Lilith Wittmann thinks my Video is a Criminal Threat!

Well, apparently I have now become a potential criminal because Lilith Wittmann doesn't like what I said about her in a video. On Thursday evening, she sent Malta Media an email suggesting that my comments could constitute an implied criminal threat under § 241 of the German Criminal Code. The reason? I talked about personal security, the murder of Daphne Caruana Galizia and the dangers of publishing private residential addresses in an industry where serious money, angry customers and allegations of organised crime are involved.

And then she asked again for my German lawyers' contact details or an address within the European Union where legal documents could be served. I must admit, I almost laughed when I read it, because we have already demonstrated how straightforward it is to file a criminal complaint without knowing somebody's private address. We filed one concerning Wittmann's activities and the Berlin police had absolutely no problem accepting it.

In fact, on 15 October, just hours before Wittmann sent her latest email, we received a detailed questionnaire from a Berlin criminal investigator concerning our complaint. We were asked to explain the allegations, identify the relevant parties and provide further supporting evidence. Not once were we asked to supply her private residential address.

So, if Wittmann genuinely believes I have committed a criminal offence, why doesn't she simply go to the police?

What I actually said in the video, rather than what Wittmann thinks I said

Let us start with what she considers threatening. Her email specifically refers to my comments about Daphne Caruana Galizia's murder, the possible disclosure of her residential address to criminal organisations and my remarks about the consequences of her journalistic activities. Taken together, Wittmann believes these statements could amount to a “konkludente Bedrohung im Sinne des § 241 StGB”, meaning an implied criminal threat under German law.

But what did I say? I explained that I have personally received numerous threats over recent years and have taken security precautions because of them. I have changed residential addresses, installed CCTV, sold my car because I was worried about leaving a potential target for explosives parked outside and become considerably more careful about who approaches my home. These are things I have personally experienced and decisions I have made because I take my safety seriously, not some fantasy I invented to annoy a hacker.

I also made a statement in the video that Wittmann appears to have overlooked: “Nobody should face threats or physical violence for their work, however controversial that work may be.” I said that clearly and it applies to Wittmann just as much as anybody else. Discussing the dangers facing journalists and people working in controversial industries is not the same as threatening to harm somebody. Apparently though, explaining why I take those dangers seriously has now become something Wittmann wants examined under criminal law.

And yes, I also said: “I really do wonder how cut off Ms Wittmann is from the real world.” I stand by that criticism because publishing somebody's name as a company director is one thing, but making their residential address, passport and personal documents available to everybody is something else entirely. I struggle to understand why somebody who has spent so much time investigating the gambling industry appears so dismissive of that distinction.

I have spoken to people who understand the risks in this industry

During SBC Lisbon, I spoke to quite a few people about the Casino Secrets investigation, including the publication of private residential addresses. Some thought Wittmann had completely lost her sense of proportion, while others questioned whether she understood what she was exposing people to. These were conversations with people who know the gambling industry, its ownership structures and the disputes that can arise when substantial amounts of money are involved. Their reactions reinforced the concerns I had already raised in my reporting.

The gambling industry is not some harmless little playground where everybody gets along and nobody ever becomes angry. We are talking about companies handling large sums of money, complicated ownership structures, disputes involving customers and businesses operating across different legal systems. There are people with legitimate grievances, people who have lost money and people who may be willing to behave unlawfully. Does that mean everybody involved in gambling is a criminal? Of course not, and suggesting otherwise would be bloody stupid.

But it does mean that publishing someone's home address deserves serious thought. We have also spoken to a corporate service provider who informed Malta Media that gambling operators had received threats of physical harm, although those reports have not been independently verified. The identity of the people allegedly responsible remains unknown. Still, I cannot see how making sensitive residential information available to practically anybody is supposed to improve the personal safety of the people concerned.

I do not need to invent dangers to explain my position. I have received threats myself and changed the way I live because of them. It is one thing to sit behind a computer and investigate companies, but quite another to deal with the consequences when somebody becomes angry enough to threaten you. And that is exactly what I was talking about in the video, not announcing that I wanted somebody harmed.

The organised crime allegations came from Wittmann herself!

