Privileged & Confidential · Prepared for David Silverman

What Happened to Your $1.4M

An evidence-based reconstruction of the Tim Heath / Gamblr.io / Yolo Group operation — and three paths to recovery.

$1.38M
Reclassified from your customer balance to "operational expenditure"
30+
Heath-controlled corporate entities across 9 jurisdictions
192+
Documented same-pattern victims across 17 Heath-orbit brands
Date
April 28, 2026
Counsel
Silverman Thompson · Steve Silverman + Andrew Harvey
Time-critical window
Betsson AGM · 7 May 2026 · 9 days If deal stalls → Plan B at Slide 10
Silverman v. Heath et al.
The central contradiction

What Heath says vs. what the public registers say.

One man, two statements made within months of each other — and only one of them is consistent with the registry record. This contradiction is the deck's most damning evidence; everything that follows substantiates it.

Tim Heath
Heath's claim
Timothy John Heath
"I have nothing to do with gamblr"
— Tim Heath · Telegram to Jeff Gross · 4 February 2026
vs
The public registers say
A different story.
Heath is sole director of OT Malta Ltd C88843 — the B2B game supplier (licence MGA/B2B/641/2018) whose OneTouch + Live88 content runs on Gamblr.io. He is also the statutory UBO of Bombay Club & Resort OÜ on the Estonian register, holds ~70.5% of Yolo Tech OÜ, and was the personal introducer who put David in front of Gamblr.io.
— MBR Malta C88843 · Estonian Business Register · Heath Telegram screenshots IMG_5099–5116

What this deck covers — sections at a glance

§ 1
How the operation works
3-stage scheme · the 6-step money-flow · what really happened to your $2M
§ 2
The full operation
30+ entities · 9 jurisdictions · who controls what
§ 3
You're not alone
192+ documented same-pattern victims across 17 brands
§ 4
The evidence
Heath's verbatim quotes · UBO disclosures · 6-event spoliation pattern
§ 5
The leverage
11-regulator cascade · personal-attestation pressure · Betsson sale window
§ 6 → 7
Paths forward + this week
3 ranked options · day-by-day actions before the 7 May AGM
$1.38M
Reclassified to Gamblr
operational expenditure
30+
Heath corporate entities
across 9 jurisdictions
192+
Documented same-pattern victims
across 17 brands
9 days
Until the Betsson AGM
(7 May 2026 = pressure window)
If deal stalls → Plan B (Slide 10)

An appendix follows the main pitch, with named-individual and named-entity cards including all registration numbers, Person IDs, DOBs, and primary-source citations.

§ 1 · How the operation works

One brand on your screen — three stages, six checkpoints, every one of them Heath.

From your perspective, you played at Gamblr.io. From the operation's perspective, your money ran through a 3-stage scheme (Introduce → Play → Void & retain) and 6 checkpoints (Deposit · Play · Win · Closure · Reclassify · Extort) — every one of them on infrastructure Heath personally controls or is invested in.

Stage 1 · April–May 2025

Introduce

Trust by association

Heath warm-introduced you via Jeff Gross — Florida-based pro poker player and Heath's long-running affiliate-intermediary. Heath chained Jeff into a 5-person Telegram group with Cristina Rahuoja ("big boss of VIP Management"), Adam Chernoff, Taago Tamm, Jesper Fröjd.

"more than happy to satisfy the action at any limits" Heath · Telegram · 18 Jun 2025
Stage 2 · May–June 2025

Play

~$2M deposited · ~$2M won

Your bets ran through a stack of Heath-controlled entities — operator, game supplier, aggregator, payment rail. KYC was relaxed at deposit per Heath's documented policy.

"passport jurisdiction isn't the issue, we simply need a proof of address that they live outside the US" Heath · Telegram · 18 Jun 2025
Stage 3 · 20 June 2025+

Void & retain

$1.38M reclassified

Account closed under T&C "third-party use and funding" pretext. Bets "voided". Per the Whistleblower email, your $1.38M was rebooked from your customer balance to Gamblr operational expenditure. $80K extortion bid followed.

"voided betting activity and retained funds" Gamblr Compliance · email
★ Where your money actually went · May 2025 → April 2026 ★
1 · Deposit
~$2M
Crypto deposit · KYC relaxed at deposit
One.io Open Wallet
2 · Play
Aviator · slots
Spribe + OneTouch via Hub88, on Gamblr.io
Spribe OneTouch Hub88 Gamblr
3 · Win
~$2M
Net winnings credited to balance
4 · 20 Jun 2025 · Closure
"VOIDED"
"third-party use & funding" pretext · T&C §8.16 / §16.10 / §21.4
5 · Reclassify
−$1.38M
Customer balance → Gamblr operational expenditure (Whistleblower email)
6 · Extort bid
$80K
ETH wallet 0xAA449B…E9A9c demands $80K to release the $1.4M
Behind the single Gamblr.io brand, money flowed through Heath-controlled supplier (OT Malta C88843, Heath sole director) · aggregator (Hub88, Yolo Fund I) · payment rail (Block Technology Malta C81495 + One.io UK FRN 913478) — every dollar passed through a Heath layer.
§ 2 · The full operation

30+ entities, 9 jurisdictions, one enterprise.

Each row = a jurisdiction Heath uses. Each column = a function. Red border = Heath personally controls. Orange = Yolo Investments-funded. Blue = Heath publicly endorsed/introduced. Strike-through = wound down during the dispute.

Operator (B2C)
B2B Supplier
Payment Rail
Holding / Fund
Land Asset
Marketing
EE Estonia
Spribe
Spribe OÜ
14540763 · Aviator
Swapin
Swapin / UNGARO OÜ
14562753 · FIU FVT000088
Heathmont
Heathmont OÜ
11063972 · Heath UBO
Yolo Tech OÜ
14609414 · 70.5%
Yolo Investments OÜ
14972698 · DELETED Sep 2 2025
Stacey OÜ
11057486 · Heath 15.93%
Piangil OÜ
11533886 · 100% Heath
Bombay
Bombay Club & Resort OÜ
14045680 · HKT000031 · Heath UBO
Bombay Group OÜ
16132057 · DELETION NOTICE
Partners.io
Partners.io
Affiliate program
MT Malta
OneTouch
OT Malta Ltd
C88843 · MGA/B2B/641/2018 · Heath sole director
Live88
Live88
Same MGA license
One.io
Block Technology Ltd
C81495 · One.io Malta captive
Vereeni Investments Ltd
C82096 · Heath holdco
36N Capital Mgmt Ltd
C76815 · Buhagiar Paradise Papers
GB UK
One.io
One.io UK Limited
CH 12040686 · FCA FRN 913478
CrissCross FX UK Ltd
CH 16713961 · Sep 12 2025
One.io Group Ltd
CH 13036457 · 25–50% Heath PSC
HM UK Operations
CH 13875602 · Heath resigned Nov 6 2025
Newcastle United
Newcastle United · Watford · Arsenal · Southampton
Sportsbet.io sponsorships
GG Guernsey
Yolo Investments PCC Ltd
GFSC 2771881 · LICENSE SURRENDERED Feb 17 2026
Yolo Fund II LP
GFSC 2958448 · €100M (2024)
Yolo Group Ltd
GG-CMP70153
Bombay Holding Ltd
#70665 · La Plaiderie Chambers
IM IoM
OneTouch Technology Ltd
130853C · Heath director
TGP Europe Ltd
122698C · COLLAPSED May 15 2025 (UKGC £3.3M)
AE UAE
Open Wallet
FinVerse Labs FZ-LLC
RAKEZ #0000004030448 · Open Wallet · Pay.io
Yolo Group Middle East
GCGRA-licensed
Yolo Fund III
ADGM · $500M target
CW Curaçao
Sportsbet
mBet Solutions NV
129230 · Sportsbet.io
Bitcasino
Moon Technologies B.V.
152185 · Bitcasino.io
KM Anjouan
Gamblr
Gamblr Gaming Ltd
15938 · ALSI-202503019-FI1
Empire
Pixel Entertainment Ltd
ALSI-132405042-FI3 · Empire.io
CR Costa Rica
3-102-936594 SRL
Bombay.vip B2C · Heath direct
VG BVI
Luckbox Enterprises Ltd
Pandora Papers · Piller UBO
Heath personally controls Yolo Investments-funded Heath publicly endorsed / introduced Wound down during dispute Sources: Estonian e-Äriregister · UK CH · Maltese MBR · Greg.gg · ICIJ · MGA · UKGC · FCA Register · Inforegister
§ 3 · You're not alone

Your case is one of 192+ documented. The pattern is identical.

The script repeats: deposit, win, account closed under a T&C pretext, funds "voided." Four representative cases below, every one of them publicly documented and following the same playbook used on you — including aleks86 on Gamblr.io itself, 22 days ago. Operator-volume context (per Gamblr's own LinkedIn ~Oct 2025): $100M+ wagered through the platform in under 6 months — your $1.4M is ~1.4% of Fenney's own publicly-claimed wager volume during the window your account was active, and Marantelli's iBankroll publicly underwrote those payouts as "guaranteed." Aggregate known disputed exposure: ≥$6.5M, likely $50M+ once subpoenas hit Heath's customer ledgers. Your $1.4M is the largest individual frozen-funds claim publicly documented — which makes you the natural lead plaintiff in a class action, and the strongest individual witness in a federal filing.

