A reviewed whistleblower package and supporting public-source record place Curaçao trust-office eMoore N.V., part of the EM Group, at the management and Cyprus-linked payment infrastructure of a network of online casino operators that targeted European players without national authorization. The most serious contradiction is plain: while EM Group publicly marketed compliance and German licensing support, its own subsidiary remained managing director of Bellona N.V. for nearly fifteen years while Bellona brands operated against the German market without GGL authorization.
Key Findings
- eMoore N.V. served as managing director of Bellona N.V. from 28 October 2010 to 7 April 2025, linking the firm to the operator behind 1Bet and a wider Bellona brand cluster for nearly fifteen years.
- The reviewed record says Bellona targeted German players without GGL authorization, without OASIS linkage, and remained active after a 2022 German warning.
- EM Group’s own website published a 21 December 2022 warning about German court decisions favorable to players and advised operators to obtain local legal opinions, materially undermining any non-knowledge defense.
- The materials describe a Cyprus layer involving eMoore Cyprus Ltd and vehicles including Arzella Limited, Maliom Ltd, and Xenith Ltd, presented as payment and corporate infrastructure for parts of the casino network.
- The documented network spans 35 active brands tied by registry records, website footers, invoices, or verified reporting to eMoore, EMS Management, or the Livestrong Building address in Curaçao.
- Recent EU case law has materially increased the legal exposure around unlicensed gambling claims, director liability, and freezing EU-based accounts.
FinTelegram Investigations
FinTelegram had already reported in October 2025, based on earlier whistleblower evidence, on the Bellona–Delasport network, including Bellona N.V., Arzella Ltd, Germany-facing exposure, and the apparent absence of required German controls.
The newly submitted eMoore / EM Group dossiers materially extend that picture by adding the trust-office, directorship, and broader Cyprus-management layer.
Read the Bellona – Delasport report here.
Compliance Analysis
A Trust Office at the Center of the Story
FinTelegram has reviewed a whistleblower intelligence package concerning eMoore N.V., a Curaçao corporate-services and trust-office entity operating under the EM Group brand. The reviewed record supports a serious and defensible working thesis: a group that publicly markets compliance, licensing, and regulatory support appears, on the same documentary record, inside the management and Cyprus-linked payment structure of a Europe-facing online casino network that lacked national authorization in key EU jurisdictions.
The intelligence report submitted to FinTelegram details, in a structured and document-backed manner, how casino and gambling schemes associated with eMoore and EM Group repeatedly operated in regulated European markets without the required national licences and were, in several cases, sanctioned or otherwise targeted by regulators and authorities.
Enforcement Actions Against eMoore-Linked Casinos
This is what makes the case important. The issue is not simply that offshore casino operators targeted European players. The issue is that a firm presenting itself as a compliance specialist appears, on the reviewed record, to have provided parts of the governance, management, and infrastructure that allowed such activity to continue.
The intelligence report submitted to FinTelegram contains a detailed account of compliance violations by casinos affiliated with the eMoore/EM Group network.
The Bellona Case as the Core Example
At the center of the record sits Bellona N.V., the Curaçao-based operator behind a cluster of related casino brands, including ZodiacBet, DachBet, WeltBet, EmirBet, Slotimo, Betonic, and Winolot. According to the intelligence package, Bellona’s brands worked with the Cyprus-based payment agent Arzella Limited.
Bellona was incorporated on 28 October 2010. The beneficial ownership is said to be linked to the Israeli Shemesh family, in particular Avi Shemesh and Ilan Shemesh, who are also associated with the iGaming software provider Delasport. The Bellona brands reportedly operated on a largely uniform combined casino-and-sportsbook setup built on Delasport infrastructure, using shared backend subdomains and the shared facade-api.com gateway on the same IP range.
According to the intelligence report, eMoore N.V. served as Bellona’s managing director from 28 October 2010 to 7 April 2025. During that period, Bellona’s Germany-facing activity allegedly continued without GGL authorization, without OASIS linkage, and after formal German regulatory warnings had already been issued.
That matters because it places eMoore not at the edge of the story, but inside it. On the reviewed record, eMoore was not merely an outside corporate-services provider with distant visibility. It was part of the formal management layer of the operator at the heart of this Germany-facing case study.
