#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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The inclusion of a person, company, domain, or other entity in the CasinoSecrets database does not imply illegal or improper conduct. The data was extracted directly from relevant gambling authorities and official registers on the basis of a significant public interest and reflects information available up to August 2026.

Records may be incomplete, outdated, or contain errors from the underlying source systems. Please verify identities using company numbers, addresses, domains, licence details, or other identifying information before drawing conclusions. The database is intended to make information of significant public interest accessible for journalistic and research purposes. Individual records should be understood in the context of the underlying data and the reporting published alongside them.

Bluewave Interactive N.V

Gaming OperatorRegistered March 19, 2024
2
Applications
3
Domains
15
Related Entities
0
Locations

OGL/2024/1161/0454

Granted
Submitted: October 8, 2024End Date: May 5, 2025

Customer

Contact
Jonathan Heymans
Email
bluewaveinteractive@keyfin-management.com
Company
Bluewave Interactive N.V

Review Timeline

Verification
JMJosenne Mambre (GCB User 2)
Ended Apr 24, 2024
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
CHCeline Houareau (CLHR)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
DIDarvey Isidora (CGA User DI)

Compliance Checklists

Application Verification ReviewCritical1 item
Question 8 (no longer applicable)QuestionMediumDue Jul 31, 2024

Option 8.2 is selected, but the information is not completed.

Kindly provide the information and resubmit the form.

The Applicant resubmitted the updated BCIF, in which this section is no longer available. This ticket has therefore been closed.
[Darvey Isidora - 08-04-2026 16:49]
Application Due Diligence ReviewCritical16 items
QPA/2024/00344 - Andreas Andreou - SOW (no longer applicable)Source of WealthCriticalDue Mar 20, 2025

SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.

<p>SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.</p><p>No valid SOW was provided.</p>

This individual was removed from this position effective 21 July 2025. This ticket has therefore been closed.
[Darvey Isidora - 08-04-2026 17:11]
QPA/2024/00345 - Norine Clifton - Criminal RecordCriminal RecordCriticalDue Sep 16, 2024

A criminal record is missing.The criminal record must be no more than 6 months old and a certified translation of the document should be provided.

A criminal record is missing.The criminal record must be no more than 6 months old and a certified translation of the document should be provided.

Business and Corporate Information FormMiscellaneousCriticalDue Mar 31, 2025

Question 7 is incomplete. Include details in space provided. Question 8 appears incorrect and incomplete. Update and complete Resubmit form

Question 7 is incomplete. Include details in space provided. Question 8 appears incorrect and incomplete. Update and complete Resubmit form

Compliance officer (no longer applicable)MiscellaneousCriticalDue Mar 31, 2025

UBO may not hold the role of CO due to conflicting positions. Appoint another CO, fluent in AML and submit their PHDF with relevant enclosures, including also a letter of engagement and CV

UBO may not hold the role of CO due to conflicting positions. Appoint another CO, fluent in AML and submit their PHDF with relevant enclosures, including also a letter of engagement and CV

This item relates to the previous UBO, and a new Compliance Officer has since been appointed. This ticket is therefore closed.
[Darvey Isidora - 08-04-2026 18:07]
Share Ledger CertificationShare LedgerMediumDue Mar 31, 2025

Submit share ledger duly certified

Submit share ledger duly certified

Financial StatementsFinancial AuditCriticalDue Mar 31, 2025

Submit signed financials for years ending 2023 and the latest available management accounts for 2024.

Submit signed financials for years ending 2023 and the latest available management accounts for 2024.

Business PlanBusiness PlanCriticalDue Mar 31, 2025

- Organisational structure. Inform whether any key persons have been engaged. Submit information on the same, if affirmative Submit information about payment gateways Submit a detailed 3 year financial forecast, providing a break down of the initial investment, wages, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider

1.Organisational structure. Inform whether any key persons have been engaged. Submit information on the same, if affirmative 2. Submit information about payment gateways 3. Submit a detailed 3 year financial forecast, providing a break down of the initial investment, wages, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider

AML Policy (duplicate item)MiscellaneousCriticalDue Apr 14, 2025

The AML policy must adhere to Curacao AML laws. Kindly amend.

The AML policy must adhere to Curacao AML laws. Kindly amend.

