If online gambling compliance had a jurors’ bench, the RevDuck network case would be Exhibit A: a whistleblower dossier revealing how brands like Holyluck, Trueluck, and Kokobet rotate shell companies and use domain mirroring to evade Dutch regulators while operating through SoftSwiss’s Affilka affiliate infrastructure.
FinTelegram reporting indicates RevDuck uses rotating Costa Rican “SRLs” — shifting legal entities depending on visitor origin — and deploys Dutch-language URLs, session redirections, and geo-targeted content that suggests deliberate circumvention of the Netherlands Gambling Authority’s (KSA) compliance frameworks. Critically, these offshore brands are not listed on European regulator public registers, yet they freely accept Visa, Mastercard, bank transfers, and crypto deposits from Dutch IPs.
SoftSwiss’s affiliate platform Affilka is marketed as a neutral tracking solution. But investigative reporting suggests it may be a core operational weapon in large-scale regulatory circumvention.
The RevDuck network — linked to brands such as Holyluck, Trueluck, Kokobet, and others — allegedly used Affilka to coordinate traffic, rotate domains, and dynamically redirect users based on IP location. Dutch players, for example, were funneled to mirror sites using Dutch language, local payment methods, and geo-spoofed compliance messaging, despite the brands lacking licenses from the Netherlands Gambling Authority.
Corporate registries show RevDuck entities repeatedly dissolving and re-emerging under new Costa Rican or offshore shells, while technical infrastructure, affiliate IDs, and payment flows remain unchanged — a pattern investigators describe as “legal entity hopping.”
SoftSwiss executives, including Trafimovich and Kashuba, are named in whistleblower reports as being aware of these operational realities. Critics argue that providing affiliate tools to unlicensed operators is not inherently illegal — but continuing service after clear evidence of jurisdictional targeting and regulatory breach may constitute willful facilitation.
Affilka’s role illustrates how modern iGaming compliance failures are no longer accidental — they are engineered.