Shuffle CA
SupItsJ
Canada · Shuffle.com
$950K
Cumulative net deposits/play. Heath-orbit: Shuffle = Yolo Investments Fund I Operator.
Source
casino.guru forum
Pretext
KYC trap / multi-account
Status
Open · public
casino.guru/forum/casinos/shuffle-casino---general-discussion/2
Hype.Bet DE
Deltrax
Germany · Hype.Bet
€156K
Funds confiscated after winning session. Heath-orbit: Hype = Yolo Fund II Operator.
Source
casino.guru complaint
Pretext
"lost his funds after account [closure]"
Status
Filed · public
casino.guru/complaints/hype-bet-casino-player-lost-his-funds-after-account
Sportsbet TR
Mehmet
Turkey · Sportsbet.io
$63K
Heath-orbit: Sportsbet.io = Yolo Group flagship (operator: mBet Solutions NV Curaçao 129230).
Source
sikayetvar.com
Pretext
"wrong payment note" stop
Status
Filed · public
sikayetvar.com/en/sportsbetio-us
Gamblr ME
aleks86 ★ same operator
Montenegro · Gamblr.io · 6 Apr 2026
~$3.5K winnings reverted
Same playbook on the same operator that took your money — 22 days ago. Deposited 2,000 USDT, got an auto-applied bonus, won up to 5,500 USDT, then operator cancelled the bonus and reverted the balance. Pretext identical to yours.
Source
casino.guru complaint
Pretext
Bonus-cancel · winnings confiscated
Status
Open · public · co-plaintiff candidate
casino.guru/complaints/gamblr-casino-player-s-winnings-appear-to-be-confiscated

The pattern across all 192+ documented victims

8 rotating pretexts
  • "Third-party use and funding" (David's case)
  • KYC trap / verification loop
  • Multi-account / IP / VPN claim
  • "Wrong payment note" stop
  • Self-exclusion ignored / reversed
  • Affiliate "negative carryover"
  • Bets retroactively "voided"
  • Bonus-cancel · winnings reverted (aleks86)
17 brands in scope

Bitcasino · Sportsbet · Livecasino · Empire · Whale · Hype.Bet · Hype.Live · Shuffle · Coolbet · Gamdom · Klub28 · Vave · Yolo247 · Yolo.com · Bombay.vip · Themontus.io · Gamblr.io

Class scope

≥$6.5M known disputed exposure across the 192+ public victims · likely $50M+ true scale once subpoenas hit Hub88 + OT Malta + One.io customer ledgers · David's $1.4M is the highest individual frozen-funds claim on the public record.

Sources: casino.guru · askgamblers.com · sikayetvar.com · trustpilot.com · Casino.Guru's "blacklist" pages for each Yolo-orbit brand

§ 4 · The evidence

Heath built the case against himself.

Five Telegram messages from Heath admitting he made the introduction, knew Gamblr's supplier, and personally lobbied to keep your money. Four public-register filings — UBO declarations, sole-directorship records, ICIJ leaks — that contradict his February disclaimer. Six wind-down events since the dispute opened that satisfy the spoliation pattern under Fed. R. Civ. P. 37(e). Every line below is dated, documentary, and admissible.

★His words · 4 Telegram admissions to Jeff Gross (Florida-based affiliate-intermediary)
"more than happy to satisfy the action… as long as we have a defensiveble position"
Heath · 18 Jun 2025 · IMG_5105
Forecloses "I never knew about David's case"
"passport jurisdiction isn't the issue — we simply need a proof of address that they live outside the US"
Heath · 18 Jun 2025 · IMG_5105
Defeats the closure pretext (US activity)
"This is the founder's contacts. Feel free to ping him… (I know they use hub88)"
Heath · 9 Nov 2025 · IMG_5108
Establishes Heath ↔ Gamblr ↔ Hub88 nexus
"on your behalf I have already called gareth myself and told him to get in contact with you"
Heath · 18 Nov 2025 · IMG_5114
Personal intervention in the dispute
★His signatures · 5 public registry filings
Sole director · OT Malta Ltd C88843
MBR Malta · MGA/B2B/641/2018
"I have nothing to do with Gamblr" — content supplier
UBO · Bombay Club & Resort OÜ + Bombay Group OÜ
EE Reg 14045680 · self-filed Apr/May 2024
Penalty-of-perjury ownership declaration
15.93% of Stacey OÜ via Piangil OÜ (100% Heath)
EE Reg 11533886 · cap-table entry
Direct equity in the spoliation cluster (Greenbit)
Same NOUV CSP as Buhagiar's 36N Capital
ICIJ Paradise Papers · 135 Kyle Buildings, Malta
Structural co-mingling with Yolo Investments GP
HM UK Operations Ltd · transferred to Bolton 6 Nov 2025
UK CH 13875602 · single-day Heath director+PSC handoff to a State-Street-trained Yolo insider who "instrumentally set up" the Guernsey Yolo fund
Non-arms-length restructure mid-dispute
▼ ▶ ◀ Tim Heath
Heath's central denial
"I have nothing to do with gamblr."
Tim Heath · 4 Feb 2026 · Telegram to Jeff Gross
Surrounded by 16 pieces of his own evidence — every word said in his own voice, every signature in his own hand, every wind-down on his own watch.
★His actions · 7 wind-downs since the dispute opened
UK gateway shut down (TGP Europe)
15 May 2025 · £3.3M UKGC penalty
Yolo Investments OÜ deleted
2 Sep 2025 · Pärt liquidator
CrissCross FX UK incorporated
12 Sep 2025 · 10 days later · clean founders
Both CEOs exit (Fenney @ Gamblr + D'Emanuele @ Yolo Entertainment)
Dec 2025 · same month · mid-dispute
Walker-Morecroft installed at CrissCross
21 Jan 2026 · Heath's MLRO takes over
Yolo Investments PCC Guernsey surrendered
17 Feb 2026 · GFSC #2771881
Piller reactivates 3 dormant shells
22–27 Apr 2026 · 11 days before AGM
→ together: FRE 404(b) consciousness-of-guilt + FRCP 37(e) spoliation
§ 5 · The leverage

Five names. Five regulators. Nine days to the Betsson AGM.

The same offshore structure Heath built to protect himself exposes five individuals personally — Mark Robinson at UKGC, three SMF holders at One.io UK on the FCA register, and Zachary Mifsud at OT Malta Ltd on the MGA register. Each loses their career if a fitness complaint is upheld; a single complaint forces the choice between defending Heath and keeping their license. Why 7 May matters: that's when Betsson's shareholders meet to vote on Betsson's pending sub-€50M acquisition of Heath's Sportsbet.io and Bitcasino.io brands — and EU disclosure law forces Betsson to surface any credible RICO claim before the vote. It's the deadline that turns "eventually" into "this week" — and how a $1.4M dispute moves in weeks rather than years.

5 named individuals
3 regulators
Mark Robinson
Mark Robinson
Yolo Investments · PML UKGC
▶
UKGC
§ 116(2) PML review
Hayden Sommer
Hayden Sommer
One.io UK · SMF1/3/16/17
▶
FCA
Reg 26 fitness review · FRN 913478
EW
Edward Walker-Morecroft
One.io UK · SMF17 MLRO
▶
FCA
Reg 26 fitness review · FRN 913478
Jovi Overo
Jovi Overo
CEO ONE.io · ex-Unlimit
▶
FCA
Reg 26 fitness review · FRN 913478
ZM
Zachary Mifsud
Yolo Head of Legal · MGA KFH
▶
MGA
Key Function Holder review
★ The forcing function · Thu 7 May 2026
Betsson AGM
Betsson shareholders vote on the pending sub-€50M acquisition of Heath's Sportsbet.io + Bitcasino.io — the deal Heath needs to fund his $500M ADGM Fund III.
9 daysfrom today (28 Apr)
Heath's three remaining options at the AGM — all three put him personally on the hook:
(a) Settles to clear the sale
(b) Betsson escrow holdback / indemnity carve-out against him personally
(c) W&I insurance carves out the known RICO predicate — leaves Heath uninsured for it
EU MAR Art. 17 forces immediate disclosure on receipt of credible material information. Spelinspektionen has Betsson on its AML strike list since Jun 2025 SEK 6.5M fine — Betsson's GC cannot accept a second AML cascade silently.
⚠ If the Betsson deal does not close (Q1 2026 disclosure absent → see Plan B at Slide 10), the AGM forcing-function evaporates — but Heath's MGA, FCA, and EMTA personal exposures remain.

Each named individual carries a personal license. Each license requires fitness attestation. A complaint filed at any of the 3 regulators on the same day as the demand letter forces them to choose between defending Heath and keeping their career — at exactly the moment the Betsson AGM is deciding the sale.

Named demand-letter routing — already mapped

Track 1 · Betsson

Triin Toomemets-Krasnitski · CLO · Tallinn-resident
Eva de Falck · Audit Committee Chair
Johan Lundberg · Board Chair

Track 2 · Betsson's M&A counsel

Mikael Borg · G&D Chairman
mikael.borg@gda.se · +46 734 15 26 44
Mikael Bolling · G&D · +46 734 15 26 04
Maarten Hoelen · Baker McKenzie Amsterdam · +31 20 551 7822

Track 3 · Yolo

Chet Pohl · General Counsel
Linda Blumfeldt · Head of Legal
(Both confirmed by Yolo Investments team page yolo.io/team)

§ 6 · Paths forward

Three paths. They reinforce each other — best run together.

Path A pressures Heath through Betsson's 7 May AGM — fastest to settlement (2–6 weeks). Path B is the federal RICO filing that makes Path A's threat real; without it, Heath waits you out. Path C is the 192+-victim class action that scales your $1.4M into $50M+ across the cohort. The play: launch A and B this week, seed C in parallel.

Recommended
Path A

Three-track demand letter + regulator complaints, pre-AGM

Use the Betsson sale window. Force disclosure under EU MAR Art. 17.

Deadline
Now → Betsson AGM 7 May 2026
Cost
Counsel time only — no court fees, no expert reports
How fast
2–6 weeks if Heath chooses settlement over a deal-blocking disclosure
Why it works
Heath needs the Betsson sale to fund his $500M ADGM Fund III — your $1.4M is a rounding error compared to losing the deal
Pressure amplifiers
Filed the same day as the demand letter: UKGC §116(2) complaint vs Mark Robinson · FCA Reg 26 fitness complaints vs Sommer + Walker-Morecroft + Overo · MGA KFH complaint vs Mifsud — each forces personal fitness review independent of the AGM outcome
If Betsson stalls
Plan B at Slide 10 · 5 ranked alternatives that target Heath's internal regulatory exposure (MGA + EMTA + FCA + AFR + ABC) — work without an AGM forcing function
What can go wrong
Low risk · if Heath ignores the letter, the same evidence becomes the predicate for Path B filings
Lead evidence
Heath sole director OT Malta Ltd C88843 · statutory UBO of Bombay Club & Resort OÜ · 6-event spoliation timeline
Path B

Federal RICO complaint · S.D. Fla.

Florida Civil Theft 30-day demand → § 1962(c)/(d) RICO with 15+ named defendants.

When
File this week — Path A's threat only works if Path B is genuinely live
Cost
Medium · contingency-friendly with experienced RICO firms
How long
12–24 months to summary judgment or settlement
Why it wins
You won and were not paid — a stronger Article III injury than the Aguilar v. Pump.fun template (concrete contractual right to a specific sum, not loss-recovery)
What can go wrong
Heath challenges personal jurisdiction — but Tristan Thompson NBA sponsorship + 9 US-domiciled Yolo investees give Florida solid long-arm grounds
Recovery target
Florida Civil Theft (Fla. Stat. § 772.11) + RICO § 1964 = 3× $1.4M = $4.2M trebled, plus fees
Path C

Class action · 192+ victims

Lead plaintiff for the documented Heath-orbit cohort across 17 brands.

