This is the news, emanating from the DCMS just a few days ago, which I suspect will not be welcome news to the online gambling industry. Credits go to the APCW 2nd April video for bringing this information to my attention.

I’ve commented also in my own UK online gambling article.

The plans came to light in an announcement by the DCMS of a consultation on the regulatory future of remote gambling in Great Britain. The full details of the proposals can be found as follows:

Main consultation document

Summary document

I have also produced a user-friendly version, with contents links for convenient navigation to the various sections – see my consultation document copy. If you want to read the full document, this version definitely facilitates the process.

I’ll summarise the situation as succinctly as possible:

Basically, the DCMS, the governmental department directly responsible for remote (online) gambling in the UK, is concerned about the current imbalance represented by the existence of two types of online gambling operations with access to UK customers:

• Those which are located in the UK and fully covered by UK legislation.
• Those which are located outside the UK.

The latter category represents the vast majority, and this is then divided into two groups:

• EEA member states, plus Gibraltar, Isle of Man, Alderney, Tasmania and Antigua & Barbuda.
• Everyone else.

It is the problems presented by these two non-UK based groups that the proposals seek to address.

The problems under consideration, all outlined in the document, centre on the lack of a guaranteed regulatory framework for non-UK based operators, and the risks this presents to UK customers.

First, the DCMS considered four possible options for EEA member states, which I quote here:

• Do nothing.

• Introduce non-statutory changes to the system and increased regulatory co-operation.

• Introduce the need for such operators to obtain a licence to enable them to advertise in the UK.

• Introduce the need for such operators to obtain a licence to enable them to transact with British consumers and advertise in the UK.

The option planned for adoption is the last, which is the most far-reaching.

Second, for non-EEA member states (plus Gibraltar, Isle of Man, Alderney, Tasmania and Antigua & Barbuda), The DCMS considered three possible options:

• Improve the white listing system for non-EEA jurisdictions.

• Develop a more streamlined white listing process as well as introduce licensing for operators in white listed jurisdictions.

• Abolish the white list and introduce a licensing system for operators in all non-EEA jurisdictions.

The option that the government proposes to adobt here is the second, the more “streamlined” whitelist.

To summarise to date: EEA member states (plus Gibraltar, Isle of Man, Alderney, Tasmania and Antigua & Barbuda) would need a to obtain a license to transact with UK customers; non-EEA member states would need to be whitelisted.

The proposals are currently very flexible on matters of compliance. They do suggest the following safeguards, however:

• A mirrored, tamper-proof server containing a full copy of gambling transaction records for inspection by the Commission (in Britain or elsewhere)

• A regulatory representative in Britain

• A UK registered company and certain office functions located in Britain

• More enhanced regulatory returns

• A bond lodged in Britain or payable to the Commission in the event of default.

On the question of actual enforcement: the consultation considers, and rejects, prohibitive and punitive measures (such as extradition applications for offenders, the actual blocking of transactions to non-licensed operators by UK banks, ISP blocking, and so on), preferring to focus on cooperation, rather than than sanctions, as a means of ensuring compliance.

Which is all very “British”.

They also say as follows with regard to prohibitionist measures:

We have considered whether to make it an offence for a British citizen to gamble with an unlicensed provider.

At this stage we are not minded to consider such a provision further as it seems disproportionate to the harm caused and raises issues of informed adult choice.

We do not intend at this stage to introduce an offence that would criminalise the consumer for gambling with an unlicensed operator.

This suggests that they do not rule out a US-style prohibitive approach at some future point – though I suspect this is very unlikely.

Issues of raising consumer awareness, such as a dedicated section of the Commission’s website put aside for facts relevant to the player customers, are also considered as part of the compliance / enforcement considerations. Consumers could thuswise:

• Check the licensed status of operators.

• Learn which operators have had their licences suspended or revoked.

• Learn which operators are trying to access the market without a licence (we envisage this would usually refer to repeat offenders).

• Anonymously or otherwise, inform the Commission of any operators that have been targeting British consumers without a licence.

The actual consultation document is long, but not too long. It’s definitely worth reading if these matters are of interest to you.

The proposals under consideration will certainly tighten up the online gambling scene as it relates to the UK-based customer. As such, I support them. However, I suspect the industry as a whole will not view this development with any great affection, as it represents more cost and, crucially, closer scrutiny.

Close scrutiny and online gambling are not happy bedfellows.

The Alderney Gambling Control Commission? A sham of incompetence.

The Malta Lotteries And Gaming Authority? Actions bordering, at times, on criminal.

However, in recent weeks, two regulators have issued judgements which give hope for the future. One close to home in the UK, the other on the far-off shores of the Mohawk Indian reservation in Canada. Both, rather typically, centred around the casinos’ misuse of their bonus programmes to the disadvantage of their customers.

In the first case, sportsbook and casino Bet365 promoted a free bet in a UK television advert, with the promise of further free bets if the first one was successful. Customers claimed the bet, and those who won went on to claim again; another win, and another free bet claim. And so on and so on.

Bet365 didn’t like this, and, in time-honoured online gambling fashion, refused the bets to some customers with a variety of excuses: customers showed “unusual patterns”; customers were suspected (not proven, of course) of laying off the bet elsewhere for a guaranteed profit with the bonus, which Bet365 considered “bad business”.

Oh dear.

How despicable – customers looking for ways to win. What in the world were they thinking, trying to win money in a casino?

Anyway, some customers complained to the Advertising Standards Authority, and an Adjudication on Bet365 Group Ltd was promptly issued. Here is a part of the judgement – read it and weep, online gambling operators worldwide:

We understood that Bet365 excluded a proportion of customers who they deemed to be non-recreational players; however, we considered that without defined criteria, it appeared that Bet365 had excluded customers from the offer when they were winning or were no longer profitable.

We noted the ad did not state that customers who made each-way bets, won frequently on similar bets, or used betting exchanges would be excluded from the offer.

Although we understood that Bet365 believed the viewers were exploiting the offer, in the absence of qualification in the ad to make Bet365s limitations on the offer clear, we concluded the ad was likely to mislead.

The ASA discounted all of Bet365′s whinging and whining about “non-recreational players” who were “bad for business”, on the basis that since none of those copouts were stated in the terms of the deal, they could not be arbitrarily applied afterwards as an excuse for non-payment.

Or, if I can summarise the ASA judment in my own words: “This is what you said; this is what you did; what you did wasn’t what you said you’d do…so please go take a running jump”.

This was a perfectly thought out and articulated response from the ASA. What a refreshing change to see a regulator of some description actually doing its job and making a fair call.

