The Relationship Between Betting, Match-Fixing and Money Laundering: Public Policy and Practice Recommendations for Countering The
1. Introduction
In this article, we will first address the relationship between betting and money laundering, and then offer recommendations for preventive and detective mechanisms applicable to stakeholders such as public institutions, federations and operators.
2. What Happened in the Betting Investigation?
On October 27, 2025, the TFF President announced that 371 of the 571 referees had betting accounts, and 152 were actively betting. It was reported that some accounts displayed unusual transaction volumes, with up to 18,227 transactions in a single account. Between November 1 and 3, 2025, disciplinary committees imposed eight- to twelve-month suspensions on 149 referees and assistant referees; some cases were reported to be ongoing. In summary: While there was no direct evidence of match-fixing, we witnessed with our own eyes how insider market abuse and money laundering (ML) risks can permeate the ecosystem.
3. Legal Framework in Türkiye: An Integrated View
Let’s begin by simplifying the concepts that define the legal framework. In Türkiye, sports integrity, betting, and anti-money laundering (AML) rules fall into four main pillars:
- Law No. 6222 (Preventing Violence and Disorder in Sports): It explicitly criminalizes match-fixing and incentive bonuses. It regulates the responsibilities and sanctions of all players, including club managers, athletes, referees, and intermediaries. It acts as a bridge between disciplinary and criminal law. It stipulates penalties and complicity provisions restricting freedom for actions that could influence the outcome or course of a match (e.g., obtaining money or benefits); it also paves the way for the implementation of security measures specific to legal entities when necessary.
- Law No. 7258 (Betting and Games of Chance Regime): Requires that betting be conducted under state monopoly and licensed structures. It criminalizes unauthorized/unlicensed (including offshore) organizations, the transfer of funds to these structures, and advertising/promotion. This framework also covers the oversight of licensed operators, responsible gaming and advertising principles, and consumer protection rules. Along with federation regulations and disciplinary provisions, it provides the basis for implementing the ‘betting ban’ for players in the sports ecosystem.
- Law No. 5549 (Prevention of Laundering Proceeds of Crime) and secondary regulations: Mandates risk-based know-your-customer (KYC), continuous monitoring, record keeping, and suspicious transaction reporting (STR) for obligors such as banks, electronic money institutions, and licensed betting/gaming operators. Topics such as the "tipping off" prohibition, which can be defined as the prohibition on providing information to suspects or other parties, the risk-based approach, compliance officer/compliance program, training, and internal audit are detailed in the Regulation on Measures. In practice, MASAK (Financial Crimes Investigation Board) consolidates schemes and red flags through guidelines and typology bulletins.
- Turkish Penal Code (Türk Ceza Kanunu - TCK) Article 282 (Money Laundering Offense): It regulates the laundering of assets derived from crime as a separate crime. It provides criminal liability for transactions conducted at different stages of laundering (placement, layering, and integration). Fund flows legitimized through sports betting can be considered within the scope of this article with sufficient evidence.
International reference points play a complementary role in the interpretation and application of domestic law:
- The Council of Europe Macolin Convention: It provides for the establishment of national platforms against the manipulation of sports competitions, multi-stakeholder intelligence sharing and warning mechanisms between public authorities, sports organisations, licensed betting industry, enforcement bodies, conflict of interest/betting ban rules for sports participants and tools to combat illegal/offshore operators.
- FIFA/UEFA and IFAB (International Football Association Board) regulations and national federation disciplinary codes: They set minimum standards for referees and other participants in terms of betting bans, integrity training, data sharing and a catalogue of sanctions; at the national level, the TFF Disciplinary Regulations and Competition Regulations embody this framework in domestic law.
- Financial Action Task Force (FATF) and Egmont Group resources: Typologies of laundering through gambling/betting channels, the intersection of P2P and crypto assets, and the use of third parties/mules provide red flags and examples of best practices related to risks such as these. These international standards are used as a basis for interpreting obligations under Türkiye’s anti-money laundering and countering the financing of terrorism (AML/CFT) regime.
