4 October 2021

The trillion-dollar gambling game

• Is the Premier League used as part of an unprecedented money-laundering operation? This article was originally published on Josimarfootball.com on 12 August 2021. Click here for the original.

Far Eastern gambling operators, of whom almost nothing is known, have become ubiquitous presences in the English game over the past decade. Mysterious brands invest millions in shirt sponsorships and commercial partnerships each season, often for a year or two before disappearing and being replaced by other operators which are just as mysterious. The opacity of these companies, predominantly operating from the Philippines, is such that they are widely suspected to be used for money-laundering schemes on a bewildering scale: it is estimated that 1 trillion US dollars of untraceable money is bet through unregulated bookmakers annually.

Yet, despite the regulations put in place by the British Gambling Commission, these operators have escaped all scrutiny. To avoid the gaze of the regulators, all they have to do is to use an intermediary which will obtain a UK licence for them – through a so-called ‘white label’ agent, of which one, TGP Europe Ltd, based in the Isle of Man tax haven, dominates the British market. There they can then hide in plain sight with no fear of investigation, sponsoring club shirts and becoming ‘partners’ of some of the biggest clubs in the world. Josimar can now reveal, following a year-long investigation conducted with the help of gambling industry insiders, the true nature of this business and how English football has turned a blind eye to the origin of the tainted money on which it relies to a greater extent than ever before.

Of the hundreds of millions of viewers who watched Liverpool beat Manchester United 4-2 at Old Trafford on Thursday 13 May, in what is traditionally one of the most eagerly awaited fixtures of the Premier League calendar, most will not have paid attention to the message which flashed repeatedly on the stadium’s ‘digital perimeter boards’ during the game, promoting – in Chinese ideograms – a website called hth366.com. Three months later, this company’s purported British website, which is still under construction, appears to be geo-blocked in the United Kingdom itself.

Should you be able to access it, what this website promises to deliver, ‘COMING YOUR WAY SOON!‘, however, is the very opposite of a shock. hth366.com (hthbet.co.uk in its British incarnation) is – you guessed it – a betting and gambling platform (‘a great new sportsbook and online casino offering’, according to their online blurb), one of a head-spinning number of such ventures, almost all of them based in the Far East, which have become major commercial partners of English professional football, both at Premier League and Championship level.

Eight Premier League clubs had gambling companies as their main shirt sponsors in 2020-21 (Burnley, Crystal Palace, Fulham, Leeds, Newcastle, Southampton, West Ham and Wolves). It will be nine in 2021-22. Norwich City, which won the Championship and were promoted, decided to cancel its agreement with Malaysian betting platform BK8 after a public outcry. Norwich, having come to the end of a ‘record deal’ with Dafabet, provoked a social media storm in England when it was discovered that BK8 used quasi-pornographic images of young female models to promote its brand in Asia.

Interestingly, no questions had been asked about the mysterious ownership of BK8. But then, these types of questions are not asked in English football. There certainly were none, either from fans or the governing bodies, when Watford – another promoted club – closed yet another ‘record deal’ with Sportsbet.io, a subsidiary of the Coingaming Group which is already Southampton’s main sponsor(*). In July of this year, Watford moved on to yet another e-Gambling platform, Stake.com, ‘the leading crypto casino and sports betting platform worldwide’(*).

Regarding Sportsbet.io, it is striking, highly revealing, too, how its non-UK websites differ from the British version. The ‘foreign’ websites, which drive most of the traffic, allow their customers to remain anonymous when they make deposits in cryptocurrencies and place their bets, something which is illegal in the United Kingdom. Yet it is the UK, through the Premier League, which this company has made the nexus of its advertising and marketing strategy, despite the fact that it is not British punters it seeks to attract.

Nor does the gambling industry’s involvement in elite English football stop there. At the time of writing, Aston Villa had OB Sports (‘one of the most trustworthy and reliable platforms in Asia’, according to a club statement) as a ‘sleeve sponsor’, whilst Arsenal, Brighton, Everton (previously sponsored by one of the most controversial betting platforms,  SportPesa), Leicester, Manchester United, Tottenham and West Brom all had official ‘betting partners’. Four Premier League clubs also had specific ‘Asian betting partners’.

The supposed ‘crackdown’ on betting which, according to UK media, is being envisaged by the British government in its current review of football’s relationship with gambling certainly hasn’t discouraged clubs or bookmakers from cultivating what is a fruitful relationship for both sides. It is no wonder that watching a live Premier League game on TV in the UK feels like sitting in a bookmaker’s shop, as viewers are bombarded with advertisements before, during and after the game.

