📊 Polymarket's $9B Panama shell company

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Here’s what we got for you today:

• 👀 Corporate filings reveal Polymarket's ties to Panama operator

• 🎰 Kalshi runs sportsbook-style affiliate promos

• 🏈 Prediction markets: is it all sports?

• 📈 Market Moves

• 📊 Odds & Ends

Sportico got its hands on more than 100 pages of Panamanian corporate filings for Adventure One QSS, the entity that supposedly runs Polymarket's international exchange independently, and the picture isn't flattering. Polymarket CEO Shayne Coplan is listed as an Adventure One director and briefly served as its president in late 2021. Harry Jones, Polymarket's director of global affairs, is Adventure One's current president. Neither mentions the connection on LinkedIn.

Adventure One's independence has always been the load-bearing legal fiction in Polymarket's post-CFTC settlement structure. The commission barred Polymarket from letting U.S. customers trade on its platform in 2022, and shortly after, operational responsibility for the international exchange shifted to this Panama-registered company. Polymarket's website still carries a footnote saying the international platform "operates independently" and isn't regulated by the CFTC.

However, Adventure One looks less like an independent operator and more like a mailbox. Sportico couldn't find a single LinkedIn profile listing employment there, no job postings on Panamanian boards, and a website that hasn't been updated since 2023, just two lines of boilerplate about "Web3 Development and Research." Polymarket uses the same social accounts and PR team to promote both its international exchange and QCEX, its new CFTC-approved U.S. subsidiary.

The CFTC hasn't accused Adventure One of anything, and the FBI investigation opened in 2024 was dropped without action. But the jurisdictional question is live. Federal regulations say "principal place of business" is determined by where officers "primarily direct, control, and coordinate" activities, and if Coplan and Jones are running things from New York, the CFTC might have a case even if the exchange only serves non-U.S. bettors. Former CFTC chairman Dan Berkovitz argued as much in a 2020 enforcement action, claiming the agency holds authority when "conduct occurs in the United States, regardless of the location or status of the counterparties."

Polymarket is now a $9 billion company with a regulated U.S. entity, Golden Globes sponsorship deals, and serious institutional ambitions. The gap between that trajectory and a two-sentence Panama website handling the international exchange's "operations" is getting harder to explain away. If Polymarket wants to be treated like a legitimate financial platform, the Adventure One arrangement is the kind of thing that gives regulators, and competitors playing by more expensive rules, a reason to push back.

 KALSHI'S PROMO CODE ERA 🎰

Flip through the New York Post's betting section this week and you'll find Kalshi running a promo code - NYPMAX - offering new users $10 in trading credit after placing $10 in trades on NBA Finals futures. The mechanics mirror every DraftKings or FanDuel sign-up bonus you've ever seen: enter the code during registration, clear KYC, hit the trading threshold, collect the bonus. Kalshi's help center is careful to note that the credit itself isn't withdrawable cash - only profits earned from it are. But the affiliate pages burying that distinction in fine print aren't doing Kalshi any favors in the "we're not a sportsbook" argument.

NYPMAX isn't an isolated experiment. CBS Sports is running an identical offer under code CBSSPORTS. Action Network has one. RotoWire has one. Kalshi has built out a full sportsbook-style affiliate distribution machine, funneling users toward its NBA champion market through the same publisher channels that DraftKings and FanDuel pioneered.

Four days before the Post published this promo, Nevada's Gaming Control Board sued to block Kalshi from offering sports event contracts in the state, arguing they constitute illegal gambling under Nevada law. Kalshi then lost its bid to pause the Nevada proceedings, per the Wall Street Journal, which means the state case is moving forward while Kalshi keeps onboarding users through exactly the kind of promotional language that makes regulators' case for them. Massachusetts already secured a preliminary injunction limiting Kalshi's sports contracts, with a judge calling the federal preemption argument "overly broad."

On the federal side, the door is still open. The CFTC withdrew its restrictive event contracts rule proposal on February 4, signaling the agency isn't moving to shut this category down. That creates a strange limbo: the federal regulator is stepping back while individual states are stepping up, and Kalshi is sprinting to acquire users in the gap.