Thanks to this integrated framework, disciplinary, administrative, criminal and financial sanctions can be aligned and implemented together in cases that create ‘integrity risks,’ such as referees’ betting activities.
4. Risk Chain: The Relationship Between Insider Betting, Manipulation, and Money Laundering
Referees have access to non-public information such as appointments, injuries, tactics, pitch conditions, VAR operation, and in-match trends. This information asymmetry allows them to profit from betting results by exploiting pricing/delay advantages in live betting lines, even without attempting to manipulate the match outcome; in other words, it creates a favorable environment for market exploitation. This can be compared to insider trading in publicly traded companies. Micro-events that the referee can directly influence (cards, corners, penalties, extra time, etc.) increase the risk of spot fixing, that is, the manipulation of micro-events under the referee's control. Persistent and significant deviations in these micro-event statistics compared to their counterparts are a warning sign that should be heeded.
Below, we summarize how sports betting channels can facilitate the three classic stages of the money laundering (ML) cycle in practice – placement, layering, and integration – based on typologies and case studies available in open sources:
- Placement: Cash or criminal funds are distributed through small, repeated deposits (smurfing) into betting accounts, coupons/voucher codes, prepaid cards, or physical dealer/ATM networks. Low-volatility "matched betting" and low-risk combinations are used to balance losses and profits in the initial phase, creating a visible "game history." Using third-party accounts (mules) or those of relatives/friends, the direct link between the perpetrator and the betting account is weakened. The insider advantage previously discussed on the referee's part can be used to rationalize ‘extraordinary success’ during the placement phase, masking the anomaly.
- Layering: The transaction trail is fragmented by rapid small-amount transfers between multiple betting operators and e-wallets; interspersed hedged positions with the same results across different operators; and frequent early cash-out and void/cancel cycles. Funds are layered across cryptocurrency platforms and P2P markets; and geographical layers are added using foreign payment institutions/session and OTC (over-the-counter) intermediaries. Data such as shared device/IP footprints, shared card/IBANs, and synchronized betting timestamps, along with indicators of actual connections between seemingly independent accounts, may indicate that these accounts are actually part of an organized network acting jointly for layering purposes. Synchronous in-play volume spikes prior to referee appointment/starting lineup/VAR communications, if they coincide with ‘information-based’ patterns during layering, may indicate that referees are also acting in concert with this organization.
- Integration: Amounts transferred from betting operators to bank/e-money accounts under the guise of ‘earnings’ can be declared as legitimate income and accounted for through consulting, social media/bonus/reward payments, or small business activities. Value transformation is completed through methods such as debt/loan repayment, luxury spending, and real estate/vehicle acquisition. Invoicing/mutual debt scenarios through close associates or related companies are used to strengthen the economic justification for ‘earnings.’ These flows directed to the accounts of referees or their relatives are typical indicators of integration in terms of registration and suspicious transaction reporting (STR) obligations under Article 5549.
The patterns we describe in these stages can often be complemented by secondary patterns such as: (i) account farms and mule networks, (ii) cross-border coupon/crypto/P2P bridges, (iii) unusually intensive use of arbitrage or “sure bet” opportunities, (iv) arbitrage appointments and clusters of simultaneous bets concentrated around micro-events.
5. Red Flags
We can summarize possible early warning signals, red flags, for different institutions and organizations that have a role in the process as follows:
For licensed betting operators:
- High volume of live betting and exceptional success rates incompatible with a low/declarative income profile; high ROI (return on investment) in a short time.
- Multiple accounts opened with the same device/IP/device; common address/payment instrument; fund transfers similar to “chip dumping” between accounts.
- Pre/during match concentration on critical micro-event markets (card, corner, penalty, extra time); simultaneous betting clusters aligned with odds movement once referee appointment is announced.
- Abnormally high rates of early cash out/void; small but overall large volume of coupons scattered across the same selections at different operators; systematic arbitrage.