Whilst the players are transformed into running billboards for an industry which is responsible for life-destroying addiction, thousands of personal bankruptcies and an estimated 400 suicides each year in Britain alone, television keeps hammering the message away. 237,000 gambling ads were aired in the UK in 2007, in the wake of the deregulation which accompanied the implementation of the 2005 Gambling Act. In 2013, the figure was 1.2 million, which constituted over 4% of the total advertising revenue garnered by TV companies.

Show me the money!

It is difficult to establish how much gambling sponsorships and other commercial relationships of that kind are worth to Premier League clubs as a whole, as the exact figures are kept confidential. It is, however, possible to come up with reasonably accurate estimates as far as some individual clubs are concerned.

When it comes to shirt sponsorship, gambling operators as a rule see no value in associating their brand with world-famous clubs such as Liverpool and Manchester United, as these commercial juggernauts have priced themselves out of that particular market. No betting platform would consider aligning itself on the 70 million euro Chevrolet used to pay to Manchester United per annum, for example, which is why it is ‘smaller’ Premier League (and Championship) clubs which are the betting industry’s main targets, as they’ll be ready to emblazon their shirts for fees which, according to industry specialists, range from €3.5 million to €10 million per season.

To these sums must be added the revenue of specific advertising campaigns from companies such as hth366.com, as well as income derived from secondary partnerships. One example: Manchester United is thought to have earned €3.5 million a year from its deal with Yabo Sports, a Chinese betting company which has also counted Leicester City as a ‘global partner’.

Remarkably, Yabo, a company which was registered in 2018, managed to build a quite extraordinary portfolio of such partnerships within a year of its creation, signing deals with the Argentina National Football Team, Hertha BSC, AS Monaco, Serie A, Copa América, and FC Bayern Munich ‘amongst others’. AC Milan followed in October 2020. Just as remarkably, Yabo Sports does not appear to have any presence on social media, which begs the question: who is using their platform?

That a company which did not even exist four years ago should be able to invest tens of millions in marketing its brand globally says a lot about the scale of the business it is involved in – and of the profits that can be made. Industry insiders believe the worldwide online sports betting market (which operates mostly from Eastern Asia, which accounts for an estimated 80% of their activity) to be worth 1 trillion US dollars in terms of bets placed, of which 600 billion US dollars are thought to be wagered in China alone; give or take a billion or two, roughly the combined GDPs of Sweden, Finland and Norway.

In this context, paying millions for the privilege of being associated with an English football club represents excellent business for Asian gambling operators, almost all of which are based in countries where sports betting is severely restricted or illegal: Thailand, Malaysia, Indonesia and, first among them, China (the territory of Macau excepted). To circumvent local legislation, these companies register their headquarters abroad, the Philippines being the country of choice for a majority of them, as we shall see.

Their domestic customers bet exclusively online on platforms which guarantee anonymity, sometimes going through agents who add another layer of opacity to the transactions, not that the local authorities seem particularly keen to crack down on this huge industry despite words to the contrary. The biggest problem for the gambling companies, then, is not how to operate, but how to get known and attract customers, which is against the law of their countries; and this why they have turned to European football and, more specifically, to England’s Premier League to advertise their services.

The advantages are many. Firstly, the Premier League is immensely popular in their main markets. Advertising there guarantees huge exposure, be it through shirt sponsorship or messages rolling on stadium LED boards. The PL also has a reputation for the integrity of its competition, something that could not be said of many local Asian leagues, in which corruption and match-fixing are rife. PL games are a safe bet in more ways than one.

Tellingly, the partnerships which those Asian betting giants establish with English clubs are usually short-lived, as their aim is, first and foremost, to alert their potential customers to their existence, not to grow a business in the UK itself, where their clients typically number in the low thousands – if they have any, not that it seems to bother them: the English language twitter account of LaBa360, once the official sponsor of Burnley FC, had a mere 219 followers at the time of writing. Once the name of the company has received enough exposure to build a consumer base at home – or as was the case for Moplay, a former partner of Manchester United, has gone bankrupt – it’s time to move on and be replaced by yet another ‘new’ betting company which might very well be nothing but an avatar of the previous ‘Asian betting partner’.