There is also the question of Wittmann's own allegations against the Malta Gaming Authority. She publicly accused the regulator of creating “organized crime enablement schemes”, suggesting that it had enabled structures connected with organised criminal activity. As we explained in our analysis of the Berlin court judgment, the judges protected her right to express those opinions but did not establish that the MGA was working with criminal organisations.

Wittmann has also complained about her private residential address being transmitted to Malta in connection with the Berlin proceedings. Against the background of her own allegations about organised crime, I questioned what might happen if that information eventually reached people connected with the criminal networks she claims exist around parts of the industry. That was a hypothetical question based on her own allegations, not an accusation that the MGA had supplied her address to criminals. I have no evidence that such a transfer occurred.

But I do find the double standard hard to ignore. Wittmann can publicly accuse a regulator of enabling organised crime, yet when I discuss the possible personal security consequences of those same allegations, she considers my comments a potential criminal threat. She can talk about organised crime, but I apparently cannot discuss what the involvement of organised criminals might mean for personal safety? That makes absolutely no sense to me.

What the Berlin police have confirmed?

On 6 October 2026, Malta Media filed a criminal complaint through the Berlin Police Internetwache concerning access to the Malta Gaming Authority and Curaçao Gaming Authority systems and the subsequent publication of sensitive personal documents. The complaint was registered under reference 261006-1329-i00337. A separate Cybercrime submission was made to the Berlin Landeskriminalamt, where LKA 724 ZAC confirmed on 8 October that an investigation had been initiated under reference 261008-1252-168724. The precise procedural relationship between those two references has not yet been confirmed.

Separate written submissions were also made by Malta Media to the Staatsanwaltschaft Berlin and Generalstaatsanwaltschaft Berlin on 6 October. LKA 724 ZAC stated that its investigation file would be forwarded to the public prosecutor for legal assessment. At the time of writing, Malta Media has not received confirmation of a separate prosecutorial case number.

On 15 October 2026, a criminal investigator from Landeskriminalamt Berlin, LKA 244, contacted Malta Media concerning the original Internetwache complaint. The email explicitly stated: “Sie sind Zeuge in einem Strafverfahren”, meaning that I am a witness in criminal proceedings. It also contained a detailed questionnaire requesting clarification of the allegations, the parties potentially affected, the information published and the reasons for identifying Wittmann in connection with the Casino Secrets project.

The investigator asked us to explain the relationship between Malta Media and the two gaming authorities, the background to the reported system access and the Berlin connection. We responded on 15 October, providing a detailed explanation and additional documentary references. These included the Berlin court judgment, information supplied by the Curaçao Gaming Authority and specific examples of personal documents found in the publicly accessible Curaçao Files archive.

Seven documents from a single company archive were identified as supporting evidence. They included a certified passport copy, two bank reference letters containing financial information, a telecommunications bill showing a private address, a birth register extract, a residential registration document and a shareholder certificate containing personal address details. Each document was identified by its online location so the police could examine the material independently.

The police also asked why Berlin was relevant to the complaint. Malta Media referred to the judgment of the Landgericht Berlin II, which records Wittmann's residence in Berlin, alongside public information connecting her with the Casino Secrets investigation. The investigator did not request Wittmann's precise residential address.

These are the procedural developments confirmed by the correspondence. They establish that the complaint has been accepted and followed up by police investigators, but they do not amount to a finding of criminal guilt against Wittmann.

So why doesn't Wittmann simply do the same?

Now that we have established what happened with the police, let us return to Wittmann's latest email. We filed a criminal complaint concerning her activities without mentioning where she lives and the Berlin police were perfectly capable of handling it. We identified the person involved, explained our concerns and provided the information available to us. The authorities subsequently contacted us because they wanted more details, which we supplied.

Surely Wittmann, who has spent years investigating public institutions and digital systems, can work out how to submit a video and an email exchange to the police. It really should not require me to explain the process and it certainly should not require me to employ a German lawyer simply because she wants to send me legal correspondence. If she believes the video constitutes a threat under § 241 StGB, she can submit the recording and ask investigators to examine it.

I would have no problem with investigators reviewing every word I said, including my comments about threats I have personally received and my concerns about the disclosure of residential addresses. They would also hear my statement that nobody should face physical violence for their work. I would much rather see the complete recording examined than another exchange of increasingly sarcastic emails.

