By NEIL HARTNELL

Tribune Business Editor

nhartnell@tribunemedia.net

The Securities Commission yesterday revealed “heightened concerns” sparked by accusations of “criminality” had caused it to seek the court-supervised winding-up of a $113m Bahamian investment fund.

Christina Rolle, its executive director, told Tribune Business the inability to repay investors their money when redemption requests were made, plus allegations of links to an “illegal gambling syndicate” and “unlicensed betting exchange”, had prompted the regulator to petition for the Supreme Court-supervised liquidation of the Holdun Innovation and Technology Fund.

The fund, which was licensed as a Specific Mandate Alternative Regulatory Test or SMART Fund on June 22, 2021, set out to deliver superior returns for investors via sports betting. It employed mathematical formulas, known as algorithms, to analyse the historical and current performance of players and teams, and thus predict the outcome of professional soccer matches and leagues “across the globe”.

However, Supreme Court documents obtained by Tribune Business reveal investors had complained since late August 2023 - almost two years ago - of not being paid out their investments in a timely manner when redemption requests were made. The Winterbotham Trust Company, the Fund’s Bahamian administrator, against whom no wrongdoing is alleged, then resigned from its role on April 15, 2025.

Legal papers name the Fund’s investment manager as the Holdun Family Office (Bahamas), the fifth-generation family office that traces its roots back to the late Sir Herbert Samuel Holt, a Canadian industrialist and financier who, in 1908, became the Royal Bank of Canada’s (RBC) president and chief executive.

Brendan Holt Dunn, the Holdun Family Office’s chief executive, and the company’s chief operations officer, Germaine Bullard, were both directors of the Holdun Innovation and Technology Fund. Effort to obtain comment from Mr Holt Dunn proved fruitless yesterday as calls to his cell phone did not go through, while those to the company’s Albany Financial Centre offices went to a full voice mail box.

An e-mail sent to Mr Holt Dunn’s personal work address was not responded to before press time last night. However, in an April 3, 2025, meeting with the Securities Commission to discuss the regulator’s concerns that the Fund had suffered a “substantial asset loss” worth $300m, he asserted that its funds in Turkey and the Philippines had been “confiscated” and “frozen” respectively.

The “confiscation” purportedly stemmed from the Fund’s Turkish broker, Brokerstarz, being raided “for illegal gambling activities”, while the freeze was caused by the Filipino government’s decision to “shut down the gaming industry in that country”.

However, the Securities Commission, in its August 1, 2025, winding-up petition filed with the Supreme Court, said an investor’s e-mail received just one week before on July 24, 2025, had “raised grave concerns” about the Fund’s operations.

“Specifically, the investor’s e-mail expressed a view that the Fund’s operators may have acted in a manner suggesting that a criminal investigation into the alleged actions of the directors and investment manager may be warranted,” the regulator added. “Suffice to say, the issues raised are such that the Fund cannot be permitted to wind-up voluntarily.”

The Securities Commission has been joined by investors in the Holdun Innovation and Technology Fund who have filed their own separate winding-up petition. Well-placed Tribune Business sources, speaking on condition of anonymity, revealed that the petitions were heard by Sir Ian Winder, the chief justice, last Friday.

It is understood that the Fund’s court-supervised petition has been approved, but the Order to perfect this and be presented to Sir Ian for sign-off was still being drawn-up as of yesterday. This was attributed to the fact that multiple investor groups, each with their own attorneys, wanted a say on how the Order was written with many of Nassau’s top commercial law firms involves in representing the parties.

The Order, once signed by Sir Ian, would see James Gomez, managing partner of the Ecovis Bahamas accounting firm, and Igal Wizman, the EY accountant and partner, appointed as joint provisional liquidators for the Fund. Mr Gomez had initially been lined up as its voluntary liquidator.

“The Commission has heightened concerns around the possibility of criminality,” Ms Rolle told Tribune Business, “and that’s the main reason we filed for the court’s intervention. We’d be satisfied to participate in the process involving official liquidators that the court seems to be leaning towards.”

A group of Holdun Innovation and Technology Fund investors, in their own July 29, 2025, winding-up petition revealed they had hired a private investigator to probe its operations and why their redemption requests were not being honoured. A performance report filed with the Securities Commission by the Winterbotham Trust Company showed its net asset value was $113.129m as at end-June 2024.

Mr Gomez’s appointment as the Fund’s voluntary liquidator was announced on June 30, 2025. A little over one month later, on July 25, 2025, the Bahamian accountant acknowledged investor concerns and said he would determine the Fund’s solvency “which hinges on the likelihood of recovery of the company’s assets”.

