Welcome, criminals! Do you need to launder earnings from criminal operations? What you need is a ‘grey’ source of income, such as online gambling. You can then mingle any criminal proceeds with ‘legitimate’ gambling income.
By Andy Brown, Philippe Auclair, Jack Kerr, Steve Menary, and Samindra Kunti
Net88 and DeBet are illegal gambling companies being investigated by regulators, after both brands secured ‘record’ sponsorship deals with Crystal Palace and Wolves. In this handy ‘how to’ guide, Josimar will explain how quirks in UK gambling regulation allow you to sponsor a Premier League club and launder money through the creation of what appears to be a ‘legitimate’ gambling operation.
A plethora of software companies means that setting up an online gambling business is easy for anybody with a bit of spare money, as Josimar has previously exposed. It is also easy to attract large numbers of Asian customers in a short space of time due to quirks of British gambling regulations, which allow you to advertise using ever-popular televised Premier League football.
All you need is a football club willing to take your money without asking questions and a licensed ‘white label’ partner willing to build you a dot co dot uk site. Finding a willing club isn’t difficult, as Josimar has previously exposed – 12 of the 20 Premier League clubs have Asian betting partners.
Finding a white label partner is even easier. There are currently over 700 white label agreements – one for every four licensed British operators.
Best of all is that you don’t need to hold a licence yourself. It is only necessary that your white label partner holds one. But a backstory enabling supporters to trust the deal is wise.
You can then sit back and watch your ‘legitimate’ earnings from your ‘licensed’ gambling business grow, obscuring any illegitimate revenue.
No license? No problem!
A good illustration of how this works in practice is provided by Net88 and DeBet, who agreed record deals with Crystal Palace and Wolverhampton Wanderers a day apart. To operate a gambling website, a licence is usually required from a valid regulatory authority.
Claiming to hold a licence builds trust in your brand, but be careful which regulatory authority you claim to be regulated by. Following questions sent by Josimar, the Malta Gaming Authority (MGA) has launched an investigation into DeBet’s claims that it is licensed by them.
“We confirm that DeBet does not hold an MGA licence,” said an MGA spokesperson. “Any reference to the MGA on the mentioned website is therefore false and misleading. The Authority has initiated an investigation into this issue.”
The MGA logo features at the bottom of DeBet’s ‘real’ internet site…
Net88 doesn’t display a seal on its internet site. However once logged in, the following text is displayed. ‘NET88 was established in 2020, headquartered in the Philippines with an advanced technology platform,’ reads a translation. ‘NET88 operates under a Philippine license and is under the authority of CEAZ & First Cagayan.’
Care over bogus licensing claims also needs to be taken. ‘CEAZ’ is understood to be a typo and should read CEZA, in reference to the Cagayan Economic Zone Authority. CEZA didn’t respond to questions sent by Josimar about whether it licensed Net88 through First Cagayan Leisure and Resort Corporation.
First Cagayan lists seven sub-licensees on its internet site, all of which are business names rather than gambling brands. It has failed to respond to repeated questions from Josimar about Net88 – the first set sent in June 2024.
Net88’s ‘real’ website. The grey text claims it is licensed via the Cagayan Economic Zone Authority through First Cagayan.
CEZA and First Cagayan are located within The Philippines, which is a hotbed for registering gambling companies targeted at jurisdictions where gambling is illegal. We checked if either DeBet or Net88 are owned by any companies licensed by the country’s official regulatory authority.
“The subject websites are not declared under any licensees of the Offshore Gaming Licensing Department,” said a spokesperson from the Philippine Amusement and Gaming Corporation (PAGCOR). “Any information regarding a licence with PAGCOR presented on their websites is fabricated, potentially intended to mislead the public regarding their legitimacy.”
Even if they did hold licences granted by any of the regulatory bodies in The Philippines, they are no longer valid. Following a July 24 decree issued by President Marcos, all offshore gambling licenses in the Philippines were revoked from 31 December 2024.
But, fortunately for DeBet and Net88, this doesn’t matter at all. It doesn’t even matter if your UK facing site closes down. Since your white label partner in Great Britain holds a licence, you can still advertise your brand there. And nothing has a greater appeal to Asian sports fans than televised Premier League football.
White label love
White label agreements allow gambling brands based overseas who wish to target customers in Great Britain to secure an agreement with an operator licensed by the Gambling Commission to build and manage a website for them. This was originally designed to allow brands based overseas to partner with a licensee so that they can target British customers.
The Gambling Act 2005 makes it an offence to advertise ‘unlawful gambling’ in Great Britain – i.e. gambling that isn’t licensed by the Gambling Commission. When a gambling brand enters a white label agreement with an operator licensed by the Commission, the gambling being advertised by that brand in Great Britain is licensed, so no offence is committed.
It doesn’t matter whether other dot com sites offered under that brand are targeted at customers in other countries, even if gambling in that country is illegal. It also doesn’t matter if the white label partner shuts down dot co dot uk operations, as has recently happened with BC.Game, 8xBet and Kaiyun, sponsor of Crystal Palace, Chelsea and Nottingham Forest.
