By Joanna Demarco

Updated with a comment from Komunità Malta agency.

Alexander Kuksov, a Maltese passport holder and the brother of Semen Kuksov, is wanted by the United Kingdom’s National Crime Agency. He is suspected of ‘proceeds of crime offences’ in relation to an operation investigating a Russian ‘billion-dollar money laundering network’.

Britain’s National Crime Agency (NCA) this month announced charges against Alexander Kuksov, 23, putting him on its “most wanted” list. The NCA alleged he was “involved with an organised crime group responsible for the transfer and movement of multi-millions of pounds of criminal cash”. The details have been revealed in a joint investigation between Amphora Media, OCCRP, and Times of Malta.

The agency lists the offences as including “entering into or being concerned in the acquisition, retention, use or control or criminal property [sic], in this case, cash.”

Amphora Media, OCCRP and Times of Malta previously revealed that Alexander Kuksov’s brother, Semen, was stripped of his Maltese citizenship in October last year, following his five-year sentence. Semen, 25, was convicted in the U.K. of involvement in a group the NCA called a “professional banking service for criminals across the world.” 

The brothers, together with their father Vladimir Anatolyevich Kuksov, appear on a list of people granted citizenship in 2022 by Malta. The Kuksovs appear to have been given Maltese citizenship just weeks before Russians were excluded from passport sales to wealthy investors in the wake of the Kremlin’s February 2022 invasion of Ukraine.

In July 2022 – about six months after receiving his Maltese citizenship – Semen began managing “couriers to collect criminal money and deliver the laundered money overseas,” according to a statement by the UK’s Crown Prosecution Service.

The NCA now alleges that Alexander Kusksov was also involved in the criminal money laundering operation.

Lawyers for the elder Kuksov told OCCRP in 2024 that he had “no comment to make but notes that he and his adult son have lived separate lives for some years.” 

Vladimir Kuksov did not respond to a request for comment about the new allegations against his younger son, Alexander, whose whereabouts are unknown.

The Kuksovs received Maltese passports through a controversial citizenship-by-investment program. The so-called “golden passport” scheme was eliminated this year, following a damning judgement by the Court of Justice of the European Union. 

The Komunità Malta Agency, which oversaw the citizenship-by-investment programme, responded by saying, “We can confirm that the name of the person in question has come to the attention of the national authorities, and we shall be following any developments in this case closely.”

Under Maltese law, passports can be revoked if an applicant is sentenced within seven years of becoming a citizen to a jail term of a year or longer.

The charges announced by the NCA against Alexander have not been tried in court, and the money laundering allegations against him are not proven.

When the NCA announced its “Operation Destabilise” investigation in December 2024, it said the money laundering bust was its biggest in a decade, OCCRP reported at the time. The agency said the ring run out of Moscow and Dubai had been moving billions in cryptocurrency and hard cash for criminal operations, ranging from Russian ransomware attacks to street-level drug deals in the U.K.

Several alleged members of the network were sanctioned, and the NCA said it had arrested 84 people. They included Semen Kuksov, who later pleaded guilty to laundering more than $15 million of “criminally obtained cash,” according to the UK prosecution service.

The operation uncovered a complex scheme in which the networks collect funds in one country and make the equivalent value available in another, often by swapping cryptocurrency for cash. The crime agency stated that the investigation exposed and disrupted Russian money laundering networks that support crime worldwide.

The Malta Police Force did not respond to a request for comment on the U.K. case against Alexander or whether it was investigating the allegations against him.

Previous reporting by Amphora Media had also highlighted the lag between the government initiating the passport revocation process and the citizenship being officially revoked.

Malta eliminated its citizenship-by-investment programme earlier this year following a damning judgement by the Court of Justice of the European Union, bringing anend to a long-winded saga.

Malta had tried to defend the scheme, claiming that it is being unfairly targeted despite similar schemes existing in other countries – a false claim. It has now expanded a discretionary citizenship scheme for individuals of ‘exceptional merit.