A good example of this is how LoveBet ‘succeeded’ the already-mentioned LaBa360 as Burnley FC’s shirt sponsor when, in fact, both are brands of the same entity(*). Seen that way, the investment is minimal, far less than what (if allowed, which it is not) a full-blown advertising campaign would cost on local billboards and television screens. So much money is at stake. What’s an investment of a few million when the market’s annual turnover is 1 trillion US dollars, and a market research institute predicted that ‘the online gambling and betting market in Asia Pacific was anticipated to expand at a significant compound annual growth rate (CAGR) of around 14 percent between 2018 and 2026’?

It must be noted that this vertigo-inducing figure dwarves the revenues of household names in the European gambling industry. To draw a parallel, the two giants from the British Isles, Bet365 and the rapidly-expanding Flutter Entertainment, an Irish consortium which controls Paddy Power, Betfair, Skybet, Adjarabet, TVG and other subsidiaries, generate an annual combined revenue of US$10.5 billion, from wagers totalling over £100 billion. This sounds huge, and is, but only represents roughly 1/10th of the amount which is bet through unregulated operators.

The profits are colossal. Major European bookmakers generate operating incomes which range from 14% to 26% of their turnover, and there is every reason to believe that unregulated Asian companies, all of which are registered in a variety of tax havens, are even more profitable. As to where the money ends, nobody knows, as nobody knows who owns those companies – and this includes the Premier League and Championship clubs which cut lucrative deals with them.

They too have no idea of who they are dealing with, or where the money they get is coming from. Manchester United and the others will never deal directly with the Asian betting companies which pay millions to put their names on shirts and boards. They don’t need to. One wonders if they’d want to anyway.

Yet those – predominantly Chinese – gambling giants are allowed to operate freely, in full public view, in the United Kingdom, home of the world’s most popular league, without adhering to the regulatory framework which British companies must abide by. How can that be?

The answer is simple: through using so-called ‘white label’ companies/agents, most often based in the British Crown dependency of the Isle of Man, thanks to agents such as Douglas-based TGP Europe Limited. All they need to do is fill in some paperwork and pay their fees – which are modest in comparison with the profits to be made. Then what was already a murky business turns even murkier.

The Manx ‘white label’ washing-machine

As far as TGP is concerned, it all started with a man named Joseph Frederick (‘Joe’) Jennings, in 1961, the year in which bookmakers were at last allowed to set up shop on the British high streets, when they’d been operating on the fringes of legality at racecourses and sports fields for centuries. Betting has been a steady companion of sport in Britain ever since horses have been raced and runs have been scored at cricket. But that ever-present companion had lived in the shadows until then. No-one seemed to know exactly which regulations, if any, applied to gambling on sporting events. Jennings seized his chance and opened his first betting office in the small town of Harlow, in the county of Essex.

As his business grew, so did Jennings’ ambitions. In March 1988, he had a new company, Joe Jennings (IOM), incorporated in the Isle of Man, which would become the family’s main concern in years to come. The Isle of Man, a self-governed Crown Dependency which draws its own laws, offered multiple advantages, first of them a generous tax system which has attracted a number of individuals and companies, especially insurance and eGambling ventures, which each account for an estimated 17% of the island’s GNP, that is a little over US$1.1 billion per annum.

‘Joe’ Jennings was one of three directors, the other two being Linda Jennings, presumably his wife, and (presumably again) their then 18-year-old son Jason, who was appointed two months after the company’s registration. This company then went through a series of name changes – Tigres, JenningsBet (IOM), Whitenet Solutions Ltd. to name the three Josimar found when researching the Isle of Man’s Companies Registry – before becoming TGP Europe Limited shortly before 2012. Jason Jennings retained executive control of the company after he’d moved to the ‘Beverly Hills’ of Dubai – Emirates Hills – in 2009. (Josimar has been unable to verify suggestions that TGP Europe is ultimately part of the SunCity Group, which is run by Macau-born, Portuguese national Chau Cheok Wa).

TGP Europe Limited was and is not a traditional betting company, however. It does not offer odds or take bets. Its customers are not ordinary ‘punters’, but overseas companies, overwhelmingly if not exclusively from the Far East, which use TGP, who hold a UK Operators Licence, to become ‘white label’ companies – in short, to obtain a licence by proxy.

In practice, this means that the service provided by foreign gambling operators is rebranded as a TGP offer, which runs and ‘powers’ their UK website. The re-branding in itself is enough to get the coveted licence from the UK’s Gambling Commission – a kind of legal re-packaging which opens up a market which would be out of bounds otherwise. It doesn’t matter that this amounts to a game of smoke and mirrors in the end, as the true market which these operators are aiming at is not the UK. As long as they can exist and advertise their existence, the job is done, even if the turnover of their ‘British’ arm is negligible.

