In July, Fulham became the fourth Premier League club in the past five years to name W88 as its front-of-shirt sponsor following the side’s promotion from the EFL Championship. W88 had been Wolverhampton Wanderers’ front-of-shirt sponsor in 2018/19, Aston Villa’s in 2019/20 and Crystal Palace’s in both 2020/21 and 2021/22.
The announcement came in the weeks following a report that the UK Government was expected to significantly water down its review of the 2005 Gambling Act after fierce lobbying from the gambling industry. One of the key measures which was expected to be removed was a ban on front-of-shirt gambling sponsors.
The gambling review remains unpublished, however, the Premier League has proposed that its members vote on whether to voluntarily introduce a ban itself. Reports on July 19th suggested the vote was to be delayed until September but the necessary 14 votes in favour of the measure was assured. Fulham announced W88 as its front-of-shirt sponsor on July 25.
For the 2022/23 season, nine of the Premier League’s so-called ‘Other 14’ have a gambling or cryptocurrency trading company as their front-of-shirt sponsor. Many of these entities share similar characteristics; opaque operating practices, links to tax havens and no discernible UK presence.
W88 is no different. When following the link on Fulham’s homepage to W88, the URL https://w88.co.uk/ simply leads to a blank page. Briefly in March 2019, the website exhibited its sponsorship of Wolves and Leicester, and featured an English language sign-up link but this had disappeared by July of that year. It does not appear to have been updated since that date.
What does feature on the archived version of the website is an address and registration details. The address appears to be a mostly residential building in Wapping, London. The registration details say that W88 is registered to operate in the UK via a white-label agreement with Midnight Gaming Limited under registration number 08489885 which is regulated by the UK Gambling Commission under licence number 36626.
On the Gambling Commission website, Midnight Gaming Limited shares a UK address with AliQuantum Gaming Limited in Poole, Dorset, which is supposedly currently active and has been since 2016, though its profile on Google suggests it is temporarily closed. However, on Companies House AliQuantum Gaming Limited has a different address which seems to be a residential property and was struck off in 2010. Midnight Gaming moved from the Wapping address to the Poole address in 2020. Hexopay, a gambling payment platform, also shares the Poole address. At some stage, Hexopay changed the URL for its contact us page from https://hexopay.com/contact/ to https://hexopay.com/contact-us/. The old URL now redirects to the new one on which the Poole address is not listed.
AliQuantum Gaming’s website claims that it was “one of the first companies to be granted licences from Malta”. However, searches with the Malta Gaming Authority – formerly the Lotteries and Gaming Authority (LGA) – have no record of AliQuantum Gaming, Midnight Gaming or W88 as currently licensed in the country, nor do any of the companies appear on its enforcement register. The AliQuantum website goes on to explicitly state: “In conjunction with the LGA & our partners in Malta, AliQuantum Gaming can provide help and guidance in applying for all the necessary permits and licenses [sic] required to legally operate any gaming solution.” A number of Maltese addresses for AliQuantum were identified, all of which seem to house numerous other companies.
Midnight Gaming Limited director Hilliard ‘Hilly’ Alan Ehrlich is quoted in each partnership announcement for Wolves, Aston Villa, Crystal Palace and Fulham as W88’s Business Development Manager. In the latter two announcements, Ehrlich says that W88 has a “global footprint” and, word-for-word, “is a brand which represents integrity, trust and excellence”. The former two statements do not differ significantly.
With W88’s global footprint obfuscated in the UK, it is worth turning attention to its international presence. Countless blogs (1) detail the “latest link” to use the company’s services. Unfortunately, when accessing these from servers based in the UK, Thailand, Taiwan and Singapore, you are redirected to the following URL: https://forbidden.w88in.com/. This page reveals that W88 does not provide services in the UK, China, Indonesia, Cambodia, Korea, Thailand, Singapore and Vietnam. It also says that the service is powered by Gameplay Interactive, whose own website provides little information beyond a generic contact email. However, Gameplay Interactive Limited appears on the ICIJ offshore leaks database. Golden Clover Limited, a shareholder of Gameplay Interactive Limited, also appears and both entities share an address. Gameplay Interactive and Golden Clover were both incorporated in Malta.
This conflicts with Interpol’s assertion that W88 is operated by a company named Marquee Holdings Ltd. Marquee Holdings itself features on the ICIJ offshore leaks database as it was incorporated in Tortola in the British Virgin Islands. Its incorporating agent Mossack Fonseca, the law firm at the centre of the Panama Papers leaks, was shut down after a raid by Panamanian authorities seeking information regarding links to an engineering firm who had admitted to bribery and whose eponymous founders, Jürgen Mossack and Ramón Fonseca, are subject to international arrest warrant from German authorities on charges of being an accessory to tax evasion and forming a criminal organisation.
The link between W88 and Marquee Holdings is confirmed by a lawsuit filed by Marquee Holdings with the Hong Kong office of the Asia Domain Name Dispute Resolution Centre in 2016 (case number: HK-1600849) disputing a number of domain names similar to its own (2). The case says that the complainant is “well-known in China, Vietnam, Indonesia, Cambodia, Thailand, Japan, Korea and Malaysia as a provider of online gambling and betting services through w88.com”, a domain which it purchased in 2013, and, when accessed from the UK, also redirects to https://forbidden.w88in.com/. The docket says that w88.com attracted more than 50,000 users per month, achieved around 200,000 page views per month and generated yearly revenue “to the tune of millions of US dollars”. This is surprising given that gambling is either illegal or heavily restricted in most of the aforementioned jurisdictions. As a result of the lawsuit, the disputed domain names were transferred to Marquee Holdings.
The information presented here is by no means exhaustive in terms of W88’s governance or other reputational risk factors. However, the web of tax-haven companies that surround W88 makes this an extremely opaque entity.
Despite nearly half of Fulham Supporters’ Trust members backing an outright ban on front-of-shirt gambling sponsors, the deal was still done. Advertising hoardings and players will advertise an industry that a substantial portion of fans do not feel comfortable being associated with the club.
In addition, W88 is likely using its sponsorship of Fulham to advertise gambling in jurisdictions where the practice is illegal. The same is true of its sponsorship of Wolves, Aston Villa and Crystal Palace.
This is far from unique with these sponsors. Almost all of the 2021/22 Premier League front-of-shirt gambling sponsors are incorporated in tax havens and primarily face markets where gambling is illegal. InsightX provided intelligence on them as part of our Premier League Sponsorship Review for the 2021/22 season. The review can be downloaded here.
(1) https://nhacaiw88ub.wixsite.com/w88ub, https://w88club.co/, https://www.instagram.com/w88yes/?hl=en, https://vnw88vn.com/, https://w88hn.vip/, https://w88hcm.net/, https://in.pinterest.com/w88live/, https://www.w88indi.com/
(2) w88.net, w88001.com, w88444.co, w88555.com, w88005.com, w88111.co and w8.cc
