By James Porteous , Research Head, ARF Council on Anti-Illegal Betting & Related Financial Crime
Emerging new technologies are changing how betting operators deliver their products and how customers see betting, less as a vice and more as part of the entertainment around racing and other sports. As betting operators package their products to appeal to their customers’ desire for enhanced entertainment, the nature of betting is likely to change. As a consequence, gambling regulators will need to keep pace to understand how racing and other sports entertainment games may be in fact be betting. Many emerging new technologies are also likely to be utilised first by ‘start up’ illegal betting operators as they seek to capture customers before legal licensed operators can catch up with the pace of development.
Emerging new technologies that could be used for betting, or construed as betting, take varied forms. These include Web3, which includes growing new technology areas such as NFTs, the Metaverse, and GameFi.
Web3 is hailed as anything from the next generation of the internet to the digital future of society – sceptics argue this is hype. This article examines how Web3 is impacting racing & othersports, and the blurring of boundaries between aspects of Web3 and illegal betting. Web3 loosely refers to the internet’s next stage, typically involving decentralisation and blockchain technology.It is a reaction to Web 2.0 (the current internet) in which, Web3 advocates argue, power has centralised into Big Tech’shands. Advocates believe Web3 will give power and privacy back to users.Critics argue Web3 is just a marketing buzzword.
NFTs (non-fungible tokens)are digital assets (pictures, videos, songs, anything represented by code) whose ownership and provenance is recorded on a blockchain, which is an (in theory) unchangeable record of who owns the asset, how much they bought it for, and from whom.
“Fungible” means interchangeable with other representatives of that asset:a dollar bill is fungible with all dollar bills, but thoroughbred racehorses or the Mona Lisa are non-fungible assets. Cryptocurrencies like Bitcoin are‘fungible tokens’. NFTs rose to prominence during the pandemic, fuelled by social media endorsements from celebrities. ‘Unique’ jpegs of ‘Bored Apes’traded for as much as USD 3.4 million in cryptocurrency, as bemused sceptics pointed out that these could be copied with a mouse-click, regardless of who the ‘true’ owner was.
At its height, the market was estimated at USD 41 billion according to one estimate.But as of late 2022, there was debate over whether the market has completely collapsed along with a wider decline in crypto and other assets, or is primed for a more sustainable long-term comeback.
NFT adoption is particularly high in ARF jurisdictions according to research from September 2021, with the table below showing that six of the top 10jurisdictions have ARF members. One reason for this is NFT-based ‘play-to-earn’ games, explained below.
The metaverse is typically associated with Web3 as something of a catch-all for applications involving virtual realityand/or augmented reality,often involving blockchain. A leading advocate is Mark Zuckerberg, who in October 2021 rebranded Facebook as Meta to focus on such technologies.
But the term is very loosely applied, and in the case of several ‘metaverse’ horse racing products described below, it is essentially a buzzword for ‘video game with crypto elements’.
Advocates argue that the metaverse will transform everyday life, with, for example, one forecast that 30% of business meetings will take place in the metaverse by 2026.Sceptics argue that real-world applications are limited and that there are many barriers to widespread adoption.
GameFi (gaming + finance), describes video games typically involving blockchain, NFTs and/or the metaverse. They are also, crucially in the context of betting, ‘play to earn’.
Play to earn (P2E) means users are rewarded for playing, with crypto currency issued by the game and/or with in-game items (weapons, costumes, etc) which are themselves NFTs. A fee, in the form of NFT purchases, is required to play, which as explained below means P2E may constitute gambling.
Leading GameFi examples include Axie Infinity, The Sandbox and Decentraland.
Axie Infinity users earn cryptocurrency by breeding and battling NFT ‘pets’. At its height in mid-2021, the game was some people in Asia’s primary income,despite entry NFTs costing USD 1,000 or more.Axie had more than 2 million users and USD 1.2 billion in revenue.Since then, one of its cryptocurrency tokens has lost 99% of peak value,leading to an exodus of users and criticisms of Ponzi-like economic dynamics.
The Sandbox and Decentraland are virtual reality metaverses in which players can buy land, build properties and start businesses to earn cryptocurrencies.Parcels of ‘land’ have sold for millions of dollars,and users can take out crypto mortgages. The platforms’ developers make money via transaction fees.
The table below shows the largest ‘GameFi’ cryptocurrencies as of late 2022. Given cryptocurrency’s volatility, the numbers may have changed significantly since; the purpose of the table is to show that the market is large, with the five biggest GameFi cryptocurrencies among the top 100 of all cryptocurrencies. (Chiliz is a cryptocurrency required to purchase Socios, a sports ‘fan token’ discussed below; Enjin is a platform for various projects not discussed.)