Thanks to their ‘white label’ status, courtesy of TGP, and their ad hoc new UK offices (which they are required to have by law, but are mere shells, ghost cells manned by a handful of employees), they can then engage with clubs and strike the deals they need to publicise their offer at home – in line with has been decided in Beijing or Manila, not London or Douglas. TGP does not limit itself to sports betting companies, including various on-line casinos on its extensive list of ‘white label’ partners. Football gambling, however, represents the core of its activity.

At the time of writing, TGP was providing its services to a majority of the (mostly) Chinese-controlled, Philippines-based gambling websites which have partnerships in place with Premier League clubs, such as SBOTOP/SBOBET, Sportsbet.io, LT.com, Yabo and Fun88. TGP, though dominant, is not the only ‘white label’ provider active in Britain. BetConstruct, which holds licences in Malta, France, South Africa, Sweden and Curaçao as well as the UK, is the other major actor in this field, representing Vbet and LoveBet among others.

When contacted by Josimar, the UK Gambling Commission insisted that a ‘rigorous examination of the applicant’s suitability to hold a licence’ was paramount to the granting of that licence. This examination, however, remains limited to the company which applies for the licence, that is: the ‘white label’ structure which TGP has put in place for its clients. It does not extend to the ultimate owners and beneficiaries, whose identity is neither sought nor divulged.

None of the criteria which the Gambling Commission runs the book by (‘competence’, ‘criminality’, ‘identity and ownership’, ‘finances’, ‘integrity’, ‘upholding the licensing objectives’) apply to the concerns which stand to benefit most from the licence in the end. Once again, no-one knows where the money comes from or where it ends up, despite evidence that its origin and destination could be criminal, and the near-certainty that it feeds match-fixing.

Yet, ‘gambling businesses can run their business from anywhere as long as it is legal to do so in that region’, the Gambling Commission told Josimar; and thanks to the ‘white label’ system, it all ends up whiter than white in the wash. The Isle of Man’s own Gambling Commission, when contacted by Josimar, made it clear that it considered its British counterpart to be the supreme authority in the matter.

Gamekeepers turned poachers

Garth Kimber…

TGP certainly knows how to play the game. It has the right people for that. In December 2011, Garth Kimber, until then Head of e-Gaming development at the Isle of Man government, ‘decided to return to the private sector‘. This meant taking on the position of CEO of TGP Holdings Ltd (the parent company of TGP Europe Limited, of which he is a director) as soon as he’d left his position as a public servant. Since that date, Kimber has also become the CEO of Xela Holdings Ltd, the Isle of Man branch of a gaming consortium, after being headhunted for that job by its Asian parent company. A case of the game-keeper turned poacher, in a neat reversal of the old expression.

Bill Mummery…

Kimber is not the only Manx figure whose professional life has combined public service and executive roles within the gambling industry in the Crown Dependency. William (‘Bill’) Mummery, like Kimber a former ‘e-Gaming ambassador’ for the IOM government from 2004 to 2007, is a Director of the Isle of Man’s Public Service Commission, described as ‘the Employer Body for the IOM Government Staff’ in his LinkedIn profile. He is also a Director of the Manx Utilities Authority, a director and a council member of the Isle of Man Chamber of Commerce and the Chairman of Manx Radio, the official national broadcaster of the island. In other words, Mummery is one of the best-connected pillars of the Isle of Man’s establishment.

This impressive collection of public roles did not prevent him from becoming the CEO of e-Gaming company Celton Manx Limited, which launched the first online live casino from the Isle of Man in 2009, a venture which he himself said was aimed at attracting Asian gamblers. Celton Manx Limited appears to be a vehicle for SBOBET/SBOTOP – Leeds United’s main sponsor and the company which had headhunted Mummery in 2008 – a company whose website is run by TGP and whose Asian arm, SBOTOPAsia, has its headquarters in the Philippines.

The ownership of those companies cannot be ascertained. All that can be said with certainty is that Celton Manx Limited is registered in the Isle of Man and its Asian pendants have Filipino headquarters.

A look at the list of shareholders on the Isle of Man Companies Registry would not necessarily help to clear the mist surrounding their structure. As stated on the Manx government website, under the stipulations of the Beneficial Ownership Act 2017, ‘sometimes the actual or beneficial owner will appoint a nominee to hold the shares in their name. This is entirely legal and may be simply a personal preference for not wanting others to be aware of the owner’s investment decisions.’