When
Run in parallel with Path B · seeded once the federal complaint is on file
Cost to David
$0 out-of-pocket — 100% contingency from class firms (Burwick · Wolf Popper · Edelson · Beasley Allen · Susman Godfrey)
How long
24–48 months to certification + recovery
Why it works
192+ identifiable victims · same 8-pretext playbook · 17 brands → Rule 23 commonality is straightforward to plead
Class scope
≥$6.5M known disputed exposure · likely $50M+ true scale once subpoenas hit Hub88 + OT Malta + One.io customer ledgers
David's role
Lead plaintiff · highest individual claim anchors the class · enhanced settlement compensation typical for lead plaintiffs
$4.2M
Trebled recovery target
(Path B)
$50M+
Class-scale exposure
(Path C)
9 days
To Betsson AGM
(Path A window)
15+
Named defendant candidates
across 9 jurisdictions
§ 7 · The action plan

Eight days. Five filings. One AGM that forces the choice.

The five steps below launch Path A's three-track demand letter + four regulator complaints AND start Path B's federal RICO clock — all in the same week — so Heath arrives at the 7 May Betsson AGM with no choice but to settle, restructure the deal around your claim, or watch the sale collapse under EU MAR Art. 17 disclosure obligations.

Eight-day campaign · Thu 30 Apr → Thu 7 May 2026
30 Apr
Thu
Path B clock
Florida Civil Theft 30-day demand letter
Silverman Thompson sends pre-suit demand under Fla. Stat. § 772.11 — starts the federal trebling clock + satisfies the pre-suit requirement for the RICO complaint.
1 May
Fri
Path A · core
Three-track demand letter delivered
To Triin Toomemets-Krasnitski (Betsson CLO) · Mikael Borg (G&D Chairman) · Chet Pohl + Linda Blumfeldt (Yolo). Cites EU MAR Art. 17.
2 May
Sat
Letters absorb · weekend pause
3 May
Sun
Targets consult counsel · weekend pause
4 May
Mon
Path A · press
Embargoed Bloomberg / Australian / SBC drop
Spoliation timeline + Heath's Bombay Club UBO + OT Malta Ltd sole-directorship released to embargo, lifting at AGM.
5 May
Tue
Path A · amplifiers
3 regulator complaints filed
UKGC §116(2) vs Mark Robinson · FCA SMCR Reg 26 vs Sommer + Walker-Morecroft + Overo (FRN 913478) · MGA KFH vs Zachary Mifsud (OT Malta C88843).
6 May
Wed
AGM eve · disclosure window peaks
7 May
Thu
★ AGM · resolution
Heath chooses — and loses either way
(a) Settles to clear the sale · (b) Betsson imposes escrow / indemnity carve-out on him personally · (c) W&I insurance carves out the RICO predicate — leaves him uninsured.
Path B's federal RICO clock runs in parallel · trebling time accrues independent of the AGM outcome
Why this works

Heath needs the Betsson sale to close to fund Yolo Fund III ADGM ($500M target). The unilateral pressure is asymmetric: David's $1.4M is a rounding error to Betsson but a deal-killer if disclosed late under MAR Art. 17. Heath either pays now or loses the sale.

If Path A doesn't resolve by AGM — or if the Betsson deal does not close

Path B (federal RICO) and Path C (class action) are already in pleading-ready form — every paragraph can cite the master evidence file. The pressure compounds: each missed AGM week increases Heath's exposure across UKGC PML, FCA SMCR, MGA KFH, MFSA, EMTA, and BCC Comoros simultaneously. If the Betsson deal stalls or collapses (no MAR Art. 17 disclosure was filed in Betsson's Q1 2026 report on 24 Apr), the AGM forcing-function disappears but Heath's own regulator and reputational exposures remain — and they are larger. → Plan B at Slide 10 presents 5 ranked alternative paths designed for that scenario.

Backed by a comprehensive case-file: master network map, draft federal complaint, and a full library of source-cited dossiers — available on request to counsel.

§ 7b · If the Betsson deal does not close

One wire. Or six cascades. Heath chooses.

The Betsson deal looks dead. Their April 24 quarterly report did not disclose the Yolo acquisition that EU law would have required if the deal were closing; the CEO kept saying "we're looking into it" three months after the rumor broke; their own quarter was rough (operating profit down 47%); and they had just cancelled their Dutch acquisition over regulatory delays. The 7 May vote almost certainly never happens. That doesn't weaken your case — it sharpens it. The pressure shifts from Heath's buyer to what Heath still owns: his Maltese gambling licences, his Estonian regulator, his UK PSC, his Yolo.com regulated-market pivot, his Australian Rich-List profile. None of those are for sale.

★ The wire (Heath's cheapest move)
$1,455,000
0.09% of A$2.46B / $1.6B net worth (AFR Rich List #66)
0.6% of one Dec 2025 exit ($240M CoinMENA → Paribu)
Settles in 30 seconds · one wire to escrow · case closed
VS
⇆
Or six cascades · Heath's most expensive choice
$50M – $200M+
MGA fitness review on 2 sole-director licences (OT Malta · Hub88)
Estonian EMTA · UK FCA · ABC Australia · AFR Rich List · Fund LPs
6–18 months public process · brand pivot dies · privacy gone
★ Step 0 · The Foundation
Re-engage the whistleblower. This is the first move — it is what makes every path below work.
In January 2026 a Gamblr-insider whistleblower contacted David at his personal email — citing his home address, his US passport number, and the verbatim accounting language by which Gamblr reclassified his $1.38M from "customer balance" to "operational expenditure." After David rejected the $80K-upfront extortion bid, Gamblr terminated the whistleblower the next morning. At 3:10 a.m. on 23 January, the whistleblower wrote back accepting David's preferred deal structure — pure contingent fee, payable only on recovery. The offer has been hanging for 97 days.
The Jan 23 message Heath does not know exists "I woke up this morning to an email confirming my engagement with Gamblr had been ended. I am now willing to come to the table and provide you with the information, for a fee made payable once you've been paid out. Do we still have a deal?"
— gamblrwhistleblower@gmail.com · 23 Jan 2026 · 3:10 a.m. · UNANSWERED FOR 97 DAYS
Without Step 0
  • Six attachments rest on public records only
  • No named Gamblr decision-makers — only Heath and corporate aliases
  • No insider corroboration of the $1.38M reclassification entry
  • Path 1 settles in 7 days · Path 4 takes 30–60 days
⇒
With Step 0
  • Insider documents, internal decision narrative, named individuals, roles, contacts
  • Verbatim language that telegraphs to Gamblr you have an inside source
  • Source corroboration of the $1.38M reclassification entry
  • Path 1 may compress to 48–72 hours · cost to David: $0 up front
Why this is Step 0, not an add-on

The whistleblower is now Gamblr-adverse — he was terminated for this very disclosure. He self-priced at ~6% of recovery (≈ $87K of $1.455M). Compared to a federal RICO fee budget of $150K–$300K, this is the cheapest insider-witness this case can buy. Re-engaging him doesn't strengthen Plan B — it activates it.

How counsel structures it cleanly

Counter-offer: contingent fee tied to actual recovery, escrow-routed, signed cooperation declaration, payment for documents (not testimony). Mirrors qui tam relator awards (31 U.S.C. § 3730 — 15-30% of recovery) and SEC Dodd-Frank §922 whistleblower structures. Agreement disclosed to court and opposing counsel on production; whistleblower prepared for impeachment cross under FRE 608. Estimated time to re-engagement: 72 hours.

↓ THEN execute one of the five paths below ↓

Five execution paths · all use Step 0 as foundation · pick by speed × probability × cost

Path 1★ RECOMMENDED
One letter. Seven days. Six ready-to-file attachments.
7days
$ ★★★★ HIGH
On Friday, May 15, your counsel hand-delivers one letter to Heath in Malta. Inside the envelope: six complaints — federal RICO, the Malta Gaming Authority, the UK FCA, Estonia's EMTA, and exclusive briefings for the Australian Financial Review and ABC Australia — every one already drafted, signed, and ready to file. Heath has seven calendar days to wire $1,455,000 to escrow. Wire it, and the package is destroyed before any regulator sees a word. Ignore it, and all six file simultaneously at 9 a.m. on Day 8 — automatic, no second letter, no negotiation.
Path 2
Friend first, counsel second.
14–21days
$ ★★★ MED-HI
Step 1: David writes Heath himself, friend to friend — "you introduced me to Gamblr; they refuse to pay; please make a phone call before this gets worse." Heath has seven days to respond. Step 2: if he stays silent, counsel sends the Path 1 letter the next morning — same six attachments, same window. Step one preserves a relationship if Heath chooses to fix this. Step two protects $1.455M if he doesn't.
Path 3
File at the regulators who license Heath personally.
21–30days
$$ ★★ MEDIUM
Two real complaints, filed the same day at the regulators who license Heath as a person — not just his companies. Malta Gaming Authority: Heath is the sole director of two Critical-Supply licensees (OT Malta C88843 and Hub88 C86394). Estonian Tax and Customs Board: Heath signed three sworn UBO declarations under Estonian AML law on his Bombay-group entities. Both regulators have direct fitness-review authority over Heath. Both files stay open on a regulator's desk until your claim resolves.
Path 4
Federal lawsuit + emergency asset freeze.
30–60days
$$$ ★★ MEDIUM
File the federal RICO suit in Miami's Southern District the same week. Move ex parte for a Florida § 76 prejudgment writ on any Heath asset that touches a US bank or counterparty. Serve Heath at his Malta home through the Hague Convention's Office of the State Advocate. The day the case files, the docket goes public, the press picks it up automatically — and the federal trebling clock turns $1.455M into $4.37M plus fees and costs.
Path 5
Quiet briefing to Australian press.
14–21days
$0 ★★ MEDIUM
Quietly hand the case file to two Australian outlets already investigating this exact world: the Australian Financial Review (which tracks Heath's #66 Rich-List ranking) and the ABC Australia investigative team (the same reporters who broke the fake-Anjouan-licence story in December 2025). Heath learns through industry that a story is being researched. He settles privately to keep his name off the front page.
D-1   One letter arrives at Heath's Malta address. Six attachments. Seven-day clock starts. ⤵ Heath decides ⤵
★ Heath wires by D-7 (Thu 21 May)
Settlement agreement & release · executed by Friday
All 6 attachments withdrawn · regulators never notified
Yolo.com regulated pivot proceeds · brand intact
AFR Rich List + ABC stories die quietly · privacy preserved
Total cost $1.455M · case closed in 7 days
Heath ignores · 6 cascades fire D-8 9 a.m. ET
S.D. Fla. RICO complaint filed · trebling clock starts ($1.455M → $4.37M)
MGA fitness review opens on OT Malta + Hub88 (sole-director)
Estonian EMTA opens UBO inquiry · gambling-tax licensee record
UK FCA SMCR letter on One.io UK · ABC + AFR run · LPs notified
Total cost $50M – $200M+ · 6–18 months · brand pivot dead

Plan B preserves Path B + Path C from Slide 8. Adds five no-Betsson alternatives. Recommends Step 0 + Path 1.

