Updated on 15/02/2025 with denial by Ulaş Utku Bozdoğan

Malta was used as a base by a murdered Turkish-Cypriot businessman who allegedly ran an illegal betting network worth €75 million monthly, according to his former money man. 

Halil Falyali, once wanted in the US for allegedly laundering drug money, was assassinated in Northern Cyprus three years ago when his car was ambushed by gunmen with automatic weapons.

He was known as a businessman and hotel proprietor of Les Ambassadeurs Hotel, Casino and Marina, an upscale resort in the port city of Kyrenia on the Turkish Cypriot side of the divided island. 

His former head of finance, who is fighting extradition to Turkey for allegedly masterminding the assassination, has now exposed how Malta was one of the cogs in what Turkish prosecutors allege was a cross-border illegal online betting operation.

In over 20 hours of taped interviews with OCCRP from a Dutch prison, Falyali’s former head of finance Cemil Önal details the alleged inner workings of the betting operation and Malta’s place in it.

Malta, he says, was an obvious country to use for supporting illegal activities.

“Because, why Malta? Opening a company in Malta costs €2,000. The Falyalı family could give a power of attorney from the Greek-Cypriot side and open a company in Malta through a lawyer within a day.

“Once you open a company, you have bank accounts and bitcoin. There is no problem in Malta when you exchange your bitcoins and deposit them into your bank account. That is how you clean the money,” Önal claims. 

Reporters were able to corroborate that Önal was officially employed by a Falyali company, and confirmed an Interpol red notice was filed against him stating he “used to be in charge of Falyali’s money and finances”.

Önal was indicted by Turkish prosecutors in 2018 for allegedly establishing a “criminal organisation” that laundered money from illegal betting. 

He was arrested in the Netherlands in December 2023, where he is fighting extradition to Turkey for his alleged role in Falyali’s murder. 

Önal insists he was not involved in the murder, and that the compromising information he has on payments to public officials in Turkey and Northern Cyprus makes him a target.

‘From the Balkans to Malta’

Just 10 months after Fayali’s murder, authorities in Turkey seized over €40 million in assets, with Turkey’s Interior Minister cracking down on the alleged criminal network. 

The minister even referenced Malta’s role in a press conference announcing the crackdown. 

“Virtual betting, virtual gambling and crypto constitute the circulation of money in the world without any obstacles… From the Balkans to Malta and Cyprus, they are the places where [these groups] base themselves.” 

The investigation into Falyali by Turkey’s financial crimes body uncovered cryptocurrency wallets associated with the criminal network, including Malta.

Reporters found the wallets received €1.3 billion since 2018.

Turkish authorities alleged in a December 2024 indictment that Falyali opened a cryptocurrency account in Malta in November 2020. 

A government source confirmed to Times of Malta that Falyali’s financial links to Malta are being investigated by the authorities. 

The police declined to comment when contacted by Times of Malta.

Önal claims Malta was used to facilitate the alleged illegal gambling network’s operations. 

He alleges Turkish-American national Ulaş Utku Bozdoğan, who owns the Kebab Factory restaurant chain, had ties to the network. 

Bozdoğan strongly denied the claims in comments after the article's publication. 

"I have never met or had any dealings with Mr Cemil Önal and/or Halil Falyali and I can say that this information is false." 

"What is written about me is based on allegations made by an individual with a criminal past and it is evident that information he gave is not trustworthy. In your article you quote him as saying that you can set up a company and bank account here in Malta in one day.

"This for a fact is clearly a lie and should prompt anyone to question his realiabilty. I do not know why he chose to mention me but further investigation will show that his allegations in my regard are all false," Bozdoğan said. 

While Önal was unable to provide documentation for his claims, traces of Bozdoğan’s links to the online gambling world can be found by scouring through business and website records. 

According to Albanian company records, Bozdoğan was the representative for Universal Software Solutions in Albania, a Curaçao company listed as the initial licence holder for a gambling website called BeteBet.

Bozdoğan said he has no knowledge about the dealings of Universal Software Solutions NV and claimed the listing in the Albanian registry is incorrect. 

Önal describes BeteBet as Falyali’s first venture in the alleged illegal online gambling world. 

The website was blacklisted by Turkey in 2017, Cyprus in 2019, and Latvia in 2021.

BeteBet’s ownership details were hidden from 2012 until 2019, when it became registered by Total Gaming Solutions B.V., another Curaçao company used by a man named Ibrahim Tokkan to register over 500 sites.

BeteBet was named in testimonies included in last year’s Turkish indictment, and Tokkan, who was employed by a Falyalı-owned company, was charged as a manager of a criminal organisation.

Bozdoğan said he has never met or had any dealings with Tokkan and has never heard of Total Gaming Solutions B.V.

Another person named by Falyali’s finance man is Turkish-Cypriot businessman Burak Başel, the co-owner of a Sliema eatery Food for Fit as well as a payment firm called Paymix. 

