Delasport, Bellona & Shark77: EU-Targeted Operations Under Curaçao/Malta Fronts — Compliance Risk Brief

Overview

A whistleblower alleges that Delasport Ltd (Gibraltar) exerts operator-level control for brands fronted by Bellona N.V. (Curaçao, 8048/JAZ) and Shark77 Ltd (Malta), while aiming at Germany and other EU markets without national authorizations or technical integrations such as OASIS and LUGAS. The setup is said to be completed by EU-based marketing and payment channels.

Read our Shark77 report here.

Key Points at a Glance

• Brands named: 1Bet, 18Bet, BabiBet, CasinoWinBig.

• Licensing fronts: Bellona N.V. uses the 8048/JAZ licence umbrella; Shark77 Ltd (MGA) is linked to 18Bet and CasinoWinBig.

• Delasport’s alleged scope: beyond platform tech to centralized PAM/CRM, risk & KYC, and payment routing, indicating operator-in-substance exposure.

• EU payments conduit (alleged): Arzella Ltd. (Cyprus); PremiumTradings referenced as a related “sister” back-office/brokerage.

• Affiliate acquisition & analytics: Keymarketings Ltd and Global Tech Market Ltd (director Ilan Shemesh) allegedly manage EU-facing performance marketing.

• German compliance gap: GlüStV 2021 requires a GGL licence plus OASIS self-exclusion and LUGAS reporting—none evidenced here.

• Player feedback themes: withheld winnings, withdrawal delays, and unverified self-exclusions.

Entity Map

How the Alleged Structure Works

1. B2B tech façade with B2C command: If Delasport centrally handles KYC, risk, payments, and customer communications, regulators may treat it as an operator in substance in any unlicensed EU market.

2. Curaçao/Malta fronting: Bellona N.V. (Curaçao, 8048/JAZ) and Shark77 Ltd (MGA) provide jurisdictional “covers” while consumer targeting allegedly happens inside the EU.

3. EU marketing & payments nodes: EU-based affiliate operations (Keymarketings/Global Tech Market) and a Cyprus payments link (Arzella Ltd.) are said to complete the pipeline.

4. Operational red flags: mirrored domains, EU-hosted affiliate tooling, and payment detours that can obscure geographic targeting and licensing status.

Germany as the Decisive Test

Under GlüStV 2021, offering to German residents requires:

• A GGL licence,

• Live connections to OASIS (self-exclusion), and

• LUGAS data reporting.

The whistleblower materials do not evidence these requirements. Any active targeting of Germany without them would be unlawful, exposing Bellona N.V., Shark77 Ltd, Delasport Ltd, and EU-based counterparties to potential consumer-protection, AMLD, and gambling-law liabilities. Coordinated scrutiny could involve GGL, MGA, CySEC, BaFin, OLAF/EUROJUST.

Player & Market Feedback (Selected Themes)

• Withheld winnings and slow/blocked withdrawals

• Inadequate self-exclusion or unverifiable OASIS compliance

• Opaque dispute handling and limited escalation channels

Risk Assessment (Condensed)

• Licensing risk: High (if EU targeting occurs without national authorization).

• Operator-in-substance risk: High (centralized KYC/risk/payments by Delasport implies B2C control).

• Payments/PSP risk: Medium–High (EU conduits increase regulatory touchpoints).

• Affiliate/marketing risk: Medium–High (EU analytics & acquisition for unlicensed targeting).

• Consumer-protection risk: High (complaints around withdrawals/self-exclusion).

Call for Information

Were you a player, affiliate, contractor, or PSP for any of the entities or brands above? Scam-Or Project invites documented evidence—such as KYC or withdrawal correspondence, merchant descriptors/IBANs, affiliate dashboards, internal communications—via the Scam-Or Project Whistleblower section. Submissions are treated confidentially and source-protected under Directive (EU) 2019/1937.