The Delasport Parallel and the SoftSwiss Pattern
We are also familiar with this combination of software providers and concealed operator structures from earlier investigations into SoftSwiss and its long-running role in the offshore casino sector. In those cases, too, FinTelegram identified a recurring pattern: a technology or platform provider publicly positioned as a neutral B2B infrastructure partner, while the actual operator layer behind the brands remained opaque, fragmented across offshore entities, and often closely linked to payment intermediaries and regulatory arbitrage.
Read our SoftSwiss reports here.
The Delasport-Bellona structure described in the whistleblower dossier appears to follow a comparable logic. The software and frontend layer create the appearance of a standardized, scalable platform business, while the underlying operator, payment, and management entities are distributed across jurisdictions such as Curaçao and Cyprus. This does not, by itself, prove that Delasport and SoftSwiss are the same or acted identically. But the structural similarities are significant enough to justify closer scrutiny.
This is what makes the case important. The issue is not simply that offshore casino operators targeted European players. The issue is that a firm presenting itself as a compliance specialist appears, on the reviewed record, to have provided parts of the governance, management, and infrastructure that allowed such activity to continue.
The Central Contradiction: Compliance in Public, Exposure in Practice
The strongest element of the whistleblower package is the compliance contradiction. EM Group publicly markets compliance solutions, including a Germany-facing “SecurePlay” offering. At the same time, the uploaded record points to EM Group’s own article of 21 December 2022, in which it acknowledged a growing body of German court decisions favorable to players and advised operators to obtain local legal advice on the legality of their activities. (the-emgroup.com)
This is the point that materially weakens any simple non-knowledge defense. If the group was publicly commenting on mounting German legal risk in 2022, while one of its own directed operators was reportedly already under German scrutiny, then the contradiction becomes difficult to ignore. In plain terms, EM Group appears to have been discussing the risk publicly while the same risk was already embedded inside its own management orbit.
Selective Compliance and the Germany Problem
The record becomes even more serious on the question of actual knowledge and selectivity. The dossier cites Follow the Money’s January 2025 reporting for the proposition that eMoore instructed Delasport to geo-block the Netherlands and the United States, but not Germany, which was treated as a key target market.
These reportings suggest selective compliance: some jurisdictions were protected once risk became obvious, while Germany, despite its importance and despite regulatory warnings, remained exposed.
Beyond Bellona: A Broader Operator Network
The whistleblower materials also widen the lens beyond Bellona. The uploaded network documentation ties additional operators and brands to eMoore management, including Mandarin Gaming N.V., Exedra N.V., and Casiworx N.V. Among the brands listed are 1Bet, Betonic, Slotimo, CasinoBet, BangBang Casino, Casino 770, EGB, WinCraft, SlotoRush, Norsewin, and FreakyBillion.
The intelligence report presents a structured methodology based on registry extracts, operator disclosures, invoices, and live-site verification. The broader network thesis seems certainly plausible.
The Cyprus Layer: Corporate and Payment Infrastructure
One of the most important additions in the package is the Cyprus layer. eMoore Cyprus Ltd is listed as director and/or secretary of Cyprus entities including Maliom Ltd, Xenith Ltd, and Arzella Limited. Arzella is presented as Bellona’s payment agent, while Xenith is presented as payment infrastructure for the Casiworx cluster.
That does not prove misconduct by every payment counterparty or every entity mentioned in the documents. But it does suggest that the offshore operator layer may have been paired with an EU-based corporate and payment layer. That is a critical point because Cyprus-based vehicles, accounts, and directors are potentially more reachable for courts and regulators than the Curaçao entities standing alone.
The Wunner Ruling & Implications
The Wunner ruling changes the legal risk map for eMoore’s Bellona involvement. Since the CJEU held that, as a general rule, a player may sue under the law of their own country of residence and that the damage from illegal online gambling is deemed to occur where the player resides, the long-favoured offshore-distance defence looks weaker than before. Just as importantly, the Court confirmed that claims against directors of an unlicensed foreign gambling operator are tort claims under Rome II, not protected company-law issues.
Read more about the Wunner Ruling here.
In the Bellona context, this means EU players may argue that a statutory managing director such as eMoore sits within the liability chain where Bellona brands targeted their country without the required licence.
