EM Group under scrutiny in online gambling disputes

EM Group’s role in online gambling disputes draws attention!

Editorial note. This article is based on public court documents, company registry filings and media reporting. No allegation of fraud or criminal conduct is made by us. The purpose is to highlight how corporate service providers can become involved in disputes and regulatory debates when they act as directors or administrators in the gambling sector.

The Frankfurt injunction proceedings

On 4 September 2025 the Regional Court of Frankfurt confirmed an injunction against a former player who had attempted to recover gambling losses by threatening to publish negative material about EM Group, also known as eMoore N.V.

The case concerned the online casino 1bet, operated by Bellona N.V., during a period when EM Group acted in a director capacity.

The judgment made two things clear. First, the player was prohibited from accusing EM Group of fraud or “betrügerische Praktiken” (fraudulent practices), as such statements were deemed unproven allegations of a criminal offence. Second, the use of threats to publish information in order to obtain repayment was considered an unlawful interference with EM Group’s business.

What the court did not address was whether 1bet had complied with the German Glücksspielstaatsvertrag, including obligations on OASIS self-exclusion, the €1,000 deposit cap and AML/KYC requirements. These compliance issues were raised in correspondence but treated as outside the scope of the injunction.

The outcome was that EM Group obtained protection against reputational harm in Germany, while wider regulatory questions remain unresolved.

Beyond a trustee role

Documents filed in connection with the case record that EM Group’s role was not confined to providing a registered office. The company was referenced in correspondence with players, responding to complaints not only for 1bet but also in connection with brands such as Mandarin Gaming.

Legal submissions stated that EM Group was involved in handling claims, forwarding correspondence and, in some instances, disputing complaints.

This indicates a broader point. If a corporate service provider undertakes complaint handling, management oversight or communication with players, it may be viewed as acting in an administrative capacity that extends beyond neutral trustee functions.

Regulators in Germany, the Netherlands and Malta are increasingly sensitive to such distinctions, particularly where operators target their markets without local licences.

The Curaçao Chronicle report

A comparable account appeared in the Curaçao Chronicle on 15 July 2025. The article described a dispute at Wonder Casino where a customer raised concerns over a failed bank transfer. According to the Chronicle, EM Group staff and legal representatives were included in the exchanges and were alleged to have instructed operational steps such as account freezes.

The article did not make findings of fact but observed that the case highlighted questions about how entities under provisional licences in Curaçao handle player complaints and the extent to which corporate service providers may be perceived as part of the operational chain.

EU proceedings in Luxembourg

There is also a connection to Case C-440/23 before the Court of Justice of the European Union. The reference concerns Deutsche Lotto- und Sportwetten Limited and European Lotto Betting Limited, both Maltese-incorporated companies. Public records show that EM Group provides the registered office for these entities.

The case itself concerns the compatibility of national restrictions on lottery betting with EU law. Irrespective of the eventual ruling, the fact that EM Group is linked to litigants before the Court of Justice illustrates how administrative services can extend to companies involved in sensitive regulatory areas.

Malta registry compliance

Malta Business Registry filings further highlight reporting gaps for the same two companies:

• Deutsche Lotto- und Sportwetten Limited (C 90866), incorporated on 28 February 2019, has not filed accounts since incorporation.
• European Lotto Betting Limited (C 84690), incorporated on 31 January 2018, last filed accounts for the year 2021, with no subsequent filings.

Failure to file accounts is not evidence of wrongdoing, but it does represent a compliance shortfall that can attract penalties and raises questions of transparency, particularly when companies are involved in ongoing proceedings before the CJEU and one of them holds a Malta Gaming Authority licence.

Final Thoughts and Conclusion

The Frankfurt injunction addressed a narrow legal point: a player may not describe EM Group as engaging in fraud without proof, nor apply pressure by threatening to publicise negative material. The court protected EM Group’s reputation against unsubstantiated criminal accusations and coercive tactics.

However, the documentation filed in that case also illustrates how EM Group has featured in roles that went beyond a purely passive trustee function.

The company acted as director of Bellona N.V., operator of the casino 1bet, during the relevant period. It also appeared as a point of contact for complaints, including through an email address designated for grievances.

Case exhibits referenced EM Group in connection with Mandarin Gaming, where players were instructed to send complaints directly to the company. These details indicate involvement in correspondence and customer interaction.