Asia is a key region for NFT gaming adoption. The top five markets are India (34% have played such games), Hong Kong (29%), The UAE (27%), The Philippines (25%), and Vietnam (23%), according to a May 2022 report.
Several projects, realised to various degrees, combine horse-racing, NFTs and the metaverse. Examples are Zed Run, DeRace, Metarace, Cyber Gallops, and DeFi Horse.
All of these have similar mechanics: users buy NFT ‘horses’ and can ‘race’,‘breed’ and trade them to earn crypto. Metaverse elements include (e.g.) the sale of virtual racecourses.
Most have some association with real-world racing. Zed Run hosted a ‘metaverse’ Melbourne Cup event; ex-footballer and racehorse owner Michael Owen promotes DeRace; UK trainer Oliver Cole is a Metarace partner; two Singapore trainers (Desmond Koh and Takaoka Hideyuki) are Cyber Gallops partners.
Zed Run is the most mature, with high-profile media coverage and marketing partnerships with major brands such as Budweiser,NASCAR, Atari and Netflix. DeRace has a following, but the others are less advanced and it is not clear how/if they earn revenue, or have a viable product.
Two other horseracing GameFi projects, Omnihorse and Game of Silks, both employ fantasy sports elements. Omnihorseaims to “bridge traditional sports and the metaverse” according to its founder Kia Joorabchian, a football agent and racehorse owner.
Omnihorse NFTs are based on real-life horses owned by Joorabchian’s stable. NFT owners earn crypto tokens based on the horses’ real-world success, and“exclusive benefits” such as VIP entrance at racecourses where the real horse competes.
Game of Silks is similar, but NFTs are based on the ~20,000 yearlings born in the United States every year. NFT owners earn crypto tokens when/if the real-world horses achieve racing or breeding success.A pre-requisite to earn prizes is to own a ‘Silks Avatar’ NFT – a digital picture of a robot jockey selling for (at the time of writing) around 0.15Ethereum, ~USD 222. Silks does not appear to have any agreements with the real-life yearling owners.
The table below collates several metrics, such as NFT transactions and social media followers, to try to assess the popularity of these products – although given cryptocurrency volatility, social media bots, and NFT ‘wash trading’,such metrics are not perfect.
The table shows that Zed Run has been most successful. DeRace and Silks appear to have some level of interest, but Metarace and Omnihorse appear to have little; Gallops and DeFi Horse were not examined as it did not seem they yet had a viable product.
There are also GameFi projects in other sports. Socios are so-called “fan engagement tokens” promoted by some of the world’s biggest football teams (Barcelona, Juventus, Arsenal, Manchester Cityare among 120+ partners). Fan tokens must be bought with an associated cryptocurrency, ‘Chiliz’. Socios owners can take part in polls and competitions associated with their team.Lionel Messi, one of the best footballers of all time, promotes Socios in a deal worth USD 20 million.
Another, Sorare, sees players buy NFT ‘trading cards’ representing real-life players, then use these to compete for prizes based on the players’ real-life performance. It is a licensed partner of eight football leagues, the NBA, and Major League Baseball.In February 2022, an NFT of Erling Haaland sold for more than USD 600,000.Sorare has been valued at more than USD 4 billion and was publicly praised by President Emmanuel Macron as an example of French tech innovation.
NBA Top Shots are NFT ‘moments’ – video highlights – from NBA games similar to trading cards. A Top Shot of LeBron James dunking sold for USD 208,000 in February 2021.In September 2021 Top Shot reportedly had more than 1.1 million users and developer Dapper Labs was valued at more than USD 7.6 billion.
Web3 may facilitate or blur boundaries with betting, as the following quote highlights:
“Emerging products … such as non-fungible tokens – or NFTs – ‘synthetic shares’ and cryptocurrency … are becoming increasingly widespread and the boundaries between products which can be defined and regulated as gambling are becoming increasingly blurred.
“We are likely to see more and more integration of these types of products into sport and other areas of lifestyle, as well as the legitimate gambling industry. These are lucrative growth areas, and we ignore them at our peril.”
UK Gambling Commission chief executive to International Association of Gambling Regulators, October 2022 (emphasis added).
Aspects of these blurring of the lines include the fact that GameFi may constitute gambling, the potential to bet on GameFi,the crossover between crypto and gambling enthusiasts, and new Web3 betting platforms and mechanics.
Play to Earn / GameFi typically requires payment for entry by purchasing NFTs.An algorithm typically depending on random number generation results in a financial loss or gain for the user: purchasing an NFT horse and earning cryptocurrency by winning a virtual race with it for example.
Paying money in the hope of a greater reward based on a contingency is essentially gambling as often defined, so some NFT projects have attracted regulatory attention. Sorarehas been examined by regulators in Franceand the UK,and has been banned in Switzerland. Sorare insists it does not constitute gambling in jurisdictions in which it operates and agreed to make changes to its platform to address concerns by the French regulator regarding“prevention of excessive gambling and protection of minors, integrity and transparency of gambling operations and the fight against fraud and money laundering.”