- Frequent small amount logins to betting accounts from crypto exchanges/OTCs, e-wallets and foreign payment institutions; KYC discrepancies, undocumented address/income declarations.
For banks/fintechs:
- Near-time recurring transfers to multiple licensed operators/e-wallets within a client; cyclical cash flow peaking during fixture weeks, followed by offshore/crypto outflows.
- Signals of connection to the sports ecosystem: Last name/address/IP/device affiliations with referees/club officials; payments with the description “consulting/bonus/social media collaboration.”.
- Small, similarly described payments from multiple third parties (mule network indicator); serial cash withdrawals from ATMs/digital channels.
- Unexpected forex/crypto transactions; high frequency on P2P exchanges; signs of round tripping (selling and then rebuying similar assets and values at short intervals).
For clubs/TFF:
- Recurring market anomalies when certain referees are appointed; correlation between rate movements and referee decision metrics.
- Income-to-living standard mismatch; paying off debt quickly, spending lavishly; assets acquired through third parties.
- In-play pileups indicating information leaks before appointment change/VAR protocol update.
- Potential conflicts of interest: Financial or digital ties to family members/agents/managers; confidential consulting agreements.
These red flags need to be clearly recorded so that detailed investigations (Enhanced Due Diligence) can be conducted and, if necessary, STRs can be made or reported to other public authorities, and they can trigger disciplinary action and criminal prosecutions.
6. Managerial Control Design: Elements of “Good Practice” and a Proposed Policy Prescription
In light of the red flags and risk definitions listed above, let’s now take a look at the controls that institutions should establish:
TFF and league organizations:
- Zero tolerance and active verification: Betting bans should be based not only on disclosure, but also on regular data matching with licensed operators (using MoUs/APIs). Explicit consent and periodic conflict of interest disclosures should be standardized as a condition of engagement.
- Integrity risk scoring and behavioral analytics: Peer-to-peer deviations in debit/stress indicators, assignment changes and card/penalty/extra decision metrics should be monitored; close monitoring protocols should be established for the relevant referees and officials automatically when set limits are exceeded.
- Market surveillance integration: Data analytics solutions should be developed that allow for real-time cross-referencing of live betting anomaly flows (odds jumps, “sure bet” density) with assignment/in-match data.
- Education and awareness programs: Role-based, scenario-focused ethics, conflict of interest, and AML/KYC training should be provided for referees, officials, players, and other stakeholders. At least one mandatory module per year, along with match-week micro-training, e-learning, and exam processes, should be implemented. Awareness kits and code of conduct/ethics compliance modules should be developed for managers, agents, and sponsors, and completion of these modules should be mandatory in licensing and license renewal criteria.
- Debt/welfare support programs; A counseling hotline and anonymous assistance mechanisms should be established, the indebtedness and welfare of officials should be closely monitored, and issues that can support officials in resolving potential problematic situations should be identified.
- Device and network policy: Technically blocking betting applications on matchday access devices; technical preventive and detective controls such as network monitoring in critical areas such as the dressing room/VAR room should be developed.
- Reporting and regret: Moderate reductions should be applied to those who self-report before manipulation is detected, and progressively escalating sanctions should be applied to repeat and serious violations. Deterrence should be strengthened through transparent sanctions bulletins and anonymized case summaries.
- Data protection and legitimate purpose: Data minimization, access control, and retention periods in accordance with the Personal Data Protection Act (KVKK) should be determined; the legal basis for data sharing should be clearly documented.
Licensed betting operators:
- PiS - Participant in Sport labelling and denylist: A KYC process should be established to identify referees, athletes, technical staff, managers, and representatives at the application stage; periodic synchronization should be ensured with a ‘denylist’ created in coordination with the TFF and the federations of other sports branches in question; a reporting mechanism should be established to reject/restrict matching applications and report these applications to the relevant federations.
