Game Theory: the e-mail trail

  • Kevin Richards, business development manager at the Bermuda Development Agency (Photograph by Blaire Simmons)

The BDA released more than 600 hard-copy documents it held about Game Theory, or GTL Atlantic Ltd, the name it incorporated under here, in response to a Pati request.

Unnamed BDA official, in an e-mail on July 17, 2018: “What’s the latest with Game Theory? I recall following our earlier conversation with [name redacted] that you were going to have a sidebar conversation with [name redacted] at the Gaming Commission and perhaps tee up the conversation with the RoC [Registrar of Companies] to ensure there would be no issues if/when they applied to register the company.”

Unknown sender, in response to the above: “I spoke with the Gaming Commission who said that they were much too busy getting the commission up and running to respond to individual queries like mine. I think that the client feels (understandably) that it has been quite hard to make any progress and they want to assess whether it is viable to continue to pursue Bermuda as an option.”


Unnamed Game Theory representative, e-mail dated August 10, 2018: “We are not an insurance business but a private investment office for a family.”

Unnamed BDA official, e-mail dated August 30, 2018: “Game Theory has been working with [name redacted] to incorporate an artificial intelligence company in Bermuda to support an existing business in Guernsey.”

Game Theory’s description of its business, as provided to the Government’s Business Development Unit: “We are an investment house that places bets on investing in sports businesses. We recently set up in Guernsey — 20 to 23 people were hired in a period of 6 months. Now we’re looking for a second jurisdiction to target sporting events in the US — we want to transition the company more firmly into the investment world and away from the sport and gaming side. Our company started with horse racing but we are now using fintech and AI to guide investment decisions. We are looking to have staff on the ground in Bermuda. Non-Bermudians will train the Bermuda-based team. Looking to hire 10 to 12 people to be trained as data analysts focused on trigger events.”


Unknown sender, e-mail dated September 19, 2018: “Could you look to respond to me on the other points in my e-mail, including applying gentle pressure on the BMA and the BCGC as we’d like to get the green light from both.”


Unnamed BDA official, e-mail dated October 16, 2018: “[Name redacted] from Game Theory will be visiting Bermuda next week and would like to meet with the RoC while he is Bermuda. [Name redacted] is looking to incorporate an artificial intelligence company in Bermuda to support their sister company in Guernsey and their approach is to ensure that all players on the ground have visibility to their objectives so that things go smoothly when they execute. I met [names redacted] in London with [redacted] and we think they will hire 5 to 10 people very quickly once they incorporate and that this business will diversify the type of technology offering we are seeing establish in Bermuda.”


Game Theory representative, e-mail dated November 6, 2018: “As you’re aware, the BMA have been very communicative and helpful regarding the non-regulatory nature of Game Theory’s proposed activities in Bermuda. The BCGC, however, have not been as helpful so far and did not want to meet with me during my recent trip or speak to me over the phone on previous attempts (I appreciate they may have been busy). Despite this, we’re keen to ensure we’ve ticked every box with regards to regulation and would like to receive a formal written response from the BCGC, confirming that they do not wish to regulate Game Theory’s proposed business in Bermuda. Could I ask you, together, to reach out to the best person at the BCGC to obtain this formal response. I’ve copied into this e-mail [name redacted] who has been very helpful and welcoming to Game Theory, and who previously requested to be kept in the loop should we hit any bumps in the road, in terms of obtaining regulatory responses.”


Unknown sender, e-mail dated November 19, 2018: “My sense from speaking to the Gaming Commission is that they do not want to engage with us because this would set a president (sic) that companies should reach out to them to get approval. They have confirmed that we do not fall under their purview and I would be delicate about how you approach them to get confirmation, as I felt that it was clear that Game Theory do not come under their area of responsibility.”

Unnamed Game Theory representative, e-mail dated November 23, 2018: “I’m happy to accept your advice but I would say it’s a little disappointing, given that an equivalent body (the BMA) has provided a written statement that they do not consider us to need to be regulated.”

Unnamed Game Theory representative, e-mail dated November 23, 2018: “[Name redacted] and the FinTech Business Unit will be your most critical partner in the processing of work permits and because [name redacted] has met with the relevant stakeholder you should be in good shape to incorporate and begin setting up your operation in Bermuda with the full support of the Bermuda Government.”

Unnamed Game Theory representative, e-mail dated November 23, 2018: “I’m happy for Game Theory to be an unnamed employer in the fintech space if it helps from a political point of view but don’t want to be seen as holding ourselves out as a fintech business (in the strictest sense we are not, in my opinion).”


Business story in The Royal Gazette, February 11, 2019: “Six Bermudians are to be hired as ‘sports trading operators’ by an international algorithmic trading company which is setting up an office on the island.”

Unnamed BDA official, e-mail dated February 14, 2019: “As it pertains to Game Theory, I think a personal call to [names redacted] would be the best approach. They specifically said that they do not want to see any more press, including an apology from The Royal Gazette. It is important to remember they are a [redacted] and value privacy over all else, and because we violated their request for privacy, a request they made to [redacted], the BDA and The Royal Gazette, it is important that we do not violate that request again by including them on any apology. A call to [redacted] would be a great touch and would encourage them to revisit Bermuda as a jurisdiction that they can expand to in the future.”


David Burt, the Premier, parliamentary speech on February 15, 2019: “It is now crystal clear that The Royal Gazette has joined hands with the Opposition One Bermuda Alliance in a concerted effort to cast doubt and irreversibly tarnish this Government’s work in the diversification of this economy. I speak specifically of the fintech industry.”

Mr Burt, same speech: “ ... this week Bermuda has suffered a significant loss of business and the responsibility for that lays directly at the feet of The Royal Gazette.”

Mr Burt, same speech: “The disappointment felt in the voice of Mr Kevin Richards [BDA’s business development manager], that all of his hard work over the past 6 months ... was derailed ... was palpable.”

Whatsapp message from unknown, assumed to be to Mr Richards, February 16, 2019: “What was the business of the company that decided not to come to Bermuda after the RG intervention? [Name redacted] referred to you in the House yesterday. Must make you feel kinda cool, huh? I think it’s really cool that he recognised you.”

Reply, believed to be from Mr Richards: “The company was Game Theory. And no, I would have preferred to not have been named in yesterday’s speech.”


Unnamed FinTech Business Unit official, e-mail dated February 19, 2019: “We need to follow up with Game Theory and do some damage control. What is their contact information? [Name redacted] is willing to do this.”

Unnamed BDA official, in response to the above: “My $0.02 on the Game Theory situation. What damage control? We know what happened and [name redacted] spoke to [name redacted] at Game Theory last week (after discussing with [redacted] and [redacted] over here), then he made his remarks in Parliament on Friday. The damage has already been done and, at this point, I don’t believe we can or should be reaching out to Game Theory.”

FinTech official: “ … if you think it’s a done deal and there’s no need to follow up or reach out to them, we can leave it alone. What’s their final answer or final position? Is Bermuda not an option any more or is anything salvageable?”

BDA official: “They’ve left and Bermuda is no longer an option, There are differences of opinion on whether or not the RG did anything wrong and it’s descended into a very political issue now, which we would prefer not to step into. If [name redacted] has spoken to Game Theory and presumably urged them to reconsider, and they still have decided to leave, then I feel there’s nothing more we can do.”