Corporate records show Başel is also a shareholder of Universal Software Solutions, the same company that was once listed as the licence holder for BeteBet. 

When contacted, Başel denied any links to Falyali’s alleged illegal network and downplayed his ties with Bozdoğan. 

His lawyer said the only “professional interaction” between Başel and Falyali was when Falyali’s Cypriot company Cypbet bought "offline shop software" from his [Başel’s] own Cypriot company. 

“... this software was only used in 2017, after which Cypbet transitioned to a different software provider. This transaction was a standard business agreement and did not extend beyond this period,” Başel’s lawyer said. 

The lawyer said Bozdoğan was appointed by Universal Software Solutions as its legal representative in Albania, with a limited power of attorney issued for specific responsibilities within Albania.

“Our client does not have any personal relationship with Ulaş Utku Bozdoğan,” the lawyer said. 

Bozdoğan however denied ever having any dealings with Universal Software Solutions or Başel.

On his ties with Betebet, Başel’s lawyer said licensing laws and restrictions vary by jurisdiction, and companies operating under a Curaçao license are responsible for ensuring compliance with local laws in the regions where they operate. 

The lawyer said Universal Software Solutions sells software to businesses and does not deal directly with the end users of the betting sites.

“... our client is not the owner of any business to consumer entities, and therefore not involved in any day-to-day compliance for such entities and cannot comment on their regulatory practices,” the lawyer said. 

Food For Fit said when contacted that Başel “is not involved in the management of our business. He is only a shareholder/investor".

Finance Incorporated, the owner of the Paymix brand, said when contacted, “Finance Incorporated is managed by an independent Board of Directors and in implementing its conflicts of interest framework, Mr Başel, although being the UBO, has no influence on the operation and management of the Institution.” The representative also said that “Finance Incorporated Limited does not provide services to companies that do not hold a licence to provide gambling services.”

Staying one step ahead

Önal says the alleged Falyali network can quickly switch to an alternative website if the authorities catch up with the operation and shut it down. 

Operators in Turkey require a license from local authorities, and EU countries are also free to regulate gambling nationally.

Once authorities blacklist a site, the network simply renames and relaunches it.

“Let’s say someone made a complaint [and the BeteBet website] was shut down. In one moment, in 16 seconds, BeteBet2 will be live. These are very cheap.”

Online gambling operations often spread their infrastructure widely, for instance by registering companies in one country and placing servers in another, all while moving money through other jurisdictions in the form of cash or cryptocurrency, Jeremy Douglas, chief of staff and strategy adviser for the United Nations Office on Drugs and Crime told OCCRP.

“This is a highly technical crime, and you’ve got people in either corrupted or very low-capacity jurisdictions, or both, and they’re essentially unable or in some cases unwilling to do anything about it,” he said.

Illicit online gambling has grown massively in recent years and is today estimated to bring in hundreds of billions of euros a year. But these windfalls come with a problem: How to move vast sums of cash without triggering the alarms of banks and police?

According to the Turkish finance ministry report and subsequent indictment, Falyalı’s organisation set about recruiting thousands of people to open bank, credit card, crypto, and online payment processor accounts.

These allegedly functioned as what money laundering experts call “mule accounts.” 

The basic idea is to collect player payments in different accounts and then move the funds through a large number of unrelated accounts to conceal the trail. 

The targets were often students, pensioners, housewives, or low-wage workers. Many were recruited through social media, where adverts directed them to forms they could fill out.

They then received a phone call instructing them how to open multiple bank accounts, according to a separate 2018 indictment issued by Turkish authorities against Önal and others on money laundering charges. That trial is scheduled to begin later this year.  

In some cases, the indictment said, a man on a motorbike would then show up and collect their account information and debit cards in person. The “mules” would earn about €550 a month.

Önal described a pyramid-style setup in which trusted individuals oversaw clusters of account holders, each making a commission from the money flows.

“Let’s say I am talking about our group in England… Ahmet is a kid working with me… he has 50 friends. Ahmet tells one of his friends, ‘Give me your account number, 500 pounds will arrive.’ [He] takes 10 percent of the 500 pounds – 50 pounds, gives me 450 pounds in cash…” 

For every 10 people there was a “guarantor,” responsible for making sure his group stays compliant, and who splits his 10 percent with the account holders.

The Turkish finance ministry report said the money accumulated in front accounts was then transferred many times – a process that experts call “layering.”

In one case, 10,105 transfers were made within 60 seconds, leading Turkish investigators to conclude that the process had been automated. The money was either turned into crypto assets or withdrawn as cash at ATMs, the report said.  

Önal said that the cash collected from the organisation’s operations in Europe and other regions was then consolidated in regional hubs in Eastern Europe and the Caucasus where the network could operate more freely.

Times of Malta collaborated with the Organised Crime and Corruption Reporting Project (OCCRP), Amphora Media (Malta), Follow the Money (Netherlands), Hetq (Armenia), Investigative Reporting Lab Macedonia, Belarusian Investigative Center and Shteg.org (Albania) on the research for this publication.