The P2E racing products mentioned have not yet attracted such regulatory attention. Zed Run states that its product does not constitute gambling,because “choosing virtual thoroughbreds is a game of skill”, but says the onus is on users to make a decision regarding regulations in their jurisdiction.
Play to Earn has also been criticised by addiction researchers for blurring the boundaries between gaming and speculative trading, with risks including the“deflationary nature of reward currencies and the asymmetric reward structures that heavily favour early investors and exploit late adopters”.
Despite the popularity of GameFi in Asia, South Korea and Japan have banned play to earn as gambling, China has warned against it and has a blanket ban on crypto trading, and in India the government has been asked to clarify its stance on the matter.
Naturally, products which emulate sports popular with bettors such as racing may lead to betting demand.
Zed Run intends or intended to include wagering, with its co-founder stating in2021: “We have spoken to the majority of major wagering operators from around the globe and we’re going to work with them in the future once we have the framework and legalities in place around being able to deliver that.”
The status of such plans is unknown, although it is noted that this co-founder previously was a consultant for an Australian bookmaking technology company.
Wagerr, a blockchain-based Web3 sports betting platform not known to be licensed, announced a partnership with Zed Run in January 2021 whereby Zed Run users would have Wagerr’s betting crypto-tokens deposited into their cryptocurrency wallets, enabling them to bet on Wagerr. Wagerr said it hoped the partnership would enable it to develop expertise in new sports betting markets,although it does not offer racing, real or virtual.
DeRace plans to include wagering and offer its races to bookmakers to stream for betting:
“DeRace’s ecosystem will be enriched with 3rd party betting solution. We will integrate a betting provider (one or multiple) for the execution of bets.
“Also, we will create an API for horse racing streaming platforms, online casinos and betting venues to integrate DeRace horse races in their existing solutions.
“The betting solution completes the whole DeRace NFT horse racing ecosystem.”
An emerging area of academic research indicates crossover of interests and behaviours between those interested in blockchain technology and those interested in gambling.Studies show that cryptocurrency trading is associated with problem gambling.Such crossover is not inherently wrong. But given the unregulated nature of many crypto / NFT projects, it is something for racing & other sports to note.
As detailed in the ARF’s State of Illegal Betting report, crypto is increasingly common for payment at Unregulated and Under-regulated betting operators. Stake.com, an Australia-based, Curacao-licensed sports betting and casino site whose customers reportedly wager AUD 590 million a day in cryptocurrency,is a leading example. FunToken is a similar operator in the online casino space, where gamblers can only gamble with the site’s crypto tokens.
Now, NFTs are being accepted as payments for illegal betting. At least one Licensed but Under-regulated operator accepts Socios tokens among its 42 cryptocurrency payment options. Given that this operator also sponsors various teams and leagues for which Socios tokens are available, there is an obvious off-ramp / cross-promotional avenue for Socios holders to transition to betting at this operator (which offers racing from many ARF jurisdictions).
Many other platforms are trying to capitalise in novel ways on the intersection between gambling and crypto.
‘Gambling Apes’ is a Curacao Licensed but Under-regulated betting website which claims to offer holders of its NFTs a share of the site’s profits. Almost 400Ethereum-worth of gambling apes NFTs have been sold, likely equivalent to ~USD1 million.
Somewhat similar are ‘Slotie’ NFTs,digital pictures of slot machines which supposedly give owners a cut of the profits of an online casino.It was hit with a multi-state cease-and-desist order for encouraging illegal betting in the US.
Bet U, Australia-foundedbut Curacao-licensed, throws several buzzwords together in plans to incorporate“crypto betting, Play-to-earn sports & esports prediction games, and a licensed metaverse resort and casino”. It issues cryptocurrency tokens essentially equivalent to a rebate on bets.
Still another model is playwithstakes.com (not associated with stake.com),where users compete against each other to earn NFTs for predicting sports results. Its CEO insists this is not betting, but also states: “we are creating a new category of sports wagering platform that is Web3 native.”
While it seems many such examples are merely seeking to exploit NFT/crypto hype– and others not mentioned appear to be outright scams – there is clearly a burgeoning supply and demand for new Web3 betting products which may affect betting on racing & other sports in unforeseen ways.
A project with greater credibility because of its founders’ experience is BetDex, a blockchain-based betting exchange licensed in the Isle of Man, created by former executives of leading US sports betting operator FanDuel.
Its CEO states that BetDex will target the crypto/gambling crossoverd emographic, saying “We think there is 30/40% overlap of crypto natives and people who bet on sports.”