- Advanced KYC and continuous monitoring: Data analytics tools that can monitor device fingerprinting, IP risk scores, geographic anomalies, multiple accounts, and third-party payment instrument usage should be developed; methods applied in financial institutions, such as verifying the source of funds in high-risk profiles (Source of Funds/Source of Wealth), should be followed.
- Scenario analytics: Data analytics and technological methods such as simultaneous in-play volume increases, arbitrage and early cash out density, void/cancellation rates, and correlation analysis across different operators simultaneously should be applied before referee-controlled micro-events.
- Recording and reporting: Control mechanisms for the integrity of the institution should be developed, such as the secure storage of transaction telemetry, communication and payment traces for the period stipulated by legislation; targeted EDD and timely STR; and regular AML/integrity training for employees.
Banks/fintechs:
- Determining gaming/betting exposure: Entries originating from betting should be identified using the Merchant Category Code (MCC), counterparty lists, and classifications; fund entry analyses that can identify entries with clustered ‘earnings’ descriptions should be developed.
- High risk classification: Increased risk assessment and classification should be implemented for referees/club officials and their immediate surroundings; dynamic monitoring and rapid STR/reporting mechanisms should be established during fixture periods where intense betting is expected.
- Control of crypto/e-currency bridges: Additional investigations should be conducted on transfers to P2P exchanges and e-wallets, including monitoring and detection of geographic/day/night anomalies, and comparing account holder profiles with the volume of transactions occurring on their accounts to enable third-party/mule identification. These mechanisms are already implemented in various areas in accordance with anti-CPA legislation and best practices.
7. Review Guide: What to Do When a Red Flag Is Spotted
A. Fast protection and chain of custody:
- Legal hold: Betting transaction logs, KYC files, session/IP/device data, customer communications, and payment/withdrawal instructions should be collected and secured with immutable hashes and timestamps. This chain should be defined as a responsibility of all stakeholders, particularly to prepare for potential investigations by legal authorities.
- Record keeping: Secure storage for the periods stipulated by the legislation, recording of access authorizations, and minimization in compliance with KVKK must be ensured.
B. Analytical process, grouping and relationship networks (examples):
- Relationship mapping: Account-referee-proximity manager/agent networks; graph analysis based on common IBAN/card, device fingerprint, IP and address matches; mule clusters.
- Timeline and matching: Chronological matching of bet timestamps and in-match events (cards, corners, VAR, extra time); examining the impact of information releases such as appointment, starting 11 and VAR announcements on bet clustering.
- Financial monitoring: Layering indicators in betting operator, e-wallet, bank/crypto inflows/outflows; micro-slicing in P2P exchanges; recurring cycles with offshore payment institutions.
- Comparative metrics: Z-score deviations of suspect referee's decision metrics compared to peer group; comparison with previous season/league averages.
C. Legal coordination and notifications:
- STR under 5549: If the detected suspicion threshold is exceeded, notification to MASAK without delay; taking the necessary measures to prevent tipping off, i.e., providing insider information to employees/related persons; and operating internal approval and registration procedures.
- 6222/7258 processes: Coordination with the TFF; preparation of evidence and data for disciplinary investigations and, when necessary, applications to the prosecutor's office.
- International cooperation: Utilizing information sharing channels with the Macolin national platform, licensed operators and foreign regulatory/enforcement bodies.
D. Improvement and feedback loop:
- Post-closing root cause analysis; updating rule/analytic thresholds and risk assessments; training and process improvements.
- Anonymizing case summaries and sharing them with relevant stakeholders (operators, clubs, banks); reporting that ensures transparency for deterrent purposes and also prevents personal data breaches.
8. Policy and Regulation Recommendations: Concrete and Applicable Steps by Stakeholder
In this section, we will present clear public policy recommendations for various stakeholders, based on the “what, how, and when” framework. The recommendations are grouped by short-, medium-, and long-term, with the primary responsible unit and key performance indicators (KPIs) identified for each item in the following sections. In summary:
- Short (0–3 months): Denylist, customer acceptance policies, fast STR line, device/network policies, basic training.