Yet it is instructive to dig deeper in what is made publicly available (for a modest fee) by the Isle of Man government, even if this means hitting a wall at the end. Firstly, a look at the list of directors of Celton Manx illustrates how intimately linked that company is to Eastern Asia. Of its seven current directors, three are Singaporean, including Chief Finance Director Oan Chim Seng, one is Malaysian (Chief of Finance Siew Leon Ng) and the fifth is Taiwanese Strategy Consultant Yu-Cheng Lin. Some of these directors have been associated with the company since the very beginning, namely Oan Chim Seng and, until recently, Canadian Chief Executive Jimmy Lai.

Interestingly, these two individuals were among the eight, all of them Eastern Asians apart from Lai, who transferred their shares of Celton Manx Limited to another company registered in the Isle of Man, Celton International Limited, some time in 2008 or 2009. But looking at the documents filed by Celton International Limited at the IOM Companies Registry reveals something else: all of its 10,000 ordinary shares are owned by yet another company, Cardenhill Limited, registered in Tortola, British Virgin Islands. There the trail ends, as it usually does when it’s led to the Caribbean tax haven.

Makati, the Square Mile of online gambling

The bewildering complexity of the management and ownership structure of Celton Manx SBOTOP/SBOBET is typical of the way ‘white label’ companies operate, and explains how the Asian/Chinese betting giants can prosper undisturbed, unquestioned even, even though there would be plenty of tricky queries to answer to. The Isle of Man government itself is unlikely to do the questioning. It actively courts the biggest names in Asian e-Gaming on their own patch and regularly sends envoys to the major industry shows which are held in the region. This is how Tony Ure, a former executive specialising in poker at IGT GTECH and the Head of e-Gaming at the Isle of Man Digital Agency since 2017, was present at the largest event of this kind in the region, the G2E Asia Gaming Expo held in Macau in May 2019, as he had been a member of the jury of the G2E Asia Awards the year before that.

Most of the Asian online gambling entities have brought their operations to the Philippines, where they cannot offer their services to Filipinos, but are free to propose them to anyone else. Setting up there, in the so-called ‘Cagayan Special Economic Zone and Freeport’, requires the payment of an application fee of US$40,000, which is topped up by another fee of $48,000 once the application has been approved by the Filipino authorities, after which the licence will be renewed at a cost of $60,000 a year. Despite opposition by local politicians, safeguards are virtually non-existent in the Philippines, perhaps a reflection of the contribution of gambling to the country’s finances: the gambling boom is said to have created 470,000 jobs and to contribute $11 billion annually to the Filipino economy.

These steep fees have not deterred prospective applicants. It has been estimated that almost a third of office space in Manila’s business quarter Makati is occupied by at least 300 online gambling operators, of which about a sixth – the major actors – are known as POGOs(*).  These operators bring in, sometimes illegally, their Mandarin-speaking staff, whose working conditions are so harsh (confiscation of passports, twelve-hour working days and employees manacled to their desks, for example), that at least one suicide was reported in the Filipino media.

Makati is the base from which the Chinese companies deploy their marketing campaigns in the UK, which then boomerang back home thanks to the popularity of the Premier League, whilsts agents on the ground – mainly on the Chinese mainland – take care of customers. ‘Taking care’, in this instance, is thought to include loaning money at shark rates to losing punters. There are no regulations, no safeguards, no limits.

Whilst European gambling concerns will cap maximum bets at an ‘affordable’ level (£100, for example), will keep track of who exactly is betting and have a duty of care towards their customers (regardless of what could be said about the ethical nature of betting per se), those Far Eastern operators whose names are writ large on Premier League shirts will accept bets from anyone, in a number of currencies, including cryptocurrencies, with no maximum wager set. Some individuals will bet thousands, even tens of thousands of dollars on a single outcome. All transactions are cloaked in complete secrecy, just as is the identity of those who will continue to earn millions, billions even.

A ‘cancer’ which nobody seems willing to root out

It is not as if it were impossible to take action against those secretive e-Gambling companies. It is just that almost everyone seems reluctant to do so. The Chinese government’s attitude remains ambiguous. On one hand, it uses the fiercest of rhetorics to condemn gambling and, especially, e-Gambling, a ‘cancer’ which must be ‘eradicated’. On the other hand, it still allows it to flourish in the ‘special administrative zone’ of Macau, just as it allows gambling operators to advertise their services in Hong Kong. It has seized more than US$32.95 billion  from bank accounts linked to online gambling and precipitated the closure of some operators, such as AG Asia Entertainment, but hasn’t cracked yet as forcefully as it could have, and most of its e-Gambling industry remains relatively unscathed as a result.

