#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Mirth B.V.

Gaming OperatorRegistered March 19, 2024
1
Applications
1
Domains
8
Related Entities
0
Locations

OGL/2024/1124/0444

Granted
Submitted: August 14, 2024End Date: May 9, 2025

Customer

Contact
Jonathan Heymans
Email
mirth@keyfin-management.com
Company
Mirth B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Ended May 14, 2024
Due Diligence
MGMario Galea (CGA Admin 1)
Background Check
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
AMAndrew McCulloch (Amcc)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
SPSulmahine Penza-Kwidama (CGA USER 59)

Compliance Checklists

Application Verification ReviewCritical0 items
Application Due Diligence ReviewCritical10 items
QPA/2024/01070 - Lyudmila Zhukova - PHDFMiscellaneousCriticalDue Dec 31, 2024

The PHDF must be digitally signed and verified. Please resubmit. Additionally, the UBO isn't allowed to act as a compliance officer. Kindly update.

The PHDF must be digitally signed and verified. Please resubmit. Additionally, the UBO isn't allowed to act as a compliance officer. Kindly update.

QPA/2024/01070 - Lyudmila Zhukova - Update DocumentsMiscellaneousCriticalDue Dec 31, 2024

Kindly provide valid documents (Criminal Record and Reference Letter) that are current within the past six months.

Kindly provide valid documents (Criminal Record and Reference Letter) that are current within the past six months.

QPA/2024/01070 - Lyudmila Zhukova - SOWSource of WealthCriticalDue Apr 16, 2026

Please submit more SOW along with certified supporting evidence in order to support the business.

Please submit more SOW along with certified supporting evidence in order to support the business.

QPA/2024/01070 - Lyudmila Zhukova - Birth CertificateBirth CertificateCriticalDue Dec 31, 2024

A birth certificate has not been submitted. Kindly submit a certified true copy of the birth certificate.

A birth certificate has not been submitted. Kindly submit a certified true copy of the birth certificate.

Source of funds of businessSource of FundsCriticalDue Mar 19, 2025

Submit enhanced certified documentation showing how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties

Submit enhanced certified documentation showing how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties

Financial StatementsFinancial AuditCriticalDue Mar 19, 2025

Submit any form of financials, such as management accounts, until end of 2024

Submit any form of financials, such as management accounts, until end of 2024

Share Ledger CertificationShare LedgerMediumDue Mar 19, 2025

Share ledger is uncertified. Resubmit certified

Share ledger is uncertified. Resubmit certified

Compliance officerMiscellaneousCriticalDue Mar 19, 2025

No CO appointed. Appoint a CO fluent in AML and submit their PHDF, together with relevant enclosures , as well as a CV and letter of engagement. No SOW required. Note that UBO may not be a CO due to conflicting roles.

No CO appointed. Appoint a CO fluent in AML and submit their PHDF, together with relevant enclosures , as well as a CV and letter of engagement. No SOW required. Note that UBO may not be a CO due to conflicting roles.

Player RegistrationPlayer RegistrationCriticalDue Mar 24, 2025

The registration form does not require the player's name, address, country or DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.

The registration form does not require the player's name, address, country or DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.

QPA/2024/01070 - Lyudmila Zhukova - PHDF & Reference LetterMiscellaneousCriticalDue Apr 16, 2026

Please note that the SOW in the PHDF is not valid for supporting the application. Also, please certify the reference letter.

Please note that the SOW in the PHDF is not valid for supporting the application. Also, please certify the reference letter.

Player Complaints PolicyCritical2 items
Recommencing ADR process with a different entityPolicy DocumentCriticalDue May 1, 2026

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

Recommencing dropped ADR processesPolicy DocumentCriticalDue May 1, 2026

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

AML PolicyCritical3 items
Business Risk Assessment (BRA)Policy DocumentCriticalDue May 8, 2026

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

Crypto PolicyPolicy DocumentCriticalDue May 8, 2026

The policy must define the rules and risk controls around virtual assets and crypto usage.