Players 1 / casinos 0.

The next case was one I was involved with myself. A player contacted me, saying that he’d had a €10,000 cashout confiscated by a Microgaming casino group, on the basis of infringing the conditions of the bonus he’d received on his deposit. He had indeed, but the terms were so cleverly hidden by the casino that breaking them was almost a certainly.

To cut a long story short, the player filed a complaint with the Kahnawake Gaming Commission. The KGC has long been something of a running joke on the online gambling scene, allowing its licensees to get away with almost anything. However, I had heard that a new complaints officer had recently been appointed, and that the Commission was generally trying to get its act together and be taken seriously as a genuine regulator. But I wasn’t holding my breath.

As such, the Kahnawake judgement left me astonished – see the full complaint against UK Casino Club, of which here is an central extract:

Mr. N’s dispute centres on the argument that, at the relevant time, some additional terms and conditions that were posted on the Casino’s site regarding signup bonuses (the “Terms and Conditions – Multiple Bonus Promotion”) did not clearly incorporate the provisions of the Casino’s T&C.

However, given the fact that Mr. Niemz did accept the T&C and that his pattern of play subsequently breached Clause 13(i) of the T&C, we cannot conclude that it is reasonable to direct the Casino to reimburse Mr. Niemz for 100% of the amount of the disputed amount – 10,000 Euro.

We do accept that the Casino must bear some responsibility for failing to make it clear that the Terms and Conditions – Multiple Bonus Promotion incorporated the provisions of the Casino’s T&C.

In view of the foregoing, we hereby direct that:

1. The Casino must, on or before 8:00 p.m ET on February 18, 2010, deposit 50% of the disputed amount – i.e. 5,000 Euro – into Mr. N’s account and permit him to withdraw this amount, and

2. The Casino must immediately amend its Terms and Conditions – Multiple Bonus Promotion to clearly indicate that they incorporate the provisions of the T&C.

This was an excellent resolution, as much for its sheer unexpectedness as for the fact that it was fair. Way to go, Kahnawake.

Players 2 / casinos 0.

I’ve commented on both these cases in more detail in my Kahnawake Gaming Commission and Bet365 posts.

I had assumed that hell would freeze over before any official “watchdog” or “regulator” would arbitrate a conflict between player and gamnbling operation and find in the player’s favour. As such, I’m pleasantly surprised – or, to be a bit more honest, entirely gob-smacked – at the outcomes of the cases handled by the UK ASA and the Mohawk KGC.

It’s not all bad, folks.

The following was reported by eGaming Review:

Mastercard crackdown leaves US players unable to pay

US-facing operators have been hit by an overnight crackdown on online gambling payments by credit card giant Mastercard. The US company is believed to have toughened its stance on the widespread practice of operators coding egaming transaction as other kinds of online commerce, which will all (sic) its US customers from using their cards to gamble online.

Rival US card giant Visa is rumoured to have taken a similar measure, although this could not be confirmed at the time of writing.

The action is a sign that banks and payment companies are preparing for implementation of America’s Unlawful Internet Gambling Enforcement Act (UIGEA), which bans the facilitation of online gambling by payment companies. This was originally supposed to have been enforced from 1 December 2009, although the US treasury later approved a delay allowing companies until 1 June 2009 to comply…(more)

In the followup article, it was established that Visa was also implementing the restriction on US customers:

Visa declining US egaming payments

The crackdown on US online gambling credit card payments that began on Wednesday is being operated by Visa as well as rival US credit card giant Mastercard, EGRmagazine has now confirmed, with tens of thousands of US online gamblers likely to have been affected.

As reported yesterday, US-facing operators were hit by an overnight tightening of restrictions on the use of credit cards for egaming transaction ahead of the implementation of America’s Unlawful Internet Gambling Enforcement Act (UIGEA) law on 1 June, which bans the facilitation of online gambling by banks and other payment companies.

The action was at the time of writing confirmed as applying to US-registered cards issued by Mastercard, but rumours that a crackdown had also been launched by Visa had not been substantiated. However eGaming Review has now confirmed that these too are subject to the ban. Repeated attempts to use a US-registered Visa card by an eGaming Review reporter on PokerStars last night were declined, with the American poker giant sending an email in response that read:

“Status: DECLINED.

Your credit card transaction has been declined. If your credit card information was entered correctly and you have sufficient funds, your transaction was probably declined due to Internet gaming restrictions set by your credit card issuer…” (more)

So:

In order to better avoid of the USA anti-gambling radar, some gambling operators accepting US customers have been coding their Visa and Mastercard transactions in a manner as to not appear as gambling-related. The correct “internet gambing” merchant code is 7995; some operators have been putting their transactions through thus, and taking a chance as to whether or not the deposit goes through; others have not.

To put it another way: they’ve been trying to cheat the system.

Since the February crackdown appears to have been applied retrospectively to January, players now face the prospect that their deposits – with which they will have had plenty of time to play, and lose or win on accordingly – will now almost certainly not be honoured by Mastercard and Visa, resulting in an effective chargeback. This may have a knock-on effect when it comes to winning players receiving their payments.

And while the general tone of the internet discussion on this matter has been one of condemnation of the US administration in the wielding of its prohibitionist axe, I would personally like to ask this question: why should we not lay the blame for this squarely at the door of the online gambling operators, still dealing to US customers, who tried to cheat the system in the first place?

Their motives were purely profit-driven in attempting to stay below the radar. But it is the players, who committed no wrongdoing, who may suffer as a consequence.

It is of course also the case that not all operators have been trying to cheat the system. Some, such as Pokerstars, have been coding their transactions upfront as “internet gambling”; in fact, in another EGR article they made a point of distancing themselves from the practice:

PokerStars does not, nor ever has engaged in the practices of mis-coded credit card transactions. We have therefore been unaffected by any crackdown by Visa or MasterCard to close down such mis-coded processing accounts.

So, all well and good for the folks who’ve behaved honestly.

But the casinos and sportsbooks that have been trying to put one over Mastercard and Visa, whatever the ultimate cost they pay as a result of this matter may be, do not deserve any sympathy.

They particularly do not deserve any sympathy from those players who may end up seriously inconvenienced, and possibly out of pocket, as a result of their duplicity.

There’s been, predictably enough, quite a lot of discussion of this move that has such potential sweeping effects on the industry: see the No more Mastercard article at Bookmakers Review, and the Mastercard blocks US poker discussion at 2+2 Poker (“Intentionally mis-coding a CC transaction is a crime in many places around the globe.” – I quite agree); also my own Mastercard and Visa online gambling crackdown article, and one tiny piece of mainstream media coverage, the Timesonline online gambling comment – actually, quite funny, so I’ll quote it:

Operators including PokerStars which continue to defy the US ban have been hit by a crackdown on internet gambling payments by Mastercard and Visa, the credit card companies.