What matters is that the white label partner operated a site for that brand and lists that site on the Commission’s website. If a site existed, even if it is now inactive, the brand connected to that site can advertise in Great Britain.
Gambling Commission licensees, such as TGP Europe (DeBet) or Risq Capital (Net88), are not required to check whether white label gambling brands they partner with are regulated. The only rule that comes close requires licensees to ‘ensure that any contracted third parties conduct themselves in so far as they carry out activities on behalf of licensees as if they were bound by the same licence conditions and subject to the same codes of practice.’
This provision could require licensees to check if third parties are regulated. But, perhaps tellingly, it doesn’t actually spell this out. As previously reported by Josimar, Section 331 of the Gambling Act made it an offence to advertise unregulated foreign gambling. However, that offence was repealed by the Gambling (Licensing and Advertising) Act 2014.
In the Gambling Commission’s eyes, DeBet and Net88 are not doing anything illegal. We checked by asking them if any action would be taken against licensee TGP Europe for providing a white label licence to DeBet, as it targets Vietnam where online gambling is illegal.
“TGP Europe does not provide a white label licence to DeBet,” said a Gambling Commission spokesperson, pointing towards the regulations outlined on its website. “www.de-bet.co.uk is a white label domain operated by TGP. TGP is the licensee. The Gambling Commission expects that licensees will obtain the necessary assurance by conducting adequate due diligence on the third party to ensure (amongst other things) that they are competent and reliable.”
Even if the Gambling Commission did launch an investigation into TGP, it wouldn’t tell us. “We do not talk about individual operators, cases or investigations,” said a spokesperson. “This would include neither confirming nor denying they exist. We may publish the outcome of any regulatory actions on our website.”
This use of “may publish” suggests that some investigations it conducts remain hidden from public view. This is especially useful if you need to abandon a sponsorship agreement and disappear without paying your football club partner.
A marketing executive from a Premier League club told Josimar that it now insisted on payment of sponsorship fees upfront when dealing with gambling brands. A previous Asian-facing betting partner had disappeared after only six months, failing to pay the second installment of the agreed sum. The club was unable to track back the brand in question and never got its money.
The UK is not the target
The UK sites for DeBet and Net88 show how this neat arrangement operates in practice. Analysis by SimilarWeb found that DeBet’s UK site attracted a tiny 835 visitors in total during November 2024. Net88’s UK site fared slightly better, attracting 14,700 visitors during the same period.
Midnite(dot)com, which describes itself as a new bookmaker and is licensed by the British Gambling Commission, attracted nearly 870,000 visitors in November 2024. The Sports Integrity Initiative website, run by one of this article’s authors, hasn’t featured any new content since August 2023 and attracted 10,000 visitors in the same period.
Similarweb reports just 835 visits to DeBet’s UK site in November. It appears that it was launched solely to allow the brand to advertise using Premier League football.
DeBet and Net88 are not concerned if their UK websites, launched in June last year, fail to attract a single customer. The real target of both sites is Vietnam, as previously reported by Josimar (here and here). Both brands have been operating in this market, where online gambling is illegal, for only slightly longer than they have been operating in the UK.
A Telegram group for DeBet was launched on 25 September 2022 and for Net88 on 13 October 2023. Both are exclusively in Vietnamese, as are Instagram accounts connected to the two brands.
The methodology employed by both brands suggests links between the two. On DeBet’s official Telegram group, its current site is listed as debet(dot)bot. This is also the first link returned when conducting a search from Vietnam. The site regularly changes its domain (it was previously debet(dot)moi), perhaps to avoid regulatory action.
On Net88’s official Telegram group, its current site is listed as net88(dot)tv. This is also the first link returned when conducting a search from Vietnam. The site also regularly changes its domain (it was previously net88(dot)onl), perhaps to avoid regulatory action.
Both brands post Telegram updates within minutes of each other.
Two UK licensees operate UK facing websites for DeBet and Net88. Regular Josimar readers will be familiar with TGP Europe, which operates DeBet’s UK facing site. This company operates over 15 gambling websites from a two bedroom residential flat above a betting shop on the Isle of Man, has links to SunCity, one of Macau’s gambling giants that recently rebranded as LET and its suspected Triad member Alvin Chau, jailed in January 2023 for various offences.
Net88’s UK facing site is operated by Risq Capital, a company owned by Tom Mitchell and John Nagle. “It is our policy not to disclose any information regarding our third party partners without their prior consent,” said a Risq Capital spokesperson, in response to questions about Net88’s ultimate owners. The company pointed to its British licence when asked whether Net88 holds a valid licence, and would not elaborate on how its deal to produce a UK site for Net88 happened.
Such secrecy is vital should you need to disappear quickly. A white label partner who spills the beans would prevent you from continuing to launder money by setting up a new gambling brand with a new partner. This method was used by Yabo after it was dismantled by Chinese police. Josimar exposed how it returned as Tianyu Technology and later as BOE United Technology Limited, controlling gambling brands which continued to sponsor British football clubs.