The counterclaim filings further noted that EM Group provided guidance in disputes, instructed legal representation on behalf of operating companies and was included in correspondence with players and regulators. If taken at face value, these activities align more with administrative oversight than detached corporate services.

Regulators have increasingly focused on such overlaps, particularly where companies without national licences accept customers in Germany, the Netherlands or Malta.

The Curaçao Chronicle has already published a parallel account involving Wonder Casino, where EM Group staff was reported to have engaged in communications over disputed transactions. That case reinforced the perception that EM Group may play a role beyond simply providing a registered office.

Further, proceedings before the Court of Justice of the European Union involve two Maltese companies for which EM Group provides registered offices. While the litigation concerns lottery betting and EU law, the Malta Business Registry indicates compliance gaps in corporate filings.

These omissions do not establish wrongdoing but highlight transparency concerns for companies connected to ongoing EU litigation.

The narrowing space for neutral trusteeship

Taken together, these matters show EM Group present in several sensitive contexts: civil litigation in Frankfurt, customer complaints in Curaçao, registry filings in Malta and European litigation in Luxembourg.

Each setting is distinct, but collectively they suggest EM Group’s services intersect with areas of operational, legal and reputational significance.

For regulators, the question is whether such activities fall inside or outside the perimeter of supervision. Handling complaints, instructing lawyers, overseeing payments and acting as a visible point of contact may place a trustee closer to the operational chain.

In a sector where licensing rules, AML obligations and data protection standards are tightly defined, the boundary between neutral administration and active involvement becomes increasingly important.

FAQs

What was the Frankfurt injunction against EM Group about?
The injunction prohibited a player from accusing EM Group of fraud or using threats to recover gambling losses, protecting the company’s reputation.

Did the court rule on 1bet’s compliance with German gambling laws?
No, the court did not address 1bet’s compliance with the Glücksspielstaatsvertrag, including deposit limits or AML/KYC obligations.

What role did EM Group play beyond providing a registered office?
EM Group handled complaints, communicated with players, and oversaw administrative matters for casinos like 1bet and Mandarin Gaming.

Why are regulators concerned about corporate service providers like EM Group?
Regulators monitor whether trustees’ roles extend into operational oversight, especially in markets without local licences.

What happened at Wonder Casino according to the Curaçao Chronicle?
A player dispute over a failed bank transfer involved EM Group staff, illustrating potential administrative involvement in operations.

Which EU case involves companies linked to EM Group?
Case C-440/23 concerns Deutsche Lotto- und Sportwetten Limited and European Lotto Betting Limited, with EM Group providing registered offices.

Do Malta registry filings show compliance issues for companies linked to EM Group?
Yes, some filings show missing accounts and reporting gaps, which raise transparency concerns but do not imply wrongdoing.

Does involvement in complaints mean EM Group engaged in illegal activity?
No, handling complaints or providing administrative support is not illegal, but it can blur the line between neutral trustee and operational role.

How do regulators view the boundary between trustee services and active involvement?
Activities like instructing legal representation, overseeing payments, or communicating with players may be seen as administrative, attracting regulatory scrutiny.

What is the overall implication of EM Group’s involvement in these cases?
EM Group’s presence in multiple legal and regulatory contexts highlights how corporate service providers can be drawn into operational and reputational matters in online gambling.

Sources

• Landgericht Frankfurt am Main, Urteil vom 09.2025, Az. 2-12 O 137/25.
• Curaçao Chronicle, “Accusations of Fraud Surface Against Online Casino and EM Group” (15 July 2025), available at: Curaçao Chronicle.
• Case C-440/23, Deutsche Lotto- und Sportwetten Limited and European Lotto Betting Limited, Court of Justice of the European Union (pending).
• Malta Business Registry, company records for C 90866 and C 84690: MBR
• Documents filed in the Frankfurt proceedings (counterclaim and exhibits), including references to EM Group complaint handling for brands such as Mandarin Gaming.

Legal Disclaimer

This article is based solely on publicly available court documents, company registry filings and media reporting. It is intended for informational and editorial purposes only. No allegation of fraud, criminal conduct or regulatory breach is made by the authors. References to EM Group, eMoore N.V. or any associated entities are limited to their appearance in public records or reporting. Any descriptions of involvement in disputes or regulatory matters reflect the content of those records and do not constitute findings of fact by Malta Media or its authors. Readers should not interpret this article as suggesting any unlawful activity by EM Group or its affiliates.