Key Data

• Trading Name: SMTM Holding
• Legal Entity: SMTP Holding OÜ
• Activities: Payment services holding
• Location: Estonia
• Regulation: UK FCA for TomPay Ltd (e-Money Institution)
  FIU for NeuroNext and ExFrame
• Key People: Moriel Carmi and the Ukraine Dmitri Orlov 

SMTM Holding OÜ is a holding company registered in Estonia which operates several regulated and unregulated payment processors for high-risk industries and merchants. Among them are:

• TomPay Ltd dba TomPayment (Profile) – an FCA-regulated e-Money Institution
• Magua Pay Inc. dba Black Rabbit (Profile) – an unregulated crypto payment processor
• Magua Pay Inc. dba Magua Pay (Profile) – a registered Canadian money service business (MBS)
• ExFrame OÜ dba SmartPayments (Profile) – a regulated crypto payment processor
• Banxe Ltd dba Banxe (Profile) – an unregulated payment processor
• NeuroNext OÜ dba NeuroNext (Profile) – a regulated crypto payment processor

According to public information, the Israeli Moriel Carmi and the Ukraine Dmitri Orlov are the controlling individuals of SMTM Holding.

Compliance Issue

This company is allegedly involved in processing payments for unregulated casinos operating in the UK and Europe. Reports suggest that funds may be routed through various entities worldwide, which do not publicly disclose operational details. According to LinkedIn profiles, Marat Mirzabalajev appears to have connections to some of these businesses and associated companies. It is claimed that certain payment processes might be structured in a way that prevents transactions from being categorized as gambling-related under Visa and Mastercard regulations.

The Estonian-based SMTM Holding and its various payment ventures have come under scrutiny for their alleged involvement in high-risk financial operations. According to reports, the company operates a network of payment processors and fintech firms that may facilitate transactions for industries often considered sensitive or unregulated. While little publicly available information exists about the true ownership and operational structure, whistleblowers have raised concerns about the transparency and compliance of these entities. Authorities and industry observers are reportedly monitoring these activities to assess potential regulatory implications.

Conclusion and Risk Rating

Based on the concerns raised about SMTM Holding and its associated payment ventures, significant risks appear to be present. The alleged involvement in high-risk financial activities, lack of transparency, and potential facilitation of unregulated transactions raise red flags from a compliance and regulatory standpoint. Furthermore, the reported links to undisclosed ownership structures and non-responsive entities add to the concerns about accountability and oversight.

Risk Rating: RED – Given the opacity surrounding the company’s operations and the potential regulatory issues, SMTM Holding should be approached with extreme caution. Businesses and individuals considering engaging with this entity should conduct thorough due diligence and remain aware of the potential financial and legal implications.