PayWithClick & Versus Odds: Licensing and Compliance Questions

The financial services industry operates within a strict regulatory framework designed to ensure transparency, consumer protection and compliance with anti-money laundering laws. Entities involved in payment processing, particularly those leveraging open banking technology, must provide clear disclosures regarding their licensing and regulatory status.

PayWithClick, a UK-based payment technology provider, has recently come under scrutiny regarding its role in payment facilitation and its compliance with UK financial regulations.

Regulatory Status and Licensing Questions

PayWithClick presents itself as a streamlined payment solution, promoting partnerships with banks across the UK and Europe. Its marketing suggests a role in payment processing that could reasonably lead users to believe the company operates as a licensed payment service provider.

However, upon closer examination, the company does not hold direct authorization from the Financial Conduct Authority #FCA. Instead, it claims to operate under a licensing arrangement with Yapily Connect UAB, a Lithuania-based open banking provider that is FCA-authorized to provide account information and payment initiation services.

Despite these claims, there is no publicly available confirmation of PayWithClick's registration as an agent or partner under Yapily’s FCA authorization. The FCA’s register does not list PayWithClick, nor does Yapily 's own publicly available documentation provide evidence that PayWithClick is officially recognized as an authorized entity under its licensing umbrella.

This lack of transparency raises concerns about whether PayWithClick is operating within the full scope of regulatory requirements. While companies that function as intermediaries may lawfully rely on third-party licenses, regulatory best practices dictate that their legal status should be explicitly stated and easily verifiable through official channels.

Marketing and Potential Misrepresentation

PayWithClick’s website contains language that could be interpreted as implying direct FCA authorization. Statements such as "partnered with top-tier banks", "your one-stop solution for streamlined payments" and "we are revolutionizing payments" create the impression that PayWithClick is a primary payment provider, rather than a technology intermediary relying on a third party’s regulatory approval.

This distinction is critical, as misrepresenting or overstating regulatory status can lead to increased scrutiny from financial authorities. Companies involved in payment processing are expected to ensure that their marketing materials do not mislead clients or merchants regarding their actual regulatory role.

Removal from Versus Odds B.V. Casino Websites

As part of our investigation, we identified PayWithClick as a listed payment provider on websites operated by Versus Odds B.V., a Cura?ao-based entity, which is licensed by the #CGA Curacao Gaming Authority , that operates a network of online casinos. These casinos actively target players in regulated jurisdictions, including the UK, Germany, Malta and Sweden, without obtaining the necessary gambling licenses in those jurisdictions.

Following our inquiries into this matter, PayWithClick's logo has now been removed from the casino website. While it remains unclear whether PayWithClick had an active role in processing payments for Versus Odds B.V. beyond November 2024. Its removal as a payment option represents one less transaction route for an operator like Versus Odds which is engaged in unlicensed gaming activities.

Company Response and Compliance Updates

Upon being contacted regarding these concerns, Mark Perks and Christopher Jenkins, representing PayWithClick, engaged in constructive dialogue and took immediate steps to address regulatory deficiencies on their website. The company has since:

• Implemented a Terms & Conditions page that explicitly outlines its role in payment facilitation.
• Updated its Privacy Policy to align with UK regulatory disclosure requirements.
• Clarified that it does not act as a direct Third-Party Provider (TPP) but rather facilitates payments through Yapily.

These changes indicate a willingness to improve transparency and bring the company’s public disclosures more in line with regulatory expectations.

Outstanding Questions and Regulatory Gaps

Despite these corrective actions, two key regulatory concerns remain unresolved:

• There is still no verifiable evidence that PayWithClick is officially registered under Yapily’s FCA authorization. While the company states that it operates under Yapily’s license, neither the FCA register nor Yapily’s own published materials confirm this arrangement. Given that Yapily is a regulated entity, any intermediary or reseller operating under its authorization should be easily identifiable through official records.
• The company’s marketing language continues to present a regulatory grey area. While the website now provides more legal clarity, some of its wording may still lead consumers or merchants to believe that PayWithClick is a licensed payment provider rather than a technology company leveraging a third-party license. This could warrant further scrutiny from regulatory authorities.

Regulatory Progress Made, but Key Questions remain

PayWithClick has taken important steps toward greater regulatory compliance and transparency following external inquiries. The swift implementation of updated terms and policies demonstrates a proactive approach and the removal of its logo from Versus Odds B.V.’s casino website reduces the risk of association with unlicensed gambling operations.

However, the lack of explicit verification of its regulatory status under Yapily remains a significant concern. Until PayWithClick’s authorization under Yapily’s FCA license is publicly confirmed, questions regarding its legal standing within the UK’s financial regulatory framework will persist.

For companies operating in payment processing and financial technology, compliance is not merely about technical adherence to regulations; it also requires clarity and full transparency. PayWithClick has made progress in this regard, but further steps are necessary to ensure that both regulatory authorities and consumers can verify its licensing status with confidence.