BetDex is targeting international markets including Asia. Currently it only offers football but plans to expand into other sports.The metaverse also provides unregulated gambling: Decentraland has a ‘district’ named Vegas City which reportedly offers casinos and sportsbooks including the racing of NFT horses.It is not clear how the latter works, though Zed Run has a virtual ‘HQ’ there.
ICE Poker in Vegas City, a poker room which requires users to purchase expensive NFTs to access, reportedly attracts more than 100,000 monthly players and revenue of USD 3.2 million.
It is easy to envisage a future where virtual reality racing and associated unregulated wagering could compete with the real equivalent, particularly among young people.
There are many opportunities for racing and other sports, and Licensed and Regulated betting, from Web3 – but also risks involved.
Blockchain and NFT technology could be used in racing, for example, to track and record provenance of bloodstock; to open new revenue streams from licensing image rights and intellectual property for NFT projects; and to possibly attract a new, younger, audience to the sport.
Crypto projects have already provided a financial boon to teams via sponsorship and naming rights (although some high-profile sponsors have since gone bankrupt). In 2021 it was reported that four English Premier League clubs had earned GBP 150 million through Socios,while Sorare in late 2022 was reportedly close to agreeing a GBP 30million-a-year partnership with the EPL.
But as with any new technology, stakeholders need to understand risks. This is particularly important given the crossover between crypto and gambling, the lack of regulation, and the prevalence of fraud and bad actors. There are reputational and even financial crime risks to racing and other sports from this.
In football, teams have been criticised for exploiting supporters via NFT promotions – and even encouraging gambling-like speculative trading.
Even prominent products such as Sociosand Sorarehave been accused by media of price manipulation and insider trading, (the companies deny these claims), while lesser-known ones have been outright scams.
Football team Manchester City illustrates both ends of this spectrum: it reportedly receives USD 20 million a year in sponsorship from Chinese cryptocurrency exchange OKX, but also ended a partnership with a crypto finance scheme which promised 150% annual returns to investors, after reports that the company did not appear to exist.(And OKX, despite being the more ‘reputable’ of these two crypto entities, has been banned in China, its founder subject of police interest, and is under investigation for alleged securities violations in Canada).
The spectacular demise of FTX, a very high-profile cryptocurrency exchange which filed for bankruptcy in November amid allegations of governance failings even worse than Enron,further illustrates the risks. FTX had many sports sponsorship deals including:“the official crypto exchange of Major League Baseball, official crypto partner of the Mercedes Formula One team, official crypto and NFT partner for the Washington Wizards (NBA) and Capitals (NHL) … an international rights deal with the Golden State Warriors”and a 19-year naming rights deal for the Miami Heat basketball arena. It also had several individual deals with some of the biggest American sports stars.
A February 2022 quote from Miami Heat’s marketing director (emphasis added)illustrates – in hindsight – both why such firms want to be associated with sports, and the flip-side potential reputational risk to sports of such association should things go wrong:
“I think when people saw the Heat were willing to get in bed with FTX, it gave them a check of legitimacy … People were calling and asking about it. We have a certain level of respect in our league and around professional sports that when we aligned with them, people saw them as legit.”
The Miami Heat have since dropped the FTX name from their arena and it is not known how much, if any, of the reported USD 135 million deal’s value the team (and the local government which stood to benefit) actually received.
(Coincidentally, FTX was an investor in BetDex, the blockchain betting exchange mentioned above.)
Because of such collapses, many have fundamental doubts about NFTs and blockchain technology in general. NFT marketplaces have been rife with counterfeit intellectual property, scams and wash trading.Fraud, hacks and ‘rug pulls’ – where founders disappear with crypto investors’ money – are prevalent in the crypto space, including in GameFi. In March 2022, hackers linked to North Korea stole ~USD 620 million of cryptocurrency from Axie Infinity’s blockchain, the largest ever crypto heist.
Cybercriminals, including illegal betting operators, are finding ways to exploit the metaverse to launder money. INTERPOL has warned the metaverse will open a new world of cybercrime,while an upcoming EU anti-money laundering law will reportedly include language highlighting such threats.Separately, the European Commission’s 2022 Supranational Risk Assessment Report in November 2022 rated online betting as a maximum risk of money laundering and terrorist financing for reasons including virtual currencies, gaming tokens that qualify as crypto assets, and the proliferation of unlicensed websites.
Also, as detailed in previous ARF Council publications, individuals linked to organised crime, illegal betting and money laundering, such as convicted triad gangster ‘Broken Tooth’ Wan Kuok Koi, have been heavily active in crypto and gambling schemes.
Finally, stakeholders in the Licensed and Regulated betting industry need to be aware of the potential for unregulated Web3 / metaverse gambling and gambling-like products to both cause harm to consumers and potentially to attract people, particularly young people, away from well-regulated responsible sports wagering to unregulated alternatives.