Apparently, Malta Media having gambling advertisers is now suspicious

There was another sentence in Wittmann's email that made me laugh. She explained that, when assessing my supposed threat, she also considered my publicly recognisable connections to the gambling industry, including the companies presented on the Malta Media website. In German, she referred to “Ihre öffentlich erkennbaren Verbindungen zur Glücksspielindustrie”, apparently believing that our commercial relationships were relevant to her allegation. I had to read that twice because I genuinely wondered what she thought she had discovered.

A specialist gambling publication has advertisers from the gambling industry. Well, bloody hell, what an investigative breakthrough, call the newspaper! Yes, Malta Media publishes advertising, sponsored content, industry announcements and commercial partnerships. We have never pretended otherwise and I would have thought that a quick look at our website made our business model obvious. Apparently though, those relationships have now become something worth mentioning in an email suggesting that I might have committed a criminal offence.

I wonder how Wittmann thinks specialist publishing works. If a financial newspaper accepts advertising from banks, does that make its journalists responsible for whatever those banks might do? If an automotive publication receives money from car manufacturers, does that mean every critical article it publishes is secretly written on behalf of the industry? And if Malta Media criticises a hacker investigating gambling companies, does that automatically turn our advertisers into accomplices in some imaginary campaign against her?

Sorry, but that is ridiculous. Commercial relationships can be examined when questions about editorial independence arise, but advertising is not evidence that an advertiser directed a journalist to threaten somebody. Wittmann is welcome to criticise our commercial relationships, just as I am entitled to criticise her methods. What I reject is the suggestion that publishing paid content for gambling companies somehow makes my comments about personal security more criminal.

And why exactly should I arrange a German lawyer for her convenience?

Wittmann also wants the contact details of a German law firm authorised to receive legal correspondence or an address within the European Union where formal documents can be served. She did not specifically demand my private residential address. But why should I arrange German legal representation simply because she has decided to send me an email referring to possible legal action? I don't employ lawyers as a free administrative service for people who might want to sue me.

I live in Malta and Michael Schmitt Ltd, the company behind Malta Media, is registered in the United Kingdom. German courts may have jurisdiction over certain disputes, but I see no reason to appoint a German lawyer before one is needed. Under § 78 of the German Code of Civil Procedure, legal representation is generally mandatory before German regional courts and higher civil courts. That is a question for actual proceedings, not another email exchange.

There are also established procedures for serving legal documents across European borders, including those set out in EU Regulation 2020/1784. If proceedings are initiated, the relevant arrangements can be dealt with through the proper channels. But voluntarily handing over my home address during a hostile email exchange is not something I consider intelligent, especially after everything I have said about personal security and the fact that Wittmann likes to publish private addresses.

And that brings us back to the privacy problem. Wittmann has complained about the handling of her own residential address in connection with the MGA proceedings and I understand why somebody would be concerned. Yet she seems far less troubled when people working in gambling complain about their residential addresses appearing in publicly accessible databases. Apparently, keeping an address private becomes a serious matter when it concerns her, but questioning the publication of somebody else's address suddenly makes you an enemy of investigative journalism.

The real issue is not my video. It is the publication of private documents!

I have followed Wittmann's reporting and I have no problem with journalists investigating companies, regulators or people suspected of wrongdoing. Malta Media has conducted its own investigations into gambling operators, licensing authorities and corporate structures for years. We have questioned regulators, challenged business practices and published findings that have not always made us popular. But I have never believed that working in journalism gives me unlimited rights to expose somebody's private life simply because their business interests are worth investigating.

Wittmann's activities concerning the MGA were examined in the Berlin civil proceedings, where the court upheld an injunction concerning unauthorised access to protected data while also protecting her right to express critical opinions about the regulator. The separate Curaçao affair raises its own questions, particularly concerning what happened to the documents subsequently made available through the Casino Secrets project. That is what our earlier reporting on the methods used has examined and it remains the issue I consider far more important than another dispute between a journalist and a hacker.

And the possible consequences are not limited to arguments about privacy law. Earlier this week, we reported an email offering to remove private information in exchange for a Bitcoin payment, although the sender's identity remains unverified. That story, published by Malta Media on 13 October, raised questions about how publicly accessible personal documents could be exploited by people who had nothing to do with the original investigation. Whether the sender genuinely had access to the websites remains unanswered.