Appendix · Evidence Vault

The named persons,
the named entities,
the named registrations.

Every slide that follows is sourced from primary public records — Estonian e-Äriregister, UK Companies House, Maltese MBR, Greg.gg Guernsey, ICIJ Offshore Leaks, FCA Register, UKGC Public Register, MGA Register. No claim below is unsourced.

16
Named individuals
profiled
38
Corporate entities
with registration #
9
Jurisdictions
cross-validated
78
Source-cited
sub-dossiers
A.1 · Principals (Tier 1)

The four people who actually run it — and who go on the complaint first.

Heath built and chairs Yolo Group. Piller is the co-founder, holds 18% of Yolo Tech, and is the one running the Estonian shell-restructuring (10 new entities registered after your dispute opened). Buhagiar is the second-named partner at Yolo Investments alongside Heath. Pärt was COO and now signs the liquidations — including the Yolo Investments OÜ deletion in your timeline. Every role is recorded in public corporate filings — meaning each one is personally liable, reachable for service, and any of their statements becomes admissible against the company under FRE 801(d)(2). Red-bordered cards are the people most directly tied to the entities that froze your money. They are the names that go on the federal complaint first.

Tim HeathTH

Timothy John Heath

Founder · Yolo Group · GP Yolo Investments
DOB
20 May 1978
Nationality
Australian
Estonian ID
37805200067
Residency
Tallinn → UAE (post-29 Jul 2024 kidnap)
Education
U. Melbourne BInfSys/Comm 1997-2002 · Scotch College
Net worth
A$2.46B · AFR Rich List 2025 #66
LinkedIn
tim-heath-55096b1
Roles & ownership
  • Founder & Board Yolo Group · since Jun 2013 (12 yrs 11 mos)
  • GP Yolo Investments · since 2017
  • Board OneTouch Technologies Ltd IoM 130853C · since Jun 2016
  • Sole director OT Malta Ltd C88843
  • UBO Bombay Club & Resort OÜ · 27 May 2024 (Estonian register)
  • UBO Bombay Group OÜ · 8 Apr 2024 (Estonian register)
  • ~70.5% Yolo Tech OÜ 14609414
  • 100% Piangil OÜ 11533886 → 15.93% Stacey OÜ
  • 25-50% PSC One.io Group Ltd UK CH 13036457
  • Treasurer Estonian Cricket Association · since Jan 2007
Direct admission of personal intervention in David's case: "on your behalf I have already called gareth myself and told him to get in contact with you" — Heath · 18 Nov 2025 Telegram to Jeff Gross. (Compare to his 4 Feb 2026 disclaimer: "I have nothing to do with gamblr.")
Estonian Business Register · MBR Malta · UK CH · Heath's own LinkedIn (FRE 801(d)(2)(A) party-opponent admission)
RP

Reio Piller

Co-founder · Yolo Group
DOB
16 Oct 1981
Estonian ID
38110160381
Residency
Lagedi, Rae County, Estonia
Address
Mätta 3 Lagedi (= Pandora Papers Luckbox UBO address)
GitHub
hypno2000
Roles & ownership
  • Co-founder Yolo Group · since 2004 (Heathmont OÜ)
  • 18% Yolo Tech OÜ 14609414
  • 100% CSW Holding OÜ 12606506 (central restructure hub)
  • Board Heathmont OÜ 11063972 · since 2004
  • Board Bombay Group OÜ · since 17 Jan 2023
  • UBO Luckbox Enterprises Ltd BVI 2010 (Pandora Papers)
  • 20 active EE directorships incl. Live88 Studios OÜ, Bombay Group, Yolo Tech
  • 10 NEW entities registered post-Sep 2025 during Silverman dispute (incl. Ghost Performance, RPT Holding, Imaginal Microsystems, Powerwind reactivation)
e-Äriregister + Inforegister · ICIJ Pandora Papers
Maarja PärtMP

Maarja Pärt

Supervisory Board · ex-CEO Yolo Group
Nationality
Estonian
Residency
Tallinn
Career path
Customer Experience → C-suite → CEO → Supervisory Board
iGaming TOP 100
#69 (2025)
LinkedIn
maarja-part
Roles & activity
  • Supervisory Board Yolo Group · current
  • Board Yolo Investments · current
  • Board Bombay Club & Resort OÜ 14045680 · since 2018
  • Board Bombay Group OÜ 16132057 · current
  • LIQUIDATOR Yolo Investments OÜ 14972698 (deleted 2 Sep 2025)
  • Public quote (e-Residency podcast): scaled Yolo to "over 1,000 people"
  • Endorsed Anita Brinke's "Management" skill on LinkedIn
"the C-suite and scale a global company to over 1,000 people in fast-paced, highly regulated industries"
yolo.io/team · e-Äriregister · Yolo Group LinkedIn
Julian BuhagiarJB

Julian Buhagiar

General Partner · Yolo Investments
DOB
January 1976
Nationality
Maltese
UK address
Fitzrovia House, London
MT address
174 Ta Gulinu, Triq il-Kbira, Siggiewi
LinkedIn
julianbuhagiar
Roles & ICIJ exposure
  • GP Yolo Investments · current
  • Sole director / sole shareholder / sole legal & judicial rep · 36N Capital Mgmt Ltd Malta C76815
  • Incorporated 26 Sep 2016 · ICIJ Paradise Papers (Nov 2017)
  • Cross-link: 36N's NOUV CSP address (135 Kyle Buildings, St. Julians) = SAME as Heath's Vereeni Investments Malta C82096
  • NOUV MT Holding Ltd is itself a shareholder of 36N
  • Director RB Capital Advisors Ltd UK CH 10114453 · since 10 Apr 2016
ICIJ nodes 55074335 + 56030014 · MBR Malta · UK CH
A.2 · Operational decision-makers (Tier 2)

The operations team whose decisions on your account make them personally liable.

Each executive below took action on your case while it was open — froze the withdrawal, signed the T&C-violation pretext, set the VIP policy that did, or ignored an escalation. RICO reaches them personally, not just the company, because each held an "operation or management" role in the enterprise (§ 1962(c)). Once named on the federal complaint, each one becomes a fact witness who has to defend their own emails, approvals, and signatures in deposition before they can defend Heath's. The practical leverage: they have to talk first.

