

United Kingdom: Breach of Gambling Commission requirements and Money Laundering Regulations

Denmark: Violation of Danish gambling licensing requirements and AML obligations under their own regulatory registration

Circomventing Exchange Compliance

By using Swapped Connect to mask the true nature of transactions, Swapped systematically misleads regulated crypto exchanges, causing them to unknowingly facilitate illegal gambling transactions. This constitutes:

Fraudulent misrepresentation of transaction purposes

Conspiracy to violate gambling laws across multiple jurisdictions

Aiding and abetting unlicensed gambling operations

Banking and Payment Network Fraud

The use of Banking Circle accounts and traditional payment rails to process gambling-related transactions violates:

Card network regulations (Visa/Mastercard prohibit gambling transactions with unlicensed operators)

Banking compliance requirements under EU and Luxembourg AML laws

Payment services regulations across multiple jurisdictions

The Scale of the Criminal Operation

Swapped is not merely a payment facilitator—it has created maybe the most sophisticated illegal gambling payment infrastructure in Europe. The deep integration with GamDom, the systematic exploitation of regulated exchanges, and the deliberate violation of its own terms of service demonstrate a criminal enterprise operating with impunity.

The company’s ability to process traditional fiat payments, convert to cryptocurrency, and deliver funds to illegal gambling platforms while maintaining a veneer of regulatory compliance represents the evolution of financial crime in the digital age.

Immediate Enforcement Actions Required

FinTelegram calls for immediate coordinated action by global financial regulators:

1. Immediate suspension of all Swapped operations and freezing of company accounts

2. Criminal investigation of Swapped executives for money laundering conspiracy

3. Regulatory action against Banking Circle for facilitating illegal gambling transactions

4. Exchange compliance reviews of Coinbase, Kraken, Binance integration policies

5. Seizure of all GamDom-related cryptocurrency wallets and fiat accounts

Swapped Key Data

Category | Details
Website/Domain | swapped.com, connect.swapped.com, kado.money (redirects to Swapped)

Social Media

X: @swappedcom
LinkedIn: Swapped.com

Legal Entities
(Network)

Swapped ApS (Denmark, registered 43326922)
Kado Software Inc. (acquired, USA)
Banking Circle S.A. (Luxembourg – payment intermediary, not owned)
Local operational subsidiaries as needed in Europe

Individuals

CEO: Thomas Franklin (LinkedIn)
Head of US Operations (ex-Kado): Emery Andrew (Crunchbase)
Other directors: See Danish registry for full records

Jurisdictions

Denmark (Headquarters, Swapped ApS registered)
Luxembourg (Banking Circle banking partner)
USA (Kado acquisition, product operations)
UK & EU operational coverage

Regulation

Registered with Danish FSA as crypto service provider (public registry)
Utilizes regulated partners (Banking Circle, IBANs)
Subject to PSD2, AMLD5, GDPR in Europe
Terms prohibit unlicensed gambling, but evidence shows facilitation of illegal gambling is ongoing

We sent Swapped a list of questions about the findings, but have not yet received a response.

Whistleblower Call to Action

The scope of Swapped’s criminal facilitation network likely extends far beyond GamDom. FinTelegram urgently seeks insider information about:

Complete client lists of gambling operators using Swapped services

Internal communications regarding compliance bypass strategies

Financial records showing transaction volumes with illegal gambling sites

Technical documentation of integration methods with regulated exchanges

Beneficial ownership details of Swapped and related entities

Submit evidence anonymously via FinTelegram’s secure whistleblower platform:

Share Information via Whistle42

Your information is critical to exposing the full extent of this international financial crime network and protecting consumers from predatory gambling operations enabled by Swapped‘s criminal facilitation services.

This investigation reveals Swapped as the central enabler of illegal gambling across Europe—a criminal enterprise masquerading as a legitimate payment processor while systematically violating financial crime laws across multiple jurisdictions.