I think Kalshi's affiliate blitz is a calculated bet that user adoption will create political leverage - that once millions of people are trading NBA futures through their Robinhood accounts, the cost of shutting it down becomes too high. It's the Uber playbook applied to derivatives. The risk is that running promos indistinguishable from FanDuel's while arguing you're a CFTC-regulated exchange hands every state AG a ready-made exhibit. You can't market like a sportsbook and regulate like a futures exchange forever. At some point, the product has to pick a lane - or a court will pick one for it.

ARE PREDICTION MARKETS JUST SPORTS BETTING TOOLS? 🏈 

Kalshi processed roughly $24 billion in trading volume last year. Of that, 87% came from sports event contracts, and sports didn't even launch on the platform until late January. Dustin Gouker, a journalist who covers prediction markets, dug into the data around sports on popular prediction markets and found quite the narrative. Narrow the window to the final four months of 2025, which roughly lines up with football season, and sports' share climbs to 90%. Only about $3 billion of Kalshi's annual volume came from everything else combined: politics, economics, weather, culture, entertainment. All of it. Three billion. These are not the numbers of a general-purpose information market that happens to offer sports. These are the numbers of a sports betting exchange that happens to offer some other stuff.

The new entrants aren't hiding the thesis. Crypto.com recently launched OG, a standalone prediction market app, with press materials describing it as a platform that "provides sports fans access to a most comprehensive range of CFTC-regulated sports event contracts as well as additional event contracts across financial, political, cultural, and entertainment events." Sports first, everything else second. OG's CEO said it plainly: "Sports are the natural hub of prediction markets." Open the prediction market sections of Gemini, Coinbase, or Robinhood and the first thing surfacing on every screen is sports. DraftKings launched its exchange in 38 states in December. FanDuel Predicts went live shortly after and became the first online gaming operator to offer prediction markets in all 50 states. Novig, a sweepstakes sports exchange pivoting to federal regulation, raised $75 million last week at a $500 million valuation. These companies aren't chasing CFTC registration because they're excited about weather derivatives. They're chasing it because the federal framework lets them offer sports wagering nationwide without state-by-state licensing.

People point to Polymarket's international site as proof the category can thrive beyond sports. Fair enough, but that site is banned on American soil, even if Americans can use it with a VPN. And even there, sports is the single largest category in the trailing year, accounting for 38% of volume. Polymarket's actual US app has only offered sports event contracts since it launched. It lives in the Sports section of the App Store. Meanwhile, CFTC Chairman Michael Selig has written op-eds, given speeches, and filed amicus briefs defending prediction markets — withdrawing the Biden-era proposed ban, directing staff to draft new rules, telling states to back off — all without centering the word that explains why any of this matters right now. He talks about "event contracts" that "help market participants hedge risk, aggregate information, and test hypotheses about future outcomes." That framing is technically accurate and functionally incomplete. Ninety percent of the regulated volume is people betting on games.

The legal fights tell the same story. Massachusetts secured a preliminary injunction limiting Kalshi's sports contracts. Eight other states sent cease-and-desist letters. Nevada sued Crypto.com. California gaming tribes are challenging FanDuel and DraftKings for using the event-contract loophole to bypass tribal sovereignty. These battles are almost entirely about sports. Nobody was suing prediction markets over hurricane forecasts or Oscar pools. Utah's governor put it bluntly: "I don't remember the CFTC having authority over the 'derivative market' of LeBron James rebounds."

Can prediction markets eventually be about way more than sports? Yes. The founders of Kalshi and Polymarket are true believers in that vision, and so am I. But right now, sports is king, and pretending otherwise, dressing up a $24 billion sports betting exchange as a "financial innovation platform," doesn't change the numbers. Someone is going to have to prove they can turn this into more than sports betting in the US. We believe someone will. That day just hasn't arrived in the regulated prediction market industry, and until it does, the honest move is to say the word out loud.

MARKET MOVES 📈

📈 Biggest swing: “US x Iran meeting by February 28, 2026?” moved 16% → 87% (Polymarket)

💰 Top earner: @DrPufferfish - $639,089 24H Profit (Polymarket)

🤔 Weirdest market: “State of the Union Bingo - Card 3” (Polymarket)

ODDS & ENDS 📊

• Total prediction market open interest finally crosses $1B.

• Kalshi gets called out by Nikita Bier for sponsoring posts on X without disclosing them as advertisements, sparking new ad rules.

• Trump admin backs Kalshi and Polymarket

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