Sports betting firm offered political help

  • Company head: Mike Richards of Game Theory (Photograph from

A publicity-shy company, which scrapped plans to open an office in Bermuda after media interest in its activities, offered to be categorised as a fintech firm “if it helps from a political point of view”.

Records released under public access to information show that Guernsey-based Game Theory Ltd did not view itself as a financial technology firm, but made the suggestion as it sought help from Bermuda Business Development Agency, to set up shop here, obtain work permits and liaise with regulators.

The company, a self-described “investment house that places bets on investing in sports businesses”, ultimately opted not to open an office on the island, after a small story ran in The Royal Gazette’s business section about a job advert it placed to recruit six local employees as “sports trading operators”.

The decision led David Burt, the Premier, to claim in a parliamentary speech in February that The Royal Gazette and the One Bermuda Alliance were to blame. He alleged the newspaper had joined forces with the Opposition to derail any success in Bermuda’s fledgeling fintech industry.

Mr Burt said politicians were subject to “justifiable media scrutiny”, but private businesses had a right to “keep their affairs private”.

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.

The records include correspondence between the company and the BDA, beginning from when Game Theory approached the agency for help in quickly establishing a presence on the island in 2018, to when it ditched its Bermuda plan in February this year. Almost all of the names and job titles have been removed from the documents, a decision which The Royal Gazette has challenged with BDA’s chief executive, Roland Andy Burrows.

In an e-mail from November last year, which appears to have been sent to a BDA official, a company representative wrote: “Regarding the fintech point … it was my understanding from my visit to Bermuda … that we will not be considered a fintech business (and we don’t want to be, as there is regulation attaching to this).

“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). I’d be interested to hear your thoughts.”

A reply sent on December 6, seemingly from the BDA official, said: “I wanted to make sure that you do not apply for work permits directly but do so through the [Government’s] FinTech Business Unit … as they will submit the request on your behalf so that they can legally track it and accelerate the processing of the documents.”

The Game Theory representative responded the next day at 11.02am, to confirm the work permit applications would be made through the FinTech Business Unit, “if this is correct, given that we have been told we are not to apply for fintech permits, but instead for new incorporation permits”.

In an e-mail the same day at 3.20pm, it was stated the work permit applications would be made through the “BDU”: the Government’s Business Development Unit.

The BDA connects companies to that unit. The unit offers a “concierge service” to international businesses setting up here, helping speed up their regulatory and work permit applications.

Since coming to power in July 2017, the Government has sought to position Bermuda as a leader in the global fintech space, aiming to entice executives to relocate to the island and create local jobs.

The FinTech Bermuda website encourages new technology companies to set up here and benefit from the “unique environment that prioritises regulatory certainty, investor confidence and compliance with international know your customer and anti-money laundering regulations”.

Game Theory is described in the correspondence released under Pati as an “artificial intelligence company” and a “private investment firm for a family”.

Its job advert was for “sports trading operators”; sports trading is a term generally understood to mean betting on the movement of sporting odds.

Finance minister Curtis Dickinson told Parliament in March this year the law needed to be changed to ensure the island’s betting sector was “regulated thoroughly”.

He said regulatory responsibility for betting shops would transfer from the Betting Licensing Authority to the Bermuda Casino Gaming Commission.

In its e-mails to the BDA, Game Theory said it did not believe it needed to be regulated by either the Bermuda Monetary Authority or the BCGC, providing legal opinions to that effect (the opinions are redacted from the Pati disclosure).

In an e-mail in September last year, a company representative sought help from the BDA in obtaining agreement from the BMA and the BCGC that Game Theory did “not need regulating”.

An e-mail later that month mentioned “applying some gentle pressure on the BMA and BCGC”.

According to the correspondence, Game Theory obtained a written statement from the BMA stating it did not consider that the company needed to be regulated, but it was unable to get the same from the gaming commission.

Mr Burt, though he did not name Game Theory, told the House of Assembly the company negotiated a lease for 2,000 square feet of office space on Pitts Bay Road that had been available for some time.

