#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Trust Recife B.V.

Gaming OperatorRegistered March 19, 2024
1
Applications
9
Domains
5
Related Entities
0
Locations

OGL/2024/1168/1025

Rejected
Submitted: September 3, 2024End Date: October 7, 2025

Customer

Contact
Jonathan Heymans
Email
trustrecife@keyfin-management.com
Company
Trust Recife B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
KMKevin Mallia (KM)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)

Compliance Checklists

Application Verification ReviewCritical14 items
Page 1MiscellaneousMinorDue Aug 15, 2024

The form is missing application date.

Kindly resubmit the form with the correct application date.

Page 1MiscellaneousMinorDue Aug 15, 2024

The form is missing brand name.

Kindly fill the brand name and resubmit the form.

Page 6 Question 39QuestionMinorDue Aug 15, 2024

The form has a different contact person email address from that of the portal user.

Kindly change the email address and resubmit the form.

Page 1MiscellaneousMinorDue Aug 15, 2024

The form is missing application number.

Kindly resubmit the form with the correct application number.

Page 1MiscellaneousMinorDue Aug 15, 2024

The form is missing application date.

Kindly resubmit the form with the correct application date.

Page 1 Question 1QuestionMinorDue Aug 15, 2024

The form is missing brand name.

Kindly fill the brand name and resubmit the form.

Page 1 Question 4QuestionMinorDue Aug 15, 2024

The form is missing Company Tax ID Number.

Kindly fill the Company Tax ID Number and resubmit the form.

Felipe Pragana PessoaMiscellaneousMinorDue Aug 30, 2024

Page 1: The form has an incorrect personal application number.

The Personal History Disclosure Form Page 1 has an incorrect personal application number. Kindly resubmit the form with the correct personal application number.

Felipe Pragana PessoaQuestionMinorDue Aug 15, 2024

Page 2 question 17: The year of the passport's date of issue is incorrect.

Kindly correct the year of passport's issue date and resubmit the form.

Felipe Pragana PessoaQuestionMinorDue Aug 15, 2024

Page 2 Question 18: The year of the passport's expiry date is incorrect.

Kindly correct the year of passport's expiry date and resubmit the form.

Felipe Pragana Pessoa - Birth CertificateBirth CertificateMinorDue Aug 15, 2024

The enclosed document is incomplete.

Kindly resubmit a birth certificate.

Felipe Pragana Pessoa - Proof of address:Proof of AddressCriticalDue Aug 15, 2024

The enclosed proof of address is expired (June 2023).

Kindly resubmit a valid/recent (within last six months) proof of address document or bank statement.

Jonathan HeymansMiscellaneousCriticalDue Aug 15, 2024

The Personal History Disclosure Form of Mr. Jonathan Heymans is missing.

Kindly submit the requested document.

Jonathan HeymansMiscellaneousMinorDue Sep 4, 2024

The form must be digitally signed by the person submitting the form.

The Declaration and Data Privacy on page 9 must be digitally signed by the person submitting the form. Kindly sign and resubmit the form.

Application Due Diligence ReviewCritical10 items
QPA/2024/01995 - Felipe Pragana Pessoa - Criminal RecordCriminal RecordCriticalDue Sep 1, 2025

Kindly submit a criminal record that is more recent than the one that was provided.

Kindly submit a criminal record that is more recent than the one that was provided and certified.

QPA/2024/01995 - Felipe Pragana Pessoa - Reference LetterMiscellaneousCriticalDue Sep 1, 2025

The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

<p class="MsoNormal">The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.<o:p></o:p></p>

QPA/2024/01995 - Felipe Pragana Pessoa - SOWSource of WealthCriticalDue Sep 1, 2025

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

<p class="MsoNormal">SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.<o:p></o:p></p>

Share Ledger CertificationShare LedgerHighDue Sep 1, 2025

Share ledger is uncertified. Resubmit certified

Share ledger is uncertified. Resubmit certified

Business and Corporate Information FormMiscellaneousCriticalDue Sep 1, 2025

Q7 indicates that the company is a start up. However, from verification processes, the applicant appears to have operated under a sublicense. Clarify. Amend form and resubmit

Q7 indicates that the company is a start up. However, from verification processes, the applicant appears to have operated under a sublicense. Clarify. Amend form and resubmit

Compliance officerMiscellaneousCriticalDue Sep 1, 2025

Appoint a CO fluent in AML and submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV . No SOW required

Appoint a CO fluent in AML and submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV . No SOW required

Local directorDirector's ListCriticalDue Sep 1, 2025

Local director representative to indicate position as executive director

Local director representative to indicate position as executive director

Financial StatementsFinancial AuditCriticalDue Sep 1, 2025

Submit FS for years ending 2022 and 2023, as well as signed financials in whatever form which are not older than 6 months

Submit FS for years ending 2022 and 2023, as well as signed financials in whatever form which are not older than 6 months

Business PlanBusiness PlanCriticalDue Sep 1, 2025

The Business Plan lacks information and criteria listed in the guidelines on the application portal. It requires a detailed management structure showing allocated responsibilities, controls and identification of key persons, detailed information on the business rationale, provision of information about payment gateways, contractual and financial model with key suppliers. It also lacks a detailed 3 year financial projection which is expected to indicate a break down of investments, the projected marketing expenses, wages, any commissions paid to any platform/content provider, and any loans paid, amongst key figures. Kindly review the business plan guidelines and resubmit

The Business Plan lacks information and criteria listed in the guidelines on the application portal. It requires a detailed management structure showing allocated responsibilities, controls and identification of key persons, detailed information on the business rationale, provision of information about payment gateways, contractual and financial model with key suppliers. It also lacks a detailed 3 year financial projection which is expected to indicate a break down of investments, the projected marketing expenses, wages, any commissions paid to any platform/content provider, and any loans paid, amongst key figures. Kindly review the business plan guidelines and resubmit

Source of funds of businessSource of FundsCriticalDue Sep 1, 2025

Submit recent and certified documentation showing how the operations of the business are funded and by whom, including documents which funding of the company by shareholder or third parties, as well as documents, if any, which show funds owned by the company through cashflow or other means

Submit recent and certified documentation showing how the operations of the business are funded and by whom, including documents which funding of the company by shareholder or third parties, as well as documents, if any, which show funds owned by the company through cashflow or other means