Their potential claims include recovery of losses or damages under domestic law, director-liability claims where national law recognizes them, and follow-on enforcement against EU-based assets or payment structures. The precise remedy differs from one Member State to another, but the strategic point is now much clearer: where the casino was illegal in the player’s country, the player’s law may follow the case all the way up to the management layer.
For Germany specifically, player claims are strengthened not only by Wunner, but also by German national case law and the separate Tipico line.
FinTelegram’s Working Conclusion
FinTelegram’s conclusion at this stage is narrow, strong, and defensible. The documentary record reviewed by us places eMoore / EM Group at the management, payment-related, and compliance-infrastructure layer of a network of Curaçao-linked operators repeatedly tied to unauthorized Europe-facing gambling activity.
The decisive issue is no longer whether EM Group sold compliance services in public. It did. The decisive issue is whether those services were applied consistently when the group’s own directed operators were exposed to escalating warnings, fines, court losses, and cross-border player claims. On the reviewed record, that answer appears deeply unfavorable to the group.
Summary Table
| Category | Name | Role / Relevance | Notes |
|---|---|---|---|
| Trust-office / corporate services | eMoore N.V. | Curaçao managing-director entity | Reported MD of Bellona N.V. from 2010–2025; also tied to other operators in uploaded record |
| Group brand | EM Group (the-emgroup.com) | Public-facing compliance/corporate-services brand | Markets licensing and compliance support, including Germany-facing SecurePlay |
| Key individual | George F.J.M. van Zinnicq Bergmann | Co-founder / public face / director | Public compliance posture contrasted with uploaded record; quoted by FTM and cited in dossier |
| Operator entity | Bellona N.V. | Core case-study operator | Linked to 1Bet and other brands; eMoore as MD until April 2025 |
| Beneficial owner named in dossier | Ilan Shemesh | Named beneficial owner of Bellona / sister structures | Stated in uploaded record; should be framed as dossier-based unless separately re-verified |
| Cyprus entity | Arzella Limited | Cyprus payment / corporate layer | Presented as payment agent for Bellona; |
| Cyprus entity | Maliom Ltd | Cyprus payment / corporate layer | Presented as payment-agent layer in dossier. eMoore Cyprus Ltd listed as secretary |
| Cyprus entity | Xenith Ltd | Cyprus payment / processing layer | Presented as payment processor for Casiworx brands in dossier. eMoore Cyprus Ltd listed as director/secretary |
| Cyprus entity | eMoore Cyprus Ltd | Cyprus management layer | Described as director/secretary of Arzella, Maliom, Xenith and related vehicles |
| Other operator entities | Mandarin Gaming N.V.; Exedra N.V.; Casiworx N.V.; Prolific Trade N.V. | Additional network entities | Listed in uploaded record as part of broader eMoore-linked network |
| Sample brands | 1Bet, Betonic, Slotimo, CasinoBet, BangBang Casino, Casino 770, EGB, WinCraft, SlotoRush, Norsewin, FreakyBillion | Consumer-facing casino brands | Included in uploaded 35-brand network inventory |
| Public-source media reference | Follow the Money | Heise reporting | Reported on Bellona targeting, warnings, and geo-blocking issues |
FinTelegram’s Position at This Stage
FinTelegram’s position at this stage is careful but clear. Based on the whistleblower package and the corroborating public record, there is a substantial basis to report that eMoore / EM Group appears in the management and Cyprus-linked payment infrastructure of a broader network of unauthorized Europe-facing casino activity.
That is a defensible conclusion. It does not require us to claim final legal liability or make criminal findings that only courts and regulators can establish. But it does justify serious scrutiny of the group, its related vehicles, and the payment and corporate-service ecosystem around it.
A Call to Insiders and Players
If you worked with eMoore, EM Group, Bellona, Arzella, Maliom, Xenith, Delasport, or any of the brands named in this report — as an employee, contractor, affiliate, PSP, platform provider, compliance adviser, or corporate-services provider — we invite you to contact us securely.
If you are a player who deposited with or lost money to one of these brands in Germany, Austria, the Netherlands, Sweden, Denmark, Spain, or elsewhere in Europe, we also want to hear from you.
Send us documents, payment records, internal emails, KYC material, affiliate invoices, or player correspondence securely via Whistle42.
Your information may help regulators, affected players, and the public understand how this network operated — and who enabled it.