Duplicate checklist item. This item has therefore been closed.
[Darvey Isidora - 08-04-2026 18:56]
Prohibited JurisdictionsProhibiited CountriesCriticalDue Apr 14, 2025

Although the registered domain appears to implement geo-blocking, the prohibited jurisdictions list does not include Curacao or the Netherlands. Player residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Although the registered domain appears to implement geo-blocking, the prohibited jurisdictions list does not include Curacao or the Netherlands. Player residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Business and Corporate Information Form (submitted - pending review)MiscellaneousCriticalDue Mar 31, 2025

Question 7 is incomplete. Include details in space provided. Question 8 appears incorrect and incomplete. Update and complete Resubmit form

Question 7 is incomplete. Include details in space provided. Question 8 appears incorrect and incomplete. Update and complete Resubmit form

The updated BCIF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 08-04-2026 17:58]
Uploaded - [Sent by Jonathan Heymans - 02-03-2026 14:42]
[Darvey Isidora - 08-04-2026 17:54]
Share LedgerShare LedgerCriticalDue Apr 17, 2026

Submit share ledger duly certified

<p>Submit share ledger duly certified</p><p><b><u>Update: 4/8/2026</u></b><br>Dear Applicant,<br>You are kindly requested to submit the updated, duly certified Share Ledger at your earliest convenience. Thank you for your cooperation.</p>

Customer Reply - this has been submitted
[Darvey Isidora - 08-04-2026 18:30]
Management Accounts 2025Financial AuditCriticalDue Jul 10, 2026

Submit signed financials for years ending 2023 and the latest available management accounts for 2024.

Submit signed financials for years ending 2023 and the latest available management accounts for 2024.<br><br><div><b><u>Update: 7/5/2026</u></b></div><div>Dear Applicant,</div><div>Kindly provide further clarification regarding the software expenses reflected in the financial information submitted, including a detailed breakdown of the expenses and supporting documentation where appropriate.</div><div>Furthermore, please submit the latest available management accounts as at 31 December 2025 to facilitate the completion of the CGA's financial assessment.<br>Thank you for your cooperation.<br><br></div>

Although the accounts have been submitted with the appropriate signatures, the loss of ~EUR 800k together with the unexplained "software expenses" of ~EUR 1.8 million raises concerns, further enhanced by the fact that the holding company is planned to be sold to the managing director. We recommend to ask for further clarification on the software expenses and the latest available accounts as at the end of 2025.
[Luca Camilleri - 28-04-2026 11:24]
The Management Accounts 2024 has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 08-04-2026 18:38]
Customer Reply - this has been submitted
[Darvey Isidora - 08-04-2026 18:38]
Business Plan (submitted - pending review)Business PlanCriticalDue Mar 31, 2025

- Organisational structure. Inform whether any key persons have been engaged. Submit information on the same, if affirmative Submit information about payment gateways Submit a detailed 3 year financial forecast, providing a break down of the initial investment, wages, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider

1.Organisational structure. Inform whether any key persons have been engaged. Submit information on the same, if affirmative 2. Submit information about payment gateways 3. Submit a detailed 3 year financial forecast, providing a break down of the initial investment, wages, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider

The updated Business Plan has been submitted (relevant section and extra documentation). The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 08-04-2026 18:53]
Uploaded - [Sent by Jonathan Heymans - 12-03-2026 11:07]
[Darvey Isidora - 08-04-2026 18:51]
Prohibited Jurisdictions (submitted - pending review)Prohibited CountriesCriticalDue Apr 14, 2025

Although the registered domain appears to implement geo-blocking, the prohibited jurisdictions list does not include Curacao or the Netherlands. Player residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Although the registered domain appears to implement geo-blocking, the prohibited jurisdictions list does not include Curacao or the Netherlands. Player residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

The Applicant has responded to our inquiry. The item has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 08-04-2026 19:01]
Customer Reply - This has been amended.
[Darvey Isidora - 08-04-2026 19:00]
Company Structure (reviewed and approved)MiscellaneousCriticalDue Apr 17, 2026

Updated Company Structure

<b><u>Update: 4/8/2026 </u></b><br>Dear Applicant, <br>You are kindly requested to submit the updated Corporate Structure, duly signed, at your earliest convenience. Thank you for your cooperation.

The updated Company Structure has been reviewed and approved.
[Darvey Isidora - 05-07-2026 21:15]
QPA/2026/04617 - Jonathan Heymans - Source of Wealth DeclarationMiscellaneousCriticalDue Apr 17, 2026

No valid SOW, he is a csp with multiple directorships in other applications.

No valid SOW

The SOW has been submitted (SOF Section). The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate. Thank you for your assistance.
[Darvey Isidora - 05-07-2026 21:18]