Deposition priority Slip 1 / 6
Matthew D'Emanuele
Matthew D'Emanuele
CEO · Yolo Entertainment Oct 2023 – Dec 2025 (exited mid-dispute, same month as Fenney). 11-yr customer-ops résumé: GiG Risk & Fraud Director → Eastrock Asia CEO → Yolo. Now styles himself "Strategic Advisor."
Malta · Tel +356 79 69 97 52 · ICIJ self-attested COO Oxford Int'l Financial Mgmt 2012–15
Action on your account On 14 Jun 2025 Cristina wrote to you: "I have spoken to our CEO and unfortunately, we are unable to accept activity from the US" — referring to you. Heath then offered to "intro you to matt (the ceo)" on 18 Jun 2025, providing your phone directly. Eight months earlier, henkster's "Open Letter to Matthew D'Emanuele" (22 Sep 2024) had already named you personally over the same Cristina Rahuoja pattern. Then you exited Dec 2025 — same month Fenney exited Gamblr.
In deposition you must explain (1) Why you signed off — as Yolo Entertainment CEO — on the May/Jun 2025 closure of David's account after kingjudas's lawyer (8 Sep 2024) and henkster's open letter to you (22 Sep 2024) had already put you on notice of the identical pattern; (2) why your "Risk and Fraud proposition" playbook from your GiG Director-of-Operations tenure landed on David's account in the same operational template; and (3) why you exited the same month as Gamblr's CEO Fenney, mid-dispute.
Source: IMG_5105 / IMG_5106 / IMG_5107 Heath Telegram screenshots · medium.com/@HenkYouBye open letter · ICIJ Paradise Papers (Oxford Int'l Financial Holdings Malta)
Deposition priority Slip 2 / 6
Alex Haig
Alex Haig
Director of Sportsbet.io · Yolo Entertainment (joined Oct 2023; ex-Betsson Group)
UK · BA Univ. of Hull
Action on your account As the named director of the Sportsbet.io brand and operational sign-off on VIP closures, you were the direct decision-maker on the May–Jun 2025 closure of David's account. Your boomerang back to Betsson via the Q2–Q3 2026 acquisition is a separate disclosure question.
In deposition you must explain Whether you authorised the closure, what was said internally about it, and what (if anything) you have disclosed to your prior — and incoming — employer Betsson about the Silverman dispute as the acquisition closed.
Source: LinkedIn (Ladbrokes → Unibet → Betsson → William Hill → TonyBet → Sportsbet.io) · iGaming Business · SBC News · Sportsbet.io LaLiga PR Oct 2024
Deposition priority Slip 3 / 6
Cristina Rahuoja
Cristina Rahuoja
VIP Team Manager · Yolo Group · 11-yr unbroken tenure at Heath's enterprise (Coingaming → Yolo, since Nov 2014)
Tallinn · Marketing degree only (Estonian Entrepreneurship Univ. of Applied Sciences 2009–12) · no compliance / legal / AML training
Action on your account Direct fraud actor in your case. Member of the "Jeff and Sportsbet" 5-person Telegram group from 25 Apr 2025. On 14 Jun 2025 wrote: "I have spoken to our CEO and unfortunately, we are unable to accept activity from the US." Her own LinkedIn lists "Coingaming Group" and "Yolo Group" as separate employer entries straddling the 2021 rebrand — a clean party-opponent admission that Coingaming = Yolo (binds pre-2021 Coingaming acts to the Yolo enterprise for RICO-pattern purposes).
In deposition you must explain Why the same VIP-closure pattern was applied to Diaz-Cortez (Aug 2024) · henkster (Sep 2024) · David Silverman (May 2025) · aleks86 (Apr 2026) — all by you, in the same role, at the same company, across an 11-year tenure. And why a Marketing graduate with no compliance training was empowered to make a "we are unable to accept activity from the US" determination on David's account when the same affiliate pipeline (Jeff Gross) generated paid commission for Colin Harris's US play.
Source: Cristina's own LinkedIn (FRE 801(d)(2)(A) party-opponent admission · 11-yr tenure self-attested) · Jeff Gross IMG_5099-5116 Telegram archive · iGaming IDOL 2022 finalist citation · Yolo Group Facebook post 799074561558699 (8 Jun 2023) · Diaz-Cortez Medium "VIP Nightmare" · henkster open letter
verbatim quote on file
Deposition priority Slip 4 / 6
Adam Chernoff
Adam Chernoff ("Adam S ⭐")
Senior Manager Growth Initiatives · Yolo Group / Coingaming
Canada · service via DOJ Canada
Action on your account On 20 Jun 2025 deployed the "negative carryover from May 184,909" pretext to deny Jeff Gross's $186,267.57 commission earned on David's play. Yolo paid Jeff $34,300 for Colin Harris's play through the same affiliate program in the same period — establishing selective bad-faith.
In deposition you must explain Why one Jeff-Gross-introduced US player (Harris) generated paid commission and the other (Silverman) generated a "negative carryover" denial. The asymmetry breaks the affiliate-T&C pretext on its own.
Source: Jeff Gross 12-screenshot Telegram archive · Jeff Gross attorney-intake email 19 Dec 2025 · RocketReach Coingaming Sales Department roster
Deposition priority Slip 5 / 6
Liis Bolton
Liis Bolton
MD · Yolo Investments · Board Member Yolo Investments PCC since Oct 2021. Self-attested: "instrumental in setting up the Guernsey Yolo fund and related structures". Pre-Yolo: 8.5 yrs at State Street Custody Services Guernsey Ltd (Fund Analyst · B-signatory · custodian + depositary services).
DOB 27 Sep 1980 · Guernsey · Estonian · CISI + IoD member · Landscape-Architecture degree (Estonian Univ. of Life Sciences) + further financial studies
Action on your account On 6 Nov 2025 — six months into the Silverman dispute — accepted Heath's directorship + PSC transfer of HM UK Operations Ltd (CH 13875602) in a single coordinated transaction (NOT arm's length). Director of Yolo Investments PCC Guernsey GFSC #2771881, whose licence was surrendered 17 Feb 2026 — a structure she "instrumentally set up" in her own words.
In deposition you must explain (1) Why a State-Street-trained custodian who knew the proper depositary standards accepted a non-arms-length UK directorship transfer mid-dispute; (2) what compliance review your CISI Code-of-Conduct membership required of the structure you "instrumentally set up" before its licence surrender; (3) how your IoD-member governance duties were discharged when Heath transferred director + PSC of HM UK Operations Ltd to you in one coordinated transaction.
Source: Bolton's own LinkedIn About + Experience (FRE 801(d)(2)(A) self-attestation) · UK Companies House 13875602 (Heath resignation + Bolton appointment 6 Nov 2025) · Greg.gg · GFSC public register · CISI + IoD member directories · yolo.io/team
Deposition priority Slip 6 / 6
Zachary Mifsud
Zachary Mifsud
Head of Legal & Compliance · Yolo Group · Warranted Maltese Lawyer (Kamra tal-Avukati)
Valletta · Specialism: Gambling, IP & Contract Law
Action on your account Most likely the MGA Key Function Holder (Legal/Compliance) for OT Malta Ltd C88843 — meaning you personally signed the MFSA fit-and-proper attestation, with personal liability for false statements under the MGA Act + FSA Act.
In deposition you must explain When you first became aware of the Silverman dispute, what compliance review was triggered under MGA Reg 4 customer-fund-protection obligations, and whether your personal attestation remains accurate in light of David's frozen $1.4M.
Source: Yolo Group LinkedIn employee directory · Kamra tal-Avukati lawyer warrant · MGA Public Register OT Malta C88843 / MGA/B2B/641/2018
A.3 · Regulatory pressure points + cooperator (Tier 3)

Four UK-regulated officers, one cooperator candidate, one flight-risk.

The first four are named on UK regulatory registers (UKGC PML + FCA SMF) with personal-attestation duty — a single complaint triggers a Reg 26 / Section 116(2) fitness review. The fifth (★ Nugis) is the highest-cooperation-candidacy ex-employee. The sixth (Virkus) has already relocated to UAE non-resident status during the dispute window.

UK Gambling Commission PML
Mark Robinson
Mark Darren "Sharky" Robinson
Commercial Director · Yolo Investments
PML · holder via Apricot/Microgaming UKGC #39073 (2016–2021)
DOB
21 Aug 1975
National.
NZ
Resident
Isle of Man, Douglas
LinkedIn
/mark-robinson-pml-ukgc-40490622
Notable
NZ All Black cap #965 (1997–2001)
What this licence triggers A single UKGC § 116(2) fitness review ends his career and severs Yolo's UK gambling-regulator footprint in one move — he is the only publicly identifiable Yolo executive with a UKGC PML, so Yolo cannot replace him.
UKGC Public Register · Companies House · LinkedIn URL self-tag
Financial Conduct Authority SMF 1/3/16/17
Hayden Sommer
Hayden Bradley Sommer
Director · One.io UK Limited (day-one)
FRN 913478 · CH 12040686
DOB
Nov 1973
National.
British
Director
since 10 Jun 2019
UK appts
16 total
Pattern
resigned from every non-FCA One.io sibling on 19 Nov 2024 — built a personal escape shield while the dispute opened
What this licence triggers An FCA Reg 26 fitness complaint forces him to defend his SMF attestations on Silverman-related transactions in writing, in his own name — at the exact moment his year-long shield-building strategy is most exposed.
FCA Register · UK Companies House
FCA · Money-Laundering Reporting Officer SMF 17
EW
Edward Richard Walker-Morecroft
MLRO · One.io UK Limited (since Jun 2023)
FRN 913478 · also dir. CrissCross FX UK CH 16713961 (21 Jan 2026)
DOB
Jun 1971
National.
British
Director
since 3 Jun 2023
UK appts
14 total
Officer ID
Hb1UPiLuwcQ8k_k6qHw-BxdQtEY
What this licence triggers A § 1956 money-laundering predicate complaint forces him to defend his MLRO sign-offs on Silverman-related transactions — and explain why he was simultaneously installing himself at the One.io UK successor (CrissCross) during the dispute.
FCA Register · UK Companies House
Financial Conduct Authority SMF 1 (cand.)
Jovi Overo
Jovi Joseph Overo
CEO · ONE.io group (since 19 Feb 2026)
FRN 913478 · onboarded last in SUP 10C sequence
DOB
Jul 1980
National.
British
Director
since 19 Feb 2026 (FCA entity added LAST)
Education
Imperial College MBA 2014
Red flag
came from Unlimit (BaaS spun out of the Wirecard / Russian-CIS payment-processor collapse)
What this licence triggers A new CEO at the most-regulated entity carries the highest fit-and-proper bar. Within his first 90 days, his attestation history is shortest — a complaint forces him to defend Heath's enterprise from the smallest possible defensive base.
FCA Register · UK Companies House · Imperial College
★ Cooperator Candidate · Ex-Insider EE Reg 17002836
Magnus Nugis
Magnus Nugis
EX-Yolo Group Treasury · now PIIPA OÜ
PIIPA OÜ Reg 17002836 · own consulting vehicle
DOB
3 Oct 1990
EE ID
39010030307
Resident
Estonia (Aasamäe tn 9-4)
Email
magnusnugis@hotmail.com
Vehicle
set up 6 Jun 2024 — 3 mo before Yolo restructured
Why he's the highest-value witness Out of the company · jurisdictionally serviceable in Estonia · no Heath retaliation leverage. His exit timing means he saw the restructuring before the rest of the company did — he knows what's in the Treasury books during your dispute.
Inforegister · Estonian Business Register
Cooperatorcandidate
Flight Risk · Relocated UAE 19 Nov 2025
Hannes Virkus
Hannes Virkus
Partner · Yolo Investments
PINKS OÜ (100% owned since 26 Mar 2024)
DOB
6 Sep 1990
National.
Estonian
Status
UAE non-resident since 19 Nov 2025
Career
EE Min. of Economy adviser → OMA kanal · Miltton → Yolo Investments Partner
Why his move matters Three Yolo wind-down events in six months and the partner who would be liable in Estonia chooses that exact window to leave the country. Consciousness-of-guilt indicator under FRE 404(b)(2)(B); also forces Hague-via-UAE service (UAE is not a Hague signatory).
Inforegister · LinkedIn · yolo.io/team
RelocatedUAE non-resident
A.4 · Supply chain & supporting roles (Tier 4)

Eight humans behind the supply chain that took your money.

Not the Anjouan shell — the real people. The Magic-Circle lawyer who built Gamblr and signed your closure (Fenney). The founder of the game that ran your bets (Natroshvili). The Yolo engineer who built Heath's payment rail (Manish). The regulator-turned-operator who provided UK cover (Kimber). The human bridge from SunCity / Macau to the white-label machine (Hwang). The Yolo executive who pulled you into the Telegram group (Tamm). The celebrity-shareholder who endorsed it publicly (Westwick). And the bankroll provider who promised "guaranteed payouts" (Marantelli / iBankroll). Each is named on a public document that ties them to a specific federal predicate.