- Medium (3–6 months): Market alert integration, risk score, dynamic monitoring, crypto/e-currency bridge controls, launch of the national platform.
- Long (6–12 months): Model validation, completion of guideline/standard sets, maturation of audit cycles, regular publication of transparent integrity bulletins.
8.1 TFF and League Organizations
- Central Sports Participant Denylist (Short): Creation of a standardized denylist with identity/verification fields covering referees, players, coaching staff, managers, and agents; continuous synchronization with licensed operators via API/MoU. KPI: Operator integration rate (%), number of automatic rejections/restrictions of matching records.
- Proactive Verification of Betting Ban (Short): Mass screening before assignment; rechecks with increased frequency during match weeks. KPIs: Number of officials screened, detection rate, violation catch time (T to Detect).
- Risk Score and Surveillance Panel (Medium): Dynamic risk scoring with signals such as referee decision metrics, debt/stress indicators, assignment changes, and VAR intervention rates; case opening for detailed review when risk score thresholds are exceeded. KPI: Response time per high-risk case, high-risk score rate.
- Real-Time Market Alert Integration (Medium): Assignment of live odds anomaly feeds (alert feeds) and automatic matching with in-match data. KPI: Alert case conversion rate, time from alert to first action.
- Reporting/Leniency Window and Sanction Matrix (Medium): Discounts for self-reporters, increased sanctions for repeat violations; regular publication of an "Ethics Bulletin." KPI: Number of self-reports, repeat violation rate.
- KVKK Compliant Data Governance (Medium): Documentation of legitimate purpose, data minimization, retention periods, and access controls. KPI: Number of access violations, audit findings.
8.2 Licensed Betting Operators
- PiS Labeling and Customer Acceptance Policy (Short): Sports participant identification, application rejection/restriction; daily matching with denylist. KPI: Number of matches, rate of rejected applications.
- Advanced KYC and Continuous Monitoring (Medium): Device fingerprinting, IP risk score, geo anomaly, multi-account, and third-party payment instrument rules; high-risk SoF/SoW validation. KPI: Number of cases caught by rule, manual review efficiency.
- Scenario Analytics and Model Validation (Medium): Data and scenario sets for simultaneous in-play volume growth, arbitrage, early cash out, and void/cancellation density prior to peer-controlled micro-events; annual independent model validation. KPIs: AUC/Recall, SAR (suspicion action rate), false positive ratio.
- Recording, Reporting and STR Quality (Short): Storage of transaction telemetry and payment trails in accordance with legislation; “event pattern + financial trail + timing” integrity in STRs. KPI: MASAK feedback score, returned/missing STR rate.
- Employee Integrity/AML Training (Short): Case-based micro-training; exam and case simulations. KPI: Training completion rate, exam success score.
8.3 Banks and Fintechs
- Betting Income Determination Rules (Short): Automatic detection of betting winning patterns with MCC, counterparty lists, and naming conventions. KPI: Number of suspicious flows detected, false alarm rate.
- High Risk Classification and Dynamic Monitoring (Short): Increased risk for referees/club officials and their immediate surroundings; intensified monitoring during fixture periods. KPI: High-risk portfolio size, alert case rate.
- Crypto and E-Currency Bridge Controls (Short): Transfer speed limits to P2P exchanges/e-wallets, geographic/day/night anomaly rules, and graph analysis for mule detection. KPI: Blocked/reviewed transaction rate.
- Quick STR and Tipping Off Measures (Short): Expedited internal approval pipeline; tipping-off awareness for staff. KPI: Median STR submission time, number of compliance violations.
8.4 Clubs and Referee Rules
- Conflict of Interest and Asset Disclosure (Short): Periodic declaration in referee and critical roles; declaration of close circle (family/representative) financial ties. KPI: Declaration completion rate, number of conflicts of interest identified.