Malta promises to eliminate its citizenship-by-investment program and expanding a discretionary citizenship scheme for individuals of ‘exceptional merit’, bringing to end a saga that started with a cautious agreement between Malta and the European Commission and culminated in a damning judgement by the Court of Justice of the European Union.

What was the case about?

The European Commission began challenging Malta’s citizenship-by-investment programme, also known as a golden passports scheme, in 2020.

Its argument focused on the claim that Malta sells citizenship of the entire European Union, without establishing whether the investor has, or will develop, links to Malta itself beyond the transactional requirements.

The Court upheld the transactionality argument. The judgement does not impact Malta’s current residency-by-investment scheme, where foreign nationals can buy residency rights but not a passport.

What exactly has changed?

“The amendments strengthen the existing laws related to merit-based citizenship. They are also consistent with Malta Vision 2050, with an emphasis on the need for added value and job creation,” the Home Affairs ministry said in a statement announcing the change.

An accompanying document specified that the amendments will be “removing all references to the Grant of Citizenship for Exceptional Services program, the transaction and even the agents of the programme.”

Licensed agents will still be able to facilitate the purchase of a Maltese golden visa.

Research by the Daphne Caruana Galizia Foundation has shown that the golden visa intermediary ‘market’ is extremely concentrated, and there are cases of revolving door, where high-ranking officials became visa agents.

The citizenship amendments provide considerable flexibility, but there remains a lack of clarity regarding the exact criteria and how the new framework will operate.

The new amendments would return Malta to its pre-2013 citizenship regime. Under a 2007 legal amendment, investors could become citizens at a minister’s discretion, without a structured programme, for so-called exceptional services. The 2013 amendment set a price and other structured conditions.

The proposed amendments define exceptional services and exceptional merit as “services rendered and contributions made by scientists, researchers, athletes, sports persons, artists, cultural performers, entrepreneurs, philanthropists and technologists, amongst other persons of interest”.

There are no references to obligatory investment in real estate in the published document. It appears that job creation will be a key indicator. There is also no mention of extending citizenship to family members.

Malta already runs a merit-based citizenship scheme. The government’s FAQ emphasised that existing structures will be used for the upgraded scheme.

Applicants will submit their requests to the Komunità agency, which will then initiate a due diligence process and forward the outcome to the existing evaluation board.

The board, after conducting interviews and deliberations, will issue a recommendation to the Home Affairs Minister, who will make the final decision.

People who have already acquired citizenship through the previous programme will remain citizens.

Under the citizenship-by-investment scheme, citizenship buyers have proven very difficult to deprive of their purchased passports.

Amphora Media’s investigation in February showed that Pavel Melnikov was the only known citizenship buyer to have lost his Maltese passport at the time. He was found guilty of aggravated tax fraud and aggravated accounting fraud.

Who benefitted from the citizenship by investment scheme?

The scheme was benefiting local intermediaries, such as agents and real estate owners. According to government figures, citizenship sales generated €339 million from property purchases and €158 million from property rentals.

Applicants were eligible for the scheme if they rented a property for €16,000 annually for five years. This is less than the average rent for a two-bedroom apartment in St Julian’s or Sliema.

When the Court of Justice announced its judgement in April, Prime Minister Robert Abela defended the scheme, claiming it had generated “almost a billion and a half euros that we have invested in people”, helping them “in their hour of need” during moments like the pandemic.

Amphora Media’s fact-check has shown that as of July 2024, less than 10% of the reported €1.4 billion generated from the scheme went into social projects, and that just €41,847,629, or one-third of the amount promised, had been paid out. It remains to be seen what will happen with the rest of the fund.

This narrative is two-pronged: 

• Other countries are running similar golden passport schemes,
• The EU Commission had initially approved the scheme before u-turning under the influence of the Nationalist Party.

Is this accurate?

The idea that other EU countries run similar golden passport schemes, yet only Malta faces criticism, is longstanding.

