Whistleblower Manuals Outline SOFTSWISS Payments Flows, Fees and Germany Routes

A whistleblower provided FinTelegram a packet of internal-style payment manuals and 2024 routing reports that describe third-party transfers through accounts labelled “SOFTSWISS accounts,” itemise processing fees and approval workflows, and record payment-method changes affecting Germany. The evidence collection contains 39 indexed principal exhibits, SHA‑256 verification matching the inventory, and specific documents titled Payment to Third Parties and Chargebacks & Non-Settled Deposits: A Reference Guide for Operators.

What the Payment to Third Parties manual reveals about SOFTSWISS payments

The manual titled Payment to Third Parties sets out a multi-step workflow for customers requesting transfers through accounts described in the document as “SOFTSWISS accounts.” It lists four supported payment methods and the fees attached to each:

• Bank transfer: €50 per account plus bank charges

• Cryptocurrency: 1.35% plus €50

• Skrill: 1.25% plus €50

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

The document states that SOFTSWISS charges a €50 processing fee for every payment request in addition to payment-system charges. For bank transfers the customer must supply an invoice and a signed third-party agreement; the manual specifies that invoices may be issued only to Dama or Hollycorn. The manual also mentions that white-label contractual documents may involve those same entities.

Approvals are explicit. A Business Account Manager is named as an approver, customers must specify the relevant casino brand, and bank payment confirmations may be requested after processing. The manual therefore records commercial fees, contractual requirements and an approval workflow rather than merely listing integration endpoints or API parameters.

The documents do not on their face identify the legal owner of the bank or merchant accounts labelled “SOFTSWISS accounts,” who receives the €50 fee, or which licensed entity, if any, executes regulated transfers. The phrase “SOFTSWISS accounts” in the material is descriptive; it does not by itself prove that a SOFTSWISS‑branded company holds client funds or operates as a regulated payment institution.

Chargeback guidance and the disclosure risk to acquirers

The supplied chargeback manual, Chargebacks & Non-Settled Deposits: A Reference Guide for Operators, discusses dispute processes and includes a notable passage on operational risk:

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

That passage explains why the guide recommends caution when escalating disputes to banks or arbitration: doing so may expose the payment provider and the operator-side organisation to additional risks. Another section records reluctance by some payment systems to disclose relationships with high‑risk merchants to card networks.

The guide otherwise covers standard operational matters: dispute deadlines, processing fees, 3D Secure requirements and the distinction between card chargebacks and failed bank-transfer settlements. The document does not name specific payment providers, transactions or responsible individuals tied to the described hidden features. As a result, it raises a compliance question about what merchant information was actually disclosed to acquirers, card networks and payment institutions in practice.

Germany appears in FinteqHub routing reports from 2024

The whistleblower package includes FinteqHub weekly reports from 2024 that log activation and suspension of payment methods for brands associated with Dama, Hollycorn and N1 Interactive. Selected entries in the supplied timeline read:

• 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

Those September and December entries document the activation and later withdrawal of an Open Banking route coded APM61, with Germany an explicit market parameter. Germany operates a regulated online‑gambling market under the Glücksspielstaatsvertrag 2021 and maintains an official whitelist of authorised operators and domains. A configuration naming Germany in a payment-management environment does not alone prove a German player deposited, that a specific brand lacked permission in 2024, or that a processor knowingly facilitated unlawful gambling transactions. Conclusive findings would require matching brand and domain histories, licence records and transaction-to-settlement trails.

Why Dama, Hollycorn and related corporate links matter

Dama and Hollycorn appear repeatedly across the manual and the evidence package. The Payment to Third Parties manual lists invoices that may be issued only to Dama or Hollycorn. The collection also includes a published copy of Dama’s 2025 financial statements, which record loans receivable from Dream Finance OÜ and Stable Tech N.V., and a significant Hollycorn loan payable in the 2024 comparative figures.

Earlier FinTelegram reporting documented public connections between Dama, Latiform and the Platincasino environment, and a WIPO decision recorded that Stable Aggregator Limited, Hollycorn N.V., Dream Finance OÜ and Pavel Kashuba described themselves as part of the same overarching business group. The WIPO finding did not name Dama as a complainant and does not establish ownership; the new manuals reinforce operational links by placing Dama and Hollycorn as invoice recipients in procedures that use the SOFTSWISS name.

Those accounting entries document commercial relationships but do not on their own demonstrate common beneficial ownership or individual cash movements.

Open compliance and regulatory questions

The assembled material sharpens a set of compliance questions relevant to banks, payment institutions and gambling regulators. Key issues include merchant identification and Know Your Business procedures, source and destination of funds, monitoring for high‑risk transactions, sanctions screening, and accurate disclosure of gambling activities to acquiring banks and card networks. For gambling regulators the focus is on control exercised by the formal operator and the suitability of outsourced functions. For payment regulators the question is whether any entity performed activities requiring authorisation or relied on lawful exclusions or agency arrangements.

None of those matters can be resolved from branding or terminology alone. Authentication of the manuals, identification of contracting entities, bank‑account mandates, merchant‑to‑PSP mapping records and a verifiable transaction‑to‑settlement trail are necessary to reach definitive conclusions.

What the evidence establishes and what remains open

FinTelegram received 39 indexed principal exhibits with SHA‑256 verification matching the inventory. The supplied documents support the existence of a documentary record describing: third‑party payment procedures involving accounts labelled SOFTSWISS, commercial fees and Dama/Hollycorn invoices; operational chargeback guidance referencing licensing and merchant‑transparency risks; dated payment‑route changes naming Germany; and corporate and financial records relevant to the broader SOFTSWISS‑associated ecosystem.

The materials suggest operational arrangements that merit regulatory and investigative follow-up but do not, by themselves, prove unlawful payment processing or deliberate concealment of particular transactions. The package identifies concrete lines of inquiry rather than delivering final legal findings.

Next steps FinTelegram is seeking and regulatory implications

FinTelegram has requested comment from the relevant SOFTSWISS, Dama, Hollycorn and payment‑service entities and invites insiders to provide documents identifying account ownership, payment mandates, merchant registrations, routing instructions and settlement flows. The report lists focused questions for the next investigative stage, including which legal entities owned the accounts labelled “SOFTSWISS accounts,” which entity received the €50 processing fee, and which casino brands and processors were present in the Germany‑labelled APM61 configurations during 2024.

Payments vendors and compliance teams should review merchant‑visibility controls and bank‑facing disclosures. Operators and regulators must determine whether contractual and banking arrangements accurately reflect who exercises operational control over funds.

For payments coverage and background on related regulatory issues see payments and FinTelegram’s prior reporting on regulation.