FinTelegram has looked at both investment and trading providers and facilitating payment processors over the past few years. The latter are the most important element for the operation of B2C services. Customers need to be able to deposit and withdraw. Very often we have found violations of regulatory requirements and AML/CFT specifications. Going forward, we also want to take a look at gambling schemes from a payment perspective, starting with MGA-regulated Shark77 Limited.
Key Data
| Trading names | Bet18 sportempire CasinoWinBig |
| Business activity | Online casino, gambling and sports betting |
| Domains | https://www.sportempire.com https://www.18bet.com http://casinowinbig.com |
| Legal entity | Shark77 Limited |
| Jurisdiction | Cyprus |
| Authorization | MGA (MGA/B2C/409/2017) |
| Platform | Delasport (www.delasport.com) |
| Payment processors | Praxis, Skrill, Rapid Klarna, Neteller, ecoPayz, MuchBetter, Volt, Revolut, flykk |
| Related individuals | Jeremy Debono, EMD Advocates (LinkedIn) |
| Related brands | RichKing Casino (www.richkingcasino.com) |
Short Narrative
The MGA-regulated Shark77 Limited officially operates the three platforms 18Bet.com, sportempire.com and CasinoBigWin.com. Allegedly, the RichKing Casino platform is also part of the Shark77 network, but we could not verify this definitively.
All platforms address customers in different regions. Among them are also UK, Norway, Germany, Austria, or Hungary although Shark77 does not have a license for these countries. According to September Similarweb statistics, the most website visitors for 18Bet.com and CasinoWinBig.com come from Hungary, Finland, Sweden and Austria. To operated in these countries, Shark77 would need a national license, and other restrictions apply beyond that.
New customers receive a welcome bonus of up to 100% of their deposits on all platforms. After registration, new customers are taken to the deposit page before a KYC check, where they can deposit up to €10,000 via credit and debit card, Skrill, Neteller, MuchBetter, Rapid, Revolut, Volt and other payment options (see table above). For customers from Norway, the facilitating payment processor is flykk.
Money-Laundering Considerations
The Malta Gaming Authority (MGA) is the supervisor for the Prevention of Money Laundering and Funding of Terrorism Regulations.
The AML/CFT obligations require MGA-licensed casino and gaming licensees, more specifically B2C licensees offering Type 1, 2, and 3 games, to apply a risk-based approach in applying AML/CFT measures, controls, and procedures. The majority of the obligations are triggered once the client reaches a threshold of €2,000 in accrued deposits throughout the business relationship or over a rolling period of 180 days.
The Funds Management Procedures shall state that the identity of players will be verified if the total accumulation of deposits equals or exceeds €2,000.
MGA Guideline
Shark77 Limited is a B2C licensee, and 18Bet is one of its trading names. Therefore, according to the AML/CFT rules in force at the MGA, no deposit of more than €2,000 should be possible without prior KYC verification. However, in our review on October 26, 2022, pre-KYC deposits of up to €10,000 would have been possible, i.e., before our identity was confirmed.
So one would think that for new customers who are not yet KYC-approved, they would not be allowed to deposit more than €2,000. This restriction would be technically easy to implement.
Share Information
If you have any information about Shark77, its brands, and its facilitators, please share it with us through our whistleblower system, Whistle42.