It is a narrative used by Malta’s Prime Minister Robert Abela and his predecessor, Prime Minister Joseph Muscat.

The Nationalist Party’s stance is less clear, with the party’s manifesto calling for the scheme to be amended, and not scrapped. 

The idea that Malta has been unfairly singled out has been regularly repeated following the court ruling, namely by MEP Alex Agius Saliba in an address to the European Parliament, and MP Alex Muscat in a recording of ‘Il-Kazin’.

“I’m also astonished that Austria—a Member State with a scheme identical to Malta’s—has been left entirely out of the discussion. I am amazed at how Cyprus, Greece, Italy, Latvia, Luxembourg, Portugal and Spain, which all have residence-by-investment schemes, can continue operating similar schemes, yet when it comes to Malta, it’s as if, because there is someone who to fans, all the windows get shut,” Agius Saliba said.

“We will abide by the Court’s decision so that we can keep a scheme that continues to generate wealth, because Malta is in no way inferior to any other Member State,” he added.

It has even extended to operators. Henley & Partners, a leading service provider for passport buyers, claimed that the “ruling, targeting the smallest EU Member State, sets a worrying precedent for the undemocratic extension of EU competences beyond its treaty-based limits.”

“It would be interesting to see what the outcome would have been if the case were against France or Germany,” it added. 

Another key claim in the current narrative is that the EU Commission approved the citizenship-by-investment programme after Malta implemented the necessary amendments, only to u-turn later following pressure by the Nationalist Party.

Both Abela and Joseph Muscat have fanned the flames of these claims. Abela has said that the PN staged a “systematic attack” and “then Simon Busuttil, David Casa, Roberta Metsola, who went out to celebrate that same day of the sentence”.

Meanwhile, Muscat told his social audience to “give a round of applause to Roberta Metsola and the PN who have worked against our country since the first minute”.

In the European Parliament, MEP Thomas Bajada described the golden passports scheme as a “programme that the EU Commission had approved, and we amended it where it was needed.”

Neither MEP replied to our request for comment to clarify the claims.

Did the Commission approve the golden passports scheme?

On 29th January 2014, two weeks after a damning resolution by the European Parliament, the EU Commission and the Maltese government reached an agreement over the golden passports scheme, which required that no citizenship or “certificate of naturalisation” would be issued unless:

“The applicant provides proof that he/she has resided in Malta for at least 12 months immediately preceding the day of issuing the certificate of naturalisation.”

The reached agreement was taken as an endorsement.

In 2021, the Passport Papers investigation exposed that officials often waived the requirement for a physical presence. 

Applicants submitted receipts for consumables or newspaper subscriptions, and the average time spent in Malta, according to calculations by the Daphne Caruana Galizia Foundation, was 16 days.

The Commission’s use of “effective residence status” in its press release about the agreement suggests that the Commission was not aware of this creative interpretation of residency. 

It referenced the investigation in the ECJ case, noting:

“The actual physical presence in Malta is required on two occasions only: to provide biometric data in order to obtain a residence permit and to swear the oath of allegiance”, and that the “legal residence” (rental or property purchase) does not constitute a “genuine link”.

The Commission’s spokesperson did not reply to a request for comment.

Was Malta singled out? Do other EU member states have similar programmes?

In 2019, the EU Commission published a comprehensive report on the risks of investor citizenship, focusing on Bulgaria, Cyprus and Malta, which were running such schemes at the time. 

The Commission’s report also noted that some countries run discretionary citizenship pathways, which are “used on a limited basis”. 

In 2020, formal notices and comments were sent to Malta, Cyprus and Bulgaria. Cyprus repealed the scheme that year, while Bulgaria halted its programme in 2022.

The Commission referred Malta to the European Court of Justice in 2022, stating that passports are granted “in the absence of a genuine link with the naturalising country, such as long-term residence.”

As of 2024, most countries in the EU had residency visas for investors, known as golden visas, which differ from citizenship by investment, or golden passports, which offer a passport, citizenship and nationality.

