How a two-tier payment architecture is keeping sanctioned iGaming groups alive after the €4.2M Starscream crackdown.
The Investigation: Beyond the Fine
In January 2026, the Dutch regulator (KSA) sent shockwaves through the CyberFinance world by imposing a €4.228 million fine on the Starscream Group. But while the headlines focused on the penalty, the real story was happening in the “plumbing” of the payment flows.
RatEx42 analysts have identified a sophisticated “Shadow Stack”—a multi-layered payment architecture involving SegoPay (www.segopay.com) and HuchPay (www.huch.tech)—designed to ensure that even when a casino is “debanked,” the money never stops moving.
1. The Front Layer: SegoPay (The Obfuscator)
The stack begins with SegoPay (segopay.com). Our investigation reveals that SegoPay acts as the “Merchant-Facing” layer.
- The Role: SegoPay provides the API and the user interface seen by the gambler.
- The Strategy: By operating without a visible EU license and utilizing rotating IBANs, SegoPay makes it nearly impossible for traditional banks to blacklist the “source” of the transaction.
- The Red Flag: SegoPay serves as the primary gateway for sanctioned brands like Rant Casino and AllStarz Casino, marketing a “zero chargeback” environment that is inherently at odds with consumer protection laws.
2. The Bridge Layer: HuchPay (The Technical Wrapper)
Once SegoPay initiates a transfer, it is frequently routed through HuchPay (HUCH SAS).
- The Role: HuchPay acts as the “Technical Bridge” to the actual banking system.
- The Strategy: By leveraging “Open Banking” (PSD2) protocols, HuchPay wraps the high-risk transaction in a layer of technical legitimacy.
- The Loophole: Because HuchPay claims to be a “technical service provider” rather than a payment processor, it often evades the strict AML reporting requirements that a bank would face.
3. The “Two-Step” Maneuver
Why use two providers instead of one? The R42 analysis suggests a risk-distribution strategy:
| Layer | Function | Risk Level |
| SegoPay | Takes the “Heat” from regulators; acts as the face of illegal flows. | ⚫ Black |
| HuchPay | Provides the “Clean” connection to the SEPA network. | ⚫ Black |
Export to Sheets
By splitting the flow, the “Shadow Stack” ensures that if one provider is blocked, the other can quickly pivot to a new partner, keeping the merchant’s “cash-in” functionality online 24/7.
The Regulatory Blind Spot
The SegoPay/HuchPay stack exploits the “Agent” loophole in EU law. By operating under the “umbrella” of larger, licensed institutions without being directly registered themselves, these entities move billions in “grey market” funds with minimal oversight.
“We are witnessing the industrialization of shadow banking for the iGaming sector. This isn’t just a failure of one company; it’s a systemic exploit of Open Banking technology.” — RatEx42 Compliance Lead
BOX OUT: R42 Risk Assessment
- Combined Signal: ⚫ High Risk (Black)
- Primary Threat: Facilitation of sanctioned entities & AML bypass.
- Featured Listings: View SegoPay Profile | View HuchPay Profile
Whistle42: We Need Your Data
Are you an employee at a European EMI seeing suspicious flows from SegoPay or HUCH SAS? Do you have merchant onboarding documents for the Starscream Group?
Help us expose the rails. Submit your documents anonymously via Whistle42.com. Your evidence could be the key to the next major regulatory enforcement.
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- Meta Title: The SegoPay & HuchPay “Shadow Stack” Investigation | RatEx42
- Meta Description: A deep dive into the payment architecture used by the Starscream Group to bypass EU gambling regulations.
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- Tags: SegoPay, HuchPay, Starscream Group, KSA Fine, Open Banking Fraud, High-Risk PSP, CyberFinance.
