Löwen Play, Lionline Entertainment and Associated Companies

This detailed investigation looks into the operations, corporate structure and regulatory practices of Löwen Play GmbH, Löwen Play Digital GmbH and Lionline Entertainment GmbH & Co. KG, alongside other affiliated companies in the gambling and financial services sectors. Based on newly obtained information and recent exchanges with representatives of Löwen Play, this report explores potential regulatory irregularities, questions of transparency and implications for public interest. Our aim is to provide a clear, fact-based analysis that raises awareness of the operational and legal practices of these entities.

Background: Corporate Structure and Associated Entities

Löwen Play GmbH , a dominant player in Germany’s gambling market, operates both physical and digital gambling platforms. Under the management of CEO Tilman Brauch and Dr. Stefan Schwenkedel who serves as both the Chief Financial Officer (CFO) and Managing Director, Löwen Play has built a broad presence within the industry. However, its association with Lionline Entertainment GmbH & Co. KG, a company officially dissolved on March 16, 2023, raises pressing questions about Löwen Play’s corporate governance and compliance practices.

Lionline Entertainment GmbH & Co. KG: Dissolution and “Anwachsung”

According to Löwen Play’s response to Malta Media dated October 24, 2024, the Lionline Entertainment GmbH & Co. KG was not dissolved in the conventional sense but underwent a process of “Anwachsung” within the Löwen Play Group. This legal procedure allowed Lionline’s business assets and activities to be transferred to another entity within Löwen Play, allegedly ceasing its independent operations. However, despite these claims, Lionline’s online presence continued well beyond the dissolution date. Specifically, the company’s website, www.lionline.de, remained accessible until October 25, 2024—the day after our initial inquiry with Löwen Play. The immediate website deactivation following our outreach suggests that concerns over Lionline’s ongoing activities may indeed have merit.

Directors Listed After Dissolution

Another notable aspect is the listing of Lionline’s three managing directors— @Tilman Brauch, @Dr. Stefan Schwenkedel and Paul Kase —on the company’s website imprint as of October 2024. This is particularly striking as Lionline had been dissolved for 17 months by this time. Löwen Play’s characterization of @Lionline as a dormant entity contrasts with the continued online listing of its directors and the company's delayed deactivation. This discrepancy raises concerns about corporate responsibility in keeping public information accurate and up-to-date, potentially misleading stakeholders about Lionline’s true operational status.

Response from Löwen Play: Transparency and Compliance Issues

Following Löwen Play’s initial response, we submitted a follow-up inquiry on October 25, 2024, seeking clarity on various points related to Löwen Play’s internal control and compliance structures. Specifically, we raised questions about Löwen Play’s frequent use of corporate restructuring mechanisms, such as “Anwachsungen,” and whether these practices align with regulatory requirements. In particular, we queried whether such restructurings were strategic maneuvers or responses to compliance pressures, given recent complaints filed with several regulatory bodies against Löwen Play.

Löwen Play’s representative, Mrs. Klein, limited her responses, refraining from disclosing details about Löwen Play’s compliance measures or internal controls. Moreover, Mrs. Klein advised that inquiries about former employees, including Paul Kase and @Lukas Kurzawa, should be directed to these individuals personally, distancing Löwen Play from questions regarding its former executives. This stance restricts the depth of our investigation and raises concerns about Löwen Play’s transparency in addressing questions directly related to its own operational integrity.

Regulatory Investigations: BaFin, GGL and Other Authorities

Our investigation uncovered multiple complaints filed against Löwen Play and Lionline with German regulatory and enforcement agencies, including BaFin, Gemeinsame Glücksspielbehörde der Länder (GGL), the Zollamt, Finanzamt, Agentur für Arbeit (Job Center) and Hauptzollamt (Main Customs Office). These complaints address a range of issues, including alleged unlicensed gambling operations, unauthorized payment processing, potential tax evasion and social security violations.

GGL Investigations

The GGL has initiated inquiries into Löwen Play Digital GmbH and Lionline Entertainment GmbH & Co. KG in response to complaints alleging potential breaches of the Glücksspielstaatsvertrag (GlüStV 2021). Each case is associated with a specific GGL reference number, underscoring the thoroughness of the regulatory review:

• Lionline Entertainment GmbH & Co. KG – GGL Case Reference: 2f42c
• Löwen Play Digital GmbH – GGL Case Reference: 2f49d

These investigations focus on several key provisions of the GlüStV 2021, including:

• § 4 GlüStV: Restricting the offer of public gambling without proper licensing.
• § 22a GlüStV: Establishing licensing requirements for virtual slot games, a category under which Lionline’s services may fall.
• § 5 GlüStV: Prohibiting the advertising of unauthorized gambling services.