Time to have some fun
On social media, Josimar struggled to find any Crystal Palace or Wolves fans that supported the involvement of Net88 or DeBet. However, some welcomed the money that the record deals would bring in. English football fans really want to trust any brand that puts money into their club, and enables them to sign star players driving ostentatious Maseratis. Any backstory that builds that trust is helpful.
But why not have a little fun? Like OKVIP, you could write a pop song featuring star football players and scantily clad dancing girls, boasting about your prowess in the Vietnamese market. A saved version of this video can be viewed here.
Or you could play on your site’s name. DeBet concocted a remarkable backstory about how it was established in Deutschland (Deutsche Bet) and somehow ‘moved’ to Vietnam. Of course, this is completely false, as previously reported by Josimar.
DeBet claims to have been established in Germany, but targets Vietnam…
Once you’ve got your white label partnership in place, it doesn’t matter what claims you make. Through Premier League football, you have your advertising window into your chosen market and regulators cannot touch you. Even if they could, it is only your white label partner that is ‘licensed’ by the British Gambling Commission. Any action taken would be against them, allowing you to conveniently disappear.
Even the advertising regulators cannot touch you. We asked the Advertising Standards Authority (ASA) whether DeBet and Net88’s use of stooges as company representatives broke any of their Codes of Practice.
“Gambling sponsorship is excluded from the ASA’s remit,” said a spokesperson. “Sponsorship, in and of itself, is a contract or other arrangement between a sponsoring brand and another party; the Codes administered by the ASA do not apply to sponsorship arrangements themselves. Where sponsorship (e.g. of events, sports teams etc.) is featured in ads, the ads are subject to ASA regulation. If an individual was used in an ad in a way that was potentially misleading, then we could, in theory, look into concerns about that.”
It is almost the perfect arrangement. This means that Forest and Chelsea can now link to Kaiyun websites that are unavailable to British customers, even though TGP Europe has shut down the Kaiyun dot co dot uk website it produced for Kaiyun. Crystal Palace is still displaying a Kaiyun link to visitors from Asia, despite its shirt sponsorship agreement with Net88. You can promote an illegal(*) site without facing any action.
But care should be taken when registering trademarks. We asked the UK Intellectual Property Office (IPO) whether it could ask a registrant, such as IPS Law or PL Consultancy (DeBet and Net88), to reveal who instructed them to register a UK trademark. We also asked if trademarks can be revoked if they are shown to be connected to organised crime and/or illegal services. “Where there is any evidence of wrongdoing by an applicant, rights holder, or their representative, we will consider actions as appropriate, within our legal framework,” said a spokesperson.
The laundry will remain open
Finally, some more good news! Many supporters and activists have welcomed the Premier League’s agreement to ban gambling brands from front of shirt sponsorship from the start of the 2026/7 season. This is a clever trick that will keep these killjoys happy, while allowing money from illegal gambling to continue to flow into Premier League football.
Premier League clubs have only agreed to withdraw gambling companies from the front of shirts, not the back, sleeves, shorts, training kit, or from perimeter advertising. Partnerships with Asian gambling companies will still exist, but will be hidden from plain sight in order to avoid scrutiny.
Crystal Palace demonstrated how this will work in the future, hiding its partner Kaiyun from UK eyes prior to the Net88 deal, as exposed by Josimar. Digital overlay technology means that these partners can also advertise so that these brands are only visible to views in Asia, as Josimar reported.
Spot the difference: The top image shows the Crystal Palace website when accessed from the UK. The bottom shows the same website when accessed from Asia.
Fortunately for criminals, nobody wants to upset the gravy train. These deals have become too valuable for football and the brands concerned, who do not have to comply with troublesome anti-money laundering regulations or measures to protect people from gambling addiction.
In August 2022, journalists working for Josimar first sent questions outlining how the white label system is being abused to the Gambling Commission. Since then, we have held meetings with the Gambling Commission’s Head of Governance, and have submitted dozens of Freedom of Information (FOI) requests. We submitted evidence on the abuse of the white label system to the previous government as part of the 2023 review of the 2005 Gambling Act.
Not once have we received a response that indicates any appetite to tackle this issue. The 2023 review of the 2005 Gambling Act didn’t mention any reform to the ‘White Label’ system, despite the evidence we submitted. In fact, the previous government didn’t even bother to reply.
The pantomime that allows an Arsenal fan to pose as two different company representatives in sponsorship deals signed a day apart will continue. Of course, such facilitators will also keep quiet, so long as they are paid handsomely. If you want to hide criminal proceeds and escape scrutiny when the heat is on, then British football and its white label gambling licensing system remain perfect for you. It’s almost as if it’s designed that way.
(*) “illegal sports betting” means “any sports betting activity whose type or operator is not allowed under the applicable law of the jurisdiction where the consumer is located,” in line with the definition agreed by the Macolin Convention.
