Cyberspace Offshore Activities Monitor: A Forensic Review of Stravi Management and Vistra (Malta)!

Dirk-Jan Bakker and his Vistra Network
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The rise of the cyberspace era has led to an increased demand for offshore companies and money laundering activities. From online casinos and gambling in the early 2000s to contemporary crypto markets, the need for discreet financial management and opaque corporate structures has never been greater. This report delves into the history and operations of two Maltese companies and their Dutch connections in the early cyberspace-related era.

Historical Context

The Dutch dominated Vistra board in 2019
The Dutch dominated the Vistra board in 2019

This report analyzes the two Maltese entities, Stravi Management Limited and Vistra (Malta) Limited, exploring their connections to the Dutch financial scene and their roles in the global offshore and money laundering landscape in the early cyberspace era.

Read our whistleblower request regarding the Vistra Group.

Both companies were closely linked to the Amsterdam financial scene. The Vistra Group is believed to have been founded around the Amsterdam money scene, where there is a tradition of the need for opaque offshore structures and money laundering. Press releases from the years between 2010 and 2014 underline the Vistra Group‘s connection to Amsterdam. Malta was very important for the Amsterdam money scene.

Malta once held a reputation as a haven for high-risk industries and money laundering, a status that began to shift around 2017. Stravi Management Limited, established in 2011, and Vistra (Malta) Limited, founded in 2001, were key players in this “Malta Period.” Offshore Leaks data from 2017 reveal that Stravi Management was associated with 160 entities, while Vistra (Malta) was linked to 324 entities. These associated companies were predominantly involved in the online casino and gambling industry.

Malta’s lax regulatory environment made it an attractive location for money laundering and offshore activities, culminating in its placement on the FATF Greylist in 2021.

Dirk-Jan Bakker and his connection to the Vistra Group

The Dutch Investor

Dirk-Jan Bakker, an Amsterdam-based real estate and online gambling investor, stated in an official document that he would be the sole beneficial owner of Vistra (Malta) in 2016. In this ownership statement the company register number of Stravi Management Limited was used. Hence, it remains unclear, whether Bakker was also the sole shareholder of this entity.

From the outset, Stravi Management was intricately linked to Vistra through Maltese Alistair Schembri, who currently serves as Country Managing Director of the Vistra Group.

Read our Vistra Request for Information here.

Dirk-Jan Bakker and his Velox3 acquire Uwe Lenhoff's Sheltyco Enterprises

Between 2014 and 2019, Uwe Lenhoff, the alleged principal of the cybercrime organization who has since died in prison in Germany, was a partner of Bakker. In 2016, Lenhoff sold part of his cybercrime empire to Velox3, which was controlled by Bakker and listed on the AIM segment of the London Stock Exchange by way of a reverse takeover financed by Bakker.

Like the Vistra Group, Velox3 (later renamed Veltyco Group and then B90 Holdings) was dominated by Dutch people. In addition to Bakker, his advisor Mark Rosman and the CFO Marcel Noordeloos were also Dutch as key figures in Velox3.

Lenhoff also deployed the services of Vistra and Stravi to found Altair Entertainment in Curacao and Payific Ltd in Malta. Both entities have been deeply involved in cybercrime activities in the Veltyco cybercrime environment.

Key Developments and Entities

On June 22, 2022, the Maltese regulator MFSA announced that Stravi Management Limited had surrendered its license. This seemingly mundane event, upon closer inspection, revealed a vast network of offshore companies tied to the global online casino and gambling industry. Stravi Management is currently in liquidation. However, its historical connections to the Vistra Group and the Amsterdam financial scene remain noteworthy.

Schembri is also active in Vistra Marine & Aviation Limited, which focuses on luxury yacht and jet procurement, maintenance, and rental. According to Offshore Leaks data for 2017, this entity was linked to 18 companies through which luxury yachts are purchased and serviced.

Notable Figures and Legal Issues

Key figures in this Vistra offshore scheme between 2008 and 2014 included Dutch nationals Bart Deconinck, Gerard Jan van Spall, Sjaak ten Hove, and Maltese nationals Alistair Schembri and Marco Bugelli. These individuals were instrumental in establishing and managing offshore structures for online gambling and other high-risk activities.

Vistra Group organized offshore entities and bank accounts for gambling operators

Documents from criminal cases reveal that the Vistra Group provided bank accounts to illegal online gambling providers, including Lenhoff’s Altair Entertainment, at the now-defunct Wirecard. Additionally, Israeli cybercrime mastermind Gery Shalon, who was arrested in 2015 and later pleaded guilty to multiple charges, utilized Vistra’s services for his illegal operations.

The Shift from Malta to Cyprus and Dubai

The publication of the Paradise Papers in 2017 marked a turning point, diminishing Malta’s attractiveness for the offshore industry. Cyprus, with its Golden Passport rules and geographical proximity to Russia and Israel, has since emerged as the new hub for these activities. Malta, meanwhile, continues to grapple with corruption scandals, further eroding its appeal.

In recent years, the desert metropolis of Dubai has also developed into a center for money laundering and cybercrime, as the recent OCCRP Dubai Unlocked investigations revealed. Especially with the advent of the crypto era, Dubai is enjoying increasing popularity and is considered the new paradise for crypto entrepreneurs. In this respect, it also helps that Dubai has no extradition treaties and, therefore, offers a golden cage.

Preliminary Conclusion

The history of Stravi Management and Vistra (Malta) illustrates Malta’s pivotal role in the global offshore industry in the early cyberspace era and its connections to high-risk financial activities. As the landscape shifts towards Cyprus and Dubai, the legacy of these Maltese companies serves as a cautionary tale of regulatory leniency and the complexities of international finance in the cyberspace era.

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We will continue our series on cyberspace offshore actitivities and explain how such schemes and their facilitators work in the crypto environment. If you have any information about our series on offshore activities in the cyberspace age, please let us know via our whistleblower platform, Whistle42.

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