Great. The one piece of mainstream media coverage gets it completely wrong.

For sale: Personal details of millions of Ladbrokes gamblers, offered to the MoS by a mysterious Australian

The confidential records of millions of British gamblers who bet with top bookmaker Ladbrokes have been offered for sale to the Mail On Sunday. The huge data theft is now at the centre of a criminal investigation after this newspaper was given the personal information of 10,000 Ladbrokes customers and offered access to its database of 4.5 million people in the UK and abroad.

(more…)

This is no fake claim, as attested to by the fact that a “taster” of the full database was handed over by the culprit, fully ten thousand names and highly confidential personal details for the purpose of whetting the potential client’s appetite.

Hey-ho. The gambling industry at its predictable worst.

These incidents are not new – I reported on an occurrence a few years ago in which an online gambling industry leader touted a database of 100,000 UK players to the highest bidder on his forum. Neither are they remotely hard to believe; while the average customer service representative might struggle to access his company’s full customer list, an employee higher up the chain in the IT department should have no such difficulty – a quick copy, paste and save…and it’s time to start lining up the buyers. I daresay the names of four and a half million bona fide gamblers would fetch a very fine price.

And while our data watchdog, the ICO, huffs and puffs its righteous indignation, I’m sure they know there really is very, very little you can realistically do about this. Just one employee with access is all you need.

It serves as a reality check: when you put your details online, they are just that: online. Assume that, at some future point, someone will be hawking your phone number, email and physical address to the highest bidder.

I commented also in my Ladbrokes data theft post, and see also the Racing Post’s Ladbrokes reassure users over data protection article.

Oh well, I don’t know; maybe privacy is overrated.

Almost exactly a year later, lightning appears to have struck twice; one of the top-ranked Microgaming poker rooms, Eurolinx, is currently giving every impression of teetering on the brink: previously fast withdrawals delayed up to three months and counting, with escalating improbable and varied excuses.

In mid May this year, the slow eurolinx withdrawals discussion was initiated on the popular “2+2 poker” forums. I have dissected the discussion at painful length in the Eurolinx withdrawal problems article I’ve written for my own site.

Here are some select highlights:

In mid May, the clearing time for bank transfers had been unexpectedly extended:

The live chat rep told me that it is a delay on the bank side and the transfer was initiated on April 23. Forgive my ignorance of the banking industry but why does an electronic transfer take in excess of 3 weeks to clear?

At the end of May, customer service at Eurolinx appeared to be living in cloud cuckoo land:

As far as I know we have been paying players normally, so in your case I am really sorry that they have not paid you on time.

By early June, problems were apparently acknowledged:

I spoke to the managing director on the phone earlier. He explained to me that they are having problems with their payment processor that is returning a lot of transfers without proper notice.

…followed soon after by an additional couple of excuses:

“Either they have provided us the wrong bank details, or our bank is very strict on big amount withdraw, they will take longer time to check, to ensure there is no money laundering.”

By early July, something almost truth-sounding was emerging:

“Kindly note though that there are some delays in processing at the moment, due to tightened security checks on withdrawals. I am afraid I do not have a strict time frame to provide you with. Your withdrawal will be processed as soon as possible.”

Mid July, and it’s bad news time for the worldly-wise online gambler – the dreaded bonus offer:

“Due to certain payment processor issues we encountered within the last months, we experienced some delays when processing withdrawals. I am aware that you have been affected by this problem and I hope you accept our sincere apologies. In addition, I would like to offer you a special bonus as a form of compensation.

Please find a $500 bonus credited to your Eurolinx poker account…”

A “going out of business sale”? I’ve seen them before.

By the end of July, it all looked good:

“The problem has now been fixed, however, we have some withdrawal backlog to deal with. That is why your withdrawal was not able to process on time.”

So there was a problem after all? What happened to the security checks / wrong bank details / money laundering concerns / the-dog-ate-your-money excuses?

By early August, a player waiting fully three months for his money acknowledged what everyone was thinking:

13th of May here, still waiting. Yes, I do believe they are broke at this point. There is no other reasonable explanation and there hasn’t been one for a long time.

To date, rough player tallies of amounts owed are in the region of half a million dollars. Some payments were being reported over the previous few months, allbethey vastly outweighed by unpaid withdrawal requests, but over the last week or so I am not aware of any player receiving a payment. In addition, customer service appears to have stopped fielding questions and is directing all enquires to the “finance department” – which doesn’t reply.

A Casinomeister warning was issued, and Eurolinx was put on Casinomeister’s no help possible list, for “reasons of veracity”, which I assume means that Bryan Bailey thought they were lying to him about the situation – which is quite likely.

Around the same time, an affiliate posted about a Eurolinx affiliate non-payment issue at the same forum. It would seem that players and affiliates alike are now receiving the cold shoulder from Eurolinx.

Eurolinx is actually licensed in a jurisdiction which borders on reputable – see the terms and conditions page:

“Eurolinx” is a company owned by Eurolinx International NV, whose offices are held at PO Box 6052, Curacao, Netherlands Antilles. It is marketed by same through an exclusive agreement with Eurolinx Ltd, whose offices are held at Vincenti Buildings, Suite 409, 14/19 Strait Street, Valletta Malta. Eurolinx shall heretoafter be referred to as the “Company.”

Eurolinx is licensed in Curacao under the master license #5536/JAZ.

Unfortunately, registering complaints with the Caracao Licensing Authority is probably not going to reunite players with their funds, since the funds appear gone.

But why? How does a poker room lose money?

Earnings come from the rake, the commission taken on a percentage basis from each pot; the players’ deposits are simply redistributed amongst the players during the course of play. In order to make a profit, the rake needs to counterbalance and exceed the room’s operating expenses. Such expenses would be: licence fees, affiliate payments, staff costs and bonuses.

But these costs should be relatively easily calculable and should not end up spiralling out of control.

So where did the money go?

It remains a mystery which I suspect will never be resolved, whether or not Eurolinx manages to get back on an even keel. On the basis of its former reputation and the fact that the room is still technically operational, many players are currently advocating continuing to play, in order to generate more rake income for the room and help to bring it back on track.

This looks like a risky and rather hopeless strategy to me, as the rake was far greater when the problems started than it is now, player good faith notwithstanding.

Welcome to the underwhelming world of Microgaming poker.