These provisions are designed to safeguard the public interest and regulate gambling services offered in Germany. Given Löwen Play’s sizable market influence, any irregularities could significantly impact industry standards and consumer protection.

BaFin Investigation

BaFin’s inquiry primarily targets Lionline’s LionCage payment system, examining whether the system operated in compliance with the Zahlungsdiensteaufsichtsgesetz (ZAG), which mandates BaFin authorization for payment services. Under § 10 ZAG, the provision of financial services without proper licensing constitutes a regulatory breach and BaFin has been tasked with determining whether LionCage adhered to this requirement.

BaFin Case Reference:

• HGS-QB 9100/00046#00932

Escalation of Tax Inquiry to Finanzamt Mainz

A complaint initially filed with the Finanzamt Bingen regarding potential tax violations by Lionline Entertainment GmbH & Co. KG has since been transferred to the Finanzamt Mainz – Steuerfahndungs- und Strafsachenstelle. The reassignment signifies the potentially serious nature of the tax issues under investigation. Key areas of concern include:

• Employer Tax Obligations (§ 38 EStG): Whether Löwen Play met its income tax deduction and remittance obligations for employees.
• Tax Evasion (§ 370 AO): Questions about whether Lionline continued generating unreported revenue post-dissolution.
• Improper VAT Use (UStG): The continued display of Lionline’s VAT number on its website post-dissolution raises concerns about potential misuse of VAT declarations.

Other Regulatory and Employment Concerns

The regulatory and employment practices of Löwen Play and its associated entities continue to draw attention, particularly concerning compliance with labor laws and transparency regarding Lionline Entertainment’s operational status post-dissolution. Recent inquiries by German regulatory authorities, including the Hauptzollamt Mainz and the Agentur für Arbeit Mainz, highlight alleged discrepancies in employment reporting and social security compliance.

Moreover, ongoing claims of employment with Lionline Entertainment on professional platforms raise questions about whether operations truly ceased following the company’s official dissolution in 2023. The following sections explore these regulatory concerns and the unusual persistence of employment affiliations with a dissolved entity.

Hauptzollamt Mainz (Main Customs Office)

The Hauptzollamt Mainz is investigating potential breaches of employment and social security regulations by Lionline. This investigation covers multiple statutory requirements, including:

• Schwarzarbeitsbekämpfungsgesetz (Act to Combat Unregistered Work): Addressing concerns that Lionline may have continued operations without properly registered employees.
• Sozialgesetzbuch IV (SGB IV) § 28a: Employer obligations to report employees to social security.
• Einkommensteuergesetz (EStG) § 38: Compliance with tax withholding requirements for employment income.

The Hauptzollamt investigation complements the ongoing inquiries by the Finanzamt, focusing on potential unregistered employment and associated financial violations.

Agentur für Arbeit (Job Center) Mainz

A complaint with the Agentur für Arbeit Mainz raises concerns about possible labor law violations by Lionline Entertainment GmbH & Co. KG. Specific allegations include unregistered employment practices, underreporting of employee numbers and non-compliance with social security obligations under the Schwarzarbeitsbekämpfungsgesetz (SchwarzArbG). These issues have serious implications for the protection of workers' rights and adherence to German labor laws.

Continued Employment Claims Post-Dissolution

Next to the three directors mentioned in the imprint on Lionline.de, in addition to these, the ongoing operational concerns surrounding Lionline Entertainment GmbH & Co. KG, our investigation uncovered an unusual number of employees who, as of October 2024, publicly list themselves as current employees of Lionline on professional networking platforms such as LinkedIn. The LinkedIn profile of Lionline was immediately deleted after our contact. This is particularly noteworthy given Lionline’s official dissolution on March 16, 2023.

 

Among those who still identify as Lionline employees are @Stefan Hauschild, Tayyab Laique , Manuel Rodríguez Larrey, Juan Antonio García, Leonor Cabañas Valle and Miriam Rosa Pérez. Their continued association with Lionline on professional profiles raises further questions about the company’s true operational status post-dissolution. The persistence of these employment claims contrasts with Löwen Play's assertion that Lionline’s operations ceased following the “Anwachsung” process, transferring its business assets and responsibilities to another entity within the Löwen Play Group.