- Welfare and Debt Management Supports (Short): Financial counseling, debt restructuring, and welfare programs; early warning for at-risk personnel. KPI: Program participation rate, risk reduction.
- Device and Network Policy (Medium): Technical blocking of betting applications on matchday access devices; VAR/dressing room network monitoring. KPI: Number of blocked access attempts, number of policy violations.
- Integrity Training and Attestation (Short): Case-based training; minimum of two attestation cycles per year. KPI: Training/attestation completion rate.
8.5 Regulatory and Public Authorities (TFF, MASAK, BTK, Ministries of Interior, Treasury and Finance)
- National Integrity Platform (Long): Permanent platform between TFF-operator-MASAK-police-BTK with Macolin principles; standard data schemas and SLAs. KPI: Number of shared alerts, cross-match hits.
- Joint Fight Against Offshore Illegal Betting (Medium/Long): Payment blocking, DNS/IP access measures, and cross-border collaboration; repeated list updates. KPI: Number of blocked domains/payment channels, traffic reduction rate.
- Standards and Guidelines (Short): Red flag lists for operators/banks/fintechs, STR “minimum content” templates, model validation guide. KPI: Guideline compliance score, reduction in audit findings.
- Consistency of Audit and Sanction (Long): Risk-based audit schedule for AML and betting regulations; increased sanctions for repeat violations. KPI: Audit closure time, repeat violation rate.
8.6 Technology Providers and Data Partners
- Alert Feed Quality (Short): Low latency streams for odds anomalies, co-op betting clustering, and cash out/void explosions. KPI: Latency (ms), alert accuracy rate.
- Device/IP Fingerprinting and Authentication (Medium): Common fingerprint layer for multi-account and mule detection; privacy-preserving matching. KPI: Link detection rate, false positive rate.
9. Conclusion
The picture emerging from referees' betting accounts concretely demonstrates the intertwined nature of sports integrity and money laundering risks, regardless of any directly proven match-fixing offenses. To mitigate these risks, it is critical for the TFF and federations to establish a centralized rejection list and proactively verify betting bans, for licensed operators to implement know-your-customer and advanced monitoring scenarios targeting sports participants, for banks and fintechs to implement specific red flag sets for betting-related flows, and for all parties to submit timely and high-quality suspicious transaction reports or reports to public authorities. When the national integrity platform established under the Macolin Convention is supported by data sharing and real-time market surveillance, a more transparent and accountable structure will emerge, strengthening the perception of fair competition, making it more difficult for criminal funds to infiltrate the sports ecosystem, and facilitating a more transparent and accountable structure.
10. Abbreviations Used in the Article and Definitions of Key Concepts
This section explains the abbreviations and key concepts in the text in plain language.
- TFF (Turkish Football Federation): The national federation responsible for the management of football in Türkiye; regulates the discipline, competition and integrity processes.
- AML (Anti-Money Laundering): Legal and operational framework for preventing money laundering.
- MASAK (Financial Crimes Investigation Board): Under Law No. 5549, it is Türkiye’s financial intelligence unit (FIU) responsible for STR acceptance, analysis and guidance.
- KYC (Know Your Customer): Processes for liable entities to verify the identity of the customer and understand their risk profile.
- EDD (Enhanced Due Diligence): Intensive due diligence and monitoring measures for high-risk customers/transactions.
- STR (Suspicious Transaction Report): Reporting to MASAK the transactions deemed suspicious by the liable parties.
- TCK (Turkish Penal Cokvkkde) Article 282: Article regulating the crime of laundering assets derived from crime.
- 6222: Law on the Prevention of Violence and Disorder in Sports; match-fixing/incentive bonuses and related crimes.
- 7258: Law on the Regulation of Betting and Games of Chance in Football and Other Sports Competitions; betting regime and the fight against illegal betting.
- 5549: Law on Prevention of Laundering Proceeds of Crime; obligations, registration and notification principles.
- Macolin Convention: The Council of Europe’s Convention on Manipulation of Sports Competitions sets out the principles of national platforms and data sharing.