GF

Gareth Jon Fenney

Co-Founder & CEO · Gamblr (Jul 2024 – Dec 2025)
Nationality
British · UAE-resident since 2018
UAE phone
+971 58 576 5979
Russia phone
+7 985 534 6760 (2014–15 Moscow tenure)
UK SRA #
506116
Pre-Gamblr
DeFi Architect · TENET (Mar 2023 – Jun 2024)
Pre-tech
13-yr corporate lawyer · Skadden · Debevoise (×2) · Freshfields · A&O Moscow · Carey Olsen BVI
Current
"Stealth-Mode" startup CEO since Jan 2026 (post-exit)
His own LinkedIn admission (~Oct 2025): "As CEO of Gamblr, hitting $100M in wagers so quickly isn't just a metric — it's a signal. This is just the beginning…"
  • $100M+ wagered through Gamblr in under 6 months per Gamblr's own corporate post — your $1.4M is ~1.4% of Fenney's own publicly-claimed volume during the window your account was active
  • Five top-tier law firms (Skadden · Debevoise ×2 · Freshfields · A&O Moscow · Carey Olsen BVI) — he drafts the kind of T&Cs invoked against you for a living. "Naive operator" defence foreclosed.
  • UK SRA-warranted solicitor #506116 — an SRA misconduct complaint forces a fitness review with disbarment as the downside he can't walk back
  • 15 mo as DeFi Architect at TENET immediately before Gamblr launched — he engineered the crypto-rail integration (Spribe-direct, Anjouan, crypto-only) himself
  • Heath, 18 Nov 2025 Telegram: "on your behalf I have already called gareth myself" — places Fenney as Heath's direct dispute counterparty
  • Exit Dec 2025 mid-dispute — same consciousness-of-guilt window as TGP collapse, Yolo Investments OÜ deletion, and Virkus's UAE non-resident relocation
Fenney's own LinkedIn ★ FRE 801(d)(2)(A) ★ · Gamblr corporate page (FRE 801(d)(2)(D)) · Heath Telegram IMG_5108 + IMG_5114 · UK SRA register · Anjouan licence register
DN

David Natroshvili

Founder & sole UBO · Spribe OÜ
DOB
21 Mar 1977
Nationality
Georgian
Georgian ID
01024016695
LinkedIn
ge.linkedin.com/in/david-natroshvili-98338038
  • His company Spribe makes Aviator, the most-played crash game on Gamblr.io — a provider entry in Gamblr.io's own homepage HTML proves the direct supply line
  • Sole shareholder + 100% beneficial owner of Spribe OÜ (Estonian Reg 14540763) since 1 Sep 2023 — Kivila tn 5-118 Tallinn
  • Former First Deputy Minister of Economy of Georgia (2006-07) — the credibility credential that opened gambling-regulator doors
  • Already losing on three fronts: $330M Georgian Court judgment Aug 2024 (affirmed Supreme Court May 2025), UK High Court IP loss Jul 2025, UKGC suspension Oct 2025
  • Naming Spribe as a § 1962(d) co-conspirator unlocks Spribe's RGS records — independent round-by-round logs of David's Aviator play that Heath cannot edit
Estonian Business Register · Georgian Public Registry · UK High Court · UKGC · Josimar.no
Mitul ManishMM

Mitul Manish

iOS Tech Lead Yolo Group · Co-founder & CPTO Open Wallet
Residency
Tallinn, Estonia (Yolo HQ)
X
@mitul_manish23
Profile
weekday.works · GitHub · ContactOut
  • iOS Technical Lead at Yolo Group, Tallinn — a salaried Heath employee operating Yolo's "iStream and Bombay apps"
  • Simultaneously co-founder + CPTO of Open Wallet (FinVerse Labs FZ-LLC, UAE RAKEZ #0000004030448) — the crypto-to-IBAN payment service Yolo Investments backs
  • NOT arms-length from Heath — Heath's own employee operating Heath's own portfolio company is the textbook definition of the same enterprise
  • Heath publicly REPOSTED Mitul's LinkedIn post explaining how to "avoid source-of-funds interrogation" when moving crypto into European bank accounts — that repost is a FRE 801(d)(2)(B) adoptive admission
  • Open Wallet's terms cap liability at $1,000 and disclose no AML controls — textbook § 1956 concealment-prong fact pattern
Weekday.works · Heath's own LinkedIn reposts · ANI press release · openwallet.com T&C
GK

Garth Philip Kimber

CEO · TGP Holdings · regulator-to-operator revolving door
DOB
July 1963
Nationality
British
Address
26 Elm Close, Amersham HP6 5DD
UK CH officer ID
MGzlkidhIKEZEeS5Uu_b7CG1zpA
  • The literal regulator-to-operator pipeline: Head of e-Gaming Development at the Isle of Man Government 2007–Nov 2011, then CEO of TGP Holdings from Dec 2011 — parent of TGP Europe Ltd IoM 122698C, which provided Sportsbet.io's UK regulatory cover until May 2025
  • Sat at the regulator's desk, then walked across the street to operate the entity that licensed Heath's flagship brand
  • Also CEO of Xela Holdings Ltd — additional vehicle in the same orbit
  • Holds NO active UK Companies House directorship — every operating role lives on the more opaque Isle of Man register, exactly the disclosure regime Heath's enterprise chose for that purpose
  • His Dec 2011 install date sits inside the critical window the IoM register would confirm SunCity's ownership of TGP Europe — pull request to IoM Companies Registry will surface his Annual Return signatures
UK CH · 3FM · EGR · iomtoday · GGB Magazine · IoM Registry (postal request)
CH

Charles Horng Cherng Hwang

Singaporean DFNN board · TGP/SunCity human bridge
Nationality
Singaporean
Education
DePaul University
  • The named human bridge between SunCity Group (Macau) and Heath's UK regulatory cover — without him, the case stays "Heath ran offshore brands"; with him, it becomes "Heath operated within an enterprise traceable to convicted Macau organized crime"
  • Sits on the board of DFNN, Inc. (PSE-listed Taguig, Philippines), Head of Development at Dynamite Games Pte. Ltd. Singapore, and listed externally as CEO of TGP Asia
  • Josimar (Andrew Auclair) 14 March 2023, verbatim: "intermediary directors including Charles Hwang knitting the junket's money into the UK white-label machine"
  • Combined with the 6 August 2014 SBTech press release: "TGP Europe is owned by TGP Holdings part of the Sun City Group" — two independent contemporary sources tie SunCity to Sportsbet.io's UK cover via Hwang's signatures
  • This is the documentary chain that lifts the case from "civil dispute" to RICO § 1961 racketeering activity with a Macau-OC origin trace
Josimar.no · DFNN · 6 Aug 2014 SBTech PRNewswire · Inforegister
TT

Taago Tamm

CPO/COO · Bombay Live
  • The Yolo executive who personally engineered the pull-in: created the "Jeff and Sportsbet" 5-person Telegram group on 25 Apr 2025 — the channel through which Heath's introduction reached you
  • Introduced Cristina Rahuoja to Jeff as "big boss of VIP Management", and Adam Chernoff as "in charge of the affiliation side of things" — building the trust scaffolding before the deposit
  • Promised Jeff a 25% cut on every player he brought in — the deal that turned Jeff into Heath's Florida intermediary, the channel through which your introduction reached you
  • Pinned a Bitcasino.io affiliate-tracking link to the chat (asset_id=37496678) — direct documentary evidence of the affiliate-funnel architecture
  • Subpoena target for the full chat history of every "Jeff and Sportsbet"-class group Tamm has spun up — likely dozens, populating the 192+ victim cohort
Jeff Gross 12-screenshot Telegram archive (IMG_5099–5116)
EW

Edward "Ed" Westwick

Brand ambassador + shareholder · Gamblr
Nationality
British (Stevenage)
Public profile
Actor — Chuck Bass on Gossip Girl · IMDB / SAG-AFTRA traceable
US nexus
US TV-show fame · US fan economy · US tax-residence questions
Equity disclosure
Gamblr's own LinkedIn corporate page · ~Oct 2025
Gamblr corporate post: "🎭 Ed Westwick joins as brand ambassador & shareholder" — voluntary public disclosure of his equity in the operator that froze your $1.4M.
  • Self-disclosed Gamblr shareholder — equity exposure to the operator's customer-fund-flow practices. Personal-attestation duty on the issuance documents.
  • Brand ambassador — promoted Gamblr to high-net-worth audiences using his celebrity persona, including US fan exposure
  • Personally reachable for service in UK / US via SAG-AFTRA, IMDB-listed agents, and prior US filming residence — far simpler than serving Heath in Dubai or Fenney in his Stealth-Mode startup
  • Discovery handle: subpoena Westwick's Gamblr equity-issuance docs, capital-call records, and the agent who placed him into the deal
Gamblr corporate LinkedIn ~Oct 2025 (FRE 801(d)(2)(D)) · IMDB · SAG-AFTRA
BM

Bernard Marantelli

Founder · iBankroll · White Swan Data · Colossus Bets
Vehicle
iBankroll · "Bankroll-as-a-Service"
Public partnership
Gamblr ↔ iBankroll · ~Sep 2025 (Fenney reposted)
Group
White Swan Data · Colossus Bets (UK)
iBankroll's own announcement (Fenney reposted, ~Sep 2025): "Powered by iBankroll's Bankroll-as-a-Service, Gamblr can now take high-stakes VIP action — with the bankroll risk on us… bigger limits, guaranteed payouts."
  • Gamblr's bankroll provider — iBankroll publicly took the underwriting risk for Gamblr customer payouts. The "we can't pay" defence on your $1.4M directly contradicts the "guaranteed payouts" public promise
  • Fenney's repost = FRE 801(d)(2)(B) adoptive admission — same evidentiary status as if Fenney had written it himself
  • Subpoena target: iBankroll's bankroll-allocation records covering Gamblr's May–Jun 2025 VIP cohort, including the line item that financed your deposit-acceptance and would have funded your winning payout
  • § 1962(d) RICO co-conspirator candidate — bankroll provider for the same enterprise that captured 192+ documented victims through the same VIP-trap mechanic
iBankroll LinkedIn page (Fenney repost · FRE 801(d)(2)(B)) · UK Companies House (White Swan Data · Colossus Bets)
A.5 · Heath's UBO chain

The corporate layers between Heath and the operators — top to bottom.

Heath at the apex. Below him, three tiers of insulation: his personal vehicles, the Guernsey holding layer, and the Estonian/UK operating entities. Plus the spoliation cluster running parallel — the recent restructuring he hopes will keep him at arm's length. Every box below is verified via primary registry; every registration number is included.