The policy must define the rules and risk controls around virtual assets and crypto usage.

Record KeepingPolicy DocumentCriticalDue May 8, 2026

The policy must state that the operator retains records of CDD, transactions, and UTR (objective and subjective) for at least 5 years.

The policy must state that the operator retains records of CDD, transactions, and UTR (objective and subjective) for at least 5 years.

KYC PolicyCritical8 items
Failure to complete CDD/KYCPolicy DocumentCriticalDue May 8, 2026

The policy must outline the procedure that needs to be followed in instances where, following the lapse of 30 days from when the deposit threshold is met, the CDD/KYC identifcation and verification cannot be completed.

The policy must outline the procedure that needs to be followed in instances where, following the lapse of 30 days from when the deposit threshold is met, the CDD/KYC identifcation and verification cannot be completed.

Sanctions screeningPolicy DocumentCriticalDue May 8, 2026

The policy must provide for name screening against sanctions lists to be carried out prior to the onset of the business relationship and at determinate points in time afterwards, the procedure to be adopted in carrying out sanctions screening and the sources used for such purpose.

The policy must provide for name screening against sanctions lists to be carried out prior to the onset of the business relationship and at determinate points in time afterwards, the procedure to be adopted in carrying out sanctions screening and the sources used for such purpose.

PEP screening procedurePolicy DocumentCriticalDue May 8, 2026

The policy must set out the procedure to be adopted in carrying out screening for PEP status, as well as the screening of existing customers for PEP status and the frequency of such checks on a risk-based approach.

The policy must set out the procedure to be adopted in carrying out screening for PEP status, as well as the screening of existing customers for PEP status and the frequency of such checks on a risk-based approach.

PEP status timelinePolicy DocumentCriticalDue May 8, 2026

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out.

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out.

Identifying a PEPPolicy DocumentCriticalDue May 8, 2026

The policy must explain the procedure that needs to be followed when a PEP is identified, including the procedure for obtaining senior management approval, establishing the player's source of wealth and, where applicable, their source of funds and conducting enhanced on-going monitoring of the customer’s activity.

The policy must explain the procedure that needs to be followed when a PEP is identified, including the procedure for obtaining senior management approval, establishing the player's source of wealth and, where applicable, their source of funds and conducting enhanced on-going monitoring of the customer’s activity.

Gathering informationPolicy DocumentCriticalDue May 8, 2026

The policy must set out the procedure to be followed and the sources which will be used to gather and obtain information on the Purpose and Intended Nature of the Business Relationship and build a business and risk profile for the different player risk categories.

The policy must set out the procedure to be followed and the sources which will be used to gather and obtain information on the Purpose and Intended Nature of the Business Relationship and build a business and risk profile for the different player risk categories.

Transaction monitoringPolicy DocumentCriticalDue May 8, 2026

The policy must list the procedures and measures to be applied when carrying out scrutiny of transactions based on the level of customer risk, as well as the timing intervals to carry out the scrutiny of transactions based on the level of customer risk.

The policy must list the procedures and measures to be applied when carrying out scrutiny of transactions based on the level of customer risk, as well as the timing intervals to carry out the scrutiny of transactions based on the level of customer risk.

EDD scenariosPolicy DocumentCriticalDue May 8, 2026

The policy must list the circumstances and scenarios in which enhanced due diligence (EDD) would need to be carried out. This shall include PEPs, high risk rated customers, customers linked to high risk and non-reputable jurisdictions and customers using multiple payment methods.

The policy must list the circumstances and scenarios in which enhanced due diligence (EDD) would need to be carried out. This shall include PEPs, high risk rated customers, customers linked to high risk and non-reputable jurisdictions and customers using multiple payment methods.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 14, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 14, 2026

List Position:

Native NameQuestionCriticalDue May 14, 2026

Please list the native name.

PHDFQuestionCriticalDue May 14, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 14, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 14, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 14, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 14, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 14, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 14, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 14, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 14, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 14, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 14, 2026

Add the URL and give a small summary.