“I have asked the Securities Commission, as regulator, if it would be inclined to petition the Supreme Court of The Bahamas for a court supervision Order. For the sake of clarity, a supervision Order is typically obtained when a company is unable to pay its debts or if the court deems it to be just and equitable for the company to be wound up,” Mr Gomez wrote.

“While the accounting records of the company show that it is solvent, it is important to note that the company has encountered an issue with satisfying redemption demands. In light of this fact, and given the concerns expressed by the directors regarding recovery of the company’s assets, the Securities Commission has committed to petitioning the Supreme Court of The Bahamas for a supervision Order on an expedited basis.”

The three corporate investors behind the winding-up petition - Falcon V, MGFO-P and Rothwell Derivatives - alleged they requested the redemption of their investments worth $3.7m, $6.202m and £7.076m, respectively, on April 19, 2024; April 9, 2024; and December 9, 2024, but no payouts had been received from Holdun Family Office to-date.

They noted that the Holdun Innovation and Technology Fund’s mandate had undergone a “material change” the previous year. While the Fund’s 2019 “term sheet” said it would invest solely in Falcon 5, the company that created the algorithm “to bet on soccer matches in the top 21 European leagues”, this was altered in 2023 to investing in Holdun Innovation and Technology Fund, a Guernsey entity, not Falcon 5.

The first signs of trouble allegedly emerged in September 19, 2024, when Holdun Family Office informed investors that “a critical partner” had been forced to relocate because of regulatory changes in the Philippines. And the 2024 season had produced “the lowest returns since the inception of the Fund, yielding approximately 4 percent annual returns for the US dollar share class”.

As a result, and with July 2024 returns at a negative -4 percent loss at the start of the new soccer season, Holdun Family Office said that had ceased all activities from September 2024 pending a review of the algorithm by data scientists.

An October 2024 message to investors acknowledged the “current liquidity challenges” facing the Fund, and asserted that its Filipino broker’s assets had been frozen by that nation’s regulators as a result of the decision to shut down the country’s gaming industry. That was alleged to have been influenced by the Chinese government due to the number of Chinese investors and clients involved.

Then, in January 2025, Holdun Family Office said the Fund’s Turkish broker had reported a $300m “loss of assets... which we understand to be assets frozen by the government following recent raids and arrests of key personnel. Independent verification of this claim is currently underway”. 

The Fund’s investors argued that all this “served only to raise more questions than they answered”, and alleged that responses to their probing from both the Fund and Winterbotham Trust Company “have been largely vague and unsatisfactory”. As a result, they hired a private investigator “to assist in uncovering the true state of affairs” of the Fund.

Detailing the investigator’s findings, the investors alleged: “The Fund’s primary betting exchange, SingBet, is a major unlicensed betting operator in Asia, with documented links to criminal activity.” And they also asserted that the Fund’s affairs, assets and management appeared to be closely bound-up with an alleged “illegal gambling syndicate” that supplied the algorithm and managed placing the bets.

“It appears that GPG Sports AG is the creator and owner of the sports betting algorithm employed by the Fund. Investigative findings suggest that its principals, Karl-Heinz Haunschild and Giancarlo Tottoli, are reportedly linked to a Swiss-Turkish illegal gambling syndicate that allegedly generated over $400m in revenue between 2019 and 2023,” the investors alleged.

“This syndicate is currently under federal investigation in Switzerland, and law enforcement authorities have reportedly conducted raids on premises associated with GPG Sports and Mr Haunschild... Importantly, it appears that GPG Sports played a central role in the Fund’s early and ongoing sports betting operations, not only by supplying the algorithm but also by managing the placement of bets.

“In fact, it seems that GPG Sport’s assets were initially pooled with those of the Fund. It is unclear why, or on what basis, the Fund engaged in business either directly or indirectly with individuals and entities that appear to have questionable ties to criminal enterprises.”

The investors added that the Fund “seemingly attempted to publicly distance itself from GPG Sports and its founders in recent years”, suggesting this was why the Guernsey company was formed. And, on October 4, 2021, Mr Holt Dunn wrote: “Clients are no longer pooled with GPG’s clients and we expect in the future this will make reporting and administration very clear.”

The Securities Commission, meanwhile, asserted that the Fund’s condition “will only deteriorate further” as it confirmed that the regulatory and governance concerns sparked by the redemption delays, asset freezes and accusations had caused the suspension of its licence. It added that a $1.943m redemption request dating from August 28, 2023, had not been processed in a timely manner.