- FIFA/UEFA/IFAB: International football governing and playing rules bodies set standards for integrity and betting prohibitions.
- BTK (Information Technologies and Communicaitons Authority): Electronic communications and internet regulator in Türkiye; competent in the field of access and technical measures.
- KVKK (The Personal Data Protection Act): Basic framework for the processing and protection of personal data.
- API (Application Programming Interface): Software interface that enables data exchange between systems.
- MoU (Memorandum of Understanding): Inter-institutional cooperation memorandum of understanding.
- PiS (Participant in Sport): Ecosystem actors such as referees, players, technical staff, managers, and agents.
- VAR (Video Assistant Referee): Video refereeing helps review critical decisions.
- ROI (Return on Investment): Return on investment ratio is also used as an indicator of profitability in betting accounts.
- OTC (Over-the-Counter): Over-the-counter financial/crypto transactions.
- P2P (Peer-to-Peer): Peer-to-peer; network/market structures where transfers occur directly between users.
- MCC (Merchant Category Code): Card payments code that identifies the business type.
- SoF/SoW (Source of Funds/Source of Wealth): Verification processes for source of funds and wealth.
- SAR (Suspicion Action Rate): The rate at which suspicious alerts are converted into action during alert/incident processing (model performance metric).
- AUC (Area Under the Curve): Discriminatory power indicator of classification models; performance metric in AML scenario models.
- DNS/IP: The domain name system and internet protocol addresses are critical technical elements in online access measures.
- SLA (Service Level Agreement): The service level agreement defines time/quality commitments on data sharing and alert flows.
- Egmont Group: The cooperation network of world FIUs shares typologies and good practices.
- FATF (Financial Action Task Force): Global AML/CFT standard setter; publishes assessments and guidance.
- Placement/Layering/Integration: The three classic stages of laundering: Placement, layering, and integration.
- Spot-fixing: Manipulation of micro-events like cards/corners/extra time instead of the entire match.
- Matched betting: A strategy that balances risk with opposing positions and can be exploited to legitimize profits.
- Mule: A person/account that facilitates the movement of funds on behalf of someone else.
- Chip dumping: Loss-inducing behavior that intentionally transfers value between betting/gaming accounts.
- Denylist: List of people/accounts/institutions whose access is prohibited; used by operators when accepting customers.
- Onboarding: Acceptance of the customer/employee into the system/process includes KYC and training steps.
- Attestation: The individual periodically confirms certain policies/rules and statements.
- Sure-bet: A strategy that aims to make a profit regardless of the outcome by using different operator rates.
References
- Anadolu Agency, TFF President's Statement on Referees, October 27, 2025
- Turkish Football Federation (TFF) – Disciplinary Referrals. October 28, 2025
- Reuters – Turkey suspends 149 referees after betting probe. November 1, 2025
- Reuters – Turkey to discipline referees after uncovering mass betting. October 27, 2025
- ESPN – Turkish federation suspends 149 referees amid betting scandal. October 31, 2025
- Action Plan to Combat Illegal Betting, Games of Chance and Gambling 2025–2026. Official Journal announcement and codes of practice, November 1, 2025.
- Law No. 6222 – Law on the Prevention of Violence and Disorder in Sports. April 14, 2011, Match-fixing/incentive bonus crimes and sanctions; responsibilities of relevant actors.
- Law No. 7258 – Law on the Regulation of Betting and Games of Chance in Football and Other Sports Competitions.
- https://www.coe.int/en/web/sport/macolin European Council – The Convention on the Manipulation of Sports Competitions (the Macolin Convention).
- FATF – Money Laundering through the Football Sector (2009). KPA typologies and red flags across the football ecosystem.
- FATF – Virtual Assets Red Flag Indicators (2020). Crypto-asset CPA/TF indicators; P2P and OTC brokerage risks.
- Egmont Group – Online Gambling and Money Laundering Typologies. Laundering patterns and indicators in online gambling/betting channels.