…again.

Have a look at the July 17th video and see what you think. It lasts ten minutes.

You can see some select graphics I uploaded in my APCW uses underage children article.

It’s been suggested to me that to complain about the use of ten year olds in online gambling promotion is evidence of excessive political correctness. They do, after all, include a disclaimer at the end, where the mocked-up nature of the enterprise is revealed.

What do you think? For me it’s totally unacceptable; for our American brethren, forever complaining about their governments’ prohibitionist stance with regard to online gambling, to be squarely handing their opponents the gun to shoot them with is verging on lunacy.

Maybe I’m just out of touch.

Another useful aspect of the likes of Moneybookers and Neteller is their incorporation in the UK, putting then under the control of the FSA and answerable to all aspects of UK law, including the 1998 Data Protection Act. They have access to a considerable amount of sensitive customer data – credit cards, bank accounts and all manner of identity verification documentation – so the tight legal framework they are bound by is important for customer peace of mind.

But how secure is the data?

Just over a year ago I started having doubts, when a Moneybookers customer reported that his account had been closed on the basis of information received from a casino client, but without ever being notified by Moneybookers as to exactly what the information was – I reported on this my Moneybookers: potential breach of UK law article.

If you look at the “rights of data subjects” section of the Data Protection Act, this bit jumps out:

7 Right of access to personal data

(1) Subject to the following provisions of this section and to sections 8 and 9, an individual is entitled -

(a) to be informed by any data controller whether personal data of which that individual is the data subject are being processed by or on behalf of that data controller,

(b) if that is the case, to be given by the data controller a description of -

(i) the personal data of which that individual is the data subject,

(ii) the purposes for which they are being or are to be processed, and

(iii) the recipients or classes of recipients to whom they are or may be disclosed,

(c) to have communicated to him in an intelligible form -

(i) the information constituting any personal data of which that individual is the data subject, and

(ii) any information available to the data controller as to the source of those data

It seemed to me that these clauses had been breached, as the data had not been disclosed to the “data subject” – customer – in question.

More recently, another possible breach came to my attention: the customer of one Cherry Red Casino had winnings confiscated on the basis of information apparently received from Moneybookers. I requested and reviewed his email correspondence with the casino in question, and posted extracts in my Cherry Red Casino and Moneybookers article. Most worrying was this revelation:

We have worked closely with third parties to ascertain which players are genuine and which are fraudulent and yours has come back as being connected to other players in Europe and as having transferred funds between Moneybookers accounts.

We are certain that the information we had received from Moneybookers and third parties constitute to the answers we have given players.

So, confidential information of some kind or another was evidently disclosed, by the payment solution to the gambling operation, with no notification to the player.

Another player reported publically, on another similar case, in the Gambling Industry Association Rushmore Casino discussion. Here, an affiliate representative gave a little more detail about the nature of the information:

Moneybookers…only confirmed with us which Moneybookers email addresses were linked and had transferred funds between themselves, it was a yes or no answer and included no further private or confidential banking information or otherwise. Moneybookers…confirmed that these accounts were in fact connected and…transferred funds between their accounts also.

There are a few problems here.

In the first place, confidential information is supposed to be genuinely confidential, and informing a third party of aspects of a customer’s account and the people to whom they make transfers is not an aspect of “confidentiality” that I am aware of. The customer in question was at no point notified by Moneybookers of the disclosure, in whatever format, of his account details to third parties.

I am not a lawyer, but this does not look right to me, insofar as it appears to contravene the section of the DPA that I quoted above.

In the second place, and marginally off the question of confidentiality but highly relevant to customers of these payment solution providers and the industry as a whole, is that this information may be leading to bogus conclusions – the fact that Customer A transfers funds to customers B and C does not necessarily make Customer A guilty of an illegal act. Whether or not the customer is guilty, the correlation between the guilt and the account activity in question is by no means absolute.

Here is a possible scenario:

Casino: “We believe these two players are connected (and therefore guilty of activities we do not allow); can you confirm this?”

Moneybookers: “Yes; the two accounts in question have transferred and received funds”.

On this basis, to summarise my above points:

1) This disclosure to a third party of a customer’s account activity may be leading to entirely erroneous conclusions.

2) More importantly: at no point was the customer – or rather, customers – informed of these behind-the-scenes information exchanges. This appears to me, in line with simple reasonable behaviour, unacceptable, as one ends up being convicted with no right of defence. But more importantly, the nature of the disclosure in question does not appear to me to adhere to the laws I quoted above.

I have, myself, carried out a few “person to person” transfers with Neteller, the payment solution I use. I would hope that Neteller never disclose this aspect of my account, or any other, to third parties.

Whether or not Moneybookers discloses aspects of my account to third parties is irrelevant to me. I no longer use their services.

I will be forwarding this article to Moneybookers for their comments.

-

Let me kick off by commenting generally on the relationship between a provider of online gambling software and the players who ultimately end up using it:

-

Techinically speaking, there is none. The provider licenses the software to a client; the client then offers the software to players, and the provider is not a part of this latter relationship. This is a contractual fact, and it makes sense as well – if you sell fresh fish to an outlet, and the outlet leaves the fish on the shelves too long, resulting in poisoned customers, it is not your fault. It’s logical.

-

And yet, software providers DO take responsibility, at various levels of involvement, for their players, notwithstanding their lack of legal or contractual requirement to so do. Why do they do this?

-

Without preempting any of my more detailed comments further down the page, the simple reason is that it makes business sense; it imbues the provider’s indirect player customers with fundemental confidence in the product, and this has great reciprocal value.

-

Provider says: “you’ll be safe here”.

-

Player says: “thanks; I’ll play”.

-

Players are safe, provider makes money. That is the basic premise at work here.

-

So: onwards.

-

Microgaming Poker was launched in 2003, an offshoot of online gambling software provider Microgaming. Originally called “Prima Poker”, it was rebranded to reflect the provider’s name in 2006.

-

Microgaming is one of the oldest software providers in the business, having opened its doors way back in 1994. It has, to a date, a one hundred percent record of bailing out players from failed licensees – I will go into in more detail about this further on.

-

The Wikipedia Mirogaming entry makes interesting reading:

-

In late February 2008, twenty-seven Microgaming-powered poker rooms closed when their licensee Tusk Investment Corporation Limited went into insolvent liquidation, leaving all players who had funds in those rooms to claim as unsecured creditors in the liquidation.

-

It is not yet known whether players will recover any of their money.

-

Sounds intruiging.

