The current debate over whether betting companies – ranging from the established to the obscure – should be allowed to be kit sponsors on the shirts of English football teams has a Maltese connection to it, The Malta Independent on Sunday can reveal.
The UK government is currently carrying out a major review on its gambling industry which is expected to look closely at the issue of football sponsorship.
The review comes at a time when the UK Gambling Commission has admitted to concerns that some betting websites being advertised to crown and country on the front of the shirts of some of the country’s biggest football teams may not have effective anti-money-laundering controls or may not carry out sufficient due diligence on their websites in order to ensure that there are no links to criminal activity.
The Malta Independent on Sunday can reveal that there is a Maltese connection to the debate and to the very presence of certain obscure gambling websites on the front of some Premier League kits.
Kit sponsorships are now a key part of a football club’s revenue – amplified by the global reach of football, in particular that of the English Premier League. However, gone are the days of when clubs were sponsored by local firms looking to gain exposure in the local market.
Football’s global appeal and reach has resulted in interest from multi-billion-pound industries – such as the gambling industry
This season, eight out of the 20 Premier League clubs have gambling companies emblazoned onto the front of their kits, while almost all of the other clubs (Chelsea, Liverpool, and Sheffield United are the only exceptions) have sponsorship agreements with gambling companies in other forms.
Some of the firms sponsoring these clubs are familiar names – William Hill (Tottenham Hotspur) and Bet365 (Leeds United and West Bromwich Albion) are two examples – however many others are obscure Asian companies which seek to market their websites to countries in Asia, particularly in China – where running and marketing gambling company is illegal.
This is precisely why some clubs can be seen sporting Chinese script on the front of their kits come matchday.
These Asian companies have access to the UK market through so-called “white label” arrangements, wherein their websites are run by intermediary companies which can be based outside of the UK.
Under such an arrangement, it is the intermediary company which has to ensure that the company they are running the website for is compliant with the UK’s online legal gambling requirements. It is also down to the intermediary to conduct the necessary due diligence on their white label partners.
This newspaper can reveal that one of the intermediary companies which has entered into white label arrangements with Asian gambling websites which sponsor Premier League football teams is Vivaro Limited – which is registered in Malta.
A profile: Vivaro Limited and its ties to English football
Vivaro Limited was, according to the Malta Business Registry’s records, registered on December 23 2008. Based in the Diamonds International Building inside Portomaso, it lists Armenian Kristine Hambardzumyan as its director, legal representative, and judicial representative.
Its sole shareholder is a company called Soft Construct Limited, which is registered in the Isle of Man. The paper trail of ownership of these companies eventually leads back to Armenians Vigen and Vahe Badalyan.
They, along with their families, received Maltese citizenship in 2016 and 2017 respectively, as per the Government Gazette. They told Armenian media outlet Hetq that they had paid around €2 million into the Maltese economy in order to obtain the citizenship, which indicates that they acquired citizenship through the Individual Investor Programme.
Another of their companies, Soft Construct LLC, which is registered in Armenia, operates the website Vivarobet, which is listed as the second most popular betting website in Armenia by the Top100Bookmakers database.
Locally though, in September 2020, Vivaro Ltd was slapped with a mammoth €733,160 fine by the Financial Intelligence Analysis Unit (FIAU) over 10 breaches of the law which included ineffective monitoring of activity and lack of correct source of wealth and source of funds measures.
According to the UK Gambling Commission’s register, Vivaro Ltd currently has two white label arrangements.
These are with ManBetX – which appear on the front of the Wolverhampton Wanderers kit – and LoveBet – which appear on the front of the Burnley FC kit.
Last month, The Athletic reported that Burnley were looking for a new shirt sponsor as LoveBet – with whom they had signed a three-year deal at the start of last season worth a reported £7.5 million per year – is facing financial difficulties.
Their new owner Alan Pace (who is American, not Maltese) had already pledged when taking over the club in December last year that he would be reviewing the club’s commercial arrangements with gambling companies.
There are a further 27 domain names registered to Vivaro Ltd which are listed as currently being inactive. These include former football sponsors which have, after great exposure, simply vanished – suggesting that they were using such an arrangement simply to enable the shirt sponsorship.
Indeed, amongst the inactive domains are those of Laba360, which appeared on Burnley shirts in the 2018-19 season, OPE Sports, which appeared on the Huddersfield Town shirts in the same season, and M88, which up until recently sponsored Bournemouth FC.
M88, who are the Asian-facing arm of Mansion Group and are otherwise known as Mansion88, were ditched by Bournemouth in May last year after the UK Gambling Commission opened a probe into its model and operations.
Vivaro have never answered questions from international media about LoveBet, M88, or their general ties to such gambling arrangements in English football.
Why use such arrangements, and what could happen next?
Little is actually known about the true owners behind these Asian companies, though a report by The Athletic earlier this month said that they are likely to be based in the Philippines, where companies can operate on the condition that they do not target Filipino gamblers.
Chinese law prohibits one from running and market gambling firms in the country. This means that companies targeting Chinese consumers need to get creative in how they obtain exposure for their brand.
Using Premier League clubs as walking and playing billboards to target people in a country which is mad for English football is the simplest way of going about it.
The practice however could soon be coming to an end. The Telegraph reported earlier this year that the British government will likely enact reforms which could ban gambling companies appearing on football shirts later this year.
A House of Lords select committee report recommended the ban last July, and Labour MP Carolyn Harris, who is a leading figure in the cross-party group which focuses on gambling and the harm it can cause, told the newspaper that she was confident of the ban being put in place.
“For me, it’s about common sense prevailing over greed, because these football clubs have alternative ways to be funded,” she said.
Indeed, the ban would leave English football clubs with a financial hole to fill – a hole which, when taking into consideration only England’s top two divisions, is estimated to be worth £110 million per year.