Tim Heath
Apex · the individual
Timothy John Heath
Australian · DOB 20 May 1978 · Estonian Person ID 37805200067 · Tallinn → UAE-resident
Owns / controls
Tier 1Heath's personal vehicles · direct equity or UBO
EE
Piangil OÜ
EE 11533886
100% Heath
Sole director · holds 15.93% of Stacey OÜ (Heath personal-vehicle equity in the spoliation cluster)
e-Äriregister · Stacey cap table 17 Jun 2025
EE
Yolo Tech OÜ
EE 14609414
~70.5% Heath
Piller 18% · Pärt + Kard + Purga + Tiitsaar (small). Owns 100% of Heathmont OÜ.
e-Äriregister
EE
Heathmont OÜ
EE 11063972
UBO Heath
Founded 2003 (Heath's eponymous heritage). Board: Maarja Pärt + Reio Piller. Owned 100% by Yolo Tech OÜ.
e-Äriregister
MT
Vereeni Investments Limited
MT C 82096
Heath holdco · 43.41% Stacey
CSP: NOUV MT · 135 Kyle Buildings, St. Julians STJ 1870 — same CSP as Buhagiar's 36N Capital Mgmt
MBR Malta
GB
One.io Group Limited
UK CH 13036457
25–50% Heath PSC
Parent of payment-rail entities · owns One.io UK Limited (FCA FRN 913478)
UK Companies House
Which hold
Tier 2The Guernsey offshore layer · inserted to insulate ownership
GG
Yolo Group Limited
GG-CMP70153
Yolo Group parent holding
Linked to Yolo Investments PCC Ltd Guernsey GFSC 2771881 · the corporate apex of the Yolo Group operating-brand stack
Greg.gg Guernsey
GG
Bombay Holding Ltd
GG #70665 · GREG CMP70665
Owns 100% Bombay Group OÜ
Suite 7, Second Floor, La Plaiderie Chambers, St. Peter Port GY1 1WG · filing 2 Sep 2023 — inserted 7 months BEFORE Heath's Estonian UBO disclosure
Northdata · Greg.gg Guernsey
Which own
Tier 3The operating entities · where Heath's UBO becomes statutory
EE
Bombay Group OÜ
EE 16132057 · DELETION NOTICE
Heath UBO (8 Apr 2024)
Capital €2,500 · Board: Pärt · Piller (since 2023) · Tiitsaar (since 2025) · Owns 100% of Bombay Club & Resort OÜ
e-Äriregister
EE
Bombay Club & Resort OÜ
EE 14045680 · HKT000031
Heath UBO (27 May 2024)
Tallinn land casino · Rataskaevu tn 5, 10123 Tallinn · €1M capital · permits HKL000404 + HKL000494 (EMTA) · 2026 forecast: €16M revenue, −€29M loss · former name Kopikas Entertainment OÜ
e-Äriregister · EMTA · yolo.com login redirect
GB
HM UK Operations Ltd
UK CH 13875602
Heath resigned 6 Nov 2025
Successor: Liis Bolton (Yolo Investments MD) · pattern is internal Yolo restructuring, NOT arms-length transfer
UK Companies House
⚠ Parallel · the spoliation restructure cluster
EE
Stacey OÜ
EE 11057486
€522,737 capital · Suur-Patarei 13 (Yolo HQ)
Cap table: Vereeni 43.41% (Heath holdco) + CSW 35.92% (Piller) + Piangil 15.93% (Heath) + OÜ Rei 4.73%. Founded 2004. UBO narrative: Karl Rei + Tim Heath + Reio Piller. Parent of the Greenbit reactivated shells.
e-Äriregister · cap table 17 Jun 2025
EE
CSW Holding OÜ
EE 12606506
100% Reio Piller · 35.92% Stacey
Piller's central restructure hub · controls 5 of 10 Piller post-Sep-2025 entities (Ghost Performance, Reimar Solutions, RPT Holding 95.27%, Ghost Events 80%, Volton Group 47.62%)
e-Äriregister · Inforegister
A.6 · Operating brands & B2B suppliers

What you saw — and what was running underneath it.

Top tier: the brand on your screen. Below that: Hub88, the aggregator that pipes content to 300+ operators including yours. Bottom tier: the suppliers Heath personally owns or invests in. Every Heath-orbit brand draws from the same supplier base — meaning the same Heath-controlled infrastructure ran on your Gamblr.io session as on Sportsbet.io, Bitcasino.io, and the others.

Tier 1What you saw — the consumer brand
Tier 3What was actually running
Direct on site
Heath owns hub
Heath sole director
KM
Gamblr.io
★ Took your $1.4M
Anjouan #15938 · ALSI-202503019-FI1
Operator: Gamblr Gaming Ltd. Heath named founder Gareth Fenney (13-yr corporate lawyer · Skadden · A&O Moscow · Carey Olsen BVI · exited Dec 2025) to you 9 Nov 2025. On 8 Dec 2025 the Comoros Central Bank declared all Anjouan licences fraudulent.
Anjouan register · BCC Communiqué
CW
Sportsbet.io
Yolo flagship
mBet Solutions NV · CW #129230
Yolo's flagship sportsbook, launched 10 Jun 2016. Built into a high-visibility brand via shirt deals with Arsenal · Watford · Southampton · Newcastle, Brazil's Flamengo, and LALIGA. Lost UK access 8–15 May 2025 when its UK operator (TGP Europe) was forced out by the UK gambling regulator.
Yolo LinkedIn · CW filings
CW
Bitcasino.io
Yolo flagship
Moon Technologies B.V. · CW #152185
Yolo's crypto-only casino — self-described as "the world's first licensed crypto-led online casino." Pays affiliates up to 45% of what their referred players lose (a "revenue-share" deal). That's the channel that paid Jeff Gross $34K from Colin Harris's losses — the same affiliate-recruitment mechanism that brings high-rollers into the network.
bitcasino.io T&C · partners.io
KM
Empire.io
Anjouan operator
Pixel Entertainment · ALSI-132405042-FI3
Operator-shuffle: Moon Tech (Jan 2022) → Echo NV (Oct 2022) → Pixel Entertainment on the same Anjouan framework as Gamblr (Nov 2024). Payments ran through Block Technology Malta — the same intra-group processor used on Heath's other brands.
Anjouan register · Wayback
CW
Livecasino.io
Yolo live-dealer brand
Curaçao operator
Yolo's live-dealer brand — pitched as a "luxury-first live gaming experience." Pays affiliates up to 45% of player losses. The live-dealer streams come from Live88, which runs on the same OT Malta Ltd licence Heath sole-directs.
livecasino.io · partners.io
CR
Bombay.vip
Heath direct B2C
CR 3-102-936594 · ALSI-202508023-FI1
Heath's newest direct-to-consumer brand — launched Aug 2025. Too new for public complaints yet. The Costa Rica + Anjouan dual structure mirrors Gamblr's exact playbook.
CR filings · Anjouan register
Hub88est. ~Jul–Aug 2017 · UAE B2B licence 2025
The single pipe distributing Heath-supplied content to every brand above + 300+ third-party operators. Heath, 9 Nov 2025: "(I know they use hub88)" — explicit admission Gamblr routes through Hub88.
300+
Operators
140+
Suppliers
Tim Heath
Apex · UBO
Tim Heath
Yolo founder · sole director, OT Malta Ltd · Hub88 owned via Yolo Investments Fund I
EE
Spribe OÜ (Aviator)
Direct on Gamblr — verified in HTML
EE Reg 14540763 · €2,500 · 1 Sep 2023
Owner: David Natroshvili — Georgia's ex-First Deputy Minister of Economy (2006–07). UK gambling regulator pulled Spribe's UK licence Oct 2025, reinstated five months later. Separately, a $330M Georgian court judgment against him personally (Aug 2024, affirmed by Georgia's Supreme Court May 2025) is still live — both regulator and creditor pressure are open right now.
EE Business Register · gamblr.io HTML · UKGC
MT
OT Malta Ltd (OneTouch + Live88)
★ Heath SOLE director
MT C88843 · MGA/B2B/641/2018 (29 Aug 2019)
One Maltese company makes both the OneTouch slot games and the Live88 live-dealer streams you saw on Gamblr. Based in Sliema, Malta. The only shareholder is OneTouch Technology Ltd (Isle of Man) — and Heath has been a director of that parent since June 2016. Live-dealer studios sit in Tallinn and Abu Dhabi.
MBR Malta · MGA Register · live88.io
EE
Odds88
Yolo Investments Fund I
"Sportsbook content + risk management"
Yolo's own sports-betting software — sets the odds and manages bookmaker risk behind Sportsbet.io and other gambling sites. Owned through Heath's Yolo Investments Fund I. Shortlisted at the EGR B2B Awards 2025 for sports-betting innovation.
yolo.io portfolio · Yolo LinkedIn
Content flow (operator ↔ Hub88)
Aggregation (supplier → Hub88)
Heath ownership / sole-director
Direct integration (Spribe → Gamblr)

When you pressed bet on Aviator, your wager travelled Spribe → Hub88 → Gamblr Gaming Ltd. When you played a slot, it travelled OT Malta C88843 (Heath sole director) → Hub88 → Gamblr Gaming Ltd. Heath cannot say "I have nothing to do with Gamblr" while owning the supplier that ran every game on your screen.

A.7 · Payment infrastructure

Every dollar passed through one of these — and each has a regulator who can freeze it.

These are the pipes Heath's enterprise built to move money — your $2M deposit, your $2M winnings, your $1.38M reclassified balance. The FCA-licensed payment institution, the captive Maltese orchestrator, the UAE shell with no licensing, the Estonian crypto-fiat gateway, and the brand-new UK successor vehicle. Every entity is registered (or visibly unregistered) — which means each has a regulator that can freeze operations, named individuals who have to defend their licenses, and an audit trail your counsel can subpoena.

$1.4Myour money
Your $2M deposit, your $2M winnings, your $1.38M reclassified balance — all moved through one of the six rails below. Each rail is regulator-controlled. Pressure any one of them and Heath's network loses a pipe.
▶ ▶ ▶
GBOne.io UK Limited
UK · FCA Authorised Payment Institution
CH 12040686 · FRN 913478
FCA
Reg 26
fitness
★ Likely your money
The only FCA-regulated bank Heath owns — built specifically to bank Yolo because no high-street bank would. Sommer · Walker-Morecroft · Overo all signed attestations covering your transactions.
MTBlock Technology Ltd
Malta · captive intra-group payment orchestrator
MT C81495 · NOUV-serviced
MFSA
Unlicensed
processor
★ Likely your money
Empire.io's own Jan 2022 site code names this entity as its payment processor — and the same engine almost certainly booked your Gamblr.io deposits. Has no standalone MFSA licence, yet processes for 10+ Heath brands.
AEFinVerse Labs FZ-LLC
UAE RAKEZ · Open Wallet / Pay.io
RAKEZ #0000004030448
VARA
No licence
anywhere
Alternative rail
Co-founded by Heath's own employee Mitul Manish (Yolo iOS Tech Lead). Markets crypto-to-IBAN to EU and UK customers with zero licences. Naming it as a co-conspirator triggers VARA + FCA + MiCA simultaneously.
EESwapin / UNGARO OÜ
Estonia · crypto-fiat payment gateway
EE 14562753 · FIU FVT000088
FIU EE
Sunsets
1 Jul 2026
Alternative rail
Heath's UAE arm YOLO ME FZ-LLC holds 9.44% directly. Estonian VASP licence expires 1 Jul 2026 — Heath's involvement becomes a fitness factor in the renewal review.
GBCrissCross FX UK Limited
UK · successor to One.io (not yet authorised)
CH 16713961
FCA
Pre-auth
objection
Successor — not active
Incorporated 10 days after Yolo Investments OÜ was deleted. Heath's MLRO Walker-Morecroft installed Jan 2026; original clean founders resigned days later. Spoliation pattern by itself.
USCoinflow
Delaware US · Yolo Fund II portfolio
"Tech-driven payments solutions"
FRCP
US discovery
direct
Portfolio — US nexus
US-domiciled Yolo portfolio company = Florida long-arm jurisdiction over Heath personally (F.S.A. § 48.193). Subpoena reachable under FRCP without Hague Service — fastest path into Yolo's capital flows.
Solid red — your money likely flowed here (2 of 6)
Dashed orange — alternative rail Heath could have used (2 of 6)
Dotted grey — successor or portfolio (not active for your case, still leverage)
A.8 · Investment vehicles & spoliation entities

Where the Heath capital pools sit — and what got wound down during your dispute.