Austria says it does not have a citizenship-by-investment scheme. 

Austria does offer exemptions for investors, but these are discretionary. While there is no minimum investment amount, applicants must make a substantial, active contribution to the Austrian economy, creating jobs and implementing projects.

Industry sources estimate that it could cost up to €10 million. A Commission fact-finding study found that all applicants for citizenship were required to pass a language and civic knowledge test and prove “uninterrupted registered residence”.

Among residency schemes, only six on the EU’s list focus on passive investment in real estate. Portugal has removed the real estate pathway, and its golden visa concentrates now on job creation or cultural contributions. 

In the case of Portugal, a country often cited in defence of the scheme, an applicant for the residency-by-investment can only become a citizen if they’ve been a resident for at least five years (with sufficient proof of residency), and must also provide certification proving fluency in Portuguese. This is the standard process for naturalisation. 

Malta, like Portugal, has a residency by investment programme. This was not subject to the court decision. 

The Commission has been pressured to do more against citizenship by investment by the majority of the European Parliament, which has repeatedly called on the Commission to ban citizenship by investment and impose stricter regulations on residency by investment.

The claim that the European Commission’s criticism regarding the absence of a genuine link focuses on Malta while ignoring comparable schemes elsewhere is false. 

Since 2019, the European Commission has criticised citizenship by investment schemes in Bulgaria, Cyprus and Malta.

By 2022, at the point of the EU court referral, no other EU country was running a similar scheme.

Austria’s investor citizenship pathway is different from a structured scheme, requiring significant investment in the country that extends to job creation.

Residency by investment (so-called golden visas) should not be confused with citizenship by investment (so-called golden passports).They are entirely different schemes that provide entirely different privileges.

The court ruling does not impact Malta’s current residency-by-investment scheme. 

The EU Commission and European Parliament have made that distinction, with the latter calling for a ban on golden passports and stricter regulation of golden visas.

The claim that the European Commission had approved the scheme in Malta before u-turning is misleading. 

When the European Commission reached an agreement on the scheme in 2014, Malta failed to live up to the agreement. Simply buying or renting property, offering scant evidence of spending, and scarcely setting foot on the island did not amount to a genuine link or proof of residency. Once those facts came to light, the Commission began its legal challenge against Malta.

This project is supported by the European Media and Information Fund. The sole responsibility for any content supported by the European Media and Information Fund lies with the authors and it may not necessarily reflect the positions of the EMIF and the Fund Partners, the Calouste Gulbenkian Foundation and the European University Institute.

Malta’s decade-long gamble on golden passports crashed to a halt after the European Court of Justice (ECJ) ruled that the citizenship-by-investment scheme infringed EU law and amounted to the “commercialisation” of both Maltese and EU citizenship.

First launched over a decade ago, the controversial programme zig-zagged through warnings and reforms, with today’s ruling potentially shutting the door on the scheme. 

“The Court acknowledges that member states are still free to decide who becomes their national, but it reminds them that when you grant nationality of a member state, you also grant EU citizenship,” the Court’s press officer explained, adding, “Citizenship rights exist because of member states being able to trust each other. All of it is based on the principles of sincere cooperation and mutual trust. That is why the acquisition of Union citizenship cannot result from a commercial transaction.”

What’s the case all about?

The European Commission began challenging Malta’s citizenship-by-investment scheme in 2020.

It argued that the scheme effectively sells citizenship of the entire European Union, without establishing whether the investor has, or will develop, links to Malta itself beyond the transactional requirements. 

In March 2023, the EU Commission brought the case before the top EU court, which is responsible for ensuring the consistent application of EU law. 

“By establishing and maintaining such a scheme, Malta compromises and undermines the essence and integrity of Union citizenship,” the Commission wrote in its plea to the court, basing its argument that citizenship buyers are not required to have a genuine link to Malta.

In response, the Maltese government claimed that nothing in EU law requires a genuine link and that demanding Malta scrap the scheme “encroached on a domain within the sovereignty of the Member States.”

