eMoore / EM Group: A “Compliance” Brand Inside a Europe-Facing Curaçao Casino Structure

Overview

A newly reviewed whistleblower dossier, together with publicly available records, places eMoore N.V., a Curaçao-based trust-office entity within the EM Group, at the center of governance and Cyprus-linked payment infrastructure tied to a network of online casinos targeting European players without proper national authorization.

The central inconsistency is evident: while EM Group promoted compliance services and German licensing support, its own subsidiary allegedly remained the managing director of Bellona N.V. for nearly 15 years, during which Bellona-operated brands were active in Germany without authorization from the GGL.

Key Findings

• eMoore N.V. acted as managing director of Bellona N.V. from 28 October 2010 to 7 April 2025, linking it directly to the operator behind 1Bet and a broader Bellona brand network.
• Bellona allegedly targeted German users without GGL authorization, without integration into the OASIS system, and continued operations even after a 2022 German regulatory warning.
• On 21 December 2022, EM Group publicly warned operators about increasing legal risks in Germany and advised obtaining local legal guidance — weakening any argument of lack of awareness.
• The structure includes a Cyprus layer involving eMoore Cyprus Ltd, along with entities such as Arzella Limited, Maliom Ltd, and Xenith Ltd, described as part of the payment and corporate infrastructure.
• The documented network spans 35 active brands, linked through registries, invoices, website disclosures, and operational footprints connected to eMoore, EMS Management, or the Livestrong Building in Curaçao.
• Recent EU legal developments have significantly increased exposure regarding unlicensed gambling, director liability, and cross-border enforcement.

Scam-Or Project Investigations

Previous reporting by Scam-Or Project (November 2025), based on earlier whistleblower submissions, had already identified the Bellona–Delasport network, including:

• Bellona N.V.
• Arzella Ltd
• German-facing activity without required compliance controls

The newly submitted dossiers expand this picture by introducing:

• The trust-office layer
• Direct management roles
• A broader Cyprus-based corporate and payment structure

Compliance Analysis

A Trust Office at the Core

The reviewed intelligence package suggests a well-supported working hypothesis: a corporate group publicly offering compliance and licensing support appears simultaneously embedded in the governance and payment framework of a network operating without authorization in several EU jurisdictions.

The dossier outlines how gambling operations associated with eMoore and EM Group repeatedly entered regulated European markets without valid national licenses and, in multiple cases, faced regulatory action or enforcement measures.

Enforcement Dimension

The significance of this case lies not merely in offshore operators targeting EU players. The key issue is that a firm presenting itself as a compliance specialist may have contributed to:

• Governance structures
• Management oversight
• Operational continuity of non-compliant gambling activities

The whistleblower materials provide detailed documentation of alleged compliance breaches across multiple casinos connected to the eMoore/EM Group ecosystem.

The Bellona Case: Central Example

At the center of the investigation is Bellona N.V., a Curaçao-registered operator behind several brands, including:

• ZodiacBet
• DachBet
• WeltBet
• EmirBet
• Slotimo
• Betonic
• Winolot

Structural Overview

• Incorporation date: 28 October 2010
• Beneficial ownership (as stated in dossier): linked to the Israeli Shemesh family, including Avi Shemesh and Ilan Shemesh
• Technology layer: reportedly based on Delasport infrastructure
• Technical setup: shared backend systems and facade-api.com gateway

Management Role

According to the dossier:

• eMoore N.V. served as managing director of Bellona from 2010 to April 2025
• During this period, Bellona allegedly:
• Targeted German users without a license
• Operated without OASIS integration
• Continued activity despite regulatory warnings

This positions eMoore not as a peripheral service provider but as part of the formal management structure.

Platform Pattern: Delasport Comparison

The Bellona–Delasport structure reflects patterns seen in earlier investigations into SoftSwiss, where:

• Technology providers are positioned as neutral B2B platforms
• The operator layer remains fragmented across offshore jurisdictions
• Payment intermediaries and regulatory arbitrage play key roles

While this does not imply identical conduct between Delasport and SoftSwiss, the structural similarities justify closer examination.

The Core Contradiction

Public Compliance vs Operational Exposure

A major element in the dossier is the contradiction between:

• EM Group’s public positioning as a compliance provider
• Its alleged internal exposure to non-compliant operations

On 21 December 2022, EM Group acknowledged:

• Increasing German court rulings in favor of players
• The need for legal risk assessment by operators

At the same time, one of its managed operators was reportedly already exposed to these risks.

This undermines any argument that the group was unaware of the legal environment.

Selective Compliance and Market Targeting

The dossier, citing Follow the Money (January 2025), indicates:

• Geo-blocking applied: Netherlands and United States
• Not geo-blocked: Germany

This suggests a selective compliance approach, where:

• High-risk jurisdictions were restricted
• Key revenue markets like Germany remained active despite regulatory pressure

Beyond Bellona: Expanded Network

The investigation extends beyond Bellona to additional entities, including:

• Mandarin Gaming N.V.
• Exedra N.V.
• Casiworx N.V.
• Prolific Trade N.V.

Associated Brands

• 1Bet
• Betonic
• Slotimo
• CasinoBet
• BangBang Casino
• Casino 770
• EGB
• WinCraft
• SlotoRush
• Norsewin
• FreakyBillion

The network mapping is based on:

• Registry data
• Invoice trails
• Website disclosures
• Technical verification

The Cyprus Layer

A critical addition in the dossier is the Cyprus-based infrastructure:

Key Entities

This structure suggests that offshore operators may have been supported by EU-based payment and corporate infrastructure, increasing exposure to European regulators.

The Wunner Ruling and Legal Impact

The Wunner ruling by the CJEU significantly changes the legal landscape:

• Players can bring claims under the law of their country of residence
• Damages are considered to occur where the player resides
• Claims against directors are classified as tort claims under Rome II

Implications for Bellona / eMoore

• EU players may pursue:
• Recovery of losses
• Damages claims
• Director liability actions
• Enforcement may extend to:
• EU-based assets
• Payment structures

For Germany, additional support comes from national case law and the Tipico line of rulings.

More info about the Wunner Ruling is here.

Summary Table

Scam-Or Project Conclusion

Based on the reviewed whistleblower materials and supporting public records, Scam-Or Project concludes that:

• eMoore / EM Group appears within the management and payment infrastructure of a network of Curaçao-linked operators
• These operators were repeatedly associated with unauthorized gambling activity targeting European players

The central issue is not whether EM Group marketed compliance services — it clearly did.

The critical question is whether those compliance principles were consistently applied within its own operational sphere.

According to the available record, that consistency appears significantly lacking.

Call for Information

If you have worked with or interacted with any of the following:

• eMoore
• EM Group
• Bellona
• Arzella
• Maliom
• Xenith
• Delasport
• Associated brands

— whether as an employee, affiliate, PSP, or service provider — you are encouraged to share information.

If you are a player from Germany, Austria, the Netherlands, Sweden, Denmark, Spain, or other EU countries affected by these platforms, your input is also relevant.

Submit documents, payment data, correspondence, or internal materials via the Scam-Or Project whistleblower section.

Your contribution may assist regulators, affected individuals, and the broader public in understanding how this network operated.