A noteworthy and unexpected development has recently come to light. As evidenced by the attached screenshots, a profile update for Stefan Hauschild dated October 24, 2024, initially listed his position as consistently employed by Lionline Entertainment GmbH. However, a more recent screenshot taken today reflects a revision, now indicating his employment over the last 23 months as with Löwen Play GmbH instead. This alteration raises further questions regarding the representation of employment affiliations within the Löwen Play Group and its subsidiaries.

 

Additionally, Sara K. (identified as @Sara Ilanah Swetlana Klimper-Tykö), referenced in a Süddeutsche Zeitung article, lists a professional history that suggests a strong connection between Lionline and other affiliated entities. After a two-year tenure at Rabbit Entertainment, she transitioned to Löwen Play, where she served as Head of Operations for over three years. While this could be coincidental, such consistent employment overlaps across Löwen Play, Lionline and Rabbit Entertainment raise questions about the continuity of business operations and personnel despite the purported dissolution.

This pattern of continued employment listings not only contradicts Löwen Play's representations of Lionline as a dormant entity but also raises additional questions regarding the clarity of the company’s dissolution process and its actual operational cessation. The implications of these ongoing employment claims may necessitate further scrutiny from regulatory bodies to verify the transparency and legality of Löwen Play’s corporate structuring and personnel practices.

Additional Findings: Broader Corporate Connections

The investigation has expanded to include potential links between Löwen Play, Lionline and other companies, notably @Rabbit Entertainment , Max Gain Media and Tornado Games. Max Gain Media, a Maltese entity I was employed at for around 18 month, appears closely aligned with Löwen Play’s interests. According to corporate records, Max Gain Media Holding Ltd. owns Rabbit Entertainment Holding Ltd., which in turn wholly owns Rabbit Entertain IT Ltd.—the entity holding the German GGL license for gambling platforms like Lapalingo, TigerSpin and Lord Lucky.

Notably, these companies share the same registered address at 14 East Triq TAS-Sliema, M-GZR 1639 Gżira, Malta. This shared address raises questions about the level of independence within the network and suggests possible strategic affiliations across jurisdictions.

Additionally, personnel overlaps between Lionline Entertainment and Max Gain Development highlight potential operational links, as numerous former Lionline employees are now employed at Max Gain Development.

Cross-Company Employment Connections

Our investigation also uncovered a web of connections among employees across affiliated entities, suggesting potential overlaps in personnel between Lionline Entertainment, Löwen Play and other related companies such as Max Gain Media, Tornado Games and Max Gain Development. These connections, spanning various positions and departments, raise questions about the operational independence and strategic alignment within these entities.

One notable connection is Manuel Molina, a professional contact of Sara Ilanah Swetlana Klimper-Tykö (Sara K.), who is herself linked to both Löwen Play and Rabbit Entertainment. Manuel Molina’s association with Sara K., alongside his current role, highlights a potential continuity of professional networks within these interlinked companies. Thaluana Muscat, who held a senior position as Head of Sales at Tornado Games from November 2022 to May 2024 in Malta, further illustrates this overlap. Her recent tenure in the gaming sector within Tornado Games raises the possibility of operational affiliations among these companies, particularly given the overlap in locations and industry focus.

Additionally, we identified Matthew Sciculana, a former software developer at United Remote from April 2021 to May 2022, as another connection within this network. This individual’s professional history aligns with broader industry roles, potentially bridging multiple companies through shared personnel or contract-based relationships.

Further links exist between Lionline Entertainment and Max Gain Development through employees like Roberto J. Muñoz de León, who serves as a backend developer at Max Gain Development in Málaga, Spain. His technical role at Max Gain Development suggests a continuity of technical expertise between the companies, which is noteworthy given that Max Gain Development specializes in online gambling software solutions—a core area for both Löwen Play Digital and its affiliated entities.

Additional individuals associated with Max Gain Development include Carlo Bertoldi González, Toni Villena Jiménez, Jesús Segado Fernández, Daniel Arias, David Rojo Martín and Basilio David Gomez Fernandez. Their positions within Max Gain Development hint at a shared resource or workforce model, particularly across IT and development roles essential to online gambling operations. These employment overlaps, spanning various geographic locations and functional roles, suggest a potential strategy of resource-sharing or personnel mobility across the interconnected entities within this corporate network.