The ruling Labour Party, which introduced the scheme, has called for a “new chapter of national convergence on the subject” of citizenship by investment. Various government officials, including Prime Minister Robert Abela, have emphasised that the citizenship scheme contributes to a fund that “is helping those who are most in need in society.”

The Nationalist Party’s position is less clear. While leader Bernard Grech had previously come out against the sale of passports to Russian nationals following the invasion of Ukraine, after sales to them were stopped, he has steered away from making his stance on the scheme clear. 

Meanwhile, Alex Borg, one the party’s up-and-coming politicians, recently said that while the scheme initially had significant due diligence issues, it went on to bring a lot of benefits to Malta – and that the sale of passports should be “maximised”, and should be used to grow new industries in the country.

What is Malta’s citizenship by investment scheme?

The current citizenship-by-investment legal framework was launched in 2014 as the Malta Individual Investor Programme (MIIP). 

Maltese law previously allowed for fast-track citizenship, but under a 2007 legal amendment, investors could become citizens at a minister’s discretion, without a structured programme, for so-called exceptional services. The 2013 amendment set a price and other structured conditions.

Specifically, these legal changes allowed individuals to obtain Maltese citizenship by paying €650,000 into a development fund, without any conditions on prior investments in or residential links to Malta. Dependent family members could also get their passports for a fraction of this sum. 

In an interview in 2014, Joseph Muscat compared golden passports to roads, which are built by foreign nationals but ultimately benefit the Maltese.

Over the years, the government has announced that citizenship purchases have raised close to €1 million for Mater Dei Hospital, €10 million for health centres, €1.5 million for Caritas, and €1 million for the purchase of Puttinu Cares’ premises in London. Money collected from the scheme was also used to upgrade schools.

However, the scheme has long courted controversy. Keith Schembri, the former chief of staff of Prime Minister Joseph Muscat, has been charged in connection to allegations that he received kickbacks on the passports scheme from Russian nationals through the notorious Pilatus Bank, as they were applying for citizenship with Nexia BT’s Brian Tonna.

According to testimony of a police officer, Schembri received an initial transfer of €50,000 on 25th June 2015 and a further €50,000 on 19th August 2015. Schembri denies the charges.

Who are the buyers?

The names of citizenship buyers are published in the government gazette, but are mixed with the names of individuals who have become Maltese citizens through different means. As a result, academics, civil society, journalists and other interested actors cannot scrutinise the complete list of buyers.

In 2021, the Passport Papers investigation came out. The Daphne Caruana Galizia Foundation and media partners revealed that applicants for golden passports were assessed according to a point system.

For each day spent in Malta, an applicant accrued 15 points. Renting a flat resulted in 60 points, while opening a bank account and subscribing to a local society in Malta each accrued 10 points. The points matrix system also allowed applicants who had not spent many days in Malta to ‘score’ points through other activities such as large charitable donations.

The lax rules became attractive to oligarchs, Russian politicians, and Saudi royals, among others. 

Two sons of Russia’s long-time richest parliament member, Grigory Anikeev, as well as the sons’ mothers, became Maltese citizens. The two women went on to use their Maltese passports to shop for property in Dubai. One of them, Irina Kupareva, used a ‘gift certificate’ from Anikeev’s associate to justify her thereto unexplained wealth in her Maltese citizenship application.

Asked about facilitating the acquisition of EU citizenship for politically exposed persons, Henley & Partners, the company that recruits and screens applicants for the citizenship scheme, told the Times of Malta, “We have no legal obligation to do any compliance checks” and that this is the government’s responsibility.

A government spokesperson told the Passport Papers team that the screening of applicants “involves Interpol and Europol database checks, border controls and physical presence in Malta.”

Former gold mining executive Pavel Grachev also purchased Maltese passports for himself and his family, which he used to acquire a property in Dubai. Grachev was sanctioned by the US in 2022 for his role in Polyus, Russia’s largest gold producer and one of the world’s largest gold mining companies. The Financial Times recently found seven sanctioned Russians among Maltese citizenship buyers.