What public interest is served by publishing a complete passport, a private residential address or somebody's personal banking information when the actual story concerns casino ownership or licensing? I have yet to hear an answer that convinces me those details need to be available to everybody. And I am certainly not going to stop asking because Wittmann considers my criticism unpleasant.

If Wittmann wants a court case, I would welcome it…

I have said before that I would welcome judicial scrutiny of this affair and I have not changed my mind. Wittmann is entitled to challenge statements she considers unlawful, whether through criminal complaints or civil proceedings. I am equally entitled to criticise her reporting methods and explain why I think the publication of private documents creates serious risks. Disagreeing with Lilith Wittmann does not automatically make somebody a criminal. Also having advertisers in the gambling industry certainly does not prove that somebody is acting on behalf of a criminal network.

I don't give a shit whether Wittmann likes me, approves of Malta Media or considers my criticism irritating. What I care about is the underlying issue: private information, the rights of the people concerned and the consequences when sensitive documents end up being accessible to practically anybody. I have experienced threats myself, and I know why personal security matters to people whose work or business activities attract unwanted attention. That is not a threat against Wittmann and I reject the suggestion that discussing those risks means I want anybody harmed.

I would welcome the opportunity to explain my statements in court. If Wittmann files a criminal complaint, investigators can examine the recording and its context. If she brings a civil case, both sides can present their arguments and the court can decide which statements and evidence are relevant. But until then, I will continue asking why a hacker who considers her own residential address worth protecting appears so comfortable defending the public exposure of other people's private information.

People have rights, even when they work in gambling. And those rights do not disappear because Lilith Wittmann has decided to investigate their industry.

FAQs

Why does Lilith Wittmann consider the Malta Media video a potential criminal threat?
Lilith Wittmann suggested that comments about personal security, organised crime and the murder of journalist Daphne Caruana Galizia could constitute an implied criminal threat under German law.

What did Lilith Wittmann say about Section 241 of the German Criminal Code?
Wittmann referred to Section 241 StGB, which addresses criminal threats under German law. She suggested that statements made in the video could fall within its scope, although no judicial determination was reported.

Why did Malta Media reject Lilith Wittmann's interpretation of the video?
Malta Media maintained that the comments concerned personal security risks and the potential consequences of publishing sensitive information. The publisher rejected the suggestion that the remarks constituted a threat against Wittmann.

Did Malta Media file a criminal complaint concerning Lilith Wittmann's activities?
Yes. Malta Media reported filing a criminal complaint with Berlin Police on 6 October 2026 concerning alleged unauthorised system access and the publication of sensitive personal documents connected with gambling regulators.

What did Berlin Police communicate to Malta Media on 15 October 2026?
An investigator from Landeskriminalamt Berlin contacted Malta Media, identified the complainant as a witness in criminal proceedings and requested additional information about the allegations and supporting documentation.

Has Lilith Wittmann been found guilty of any criminal offence in this investigation?
No finding of criminal guilt was reported. The police correspondence described investigative steps following a complaint and did not establish criminal responsibility.

What is the connection between Lilith Wittmann and the Casino Secrets investigation?
Wittmann has been associated with the Casino Secrets investigation, which examined gambling regulatory systems and related documents. The publication of sensitive personal information has become a central issue in the dispute.

Why are private residential addresses a concern in gambling investigations?
Publishing residential addresses can expose individuals to privacy and security risks, particularly when information becomes accessible beyond those directly involved in an investigation. Such disclosures raise questions about necessity, proportionality and public interest.

What did the Berlin court decide in the dispute involving Lilith Wittmann and the Malta Gaming Authority?
The Berlin civil proceedings upheld an injunction concerning unauthorised access to protected data while recognising Wittmann's right to express critical opinions about the regulator. The ruling did not establish that the authority was involved in organised crime.

Why did Lilith Wittmann request German legal contact details from Malta Media?
Wittmann requested details of a German law firm authorised to receive legal correspondence or an address within the European Union for formal service of documents. Malta Media questioned the need to appoint German legal representation before proceedings had been initiated.