The consistency of these employment links across Lionline Entertainment, Löwen Play, Max Gain and associated entities may warrant further regulatory attention to ensure that the independence and legal standing of each company are maintained and transparent. This pattern, combined with our previous findings on Lionline's continued presence, underscores the complex and potentially interdependent structure of these companies within the broader gaming and financial service sectors.

Trustees and Corporate Service Providers

The roles of ARX Trustees Ltd. and Dr. Luca Zahra Brincat in managing multiple companies within this network have also come under scrutiny. Dr. Zahra Brincat, in particular, is implicated in overseeing strategic decisions across several firms in this network. His involvement, as documented in company records, raises questions about the influence trustees exert over these companies. Should regulatory authorities advance their inquiries, the activities of these trustees may be instrumental in understanding the control structures within this corporate framework.

Remaining Questions and Löwen Play’s Refusal to Respond Further

Despite our detailed follow-up inquiry on October 25, 2024, Löwen Play declined to answer additional questions. Among our inquiries were questions regarding Löwen Play’s compliance and ethics policies, its internal systems for detecting potential regulatory violations and the rationale behind its frequent corporate restructuring activities.

This limited response from Löwen Play constrains our investigation and raises concerns about Löwen Play’s willingness to engage transparently on matters critical to its reputation and regulatory compliance.

Assessing Broader Implications and Continuing the Investigation

This investigation has revealed a complex web of interconnected companies, directors and trustees operating within the gambling and digital services sectors. Löwen Play GmbH, Löwen Play Digital GmbH and Lionline Entertainment GmbH & Co. KG appear intricately linked to other entities, such as Rabbit Entertainment, Max Gain Media and Tornado Games, suggesting an extensive network with potential shared influence and oversight.

The involvement of key figures—Paul Kase, Lukas Kurzawa, Luca Zahra Brincat, Carlo Borg, Philippe Warzee, Tal Zamstein, Sven Jendrzejek, Bülent Kaya and others – indicates that authority and control may extend across multiple companies within this network.

The role of regulatory bodies, including #BaFin, #GGL and other authorities, will be essential to ensuring transparency and accountability within these entities. Any substantiated violations could have substantial repercussions, potentially affecting the validity of licenses and the operational scope of the companies involved. Given the considerable impact of these companies on the gambling industry, public interest calls for a comprehensive understanding of their operations.

Our investigation remains active, as we continue to explore the connections and relationships among these entities. This ongoing work seeks to provide clarity and transparency, contributing to an informed public and supporting regulatory efforts within the gambling sector.

FAQs

What is the focus of the investigation into Löwen Play GmbH and its affiliates?
The investigation examines the operations, corporate structure, and regulatory practices of Löwen Play GmbH, Löwen Play Digital GmbH, and Lionline Entertainment GmbH & Co. KG, raising questions about transparency and compliance.

Who are the key executives of Löwen Play?
The key executives include CEO Tilman Brauch and CFO Dr. Stefan Schwenkedel, who also serves as Managing Director.

What does the term “Anwachsung” mean in this context?
“Anwachsung” refers to a legal procedure through which Lionline's business assets were transferred to another entity within the Löwen Play Group, effectively ceasing its independent operations.

Why was there a discrepancy regarding Lionline's directors after its dissolution?
Despite Lionline being officially dissolved, its managing directors were still listed on the company’s website, raising concerns about corporate governance and transparency.

What are the regulatory bodies involved in investigating Löwen Play?
The investigation involves multiple regulatory bodies, including BaFin, GGL, and the Finanzamt, focusing on various compliance issues.

What specific allegations have been made against Löwen Play?
Allegations include unlicensed gambling operations, unauthorized payment processing, potential tax evasion, and labor law violations.

What are the key provisions of the Glücksspielstaatsvertrag (GlüStV) relevant to Löwen Play's operations?
Key provisions include restrictions on unlicensed public gambling, licensing requirements for virtual slot games, and prohibitions on unauthorized gambling advertising.

What is BaFin's role in the investigation?
BaFin is investigating whether Lionline's LionCage payment system operated in compliance with the German Payment Services Supervision Act (ZAG).

What concerns are raised regarding Löwen Play's employment practices?
Concerns include potential unregistered employment, compliance with tax obligations, and transparency regarding the operational status of Lionline post-dissolution.

What implications do the findings of this investigation have for the gambling industry?
The findings could significantly impact industry standards and consumer protection due to Löwen Play's large market influence and the potential for regulatory breaches.