As reported by Amphora earlier, Semen Kuksov, a citizenship buyer’s son, imprisoned in the United Kingdom for “running a professional banking service for criminals across the world”, is serving his sentence as a Maltese citizen despite announcements that his passport revocation process has begun.

Citizenship revocations have been published in the government gazette since 2020. From that date, Pavel Melnikov remains the only known citizenship buyer to have lost his Maltese passport. He was found guilty of aggravated tax fraud and aggravated accounting fraud in Finland earlier this year.

Why did the EU Commission challenge Malta over its Passports Scheme?

Transparency International, an international watchdog, has warned that “a consensus has emerged that these schemes open the EU’s doors to money laundering, corruption and security risks” and that “golden passport programmes are schemes with specific features that make them vulnerable to abuse” because they favour passive investment into luxury property – a favoured money laundering method.

However, it is not the evidence of the citizenship scheme’s sanctions evasion, corruption and money laundering risks that formed the basis of the European Commission’s challenge against Malta. The Commission chose to focus its arguments on the requirement of a genuine link to Malta.

In October 2024, the EU court’s Advocate General Anthony Michael Collins issued a legal opinion that EU legislation does not require any such link, and member states “have decided that it is for each of them alone to determine who is entitled to be one of their nationals.” The opinion was not binding.

“The opinion allows the Court to have a possible answer, but it is not always followed,” the Court’s spokesperson explained.

“There are individual cases where there is a very strong suspicion that, if it can be shown that Malta, by allowing this practice, opens the door to money laundering or corruption, and this can be proven with evidence, then this could be an additional link for declaring those [citizenship by investment] measures as contrary to EU law. But this has not been subject to this case, the Commission has not argued that,” said Nils Seidel, a researcher in EU and public international law at Leipzig University.

Malta is the sole remaining EU member state to offer citizenship by investment after Bulgaria and Cyprus scrapped their programs under pressure from the European Commission.

How Malta tried to save the case through reforms

Malta’s citizenship-by-investment scheme was reformed in 2020. 

The reform clearly outlines a ‘residency stage’, ‘eligibility stage’ (at which additional payments are made), and ‘citizenship stage’, at which the qualifying property must be bought or rented.

The agency’s guidelines also specify that the responsible agency conducts continuous monitoring for a period of five years. Agents handling the application must inform the agency about the applicant’s status as a politically exposed person or appearance on any sanctions list. Where, like in China, social credit reports are a standard practice, these need to be submitted with the application too. 

The European Commission’s infringement proceedings came a few months after the reform, and Malta argued that past criticism, including that from the evidence compiled in the Passport Papers, had been addressed by the 2020 reform.

In court, Malta’s representatives argued that “A rate of refusal of approximately one third of all admissible applications is sufficient proof of the absence of any automaticity.” Malta hired Professor Daniel Sarmiento Ramírez-Escudero to make its case. The Shift News has reported that he was also hired to work on the finch trapping case, which Malta also lost.

“A Member State cannot grant its nationality – and indeed European citizenship – in exchange for predetermined payments or investments, as this essentially amounts to rendering the acquisition of nationality a mere commercial transaction,” the Court stated in a press release on the ruling. The Court also ordered Malta to pay the cost of the proceedings.

“The current scheme has been declared to be contrary to EU law and must therefore be either scrapped or changed to conform with the judgement,” the Court’s press officer explained, adding that if Malta continues violating EU law, the Commission has the option to request that the court imposes a fine.

It remains to be seen whether Malta will follow the ruling, whether it will entirely reform the programme, or scrap it entirely. In a statement, the government promised to respect the court’s judgement.