The Pati disclosure shows that Game Theory met with a realtor and that the company was looking for “commercial office space to house six to 12 staff”, with “top-of-the-range internet/telecommunications connections”.

A company representative wrote: “Preferably, I like properties on the top floor, away from other tenants.”

The Royal Gazette business story ran on February 11 and Mr Burt gave his speech on February 15. The Pati disclosure includes an e-mail dated February 19, which appears to be from a BDA official responding to a suggestion from a FinTech Business Unit official that some “damage control” be done.

The BDA official wrote: “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.”

In response to questions, Mr Burrows said on Sunday: “Respectfully, I am unable to specifically answer your questions given that the current Pati request [is] under way.

“Please note, however, one [of] the BDA’s primary roles is to provide a concierge service for Bermuda inbound clients, which is an introduction to the Government Business Development Unit’s concierge programme and private sector companies, as appropriate.”

He added: “The inbound clients are new business opportunities in line with our mandate and one would suggest that Game Theory was an opportunity.”

Mr Burt said last night that the BDA “manages a critical part of business development for Bermuda and engages with hundreds of companies and interested investors annually”.

He added: “Each company has unique needs and insofar as is possible the BDA is determined to meet them. That work is made more difficult when those needs are disrespected and subjected to unwarranted intrusion into corporate affairs.”

Mr Burt said that the public “can be confident that each and every company is properly vetted and confirmed as suitable to do business in Bermuda”.

He added: “Where other interests, for their own political or other agendas, seek to disrupt that process, Bermuda loses.

“Jobs are lost; opportunities are lost; economic growth is stymied.”

There was no response to an e-mail sent to Mike Richards, of Game Theory.

To read more from the BDA’s Pati disclosure, click here.

Who is who in the failed recruitment of Game Theory

Game Theory Limited/ GTL Atlantic

Game Theory Limited is a Guernsey-registered company which describes itself as an “investment house that places bets on investing in sports businesses”. It incorporated as an exempted company in Bermuda in January with the name GTL Atlantic Limited. Its principal business was described to the Registrar of Companies as “data analytics”.

It is described in correspondence released under Pati as an “artificial intelligence company” and a “private investment firm for a family”.

Bermuda Business Development Agency The BDA is a publicly funded agency which helps companies start up, relocate or expand their operations on the island.

Its website describes it as an “independent, public-private partnership” which connects international companies” to “industry professionals, regulatory officials, and key contacts in the Bermuda Government to assist domicile decisions”.

Bermuda Monetary Authority The BMA regulates Bermuda’s financial services sector. Its website says it “develops risk-based financial regulations that it applies to the supervision of Bermuda’s banks, trust companies, investment businesses, investment funds, fund administrators, digital asset businesses, money service businesses, corporate service providers and insurance companies. It also regulates the Bermuda Stock Exchange and Bermuda Credit Union”.

Bermuda Casino Gaming Commission The BCGC was set up to establish and regulate a sustainable casino gaming industry in Bermuda. There are not yet any casinos on the island.

Curtis Dickinson, the finance minister, said in March: “It is the intent of Government to transfer the regulatory responsibility of betting shops from the Betting Licensing Authority to the [gaming] commission.”

The minister said the law needed to be updated to “ensure this sector is regulated thoroughly and to a level or standard equivalent to mature regulatory jurisdictions”, adding that the commission would complete the legislative framework for the licensing and supervision of betting and other non-casino gaming activities this year.

FinTech Business Unit A government unit set up to oversee the evolving financial technology sector. David Burt, the Premier, told Parliament in July that 19 jobs had been created so far in fintech, with more to follow. He said on Monday that the fintech sector had so far created “eight active offices with 31 new jobs”.

Business Development Unit The Government’s BDU works with the BDA to provide “concierge services” to international businesses looking to set up in Bermuda. It helps set up meetings with government officials and speed up regulatory and work permit applications.