-

The first sign of trouble was an apparently innocuous report issued on 15th February 2008 by eCOGRA, an ostensible online gambling inspectorate, initiated and part-funded by Microgaming, and which endorses most of the the Microgaming operations:

-

An onsite review was recently conducted by eCOGRA`s Compliance and Advisory Services staff at the operations for the following casinos as part of a normal seal renewal process:

-

Challenge – www.challengecasino.com
Golden Reef – www.goldenreefcasino.com
I Big Casino – www.ibigcasino.com
Music Hall – www.musichallcasino.com
Nostalgia – www.nostalgiacasino.com
UK Casino Club – www.ukcasinoclub.com

-

The audit revealed failures in compliance with eCOGRA`s Generally Accepted Practices. It has therefore been decided to suspend these seals pending further investigation.

-

During the discussions about the above eCOGRA statement on the Casinomeister player forums, a representative for the casino group in question popped in for this update:

-

We have been in discussions with eCogra and these purely administrative issues will be resolved shortly.

-

In no way has our honesty, integrity or customer service been questioned and our reputation speaks for itself!

-

We are expecting our eCogra seals will be reinstated very soon, but in the meantime it is business as usual.

-

Since eCOGRA’s announcement had been so innocuous, this didn’t seem at all unreasonable.

-

Unfortunately, the whole operation was gone seven days later.

-

The following Tusk licence termination statement was reported by a prominent online gambling commentator:

-

Company Statement:

-

Microgaming announces that it has terminated its software licence with Tusk Investment Corporation – with immediate effect, after having received Tusk’s notification of its plans to put the Company into liquidation.

-

Microgaming is presently gathering all facts related to this matter and will provide further announcements as and when information becomes available.’

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About Tusk

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Tusk Investment Corporation Limited operates a number of casino sites and poker rooms:

-

Casinos:

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Challenge Casino
Golden Reef Casino
Music Hall Casino
Nostalgia Casino
UK Casino Club
Big Casino

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Poker rooms:
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Battlefield Poker
Royal Card Club
Red Nines
Arctic Poker
Raw Poker
Poker.ie
Daily Poker
Flush Draw Poker
Will Bet Poker
Bet Road Poker
Grand Central Poker
Off The Rail Poker
Privy Poker
Berserk Poker
Atomik Poker
Dave’s Poker Room
Hetman Poker
Hot Pepper Poker
Poker Seas
TilttAA Poker
Loose Games Poker
CPT Gaming Poker
Ice Bear Poker
GoHard Poker
Caya Poker
Mr Urban Poker
Poker Sweden
Euro Poker Dream

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Blimey.

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What was that eCOGRA told us?

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The audit revealed failures in compliance with eCOGRA`s Generally Accepted Practices.

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Well, I can only say that this was one hell of a “compliance failure” which led to the collapse of fully 34 casinos and poker rooms. Way to go, eCOGRA. Any chance of a slightly more accurate statement next time? “Licensee dead in the water” would have been a tad more accurate than “compliance issues”.

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Anyway, to cut to the chase: liquidators were appointed for the Tusk group, as reported by Microgaming in their 20th March company statement, and those six casinos in the previous Microgaming statement, which had player liabilities of $194,000 in total, were taken over by another group.

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That another group took over the defunct casinos was good.

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Unfortunately, the good news stopped there.

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The liabilities to the poker players was a bit more. A little over $5,000,000 more, to be precise.

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To be even more precise, the total poker player liability was $5,312,923. Five million, three hundred and twelve thousand, nine hundred and twenty three dollars.

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It is therefore maybe not so surprising that a buyer did not come forward for the poker rooms in the way that the casino buyer did.

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But what about the customers of the twenty eight poker rooms? Who is responsible for paying these players their balances?

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These poker rooms were all “skins”, or “white labels”, of Tusk Investment Corportation, operating their poker branch under the name “My Poker Profit”. Skins are glorified affiliate sites which send players to the parent company (in this case, Tusk) but with no access to player funds, the financial side being handled exclusively by the parent company. The “skin” has information on player numbers and maybe other relatively trivial matters, but they have no control over the finances.

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For an excellent Tusk operator’s description of the skin concept, and other relevant matters, see the open letter to Microgaming at the 2+2 forum written by one of the skin owners, Red Nines Poker:

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At the end of 2005, Rednines contacted Microgaming (then named Prima Poker) to explore the possibilities of becoming a skin into the Microgaming network.

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We were advised by Microgaming to contact Tusk to get a deal through them instead, since they had a deal in place with Microgaming which made it possible for new partners to get a skin up and running within days.

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This process is known as a white label solution, which means that our work on Rednines.com would basically be to get players, and get a revenue share of these players. In other words, Tusk / MyPokerProfit.com would take care of everything from Payment Gateways, holding on to player funds, dealing with Microgaming and handling customer support.

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The only information we had access to was the players signed up through Rednines.com, we could see their names, emails and their current rake. We had no way of even making a deposit to a players account without going through Tusk / MyPokerProfit first. In fact any poker room related issue had to go through TUSK.

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Let me interrupt the narrative here to add a personal comment on “skins”:

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Skins are nothing but bad news for the player. They create endless confusion through lack of any real clarity about the parent company, the result of which is that the players end up being completely misled with regard to who is responsible for their money. In this case, clients of “Battlefield Poker” thought that “Battlefield Poker” held their money and paid them; some, in fact, thought Microgaming held their money; NOBODY knew the truth, that Tusk Investment Corporation held their money, because noone told them, and the Tusk involvement would have been buried deep in the terms and conditions at best, if it was mentioned at all. Here are a couple of representative comments made by players in the lengthy discussion at the 2+2 poker forums:

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where are the player’s bankrolls held?

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are cashouts/deposits done through microgaming as a whole or is each skin seperate in that regard?

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Sorry fella, wrong on both counts.

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So is Tusk or Microgaming holding the players’ money currently?

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Getting closer, but they still don’t know.

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So, total player confusion.

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I have heard the absurd justification that skins serve a “niche” market; for example, if I am a one-legged Mongolian crocodile trainer, I would like to play at a gambling operation called “One Legged Mongolian Crocodile Trainers” more than “Ladbrokes” or “William Hill”. What absolute nonsense. How do our professions or hobbies dictate our preference for the name of the gambling operations we patronise?

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Skins serve one thing alone: the gambling industry. They allow individual operations to effectively transform and mutate into any number of other operations, with apparently distinct identities and all the adherent marketing and profit potential for the original parent companies.

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For the player, they create nothing but confusion and trouble.

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Or, in this case, the loss of $5,300,000.

