Dear Sir/Madam,
I am writing to formally raise a serious complaint regarding bank transfers taken from my account in connection with Instaspin.com, which were processed via PASSPOINT Sp. z o.o., reportedly banking with Banking Circle.
Following extensive research into the entity that received my funds, I have identified significant regulatory and compliance concerns that call into question the legitimacy of these transactions.
PASSPOINT Sp. z o.o. is registered in Poland under PKD classification 64.99.Z ("other financial service activities"). However, this classification is extremely broad and does not constitute a licence to provide regulated payment services. It merely describes the type of activity the company declares.
In Poland, any entity operating as a payment service provider (PSP) must be authorised or registered with the Polish Financial Supervision Authority (KNF), typically as a:
National Payment Institution (KIP), or
Small Payment Institution (MIP)
If a company is not listed within KNF registers, it is not authorised to provide regulated payment services. Based on available information, there is no clear evidence that PASSPOINT Sp. z o.o. holds such authorisation.
Furthermore, the situation is significantly more serious given that these payments are linked to gambling activity. Poland enforces strict gambling regulations under the Polish Gambling Act, and payment providers are expected to:
Block transactions related to unlicensed gambling operators
Not facilitate offshore or unregulated gambling services
The operator in question appears to be licensed in Anjouan (Comoros), a jurisdiction which is not recognised within the UK or EU regulatory frameworks. As such, a properly regulated Polish PSP should not be facilitating these transactions.
Based on these findings, the following serious red flags arise:
No confirmed KNF authorisation as a payment institution
Lack of transparency regarding PASSPOINT’s role in processing these payments
Acting as an intermediary between myself and the gambling operator
Potential misclassification of transactions, including the use of incorrect Merchant Category Codes (MCCs), which may have disguised the true nature of the payments
These issues raise substantial concerns regarding regulatory breaches, consumer protection violations, and potential circumvention of financial safeguards.
Given the above, I formally demand:
A full and immediate refund of all payments processed via PASSPOINT Sp. z o.o. in relation to Instaspin.com
Full disclosure of the legal and regulatory basis under which these transactions were processed
Confirmation of PASSPOINT’s regulatory status and authority to act as a payment intermediary in this context
If this matter is not resolved promptly, I will have no hesitation in escalating complaints to the appropriate regulatory and enforcement authorities, including:
The Polish Financial Supervision Authority (KNF)
Relevant UK financial and consumer protection bodies
Authorities overseeing the Anjouan licensing framework
I expect an urgent response confirming that my funds will be returned without delay.
Yours faithfully,




