Leaked documents describe third‑party payments via “SOFTSWISS accounts” and Germany routes

An internal report supplied by a whistleblower gave FinTelegram 39 primary pieces of evidence on 10 October 2026, including payment manuals that describe transfers to third parties via accounts labelled “SOFTSWISS accounts”, processing fees and approval procedures. The documents list four payment methods with explicit charges — bank transfer, cryptocurrency, Skrill and Neteller — and include chargeback guides, 2024 operational reports citing Germany, and corporate records linked to Dama and Hollycorn.

SOFTSWISS payments: what the manuals say

The package includes a manual titled Payment to Third Parties that instructs clients how to pay third parties using accounts referred to as “SOFTSWISS accounts”. The document describes four methods and the fees stated in the manual itself:

• Bank transfer: €50 per account plus bank fees

• Cryptocurrency: 1.35% plus €50

• Skrill: 1.25% plus €50

• Neteller: 0.25% plus approximately €1 and €50

The manual requires for bank transfers an invoice and a signed agreement with the third party; invoices may only be issued to Dama or Hollycorn, and potential white‑label contracts linked to those entities are mentioned. It also states that a Business Account Manager must be listed as approver and that clients must specify the casino brand involved. After processing payments, bank confirmations may be requested.

The document is not limited to describing payment APIs: it sets out a workflow composed of payment instructions, contractual documentation, commercial fees, approvals and bank confirmations. The package does not by itself prove which legal entity owns the accounts, who executed the transfers or who collected the €50 fees.

Chargebacks guide and the risk of operating in unlicensed markets

A second document, Chargebacks & Non-Settled Deposits: A Reference Guide for Operators, addresses why some chargebacks are not contested. One section states that processing transactions “with hidden features or operating in markets without a local license” can expose the payment provider and the operating organisation to greater risk. The text adds that escalating certain disputes to banks or arbitration can increase that risk and that some payment systems refuse to disclose relationships with high‑risk merchants to card networks.

“processing transactions with hidden features or operating in markets without a local license”

— passage reproduced from the chargebacks manual

The manual also covers routine operational matters: dispute windows, processing fees, 3D Secure requirements and the distinction between card chargebacks and unresolved bank settlements. The document does not identify specific providers or transactions tied to the practices described, so it does not constitute proof of wrongdoing or criminal conduct by an identified provider.

FinteqHub 2024 reports and the explicit mention of Germany

The leak also contains weekly FinteqHub reports from 2024 that record changes to payment methods for casino brands linked to Dama, Hollycorn and N1 Interactive. Selected entries include:

• 4 January 2024 — CCPSP76: deposits launched for Dama and Hollycorn brands, including Germany among affected markets.

• 29 January 2024 — APM15: Direct Banking disabled for Germany on Dama, Hollycorn and N1 Interactive brands.

• 23 September 2024 — APM61: OpenBanking enabled for standard deposits on Dama brands, with Germany listed.

• 9 December 2024 — APM61: OpenBanking disabled on previously enabled brands due to provider restrictions, including Germany.

The September and December reports document the activation and removal of the same coded method (APM61/OpenBanking). The inclusion of Germany as an operational parameter indicates the payments management environment considered individual markets when configuring methods. Germany regulates its online gambling market under the Glücksspielstaatsvertrag 2021 and maintains an official whitelist of authorised operators; however, a technical configuration labelled Germany does not by itself prove that a German player completed a deposit or that a brand lacked permission at that time.

Why Dama and Hollycorn appear in the operations

Dama and Hollycorn already appeared in earlier investigations related to SOFTSWISS. A WIPO file cited in prior reports linked names such as Stable Aggregator Limited, Hollycorn N.V., Dream Finance OÜ and Pavel Kashuba within the same corporate group as declared by the parties. In this leaked collection, Dama and Hollycorn appear as authorised recipients of invoices within the payment procedure that uses the SOFTSWISS label.

The package also includes Dama’s 2025 financial statements, which record loans receivable from Dream Finance OÜ and Stable Tech N.V., and a significant loan payable to Hollycorn in the 2024 comparative figures. Those ledger entries document financial relationships but do not prove common beneficial ownership or specific cash flows.

The compliance issue: who controlled SOFTSWISS payments

The documents combine technical payment orchestration architecture, operational instructions and corporate records. The architecture described by FinTelegram in September 2026 demonstrates the ability to identify merchants and projects, select integrations and terminals, route transactions between providers and record information at the transaction level. The new instructions detail approval, documentation and confirmations.

Critical contractual and banking questions remain unanswered: which legal entity owned the “SOFTSWISS accounts”, what bank mandates existed, how were KYC/Know Your Business procedures applied, and what merchant information was passed to acquirers, card networks and payment entities. For banks, acquirers and payment regulators, concrete concerns include merchant identification, origin and destination of funds, monitoring of high‑risk activity and exposure to sanctions. For gambling regulators, the focus is operator responsibility and the suitability of outsourced functions.

What the evidence shows and what still needs proof

FinTelegram received 39 primary pieces of evidence indexed and verified by SHA-256 against the supplied inventory, which confirms the package’s internal consistency but not the authorship or independent authenticity of the documents. The set documents:

• payment procedures to third parties labelled “SOFTSWISS accounts” with fees and approval requirements;

• an operational chargebacks guide that mentions risks from unlicensed markets and lack of merchant‑acquirer transparency;

• dated changes to payment routing that include parameters for Germany in 2024;

• corporate records and financial relationships relevant to the network linked to SOFTSWISS.

Although the documentation suggests possible operation of SOFTSWISS in payment functions without authorisation, it does not by itself prove that specific transactions were concealed or that payment providers facilitated illicit activity. A full assessment requires authentication of the manuals, identification of contracting entities, bank mandates, merchant/PSP mappings and at least one verifiable transaction‑to‑settlement trail.

Open questions the investigation must resolve

FinTelegram sets out key questions to progress the investigation: which legal entities owned or operated the “SOFTSWISS accounts” and who received the €50 fee? What contractual and commercial roles did Dama and Hollycorn have in the procedure? Which providers or practices do the passages about “hidden features” and unlicensed markets refer to? Which brands and processors participated in the APM61 configurations labelled with Germany in 2024? What merchant and gambling activity information was passed to acquiring banks and card networks?

FinTelegram has not received responses from SOFTSWISS, Dama, Hollycorn or the payment entities mentioned at the time of publication. The outlet requests further documentation from industry insiders, casino operators, former employees and compliance officers who can identify account ownership, payment mandates, merchant records, routing instructions and actual settlement flows.

Isabela Fuentes, Payments Correspondent, will continue coverage and update the piece if substantive explanations or corrections are received.