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Anyway, moving on:

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The poker side of the Tusk collapse has been discussed at huge length in the monumental 27 Microgaming skins to close discussion at the 2+2 forum. I have not read every one of the 3000+ posts, but what I have read represents little useful information; for the most part, players are expressing their general confusion and anger, and a hope that their balances will not be lost.

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One startling fact to emerge from the discussion is that the skin operators appear to have been treated with the same scant disregard by software provider Microgaming as the players. If you look again at the Red Nines open letter:

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Rednines.com is no longer running, along with BattlefieldPoker.com and several other white label solutions of Tusk / MyPokerProfit. Microgaming has not reached out to us, nor have we been able to get a hold of anyone with a say in Microgaming that could help us solve what happened. Even though it is several months since Tusk went bankrupt we have at several occasions tried to get a hold of someone that could take responsibility for what happened – unfortunately without success.

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I have been told by many that they feel Rednines.com should pay up for player balances and their losses, and I can understand their frustration. The problem is that we never saw any of these deposits, we simply got a revenue share for our players rake. This was around $25,000 gross profit every month for the months we were operative. Microgaming was actually making a bigger profit than us on our players.

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I would like to see Microgaming take a stand in this matter, and be the responsible party, which means they should pay for the player balances.

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This latter feeling is also expressed by the players, some of whom took it for granted that Microgaming would honour their balances – these comments are taken from the mighty 2+2 thread:

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I believe Microgaming has covered players’ balances when things like this have happened with casinos running their software before.

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All the balances are covered by Micro Gaming.

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Microgaming has been around since before online poker, and I don’t think a player has ever lost money when one of their casinos or poker rooms shut down. I’m sure your money is safe.

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In this case I would think that Microgaming would step in to cover player balances, and as such your money should be safe.

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I really doubt that Microgaming will allow the money in accounts to be lost.

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Unfortunately, notwithstanding the opinions and hopes of both players and skin operators alike, Microgaming has failed to communicate.

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In mid-2008, six months after Tusk / My Poker Profit collapsed, Microgaming received a letter from a lawyer representing one of the players who had a large investment, notifying them of a proposed court action. The player in question reported the matter in this short 2+2 post:

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My dad sent microgaming a letter notifying them he was intending to take them to court. Within 4 days he got a response from a firm in Toronto (they have hired legal counsel already) saying they take no responsibility and that our accusations against them were erroneous.

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So: no comment from Microgaming, apart from one denial of responsibility when they were forced to respond.

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Earlier on I mentioned the provider / player relationship, and the responsibilities thereof. Now would be a good time to start to consider them in detail.

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Two questions to consider:

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Is Microgaming going to honour the balances of the players involved in the Tusk collapse?

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They may yet, but it doesn’t look good. They have been uncommunicative to all involved parties, and the one occasion that they chose to break silence was to deny any responsability. It may be the case that they are waiting for the liquidation to run its course, at which point they’ll survey the damage and take the necessary remedial action.

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However, since they know the numbers involved from the liquidation report (see below), they know exactly the extent of their potential liability and should therefore be able to give some sort of indication of their intentions. The fact that they have not done so suggests to me that they are not planning on making the players whole.

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So it’s not looking good.

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Should Microgaming honour these balances?

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This one’s easy: yes. Microgaming should compensate the poker customers of failed licensee Tusk Investment Corporation, notwithstanding the fact that, as the software provider, they have no legal liability. There are two reasons for this:

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In the first place, it’s the right thing to do and they’ve done it before.

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It’s the right thing to do because the players are, at the end of the day, customers of Microgaming. As I said in my opening remarks, players, for their part, have the confidence of knowing that, whichever licensee or skin they’re patronising, they are safe because Microgaming is safe. Good for Microgaming, good for the players.

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And yes, it’s happened before:

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When the Tropika group failed in 2001, Microgaming paid – see the Microgaming to pay all Tropika players thread from Winneronline.

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When Goodfellas Casino failed, Microgaming paid – see the Goodfellas thread at Winneronline.

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On these occasions, Microgaming did the right thing and should receive all due credit.

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Why would they not now?

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Aside from the moral responsibility and the good business sense of helping – and the potentially disastrous business consequences of not – there is another slightly less altruistic reason for expecting a provider hand up on this one:

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Microgaming directed the skins to Tusk in the first place.

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Look again at the open letter at 2+2:

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We met Microgaming and their representatives at a hotel in London in early 2006 in connection with the ICE gaming show. During this meeting Microgaming stressed the fact that they were backlogged in the process of accepting and adding new skins to their network already.

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We were then advised by Microgaming to contact Tusk (also known as MyPokerProfit.com) to get a deal through them instead, since they had a deal in place with Microgaming which made it possible for new partners to get a skin up and running within days.

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This was far away from what we would prefer. Maybe we are guilty of being naive, but as Microgaming said it was an easy way to join the network, and Tusk/MyPokerProfits way of doing business was condoned by Microgaming themselves. This made the deal seem legit and secure for us.

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In addition to this, Microgaming said that once we were integrated in Tusk/MyPokerProfit’s system, it would be an easy process to re-convert us over to Microgaming as a regular partner once their queue was less backlogged.

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So, Microgaming specifically directed these potential skin customers to Tusk.

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And Tusk failed.

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If you look at the liquidator’s report to creditors, you can see that during the financial year in which Microgaming recommended Tusk to skins Battlefiend and Red Nines, they were hardly doing well, with a total profit of $282,000 for the year – you can see screenshots of the relevant pages in the liquidation report section of my other article.

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Maybe in late 2005, when Microgaming made the Tusk recommendation to these skins, they were doing less badly.

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Or maybe they only had the 2005 report to go by, which may have been better.

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Or maybe Microgaming knew that Tusk was struggling, and tried to help by sending them skin customers. Eeek, now there’s a thought.

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Or maybe they didn’t look at the figures at all?

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However, at the end of the day, Microgaming recommended Tusk, which was NOT the solution that at least two of the skins wanted, preferring a direct arrangement with Microgaming whereby THEY would take care of THEIR players in all matters, financial and otherwise. These potential licensees did not want to hand over these key aspects to an unknown third party, such as Tusk. They wanted a responsibiity that they were denied – look again at Red Nines’s comment:

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This was far away from what we would prefer. Maybe we are guilty of being naive, but as Microgaming said it was an easy way to join the network, and Tusk/MyPokerProfits way of doing business was condoned by Microgaming themselves. This made the deal seem legit and secure for us.

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And now, these skin partners themselves are owed money by Tusk – $1,522,649 to be precise.

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So quite the charming little disaster all round.

