LONDON, UK, February 2026 – FinTelegram, a cyber-finance intelligence platform focused on financial crime and regulatory risk, has raised compliance concerns involving payment facilitator Klyme and UK-based Open Banking provider Yapily, following a misdirected internal email that sheds light on how complaints tied to potentially unlicensed gambling merchants are handled within payment networks.
The concerns stem from a compliance-related email inadvertently shared with a customer in February 2026. The message, originally intended for Klyme, referenced a complaint concerning an online casino alleged to be operating without proper authorization in the Netherlands. The complaint had first been submitted by a user in December 2025, citing concerns about the merchant’s regulatory status and cross-border activity. The communication provides insight into internal review processes and illustrates how complaints are routed within multi-layered payment ecosystems.
According to FinTelegram’s review, the email indicates that instead of escalating the matter against the merchant, the reporting user’s access to payment services may have been restricted. The correspondence also referenced geographic access controls in Lithuania, despite the complaint relating to alleged regulatory breaches under Dutch law. This discrepancy has prompted questions about jurisdictional oversight and the processes used to assess cross-border compliance risks. It also highlights the complexity of enforcing regulatory standards when payment activity spans multiple EU member states.
FinTelegram’s analysis highlights Klyme’s role as the intermediary responsible for merchant onboarding and integration, including merchants linked to the casino referenced in the complaint. While Yapily provides the underlying Open Banking infrastructure and regulated payment initiation services, Klyme operates at the merchant-facing layer of the payment flow. This structure enables merchants to access account-to-account payment rails through a layered model involving both infrastructure providers and facilitators.
Such arrangements are common within the Open Banking ecosystem, where infrastructure providers supply API connectivity to regulated banking institutions, and intermediaries manage merchant acquisition, onboarding, and transaction flows. While the model supports innovation and scalability, it also requires clearly defined compliance frameworks. FinTelegram’s findings suggest that if responsibilities for monitoring, escalation, and merchant due diligence are fragmented, oversight gaps may emerge.
The report raises broader questions about transaction monitoring procedures, complaint escalation frameworks, and accountability allocation across the payment chain. In particular, it underscores the importance of clear documentation, internal controls, and consistent application of risk policies when dealing with high-risk sectors such as online gambling. The time gap between the initial complaint in December 2025 and subsequent internal communication in February 2026 may indicate potential delays in reviewing or escalating higher-risk merchant activity.
As Open Banking adoption continues to expand across Europe, intermediaries and infrastructure providers are playing an increasingly interconnected role in facilitating account-to-account payments and financial data access. This evolution has drawn growing regulatory scrutiny, particularly in sectors where licensing and consumer protection standards vary across jurisdictions. Cross-border merchant activity, combined with layered payment structures, places heightened importance on transparent compliance controls and clearly defined oversight responsibilities.
FinTelegram’s findings are expected to prompt further examination of how payment facilitators and Open Banking providers manage merchant risk exposure, especially in industries subject to strict licensing regimes and enhanced regulatory supervision. The case may also contribute to broader discussions around supervisory expectations for intermediaries operating within regulated financial infrastructure.
About FinTelegram
FinTelegram is a cyber-finance intelligence platform focused on uncovering financial crime risks, regulatory violations, and high-risk market activity through evidence-based investigative reporting. The platform provides compliance professionals, regulators, and journalists with structured insights into emerging risk signals, cross-border regulatory challenges, and systemic vulnerabilities within digital finance ecosystems.
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