Why? Some have said that this was a means to gain political influence over countries such as the Philippines by maintaining the threat to move decisively against one of their key economic sectors – in other words, tow our line, and we’ll leave you undisturbed. Others suggest that corruption within the Chinese authorities is so rife that gambling operators can pay for their relative inaction. In any case, very little has changed in practice, and there are no clear signs this is to change in the near future.

Neither will decisive action be taken by Rodrigo Duterte’s government, which has ruled out banning offshore gambling companies in the Philippines outright, even if two of these, Suncity and Hong-Kong-based Don Tencess Asian Solutions, sought a cancellation of their licence following ‘tax problems’ with the Filipino authorities, the latter being dissolved in May 2020. This is despite multiple reports of suspected links between at least some of these companies with labour exploitation, flouting of immigration rules, bribery of officials, sex-trafficking (some Manila casinos double as brothels) and, especially, money-laundering.

Data gathered by the Filipino Bureau of Customs evaluate that US$390 million were laundered in the Philippines through e-Gambling by Chinese criminal syndicates in 2019 – to which must be added $633 million of ‘suspicious’ cash which was brought into the country from September 2019 to March 2020. Isolated raids have been conducted (277 Chinese online scammers were arrested in one of these last year), but this constitutes a mere drop in the ocean. 56 predominantly Chinese POGOs (Philippine Offshore Gaming Operators) have been granted a licence in the country since they acquired legal status in 2016 (*), which employ an estimated 250,000 Chinese nationals. As presidential spokesman Salvador Panelo said in March of last year, “we still need their money”.

The Premier League itself, should it wish to have a closer look at the relationship of many of its clubs to ‘white label’ e-Gambling platforms (something which these clubs might not be necessarily keen on), would not be able to do so as, ultimately, it all falls down to the British Gambling Commission to apply the rules. And so we get back to square one: the ‘white label’ system, as it exists today, makes it near-impossible to track down who owns these e-Gambling platorms and benefits from them. As long as this system is in place and companies can hide behind a screen of other companies and the ultimate shareholders can conceal their involvement by appointing nominees, nothing will change.

The biggest threat to the sports betting operators, in fact, has not been the governments of China or the Philippines, but the COVID-19 pandemic, which led to the postponement and/or cancellation of almost all sports competitions worldwide from March 2020 onwards and also put an end to ‘VIP gambling’, as international travel became impossible and casinos had to shut down. Gamblers accustomed to bet on Premier League matches had to turn their attention to the handful of leagues which still functioned. For example, friendly games between amateur Swedish sides, some of which were broadcast live on YouTube, were offered on e-Gambling platforms (including those which sponsor Premier League clubs) and each attracted hundreds of thousands of dollars in bets amidst allegations of match-fixing and player intimidation.

But this represented only a fraction of the money POGOs churned up pre-COVID, and dealt a fatal blow to at least five of them in the Philippines, as well as at least ten of their local service providers. The others survived, however, and can prosper again now that full league programmes have resumed throughout the world. All of this, thanks in part to the silent complicity of some of the biggest clubs in the world.

Josimar asked William Mummery and TGP Europe Limited for comment and provided them with a list of detailed questions. We have not heard back from them. (**)

(*) Burnley’s new shirt sponsor, Spreadex, is also an e-Gambling operator, which offers spread betting on sports events and on the stock market. They are based in the United Kingdom. It is worth noting that the ‘multi-million deal’ announced by Burnley represents a surprisingly high proportion of their annual turnover, which was £49.06m over the last tax year.

(*) POGO = Philippine offshore gaming operators

(*) 45 were active at the time of writing, which include all of those which are currently linked with Premier League clubs.

(*) According to a statement posted on Watford FC’s website, ‘Founded in 2017, Stake.com is one of the leaders in its industry, with over 30 billion transactions per year accounting for over five per cent of Bitcoin transactions worldwide’. However, their UK website (for ‘UK customers only’) doesn’t appear to be operational yet. Stake.com is also UFC’s official partner for Asia.

(**) When first published, this sentence read ‘We have not heard back from either despite repeated inquiries’. We have contacted Mr Mummery and  TGP Europe Limited once each – not multiple times. The sentence was amended on Tuesday 24 August 2021 at 12:30 Norwegian time.

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