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Assuming Microgaming fails to honour the players, they can they expect to receive around fifteen percent of their balances from the liquidation – if you look again at the liquidation report, you’ll see that there is $1,400,000 cash in the bank against the $9,000,000 total creditor, or about 15%.

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Of that $9,000,000, the sum total of the poker player balances is a cool $5,312,923.

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Hopefully, Microgaming will break silence on this and offer to compensate the affected players. If they do not, it will be their first failure in these circumstances, and it will send a big, fat, red warning to players that their deposits at Microgaming operations are no longer as safe as they once were.

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It may be of interest to note the full list of Microgaming poker clients.

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The point of saying that is not to warn players against patronising the listed operations – some, like Ladbrokes, are big names and very solid.

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The point is to be aware that should any of them fail, it must not be automatically assumed that Microgaming will bail out the players, as once was the case; as such, players should not simply rely on the name of Microgaming when choosing to play there.

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I will be keeping on top of ths matter, and will report any developments.

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I attended the 2009 International Casino Exhibition in January this year for the purposes of speaking to the Malta Lotteries And Gaming Authority and the Alderney Gambling Control Commission.

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My reason for seeking out the LGA were complaints at Malta-based sportsbooks Interwetten and BetChance. Betchance is covered in detail in my Betchance article here, and the Interwetten matter is described in great detail in the Interwetten report on my own site.

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I was looking for the Alderney Commission to raise issues which I described in the AGCC article for Midas Oracle – namely, why the AGCC considers it acceptable for a licensee to revoke a player’s winnings after the player followed all the rules to the letter.

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Those above-mentioned articles are infinitely more interesting than anything I can say here. The visit was a monumental waste of time.

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To give the LGA credit, they were at least available to talk, which is more than can be said for the AGCC.

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I spoke to two members of the LGA’s legal department, Dr. Edwina Licari and Dr. Joseph F. Borg. I had been given Dr. Licari’s name by the “complaints manager”, one Frances Blenheim, who told me she would not be in attendance herself. She also said that Dr. Licari would be up to speed with the matter.

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However, Dr. Licari knew nothing about my case. I said “hey, your friend Frances told me to talk to you!”, to which the lady replied that although the complaints woman had notified her that I was intending to visit, she had NOT told her anything about the case. As such, she was in no real position to say anything other than that which would have been complete guesswork.

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So, zero out of ten for that.

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I felt a little sorry for Dr. Licari. She looked frankly terrified during my entire visit, as if she thought I could be on the verge of doing something totally unpredictable (granted, always a possibility). This, in its turn, put me slightly on edge.

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Never mind. Onwards to Betchance.

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I had pepared a sheet of paper with reports from Sportsbook Review, detailing in brief the unfolding situation, namely that Betchance’s debts were around $100,000, the silence was absolute and the Malta LGA still listed them. I read this out to Dr. Borg.

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He told me that Betchance’s license was under “notice of suspension”.

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And that was all. Because of this notice, no comment was possible.

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I also quoted ex-CEO Galea’s comments, that the Betchance players were “lying”, and that people who questioned the LGA should watch their backs.

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Again, no comment was possible. Galea would have to speak for himself. And, of course, Galea is no longer part of the LGA.

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In fairness to the LGA I should add: Betchance’s license was suspended two weeks after this, on February 2nd – see their suspended licenes page.

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Also in fairness, Dr. Borg was a nice enough fellow, who offered to look at my own Interwetten case. We also glanced over other general matters – he pointed out that the LGA was not a court of law and could only make recommendations, and acknowledged that the Interwetten players’ ten month wait for just a response from the LGA was unacceptable.

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However, answers there were none.

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So then I sought out the Alderney Commission.

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A “States of Alderney” stand there indeed was. Unfortunately, there were no more than two reps of the Gambling Control Commission.

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So could I please come back later?

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So I did. Still nobody. OK, try again, shall we?

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Next time, I spoke to a lawyer – somewhat out of desperation, as I could see I was getting nowhere with anyone on the actual commission. I told this gentleman I wanted to discuss matters pertaining to player complaints – could he be of help?

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He said he’d listen, but it wasn’t his department so he would be unlikely to be able to shed any light on my concerns.

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So we should probably just leave it at that, eh?

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Good idea. No sense in wasting anymore time.

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So I departed.

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In a fairly bad mood.

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And that was it. No answers from anyone. The Malta LGA couldn’t say anything, and Alderney was barely there.

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I’ll finish off this non-article with a customary rant – I think it’s justified:

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This exhibition, and others like it, is a quintessentially perfect representation of the gambling industry. It’s like candy floss. It looks lovely, but one lick and it’s gone – or, in this case, one flick of the duster. There is no substance. You go up to a snappy looking stand, full of smart looking people wearing nice suits, and you think: hey, this is the business. Then you ask them a question, and you discover there’s nothing there. There isn’t even a bit there, there is nothing. A question: nothing. Another question: nothing. Try somewhere else, and you can’t even ask a question in the first place, because despite all the throngs of people in evidence, nobody has anything to do with anything of substance. One puff and it’s gone. Back to nothing.

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Which is all rather like Las Vegas, or any other gambling centre: monumental homages to nothingness, with no real entertainment other than for the masochistically inclined.

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So, I suppose I got what I expected so shouldn’t really complain.

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Thank you for reading my non-report on my non-visit to the non-event that was the 2009 Earls Court International Casino Exhibition. If it bored you, think about me going to it and writing about it, and hopefully you’ll feel a lot better.

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My next report will be on an online poker scandal currently and painfully being played out. It is, I promise, more interesting.

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Since my previous articles, I should point out that there have been some changes pertinent to the title: Mario Galea has resigned from his position as CEO of the LGA. Why this is I do not know.

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In those articles I highlighted the case of the Malta-based bookmaker Betchance, apparently insolvent and offering to make partial settlements to players, in the region of twenty five to thirty percent of their balances, upon the signing of a potentially highly compromising and unsatisfactory contract. None of these players have received any money that I am aware of.

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Although Betchance continued to maintain a full Maltese Class 2 license all this time, there were two facts which one could at least hesitatingly class as a demonstration of quasi-integrity: the bookmaker was not accepting new customers, and they were not actually denying their debts. In addition, the Lotteries And Gaming Authority, though almost totally silent on the matter, were also not denying that these players were owed.

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Since then things appear to have changed, and not in the players’ favour:

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Betchance, apparently insolvent and semi-closed, is now fully up and running, accepting new players and taking bets. In fact, business as usual. This is odd, considering that the situation which caused their insolvency – insufficient funds to pay players – does not appear changed in the slightest, no players having been paid.

