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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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The Authority may order the suspension or cancellation of a license if…the license holder has failed to meet commitments to players.

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This is important, because the ultimate purpose of any gambling regulatory organisation is to ensure protection of its licensees’ customers, the players.

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On the face of it, this appears to be a pretty serious organisation; it’s a governmental body, and one located within the European Union as opposed to some Caribbean or Costa Rican outpost; it’s got a snappy website whose contacts page lists an email address for player complaints; the LGA also moves on the international circuit: they attended the 2008 International Casino Exhibition in London this year, and will be attending the European iGaming Congress and Expo in Barcelona in a few months. It’s fair to say that the LGA folk don’t exactly hide away behind closed doors.

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So, does the LGA ensure that its licensees “meet commitments to players”?

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No.

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In fact, the Malta Lotteries And Gaming Authority appears to do nothing whatsoever for the players.

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As reported in the Malta Independent Online “Gamer demands £66,000 payout” report, and discussed in reasonable detail at the Winneronline forum, in late 2005 a player racked up £66,000 of winnings at Malta-based operation “Bingos”, which the casino subsequently refused to pay, citing “software error”. The LGA initiated an investigation, and along the way reported that there was no software error. Beyond that, they made no ruling; rather extraordinarily, they told the player to take legal action against the operator in Malta, and apparently offered some guidance with this task.

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Before the matter came to trial, and after the player had spent a lot in legal fees, the casino in question offered a payment settlement which the player accepted. This would almost certainly have come with a non-disclosure agreement, as the player made no further comment and the exact final details were never reported.

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Why did the player have travel to Malta and take expensive legal action? And why did the LGA advise him to do this while they were still “investigating”? A regulator’s job is to investigate a case and rule on it, not encourage the complainant to sort it out himself at his own expense while their investigation is ongoing.

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This is not regulation, this is passing the buck – and it’s grossly unprofessional and unacceptable. The LGA has at its disposal the right to suspend or revoke licenses “if the license holder has failed to meet commitments to players”. They have absolute power in this regard. Yet, they prefer to let the player divest them of their responsibilities and do nothing of value.

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All that said, at least in the above case the LGA appeared active to a degree. More recently, even this has been almost totally absent.

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A year ago, in July 2007, sportsbook “Betchance”, LGA license Class 2 no. 189, started showing signs of trouble – voided bets, delayed payments, bizarre excuses, general lack of communication, promises of payment from “new investors”. In short, Betchance was in financial strife. Players complained to Bill Dozer at Sportsbook Review, and you can read a summary of the unfolding story on his Betchance news page. Bill’s most recent comment, as good an overall summary as any, reads thus:

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Betchance is no longer pretending to take bets or allowing players to look at their balance. The book’s homepage gives players the message that the “operation is suspended for technical problems” and it “apologizes for any inconvenient..” The Malta-licensed sportsbook baited players with large deposit bonuses and advantageous lines and pricing. Some players have been pursuing their funds from betchance for nearly one year. History suggests, despite what betchance offers or arranges with players, the book will continue to stall and will not pay. Multiple players have stated that their opinion is the book will only pay if somehow leveraged to do so by The Lotteries and Gaming Authority of Malta and will hold out hope for their full balance. The LGA issued small payments to players on behalf of no-pay sportsbook Playbanks in March, months after the book had closed.

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The Betchance issue is also documented by Bookmakers Review – the full list of Betchance articles can be found on the Betchance update page. Some of the comments bear quoting, if nothing else for their amusement value:

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Betchance told us “not to make a fuss out of nothing.”

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Followed by:

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Betchance informs its customers to be in negotiations with new investors, practically admitting being broke.

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The LGA tells Bookmakers Review that new shareholders have been officially approved and they have now provided capital to BetChance. “The situation will really be solved in the next few days,” said a spokesperson for the LGA. [24 October 2007]

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Followed by:

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A Russian player received an e-mail from a representative of betchance.ru saying that it will take four more weeks to get paid as the company is trying to obtain a bank loan. [2 November 2007 - what was that from the LGA about resolution "in the next few days"?]

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Betchance has apologized for the delayed payments claiming that all problems have now been solved. [February 2008]

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Followed by:

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Three months after scam bookmaker BetChance said all problems had been resolved, players who have been waiting up to 8 months to get paid continue to be feeded with the usual worthless babble that all payments will be made within few days.

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Now take a look at the LGA licensees page, and select “class 2″.