• Documents link Vigen Badalyan, an Armenian with Maltese citizenship, to VBETTR, and its numerous iterations – illegal gambling sites blacklisted in Türkiye
• Illegal VBETTR websites carry partnerships with the Maltese Premier League and the Malta National Football team
• Records and a first-hand account suggest Badalyan & his SoftConstruct provided services to the illegal gambling network of Halil Falyalı, a Turkish Cypriot businessman murdered in 2022.

Vigen Badalyan, an Armenian with Maltese citizenship, was named “leader of the year” for his “visionary strategies” at SiGMA Europe 2024 in Malta, a government-endorsed conference which carried the logo of Badalyan’s BetConstruct on every participant’s badge. However, an investigation by an international media consortium has shown that Badalyan’s interests allegedly extend to lucrative illegal gambling markets, notably in Türkiye.

Documents obtained by OCCRP, Amphora Media and other media partners have uncovered that Vigen Badalyan was behind vbettr.com and its numerous iterations – illegal gambling sites blacklisted in Türkiye. This website family is a Turkish twin of Badalyan’s Vbet brand. Vbet has partnered with the Maltese Premier League and the Malta National Football team, and this is displayed on the Türkiye-targeting website as well.

SoftConstruct’s legal team said, “Vbettr.com is not owned, managed, or operated by SoftConstruct or Vigen Badalyan”. However, they did not reply to our request for clarification when provided with website registrations, which showed the contrary.

According to a former head of finance of slain alleged illegal gambling tycoon Halil Falyalı, Badalyan’s companies allegedly provide betting infrastructure to Falyalı’s illicit network. 

The investigation team verified website registration data to find that SoftConstruct Limited is listed as the internet service provider for at least four websites blacklisted in Türkiye that were registered by Ibrahim Tokkan.

Tokkan was indicted in 2024 as an alleged manager of the illegal betting network of Halil Falyalı and worked for companies belonging to the Falyalı family. He denies the charges.

Read more about Halil Falyalı global betting empire in this story by our publishing partners, OCCRP

And our story exploring the alleged network’s operations in Malta

The legal team of SoftConstruct denied the claims, saying, “We categorically reject any suggestion of involvement in unlawful activities or associations with criminal organizations. As a B2B [business-to-business] technology provider, SoftConstruct supplies gaming software solutions, but it does not operate or control third-party businesses that use its products.”

The Badalyan’s ties to Malta and VBETTR’s operations

Vigen Badalyan and his brother, Vahe, are known for founding Soft Construct, which owns the BetConstruct brand. Data from 2021 shows that in Malta, they were the declared beneficial owners of Vivaro (now SCGO) and Soft Construct (Malta), as well as owners of FastShift Ltd. and V Venture Ltd.

The brothers and members of their families have become naturalised Maltese citizens through the citizenship-by-investment scheme. 

In a corporate network that spans continents, Soft Construct and BetConstruct offer products and services targeting businesses (so-called B2B products), while Vbet targets gamblers directly.

Vbet websites are owned by corresponding national branches or the Maltese branch, which targets several EU countries and the UK. Badalyan companies use similar brands across jurisdictions.

Their Maltese companies, either owned directly or via the Isle of Man, are registered at the same address in Portomaso and have, over time, shared the same directors.

Yet there is one website, and its many spelling variations, which, despite similar branding, is not immediately recognisable as part of the Vbet family and does not appear to be run by the same people.

VbetTR, with its numerous iterations, does not appear on the official whitelist of licensed gambling operators in Türkiye. On the contrary, different numbered variations of VbetTR are found on the country’s blacklist.

Still, websites targeting gamblers in Türkiye have carried the familiar Vbet logo and display the Badalyan company’s partnerships with European football clubs.

The website targeting Türkiye is listed on a licence issued by Curacao – as a recent investigation by Follow the Money shows, Curacao is a go-to jurisdiction for gambling operators in the grey area. While they obtain some form of licence, they do not operate with one that covers the jurisdiction of their target players. In this case, being a licensed gambling provider in Curacao -or Malta- does not entitle a provider to offer gambling in Türkiye.