 Gilad Edelman, ‘TheFather of Web3 Wants You to Trust Less’, Wired, 29 Nov 2021 (https://www.wired.com/story/web3-gavin-wood-interview/ accessed 25 October2022)
 Usually used to refer to Google, Amazon, Apple, Meta (Facebook) and Microsoft but also encompassing large technology companies in general
 Taylor Locke, ‘ToElon Musk, Web3 seems more like a ‘marketing buzzword’ than a reality’, CNBN,December 2021 https://www.cnbc.com/2021/12/20/elon-musk-web3-seems-more-marketing-buzzword-than-reality-right-now.html accessed 25 October2022)
 Gilad Edelman, ,‘Paradise at the Crypto Arcade: Inside the Web3 Revolution’, Wired, 10May 2021 (https://www.wired.com/story/web3-paradise-crypto-arcade/ accessed 25 October2022)
 Sam Dean, ‘$69million for digital art? The NFT craze explained’, Los Angeles Times, 11 March2021 (https://www.latimes.com/business/technology/story/2021-03-11/nft-explainer-crypto-trading-collectible accessed 25 October2022)
 Louis DeNicola, ‘Whatto know about non-fungible tokens (NFTs) – unique digital assets built on blockchain technology’, Business Insider, 1 September 2021 (https://www.businessinsider.com/nft-meaning accessed 25 November2021)
 KC Ifeanyi, ‘The Bored Ape Yacht Club apes into Hollywood’, 18 January 2022 (https://www.fastcompany.com/90706534/the-bored-ape-yacht-club-apes-into-hollywood accessed 25 October2022)
 Natasha Dailey, NFTs ballooned to a $41 billion market in 2021 and are catching up to the total sizeof the global fine art market, Business Insider,January 7 2022 (https://markets.businessinsider.com/news/currencies/nft-market-41-billion-nearing-fine-art-market-size-2022-1
 Paul Vigna, ‘NFT Sales Are Flatlining’, The Wall Street Journal, 3 May 2022 (https://www.wsj.com/articles/nft-sales-are-flatlining-11651552616 accessed 25 October2022)
 An entirely simulated, 3D virtual world perceived through goggles
 An overlay of digital imagery onto the real world by e.g. smart glasses or through a smartphone screen
 ‘Introducing Meta: A Social Technology Company’, Meta, 28 October 2021 (https://about.fb.com/news/2021/10/facebook-company-is-now-meta/ accessed 25 October2022)
 Conn Stamford,‘Gartner Predicts 25% of People Will Spend At Least One Hour Per Day in the Metaverse by 2026’, Gartner, 7 February 2022 (https://www.gartner.com/en/newsroom/press-releases/2022-02-07-gartner-predicts-25-percent-of-people-will-spend-at-least-one-hour-per-day-in-the-metaverse-by-2026 accessed 25 October2022)
 ‘A beginner’s guide to the GameFi ecosystem’, Cointelegraph, (n.d.) (https://cointelegraph.com/metaverse-for-beginners/a-beginners-guide-to-the-gamefi-ecosystem accessed 25 October2022)
 ‘What is GameFi? ‘Play-to-Earn’ Gaming Explained’, Crypto, 3 August 2022 (https://crypto.com/university/what-is-gamefi-play-to-earn-gaming-explained accessed 25 October2022)
 Christian Nunley,‘People in the Philippines are earning cryptocurrency during the pandemic by playing a video game’, CNBC, 14 May 2021 (https://www.cnbc.com/2021/05/14/people-in-philippines-earn-cryptocurrency-playing-nft-video-game-axie-infinity.html accessed 25 October2022)
 Miles Kruppa, TimBradshaw, ‘Crypto’s hottest game is facing an economic maelstrom’, Financial Times. 26 November 2021 (https://www.ft.com/content/b0c49d6f-a06a-4def-8469-45ad009ac13c accessed 25 October2022)
 Edward Ongweso Jr,‘The Metaverse Has Bosses Too. Meet the ‘Managers’ of Axie Infinity’,Vice, 4 April 2022 (https://www.vice.com/en/article/88g3ag/the-metaverse-has-bosses-too-meet-the-managers-of-axie-infinity accessed 25 October2022)
 Carla Mozee, ‘A plot of virtual land that went for $4.3 million in The Sandbox is the most expensive metaverse property sale ever’, Insider. 30 November 2021 (https://www.businessinsider.in/stock-market/news/a-plot-of-virtual-land-that-went-for-4-3-million-in-the-sandbox-is-the-most-expensive-metaverse-property-sale-ever/articleshow/88015620.cms accessed 25 October2022)