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Betchance is still fully licensed by the LGA. The license has not even been temporarily suspended – an entire year has gone by in which Betchance has “failed to meet commitments to players”, the reason given for which the LGA may revoke or suspend licenses.

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Yet they have done nothing.

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I will briefly mention one more case, in which I am involved myself. The full details can be found in my Interwetten: confiscation of more than £5000 article. Several other players have posted mirror complaints in the Interwetten confiscating winnings discussion at Casinomeister.

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In summary, Interwetten offered a very generous bonus promotion, which they subsequently claimed was a “mistake”, in spite of the fact that the promotion played out exactly as it had been advertised.

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The complaint was initiated four months ago. I have, to date, received two communications from the LGA: one form response, and a subsequent acknowledgement of receipt of the complaint. The latter was received after a flurry of complaints about the LGA’s lack of response in the Casinomeister discussion, and it seems at least two other players received the same response at the same time as I did.

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Beyond that, the silence from the LGA has been total.

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Could there be an explanation for the LGA’s complete failure to do anything for its licensees’ players?

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CEO Mario Galea joined the LGA in 2004. Previous to this he was owner of Bell Med. Bell Med is the company which supplies hosting facilities to online gambling operations in Malta – see the Bookmakers Review article on the matter.

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Mario Galea sold his shares in Bell Med four months after being appointed to the LGA.

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Why did he not sell them before being appointed? The conflict of interests is very clear: as owner of BellMed, Galea received fees from those same companies that his new company sought to regulate.

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Even after selling his shareholding in BellMed and apparently divesting himself of all interest in the company, the fact remains that Galea is still in charge of regulating companies with which he had, at one time, a business relationship. It’s one thing removing a technical conflict of interest, but the human factor remains: one is “regulating” ones former colleagues and business partners. This is an absurd situation: why appoint to the top position of a regulatory operation the one person more closely associated than anyone with the operations to be regulated?

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One final points bears adding to the mix: according to sources at BookmakersReview, I can reveal that as late as last year, people on location in Malta alleged that Mario Galea was still very much involved with BellMed. I cannot corroborate this myself, but have permission from BookmakersReview to quote them.

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Either way, in or out, there is a clear conflict of interests at work here.

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Why do the people of the Malta Lotteries And Gaming Authority do nothing for their licensees’ customers?

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Presumably because they simply don’t want to.

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I’m surprised and disappointed.

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I did a quick research, and here are 2 points I got:

1. The European Union’s Commissioner for Internal Market and Services, Charlie McCreevy, praised Malta’s Lotteries and Gaming Authority for their professionalism.
2. Malta’s Lotteries and Gaming Authority are working on a “Remote Gaming Standard”. (PDF file) - Sounds good.

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As you remember, BetFair Games, BetFair Poker, BetFair Casino, BetFair Multiples, and all non-UK BetFair customers, are covered by Malta’s Lotteries and Gaming Authority.

I’ll have, later on, a short post on the API delays for BetFair’s non-UK traders.

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UPDATE: Tiny API delays for non-UK customers of BetFair —since all international BetFair bettors, traders and gamblers are now served from Malta, not from London.

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Change to Terms and Conditions for non-UK Betfair customers

Betfair Customer Services 01 May 11:20

For operational and commercial reasons, Betfair is restructuring its international business.

If you are a Betfair customer with a UK-registered address, this change will have no impact on you whatsoever. If you are a non-UK customer, the changes will not impact your betting experience or the features available. Equally, the provision of helpdesk, payments and other services will be unaffected. The only change is that the company you will be betting with, Betfair International, will be licensed in Malta, as is already the case for Betfair’s existing Games, Poker, Casino and Multiples betting products.

This means two things for you: first, you will be asked to accept a new set of Terms and Conditions, because Betfair International is governed by Maltese law, not English law.

Second, in the event that you have an unresolved dispute, the regulator to which you should make a complaint against Betfair is the Maltese regulator, and not the UK Gambling Commission.

If you are interested in a more detailed explanation of what this change involves technically, more information is available on the Betfair Developers Program website, which can be found here.

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Lotteries and Gaming Authority (LGA) – Malta, E.U.

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I’ll update you in the coming weeks or months, as whether this is good for non-UK traders. I have no prejudice against Malta. I’ll look into that, later on, with an open mind.

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UPDATE: Tiny API delays for non-UK customers of BetFair —since all international BetFair bettors, traders and gamblers are now served from Malta, not from London.

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