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Complaint to Alderney Gaming Control Commission re: Full Tilt Poker

Complaint to Alderney Gaming Control Commission re: Full Tilt Poker

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Complaint to AGCC re: Full Tilt, the AGCC and Full Tilt tried to duck this, a different version has been filed with the Kahnawake Gaming Commission. The credit companies have reaped million in fees and interest due to money laundering activities by Full Tilt.
Complaint to AGCC re: Full Tilt, the AGCC and Full Tilt tried to duck this, a different version has been filed with the Kahnawake Gaming Commission. The credit companies have reaped million in fees and interest due to money laundering activities by Full Tilt.

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Published by: Dr. Jonathan Levy, PhD on Nov 18, 2011
Copyright:Attribution Non-commercial

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10/12/2013

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IN THE ALDERNEY GAMBLING CONTROL COMMISSION
BETWEEN[REDACTED], ON HIS BEHALF AND ON BEHALF OF THOSE SIMILARLYSITUATED,PLAYER CLAIMANTSVsORINIC LTD, FILCO LTD, VANTAGE LTD, OXALIC LTD, doing business as asFULLTILTPOKER.COM, FULL TILT POKER LTD., POCKET KINGS LLC.,TILTWARE LLC, RAYMOND BITAR, NELSON BURTNICK, KOLYMACORPORATION A.V.V., POCKET KINGS CONSULTING LTD., RANSTON LTD.,MAIL MEDIA LTD., ORGONISE-AFRICA BIZ, BIDROYAL.COM, UNLIKE.NET,CHAMBERTEL, SIMPLYSELL,NET, AND OTHER UKNOWN ENTITIES ANDTHIRD PARTIES THAT HAVE PROFITED THEREFORM COLLECTIVELYKNOWN HERE IN AS “FULL TILT.”RESPONDENTS
I. INTRODUCTION
This is a Player Complaint on behalf of the Player and all others similarly situatedhereafter known as “The Class.” Player and class members are citizens of the UnitedStates. From 2009 through June 28, 2011 Players and those similarly situated werePlayers registered with respondent “Full Tilt.” Full Tilt knowing and intentionallyviolated the Unlawful Internet Gambling Enforcement Act ("UIGEA"), making it aUnited States federal crime for gambling businesses to "knowingly accept" most forms of payment "in connection with the participation of another person in unlawful Internetgambling"Full Tilt in carrying out it unlawful conspiracy to violate the UIGEA induced Players touse their credit cards to place bets in small amount, usually $50 at a time to circumventreporting requirements by credit card processors and anti money laundering regimes. Thetransactions were processed through various front entities such as Orgonise Africa,BidRoyal, Chambertel, Simplysell and Unlike.Claimants were damaged by the illegal and scandalous behavior by respondents actingunder the guise of an entity licensed by the AGCC in that they incurred large debts ontheir credit card with interest and fees after being induced to place bets though a moneylaundering scheme initiated by Full Tilt. These debts are not dischargeable and theclaimants have incurred annual interest charges in excess of 20%. Player Claimants seek 
 
TO BE FILED UNDER SEAL
Brimstone & Co.Attorneys & Solicitors1629 K Street NW Suite 300 Washington DC 20006 USA Tel/Fax 1-202-318-2406info@brimstoneandcompany.com
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$400 million from Full Tilt to compensate them for interest and fees incurred as a resultof the organized money laundering by Full Tilt.
II. JURISDICTION
In the first instance the AGCC is vested with jurisdiction over both money laundering andplayer complaints in regards to its licensees under the Alderney eGambling Regulations2009:Section 233 (1) An eGambling licensee, a foreign gambling associate certificate holderand, to the extent applicable, other associates shall comply with the money launderingand terrorist financing provisions set out in Schedule 16 to the extent that such provisionsare therein stated to apply to such a licensee, certificate holder or associate.(2) For the purposes of section 24(5) of the Ordinance, any requirement set out inSchedule 16 is specified as a
money laundering offence
.Sections 238-240 deal with player complaints and the adjudicative process.This procedure provides for mediation, investigation and fact finding by the AGCC. TheAGCC by revoking and/or suspending the respondent’s license has already accomplishedand compiled much of the material needed to make a determination should the parties notbe able to come to terms. Invoking this process therefore is not burdensome to the AGCCwhich has been paid fees over the years by the respondent and whose expertise claimantshave relied upon. Without a finding by the AGCC on this matter claimants will beunduly prejudiced as unable to exhaust local remedies should commencement of a classaction lawsuit in the United States against Full Tilt and third parties who have beenunjustly enriched at claimants’ expense be necessary.While the claimants reserve all jurisdictional objections to the Courts of Alderney,claimants do recognize that the AGCC itself is vested with initial jurisdiction as anarbitrator under the Arbitration (Guernsey) Law (1982).
III. REFUSAL BY CREDIT CARD COMPANY TO MITIGATE
Claimant has attempted to mitigate his debt to Bank of America (See Exhibit One) andhas also reported this matter to US FINCEN. Based on the premise that debt was incurredJanuary through November 2009 through the money laundering machinations of respondents, Bank of America has refused any relief on the grounds that the anti moneylaundering provisions
 
of the
 
UIGEA did not apply to United States financial institution
 
TO BE FILED UNDER SEAL
Brimstone & Co.Attorneys & Solicitors1629 K Street NW Suite 300 Washington DC 20006 USA Tel/Fax 1-202-318-2406info@brimstoneandcompany.com
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until June 1, 2010 even though the underlying transaction were illegal under the UIGEA.Thus Claimant and those similarly situated have no remedy for credit card debts andinterest incurred after the passage of the UIGEA in 2006 but prior to its provisions comeinto effect as to banks and credit card companies June 1, 2010.
IV.
 
FACTS
 Claimant is a resident of New York. In 2009 he incurred substantial debt to Full Tilt as aregistered player. The UIGEA was in effect in 2009 rendering the use of credit cards byFull Tilt illegal under US law. To circumvent this law Full Tilt engaged in a pattern andpractice of money laundering including the use of the cut out accounts like Organise-Africa, Chambertel, Simplysell, Unlike, and BidRoyal. Full Tilt set up these phonybusinesses to evade credit card restrictions in the United States on their activities underthe UIGEA. Full Tilt also used purchases for stored value cards and e-checks to avoiddetection by Visa and MasterCardThe AGCC has conducted an anti money laundering investigation and a regulatoryproceeding into this Full Tilt matter and is in possession of evidence that support boththese allegations and others unknown to claimants but known to the Commission andtherefore incorporates this investigation by reference as well as asking the AGCC to takenotice of the criminal indictment of Full Tilt in the United States for money laundering.
V. DAMAGES
Claimants have been damaged. While the bets placed were illegal in the United Statesthey were legal under laws of Alderney, the money laundering however itself is a crimein both jurisdictions. As a result of the AGCC licensee’s institutional money launderingwhich has been verified by the Commission, claimant and those similarly situated haveincurred an estimated $1 billion in debt upon which they have paid a minimum of 20%interest and fees per annum to credit card companies. Class damages are at least $400million.
VI LEGAL ARGUMENT
Claimant does not believe there is any legal precedent in Guernsey or Alderney caseannals which cover this particular fact pattern of an e-gambling, money laundering, classbased complaint therefore claimant refers herein to both applicable Guernsey and Englishlaw which may be deemed persuasive. See
 Helmot v. Simon
, Guernsey Law Reports2009-10 GLR 465:

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