 Richard Laycock, ‘NFT Gaming Statistics’, Finder.com, 25 May 2022 (https://www.finder.com/hk/nft-games-statistics )
 ‘This NFT Game Changer Allows Users to Benefit on Real-Life Horse Racing’, Cryptonews,3 November, 2022 (https://cryptonews.com/news/this-nft-game-changer-allows-users-to-benefit-on-real-life-horse-racing.htm accessed 25 October2022)
 ‘Find and update company information Kiavash JOORABCHIAN ‘, GovUK, (n.d.) (https://find-and-update.company-information.service.gov.uk/officers/u6vtZaW5oikl-ongV-2YjrOxkY0/appointments accessed 25 October2022)
 ‘Game of Silks Raises$2 Million To Bring Thoroughbred Racehorses Onto The Blockchain’, Bitcoinist,April 2022 (https://bitcoinist.com/game-of-silks-raises-2-million-to-bring-thoroughbred-racehorses-onto-the-blockchain/ accessed 25 October2022)
 ‘Main Page’, Socios,2022 (https://www.socios.com/ accessed 25 October2022)
 ‘Lionel Messi signs$20m deal with crypto firm Socios to promote digital fan tokens - report’, ESPN,29 March 2022 (https://www.espn.com/soccer/paris-saint-germain--frapsg/story/4627240/lionel-messi-signs-$20m-deal-with-crypto-firm-socios-to-promote-digital-fan-tokens-report accessed 25 October2022)
 ‘Main Page’,Socios, 2022 (https://www.socios.com/ accessed 25 October 2022)
 ‘Erling Haaland NFT smashes Cristiano Ronaldo’s record after selling for more than $600,000’, ESPN,1 February 2022 (https://www.espn.com/soccer/blog-the-toe-poke/story/4583160/erling-haaland-nft-smashes-cristiano-ronaldos-record-after-selling-for-more-than-$600,000 accessed 25 October2022)
 Joey D’Urso,‘Sorare: ‘An unregulated timebomb’ or a fantasy game that will revolutionise football?’, The Athletic, 27 November 2021 (https://theathletic.com/2972039/2021/11/27/sorare-unregulated-timebomb-fantasy-game-revolutionise-football/ accessed 25 October2022)
 Elizabeth Lopatto, ‘NBA Top Shot seemed like a slam dunk — so why are some collectors crying foul?’ , Theverge, 7 June 2022 (https://www.theverge.com/23153620/nba-top-shot-nft-bored-ape-yacht-club accessed 25 October2022)
 Romain Dillet, ‘NBATop Shot creator Dapper Labs raises another $250 million’ , Techcrunch,22 September 2021 (https://techcrunch.com/2021/09/22/nba-top-shot-creator-dapper-labs-raises-another-250-million/ accessed 25 October2022)
 ‘Andrew Rhodes -speech at IAGR Conference 2022’ , Gambling Commission, 18 October2022 (https://www.gamblingcommission.gov.uk/news/article/andrew-rhodes-speech-at-iagr-conference-2022 accessed 25October 2022)
 Joey D’Urso, ‘Sorare:‘An unregulated timebomb’ or a fantasy game that will revolutionise football?’,The Athletic, 27 November 2021 (https://theathletic.com/2972039/2021/11/27/sorare-unregulated-timebomb-fantasy-game-revolutionise-football/ , accessed 25 October2022)
 Raphaël Grably, Parissportifs: l’Autorité nationale des jeux met en garde Sorare, qu’elle envisage de réguler’ , BFMTV, 29 July 2022 (https://www.bfmtv.com/tech/actualites/paris-sportifs-l-autorite-nationale-des-jeux-met-en-garde-sorare-qu-elle-envisage-de-reguler_AN-202207290014.html)
‘Consumer information notice: Sorare.com’ , Gambling Commission, 8 October 2021 (https://www.gamblingcommission.gov.uk/news/article/consumer-information-notice-sorare-com accessed 25 October2022)
 Tim Smith, ‘Is Sorarea gambling game, and what would that mean for the company?’, Sifted, 25 August2022 (https://sifted.eu/articles/sorare-gambling-nfts-fantasy-football accessed 26 Sep 2022)
 Autorite National desJeux, ‘At the request of the ANJ, SORARE undertakes to develop its game offer’,18 November 2022 (https://anj.fr/la-demande-de-lanj-sorare-sengage-faire-evoluer-son-offre-de-jeu accessed 22 November2022)
 Zed Run Terms of Service (https://zed.run/terms#:~:text=GAMES%20OF%20SKILL%20ARE%20PERMITTED,%2C%20AND%20CONSIDERATION%20TO%20PLAY)
 Paul Delfabbro,Amelia Delic, Daniel L.King, ‘Understanding the mechanics and consumer risks associated with play-to-earn (P2E) gaming’, AK Journals vol.11 issue3, (2022):p716-726. https://akjournals.com/view/journals/2006/11/3/article-p716.xml