Historical domain data for the vbettr.com website reveals that in 2019, the registrant’s name was listed as “Badalyan Vigen”, and the associated email address was team.webmaster@betconstruct.com.

In response to reporters’ questions, SoftConstruct’s legal team said, “Vbettr.com is not owned, managed, or operated by SoftConstruct or Vigen Badalyan. To the best of our knowledge, the website in question [vbettr] was not registered using the email address team.webmaster@betconstruct.com. We have no record of this email being used for such a registration, and we are not aware of any connection between our systems and this domain.”

Badalyan’s AI chatbot on BetConstruct’s website provided a different answer.

Asked if his companies offer betting services in Türkiye, Badalyan’s chatbot said, “Yes, some of the companies co-founded by Vigen Badalyan, such as Vbet, offer betting services in Turkey. However, it’s important to check the specific regulations and availability of services in the region, as they can vary. If you need more detailed information, please let me know!”

Amphora Media requested clarification on the discrepancies between SoftConstruct’s replies and the documents found by reporters showing Vigen Badalyan’s involvement. However, no replies were forthcoming.

The director of IT Management Santora B.V., VbetTR’s Curacao licence holder, is Yeva Asiryan, who actively promotes BetConstruct on her Facebook account and, in some documents, appears as Yevgenya Asiryan. ‘Asiryan Yevgenya’ is also the registrant contact name on BetConstruct’s Canadian website. BetConstruct expanded into Canada in early 2025.

In response to questions sent in 2021 by our publishing partner, Hetq, a representative of Soft Construct CJSC denied knowingly participating in illegal gambling in Türkiye, saying that the company merely provides technology to various gambling operators globally, including those that target “the Turkish-speaking clients scattered around the world”.

Read Hetq’s story here.

Badalyan companies have faced regulatory action before

This is not the first time the brothers’ businesses are subject to regulatory action. In 2020, the Financial Intelligence Analysis Unit in Malta issued Malta-based Vivaro Ltd a  €733,160 fine, but it was challenged and revoked on constitutional grounds. There are two pending court cases involving Vivaro, one in the constitutional court.

In response to reporters’ questions, the Malta Gaming Authority (MGA) said, “The MGA collaborates with a wide range of international stakeholders to ensure that the gaming sector is not misused for money laundering or other criminal purposes. Therefore, when you reference Vivaro (now SCGO) and the fines that were issued by the FIAU, we would like to note that these were a direct result of a full-scope examination conducted by the MGA, where we identified a number of shortcomings. The FIAU subsequently imposed an administrative fine of €733,160 and a Follow-up Directive. The sanctions issued by the FIAU are currently pending court proceedings.”

In 2021, Swedish gambling authorities wanted to suspend the Malta-based Vivaro Ltd’s gambling licence over failing to commence operations within a year from registration. Vivaro Ltd responded in its statement that during the period June 2020 – May 2021 it had no turnover in Sweden and that 50 staff members were drafted into the Armenian army.

In the financial statement from January to December 2021, submitted to the Malta Business Registry, Vivaro reported receiving income from Sweden and having five employees in Malta. Still, Sweden’s Administrative Court reversed the decision of the gambling authorities to suspend its licences for commercial online gaming and betting and issued a warning, according to the Swedish Gambling Authority”.

In the UK, failings were found in Vivaro’s, since renamed SCGO’s, processes for money laundering prevention and safer gambling, but in 2023, SCGO reached a settlement with the UK Gambling Commission and agreed to pay £337,631.

In Romania, vbet.com found itself blacklisted by authorities in 2018 for operating without a licence. But in 2024, BetConstruct announced obtaining a licence to provide B2C betting (that is, targeting customers directly) in Romania. As the original Vbet website remains blocked, the company launched with the “Victory Bet” domain, registered by the Malta-based V Venture.

Meanwhile, Vigen Badalyan continues touring gaming events around the world, attending exclusive interviews, and collecting new gambling licences for his companies.

SiGMA did not respond to questions sent.

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