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So did something change?

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Yes. But not the substantive facts of the matter. What changed was the spin the LGA have now chosen to put on it.

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The following was reported by Bookmakers’ Review in late October 2008:

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At the recent European iGaming Conference in Barcelona, Galea told some industry operators, worried about news that several Maltese bookmakers were in financial distress, that stories on internet sites like Bookmakers Review are all lies and that at Betchance it is business as normal, with payments to players being made correctly.

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Furthermore, according to Galea, there is an international police investigation into players accused to have defrauded Betchance.

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Then earlier this week, an employee of a popular Maltese bookmaker, who on my behalf tried to get an answer about why Betchance is still allowed to operate, was told by Mr Galea the same story about players being investigated for defrauding Betchance. Galea also invited this person to stick to what he knew if he wanted to last in the gambling industry.

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So, to summarise these jaw-dropping remarks made by Mario Galea, the (then) LGA CEO who until reasonably recently was owner of BellMed, a company which provides internet facilities to the sportsbooks “regulated” by the LGA and who, it is rumoured, is still involved with the company:

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1) Betchance is paying players.

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2) The players who claim to be owed are liars, against whom there is an international police investigation.

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3) If anyone says anything against Betchance or any other Maltese sportsbook, they’d better watch out.

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Examining these remarks in order:

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1) Betchance is NOT paying players. Bill Dozer, head man at Sportsbookreview, has chronicled the events in his Betchance news updates, and at no point have more than sporadic payments been made. Betchance still appears to owe a minimum of $100,000 USD. This is not guesswork on the part of Bill Dozer, who researches and corroborates his information before going to press.

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As such, Galea’s comment about Betchance “paying players” was a total fabrication – unless, of course, Galea actually meant “paying the few select players they choose to pay and ignoring everyone else”, in which case the remarks probably contain more than a grain of truth.

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2) The players are not “lying”: see above comments. The facts of the individual cases have been investigated, corroborated and chronicled by a highly credible source: Bill Dozer of SBR. The circulation of a partial payment agreement is a matter of public record. Why was Betchance offering to pay players a percentage of balances if those balances don’t actually exist or were “fraudulent”? Why did Betchance claim to be “working on the problem”, with apparent new investors lined up, if the players were fraudulent and, as such, not owed, and there was no problem in the first place?

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Again, Galea’s comments appear nothing more than utter fantasy. As to the “international police investigation”, there is no corroboration of this from any source other than Galea’s Barcelona outburst, and I suspect it is equally fictional.

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3) Yes, I suspect that you had better watch your back if you question the liquidity of sportsbooks in Malta – the Lotteries And Gaming Authority may well have high contacts in low places. I’m sure this is not a fabrication on Galea’s part. However, how is the Maltese situation, in reality?

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Here’s a little more recent history:

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“Waubet”, another holder of a full LGA Class 2 license, was defunct as of September 2008. According to the message on the homepage, it will be paying fifty percent of player balances. Of course, that message has now been there for over four months.

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So, another Maltese sportsbook where at best half of players’ funds are gone.

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“Bettingstar 24″ was also defunct as of September, according to Bill Dozer’s Bettingstar24 updates. This latest Malta casualty has now, however, been taken over and appears to be paying.

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The security of Maltese sportsbooks does not appear all that good at all, with two books folding in the space of a month and at least one other fully operational again whilst not paying players. As such, Galea’s pugnacious and threatening attitude, with dark hints at the risk to people’s livelihoods if they question the viability of Maltese operations, was almost certainly bourne out of the fear that these prognostications are correct.

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My advice with regard to gambling operations “licensed” by the Malta LGA: if you know the book from long experience and are confident with it, play there – play there whether it’s listed by Malta or not. If you do not, do NOT patronise ANY bookmaker which is supported only by the Malta LGA.

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It could be a very expensive mistake.

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Since Mr. Galea is now no longer involved with the Malta Lotteries And Gaming Authority, I think he is deserving of a fitting epitaph in recognition of his services. I offer this in the form of two articles, written for Malta Today by journalist Matthew Vella:

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Authorities declare Gaming Chief Executive is free of conflict of interest

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Gaming chairman defends employees’ past connection in industry

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I only discovered these articles two days ago, but they add corroborative detail to my previous comments about a belief expressed by Maltese sources that Mario Galea may not have divested himself as entirely as one was led to believe of his investments in Bell Med, the company he owned which provided internet service facilities to companies located in Malta and which thereby represented a substantial conflict of interest.

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…outside the orbit of Malta’s leading internet gaming service provider Bell Med Ltd, reputedly the technical service provider of choice for 70 per cent of Maltese-registered internet gaming operators, questions are asked of whether Galea, formerly the owner of Bell Med, has indeed disposed of his interests in the company in a way that places him above suspicion.

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It would appear that Galea’s interests in Bell Med were divested through a nominee company called “Knights Corporate Business”…

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…a legal structure for trustees to act on behalf of clients which do not wish to have their names appear on paper. As directors of Knights Corporate Business, Gatt, Galea and Privitelli appear as the trustees for whoever owns Computer Aided Technologies, and for that matter, Bell Med Ltd.

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The articles go on to say:

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The transfer of Mr Galea’s shareholding to a nominee company has been made according to all legal provisions and does not give rise to any suspicions…”

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But what about passing the test of being “above suspicion”?

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It remains for the rest of us to speculate on whether or not Mario Galea did, in fact, divest his conflict of interest effectively to… himself. And since the company into which the interest was transferred was one that specifically hides the clients’ identities, there is little to allay the suspicion. This certainly appears to be what journalist Matthew Vella is alluding to.

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If this were the case, then since its inception in 2004 the Malta Lotteries And Gaming Authority would have effectively been “regulating” those exact same companies with which its CEO had a continuing business relationship as an internet facility service provider.

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Which is, I believe, a “conflict of interest”.

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As such, we should maybe not be too surprised when the legitimately owed players of an insolvent sportsbook are referred to as “liars”, irrespective of the independent corroboration of their cases by one of the industry’s most trusted sources.

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It would be equally less than eyebrow-raising to discover that said insolvent, defunct sportsbook was still fully licensed by the LGA, open and accepting deposits.

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And we can probably also avoid having to pick our jaws up from the floor when we hear the former LGA CEO telling people to watch their backs if they choose to question the integrity of Maltese-licensed operations.

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Best of luck for your future career, Mario. May you always be treated with the same level of integrity that you demonstrated during your time with the Malta Lotteries And Gaming Authority.

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