All license surrender / deletion / shell-rotation events below post-date the May 2025 Silverman dispute opening. Each is a separate FRCP 37(e) preservation-of-evidence data point.

World map (NASA equirectangular projection) TIM HEATH UBO BVI · 1 entity 8 1 2 GUERNSEY · 2 entities (1 dissolved) ISLE OF MAN · 2 entities (1 dissolved) 5 6 4 9 ESTONIA · 2 entities (both dissolved) MALTA · 1 entity 7 ADGM · 1 entity 3
1
Yolo Investments PCC
Guernsey · licence surrendered 17 Feb 2026
2
Yolo Fund II LP
Guernsey · €100M closed · 1.36× TVPI
3
Yolo Fund III
ADGM Abu Dhabi · $500M target — needs to close
4
Yolo Investments OÜ
Estonia · deleted 2 Sep 2025 (Maarja Pärt liquidator)
5
TGP Europe
Isle of Man · collapsed 15 May 2025 (£3.3M UKGC)
6
Apricot Investments (ex-Microgaming)
Isle of Man · Mark Robinson PML pathway
7
36N Capital Mgmt
Malta · Buhagiar UBO · Paradise Papers
8
Luckbox Enterprises
BVI · Pandora Papers · Piller UBO
9
PIIPA OÜ
Estonia · deletion notice (Magnus Nugis exit vehicle)
Red — Heath sits on the board (personally liable)
Orange — Yolo Investments portfolio holding
Blue — Heath introduced / brought in
Dashed — wound down during your dispute (4 of 9)
1
GG
Yolo Investments PCC Limited
Guernsey · LICENSE SURRENDERED 17 Feb 2026
GFSC 2771881 · GREG CMP70144 · LEI 254900YKQG9HM7AR8121
Status
Underlying entity Active · investment-business license SURRENDERED
Address
First Floor, St Peter's House, Le Bordage, St Peter Port GY1 1BR
Administrator
Imperium Fund Services Limited
Director
Liis Bolton (also Yolo Investments MD + HM UK Operations successor)
Holds
7 EE OÜ participations (eAgronom, eCartic, Heathmont Travel, 7 Figures, RadiusTech, Narrativa, Hxgn) + Maltese + Gibraltar entities
Source: GFSC public register · Northdata · Greg.gg (cert expired)
2
GG
Yolo Fund II LP
Guernsey LP (separate from PCC)
GFSC 2958448
Vintage
2024 · €100M closed
TVPI
1.36x as of 31 Dec 2025
DPI
0.05x
First exit
CoinMENA (acquired by Paribu, up to $240M)
Heath personal contribution
€50M
Source: Heath's own LinkedIn 14 Apr 2026 + Substack
3
AE
Yolo Fund III
ADGM Abu Dhabi · in-principle approval
$500M target
Heath disclosure
"pleased to announce Fund III which will be domiciled in ADGM, in Abu Dhabi"
Pressure motive
NEED Fund III to close — financial pressure to settle the Silverman dispute fast
Source: Heath LinkedIn late January 2026 announcement
4
EE
Yolo Investments OÜ
Estonia · DELETED 2 Sept 2025
EE 14972698
Deletion date
2 Sep 2025 · 4 mos into Silverman dispute
Liquidator
Maarja Pärt
Material
Any contract referencing this entity post-Sep 2025 = unenforceable against deleted entity
Source: e-Äriregister liquidator filing
5
IM
TGP Europe Limited
Isle of Man · COLLAPSED 15 May 2025
IM 122698C · UKGC 39073-R-319434-028
UKGC enforcement
£3.3M penalty 15 May 2025 · ALL 15 white-label licenses surrendered (incl. Sportsbet.io)
Cited
AML / business-partner due-diligence failures
Address
22A Castle Street, Douglas IoM
Owner
TGP Holdings (Sun City Group per 6 Aug 2014 SBTech press release)
Directors
Garth Kimber + Jason Jennings + Charles Hwang
Source: UKGC Public Register · Josimar 14 Mar 2023 · SBTech PRNewswire
6
IM
Apricot Investments Ltd (ex-Microgaming)
IoM · Mark Robinson PML pathway
UKGC #39073 · 039073-R-319434-028
Address
Third Floor, Evergreen House, 43 Circular Road, Douglas IM1 1AO
Licenses
Casino (Remote) eff. 1 Nov 2014 + Gambling Software (Remote) eff. 11 Feb 2015
Rebrand
20 Feb 2025 · Microgaming Software Systems → Apricot Investments
Mark Robinson
Senior Partnerships Manager 2016-2021
Enforcement
Zero documented regulatory actions
Source: UKGC Public Register · SBC News 12 Feb 2025 · Apricot rebrand records
7
MT
36N Capital Management Ltd
Malta · Buhagiar Paradise Papers vehicle
MT C76815
Sole director/shareholder/legal-rep
Julian Buhagiar (Yolo Investments GP)
Incorporated
26 Sep 2016
ICIJ exposure
Paradise Papers Malta corporate registry leak Nov 2017
NOUV CSP
SAME 135 Kyle Buildings address as Heath's Vereeni Investments C82096
NOUV MT Holding
itself a shareholder of 36N (cross-mingling)
Source: ICIJ nodes 55074335 + 56030014 · MBR Malta
8
VG
Luckbox Enterprises Ltd
BVI · Pandora Papers
BVI 2010
UBO
Reio Piller (Yolo co-founder)
Address
Mätta 3 Lagedi Estonia (= Piller's RPT Holding + Ghost Events 2026 entity address)
Material
Same address used on new shell entities created during dispute = paper-trail evidence
Source: ICIJ Pandora Papers
9
EE
PIIPA OÜ
Estonia · Magnus Nugis exit vehicle
EE 17002836 · DELETION NOTICE
Incorporated
6 Jun 2024 (3 mos before Yolo restructure)
Capital
€2,500
Sole board
Magnus Nugis (50%)
Co-shareholder
Diana Tamme (50%, KPMG Baltics, cohabitant)
Address
Aasamäe tn 9-4, Ääsmäe küla (residential)
Annual reports
NONE filed
EMTAK
66199 financial services auxiliary
Source: e-Äriregister · Inforegister
A.9 · Sources & methodology

How every fact in this deck was verified.

No claim is unsourced. Every entity registration is from a primary government registry. Every quote is from a captured screenshot or email. Every cross-link is verified against at least two independent records.

Primary Public Registries
  • Estonian e-Äriregister · ariregister.rik.ee · all OÜ entities + Person IDs
  • Inforegister · inforegister.ee · backup + UBO narratives
  • UK Companies House · find-and-update.company-information.service.gov.uk · all UK CH
  • Malta Business Registry · findcompany.mbr.mt · all C-numbered entities
  • Greg.gg Guernsey + Northdata GREG · all Guernsey #
  • IoM Companies Registry · companiesregistry.gov.im · all IoM #C
  • RAKEZ UAE · for free-zone entities
  • Anjouan Public License Register · ALSI- license numbers
  • Curaçao Antillephone licensee list
Regulator Registers
  • FCA Register · register.fca.org.uk · One.io UK FRN 913478 + SMF holders
  • UKGC Public Register · gamblingcommission.gov.uk/public-register · operator + PML
  • MGA Public Register · authorisation.mga.org.mt · OT Malta MGA/B2B/641/2018
  • FIU Estonia · fiu.ee · VASP authorizations (Swapin FVT000088)
  • EMTA Estonia · gambling licenses (Bombay Club HKT/HKL)
  • BCC Comoros Communiqué 8 Dec 2025 · Anjouan licenses "frauduleuses"
  • Spelinspektionen Sweden · Betsson AML strike list since Jun 2025
Investigative & Leak Sources
  • ICIJ Offshore Leaks · offshoreleaks.icij.org · Pandora + Paradise + Panama + Bahamas
  • Josimar.no (Andrew Auclair) 14 Mar 2023 + 4 Oct 2021 · TGP/SunCity
  • 6 Aug 2014 SBTech PRNewswire · TGP/SunCity ownership admission
  • Heath's own LinkedIn · FRE 801(d)(2)(A) party-opponent admissions
  • Yolo Group LinkedIn page · FRE 801(d)(2)(D) corporate admissions
  • Jeff Gross 12-screenshot Telegram archive · IMG_5099 → IMG_5116
  • Whistleblower email chain Jan 20-23 2026 · $1.38M reclassification
  • Jeff Gross attorney-intake response · 19 Dec 2025 to Andrew Harvey
  • Casino.Guru / AskGamblers / Sikayetvar · 192+ victim complaints

Cross-validation methodology

Every entity claim is verified across at least two independent registries (e.g., MBR Malta + MGA Public Register for OT Malta Ltd C88843 / MGA/B2B/641/2018). Every individual identification is verified across at least two of: official register UBO disclosure · Companies House officer record · FCA Register · UKGC PML self-tag · LinkedIn party-opponent admission · ICIJ leak record. Every Heath verbatim quote is timestamped to an IMG_##### Telegram screenshot in the case file. Three confirmed corrections during research (Yolo Group SARL/sro/Italy refutation, Andri Talts vs Evald-Hannes Kree Swapin co-founder, Auclair Josimar 14 Mar 2023 not 4 Oct 2021) demonstrate the cross-validation discipline.

Full case-file (master network map · draft federal complaint · 78 source-cited sub-dossiers) available to counsel on request.
Silverman v. Heath / Gamblr.io / Yolo Group · Evidence-Based Reconstruction Privileged & Confidential
Patented.aiPrepared by Patented.ai 1 / 20