 Sam Reynolds, ‘GameFi Faces Regulatory Headwinds in Major Asian Markets’ CoinDesk, February 12022 (https://www.coindesk.com/policy/2022/02/01/gamefi-faces-regulatory-headwinds-in-major-asian-markets/ )
 Tom Wiggins, ‘From Neigh to Zed: How Digital Horse Racing Became an NFT Favorite’, Decrypt,29 May 2021 (https://decrypt.co/72208/from-neigh-to-zed-how-digital-horse-racing-became-an-nft-favorite, accessed 25 October2022)
 Betmakers per media reports and LinkedIn https://www.linkedin.com/in/iamlaurent/
‘Wagerr x Zed Run Partnership’, Wagerr News, 18 January 2021 (https://news.wagerr.com/wagerr-x-zed-run-partnership/ accessed 25 October 2022)
‘Wagerr x Zed Run Partnership’, Wagerr News, 18 January 2021 (https://news.wagerr.com/wagerr-x-zed-run-partnership/ accessed 25 October2022)
 DeRace white paper https://derace.gitbook.io/derace/technical-summary/third-party-betting-and-streaming-solution
 Fred Steinmetz, ‘The interrelations of cryptocurrency and gambling: Results from a representative survey’, Science Direct vol. 138, (2022): 107508 https://www.sciencedirect.com/science/article/abs/pii/S074756322200259X
 Devin J Mills, LiaNower, ‘Preliminary findings on cryptocurrency trading among regular gamblers:A new risk for problem gambling?’, PubMed vol: 92 (2019): p136-140 https://pubmed.ncbi.nlm.nih.gov/30639898/
The Courier Mail (https://www.couriermail.com.au/business/victoria-business/from-computer-nerds-to-gambling-with-drake-meet-melbournes-crypto-billionaires/news-story/bc5dff7acca3dff1a29f25f392c8ac0d access 25 October2022)
 Gambling Apes (https://looksrare.org/collections/0x90cA8a3eb2574F937F514749ce619fDCCa187d45/activity
 http://slotie.com/ accessed 25 October2022)
 ‘Leading Software Company, Elia Announces The Launch of its NFT Project Is In the Works’,Bloomberg, 24 November 2021 (https://www.bloomberg.com/press-releases/2021-11-24/leading-software-company-elia-announces-the-launch-of-its-nft-project-is-in-the-works accessed 25 October2022)
 Paige Tortorelli,‘Four U.S. states order a metaverse casino to halt sale of NFTs’ CNBC 20October 2022 (https://www.cnbc.com/2022/10/20/four-us-states-order-a-metaverse-casino-to-halt-sale-of-nfts.html)
 LinkedIn profile (https://www.linkedin.com/in/paul-rogash-72497622/)
 BetU (https://betu-1.gitbook.io/betu/token-betu/tokenomics)
 Dean Takahashi,‘Stakes raises $5.3M for NFTs for sports wagering fans’, Venture Beat, 3May 2022 (https://venturebeat.com/business/stakes-raises-5-3m-for-nfts-for-sports-wagering-fans/ accessed 25 October2022)
 ‘BetDEX Exchange Becomes First Fully-Licensed Sports Betting Exchange On Blockchain’, Cision PR Neweswire (https://www.prnewswire.com/news-releases/betdex-exchange-becomes-first-fully-licensed-sports-betting-exchange-on-blockchain-301664556.html accessed 25 October2022)
 ‘The Startup Month#4’, Earnings+More ,1 November 2022 (https://earningsandmore.substack.com/p/the-startup-month-4?utm_source=substack&utm_medium=email accessed 25 October2022)
 Stoyan Todorov,‘BetDEX CEO Varun Sudhakar: “We Look Forward to Leading the Revolution inSports Betting and Web3’, Gambling News, 1 November 2022 (https://www.gamblingnews.com/news/betdex-ceo-varun-sudhakar-we-look-forward-to-leading-the-revolution-in-sports-betting-and-web3/ accessed 3 November2022)
 Conor Porter, ‘VegasCity: The metaverse’s specifically designed gambling hub’, SBC Americas,10 October 2022 (https://sbcamericas.com/2022/10/10/vegas-city-metaverse-gambling-hub/ accessed 25 October2022)
ZED RUN Unveils Resplendent New HQ in Decentraland, September 2021 https://nftplazas.com/zed-run-unveils-resplendent-new-hq-in-decentraland/
 Sean Dickens, ‘ICEPoker is attracting players in their thousands to the metaverse’, YahooFinance, 5 February 2022 (https://finance.yahoo.com/news/ice-poker-attracting-players-thousands-164538146.html accessed 25 October2022)
