Compliance Report: Lithuanian Crypto Gateway utPay At The Heart Of Germany’s Illegal Online Casino Payments

Charlene Lensburg
Fri, 26 Dec 2025 11:09:42 +0000
Crypto Compliance, Gambling Compliance, ticker, BetAlice, Fat Pirate, Legiano, NovaForge, Rabidi, Rabidi Group, utPay, Utrg

FinTelegram has completed an in‑depth compliance investigation into Lithuanian VASP UTRG UAB d/b/a utPay. The findings indicate that utPay has evolved into a high‑volume payment hub for unlicensed online casinos and sports betting operators, particularly targeting German players through deceptive “fake bank transfer” schemes.​

Summary of the Compliance Report

FinTelegram’s long‑form compliance report on UTRG/utPay, now available as a downloadable document linked in this article, reconstructs the group’s structure, licensing status, traffic patterns, and merchant portfolio using registry data, Similarweb analytics, and previous investigative work on NovaForge and associated casino networks.

The report identifies UTRG UAB as a Lithuanian‑registered virtual currency exchange and depository wallet operator whose payment gateway app.utpay.io processed more than 720,000 visits in November 2025, nearly 80% of which originated from Germany.​​

Traffic and referral analysis shows that at least 58% of utPay’s observed traffic is driven by casino, gambling, and sports betting sites, with the top five referrers all being offshore casinos such as Legiano and BetAlice. These flagship merchants are operated by Marshall‑Islands entities within the NovaForge network and licensed in high‑risk jurisdictions like Anjouan or via non‑EU regulators such as PAGCOR, meaning they are not authorized to serve German players under the GlüStV 2021 regime.​​

Analysis and Interpretation

The report documents how utPay’s checkout is embedded in casino cashier pages as a “bank transfer” or card deposit option, while the underlying transaction is in fact a crypto purchase from UTRG followed by an on‑chain transfer to the casino operator. This structure allows offshore casinos to route German player deposits via regulated SEPA and card rails while formally categorizing the payment as a crypto exchange transaction rather than gambling, effectively bypassing German payment blocking measures and bank‑side gambling controls.​​

FinTelegram’s analysis highlights that 42% of utPay’s referral traffic in November 2025 came from BetAlice and Legiano (connected to Fat Pirate), both linked to NovaForge Ltd, a Marshall Islands vehicle previously exposed by FinTelegram as the successor structure to the collapsed Rabidi Group network of illegal casinos. Combined with the complete lack of publicly disclosed beneficial owners, overdue financial filings in Lithuania, and the imminent MiCA licensing deadline, the pattern strongly suggests a business model optimised for regulatory arbitrage rather than long‑term, compliant operations.​​

Compliance Hypothesis

Download the full UTRG Compliance Report 2025 here.

Based on the compiled evidence, FinTelegram formulates the following working compliance hypothesis:

UTRG UAB d/b/a utPay operates as a crypto‑based payment facilitator whose core business consists in processing German player deposits for unlicensed offshore casinos through deceptive “fake bank transfer” flows, thereby enabling large‑scale violations of German gambling law and creating a high‑risk channel for money laundering and player‑loss recycling.

This hypothesis is supported by:

The overwhelming German traffic share to app.utpay.io and the exclusive referral pattern from gambling domains.​​

The integration with NovaForge‑controlled casinos documented as part of an illegal, multi‑jurisdictional network using Cyprus‑based payment agents and high‑risk processors such as MiFinity and Binance.​​

The structural opacity around UTRG’s beneficial owners and the lack of current audited financial statements despite very strong growth in transaction volumes.​

The report concludes that UTRG/utPay should be classified as a critical‑risk counterparty for banks, payment institutions, and crypto exchanges and that Lithuanian and German authorities, in cooperation with other EU supervisors, should review the case in the context of MiCA licensing and GlüStV 2021 enforcement.​

Call to Whistleblowers and Insiders

FinTelegram’s investigation into utPay and the NovaForge casino network is ongoing. The current report is built on open‑source intelligence, registry data, traffic analytics, and previous enforcement precedents, but important questions remain unanswered—especially regarding internal ownership structures, banking relationships, and the exact flow of customer funds between UTRG, casino operators, and associated payment agents in Cyprus and elsewhere.​

If you have insight into utPay, NovaForge, or their banking and payment structures, visit Whistle42 and help FinTelegram shed more light on this suspected high‑risk payment gateway. Your information may be crucial for regulators, affected players, and future enforcement actions.