 Tom Morgan,‘Exclusive: Europe’s top clubs - including Arsenal and Man City - bank £150mfrom Socios ‘cryptocurrency’’, The Telegraph, 21 August 2021 (https://www.telegraph.co.uk/football/2021/08/21/exclusive-europes-top-clubs-including-arsenal-man-city-bank/ accessed 25 October2022)
 Mark Kleinman, ‘‘, SkyNews, 27 October 2022 (https://news.sky.com/story/premier-league-lines-up-30m-a-year-digital-tokens-deal-with-sorare-12731686 accessed 1 November2022)
 Joey D’Urso, ‘Special report: Socios expects to make £150 from each fan who buys a token’, The Athletic, 29 April 2022 (https://theathletic.com/3140771/2022/04/29/special-report-socios-expects-to-make-150-from-each-fan-who-buys-a-token/ accessed 25 October2022)
 Emma Roth, ‘‘Fan token’ company Socios accused of crypto price manipulation’, The Verge,13 March 2022 (https://www.theverge.com/2022/3/12/22974337/fan-token-company-socios-accused-cryptocurrency-price-manipulation accessed 25 October2022)
 Joey D’Urso, ‘Sorare:‘An unregulated timebomb’ or a fantasy game that will revolutionise football?’,The Athletic, 27 November 2021 (https://theathletic.com/2972039/2021/11/27/sorare-unregulated-timebomb-fantasy-game-revolutionise-football/ accessed 25 October2022)
 Alessandra Bonifacio,‘UEFA football crypto fund: a multi-million euro scam’, Cryptonomist, 21October 2022 (https://en.cryptonomist.ch/2022/10/21/uefa-football-crypto-millionaire-scam/ accessed 25 October2022)
 Jack Gaughan,‘Manchester City end partnership with mysterious crypto firm 3Key Technologies after just two months, as firm executives did NOT appear in online searches’, DailyMail, 5 January 2022 (https://www.dailymail.co.uk/sport/football/article-10372971/Manchester-City-end-partnership-mysterious-crypto-firm-3Key-Technologies.html accessed 25 October 2022)
 Philippe Auclair,‘City of controversy’, Josimar, 18 July 2022 (http://josimarfootball.com/city-of-controversy/ accessed 25 October2022)
 According to liquidator’s comments in bankruptcy filing – the liquidator is the same person who handled Enron’s liquidation
 Jeff Beer, ‘How FTX led crypto’s takeover of sports in less than a year’, Fast Company, 7February 2022 (https://www.fastcompany.com/90717799/how-ftx-led-cryptos-takeover-of-sports-in-less-than-a-year accessed 18 November2022)
 Lora Kelley, ‘FTX Spent Big on Sports Sponsorships. What Happens Now?’, New York Times, 10November 2022 (https://www.nytimes.com/2022/11/10/business/ftx-sports-sponsorships.html accessed 18 November2022)
 Eli Tan,‘Solana-Based Sports Betting Protocol BetDEX Closes $21M Seed Funding Round’, CoinDesk,18 November 2021 (https://www.coindesk.com/business/2021/11/17/solana-based-sports-betting-protocol-betdex-closes-21m-seed-funding-round/ accessed 18 November2022
 Lois Beckett, ‘‘Hugemess of theft and fraud:’ artists sound alarm as NFT crime proliferates’, TheGuardian, 29 January 2022 (https://www.theguardian.com/global/2022/jan/29/huge-mess-of-theft-artists-sound-alarm-theft-nfts-proliferates accessed 25 October2022)
 Edward Ongweso Jr,‘The NFT Ecosystem Is a Complete Disaster’, Vice News, 2 February 2022 (https://www.vice.com/en/article/xgdvnd/the-nft-ecosystem-is-a-complete-disaster accessed 25 October2022)
 Theo Tsihitas,‘Worldwide cryptocurrency heists tracker (updated daily)’, Comparitech,3 November 2022 (https://www.comparitech.com/crypto/biggest-cryptocurrency-heists/ accessed 25 October2022)
 Dina Kartit and
 Jack Schickler,‘Money Laundering via Metaverse, DeFi, NFTs Targeted by EU Lawmakers’ Latest Draft’, CoinDesk, 29 September 2022 (https://www.coindesk.com/policy/2022/09/29/money-laundering-via-metaverse-defi-nfts-targeted-by-eu-lawmakers-latest-draft/ accessed 25 October2022)
 European Commission, Commission Staff Working Document, 27 October 2022, (https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52022SC0344&qid=1668133326304&from=EN accessed 22 November2022, pages 201-236)
 US Department of the Treasury, Treasury Sanctions Corrupt Actors in Africa and Asia, December 92020, (https://home.treasury.gov/news/press-releases/sm1206)