#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Free Games B.V.

Gaming OperatorRegistered March 20, 2024
1
Applications
1
Domains
10
Related Entities
0
Locations

OGL/2024/1209/0631

Granted
Submitted: January 30, 2025End Date: November 10, 2025

Customer

Contact
Lorenza Godett
Email
freegames@xcm.cw
Company
Free Games B.V.

Review Timeline

Verification
RTRowenne Tweed (GCB User 4)
Due Diligence
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
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)

Compliance Checklists

Application Verification ReviewCritical14 items
PAGE 1: APPLICATION DATEQuestionCriticalDue Oct 10, 2024

The application date must be filled and within six month’s of today’s date.

The application date is missing the application date. Kindly resubmit the form with the correct application date.

PAGE 6: QUESTION 34 - 38QuestionMinorDue Oct 10, 2024

In the Online gaming application form has a different contact person than that of the portal administrator.

Kindly change to the appointed contact person and resubmit the form or contact the GCB for changes in the contact person.

PAGE 7: DECLARATION AND DATA PRIVACYQuestionCriticalDue Oct 10, 2024

The Online gaming application form must have the Declaration and data privacy on page 7 named by the contact person.

Kindly fill the Declaration and resubmit the Form.

Lorenza GodettQuestionCriticalDue Oct 10, 2024

The application date is missing or has an incorrect application date.

Kindly resubmit the forms with the correct application date.

Gonzalo Perez SilvaQuestionCriticalDue Oct 10, 2024

The application date is missing or has an incorrect application date.

Kindly resubmit the forms with the correct application date.

Pedro Britto AtkenQuestionCriticalDue Oct 10, 2024

The application date is missing or has an incorrect application date.

Kindly resubmit the forms with the correct application date.

Walter Cortes BaldwinQuestionCriticalDue Oct 10, 2024

The application date is missing or has an incorrect application date.

Kindly resubmit the forms with the correct application date.

PAGE 6: QUESTION 35 - Online Gaming Application FormQuestionMinorDue Nov 5, 2024

Question 35 is missing a response. Kindly select at least one item from Question 35 and resubmit the form.

Question 35 is missing a response. Kindly select at least one item from Question 35 and resubmit the form.

Online Gaming Application Form - Page 6 Question 34QuestionMinorDue Nov 25, 2024

The Online Gaming Application Form has a different contact person (Lorenza Godett) in question 34 that that of the portal admin (Analissa Heiland). Kindly change to the portal admin and resubmit the form.

The Online Gaming Application Form has a different contact person (Lorenza Godett) in question 34 that that of the portal admin (Analissa Heiland). Kindly change to the portal admin and resubmit the form.

Online Gamming Application Form - Page 6 Question 39QuestionMinorDue Nov 25, 2024

The Online Gamming Application Form has a different email address in question 39 (lgodett@xcm.cw) from that of the portal user (freegames@xcm.cw). Kindly change the email address and resubmit the form.

The Online Gamming Application Form has a different email address in question 39 (lgodett@xcm.cw) from that of the portal user (freegames@xcm.cw). Kindly change the email address and resubmit the form.

Online Gaming Application Form - Page 7QuestionCriticalDue Nov 25, 2024

The Online Gaming Application Form must have the Declaration and Data Privacy on page 7 named and signed by the portal admin. Kindly name and resign page and resubmit the form.

The Online Gaming Application Form must have the Declaration and Data Privacy on page 7 named and signed by the portal admin. Kindly name and resign page and resubmit the form.

Gonzalo Perez Silva - PassportPassportCriticalDue Dec 12, 2024

We request a new passport for Gonzalo Perez Silva due to the expiry of the current provided passport 19 nov 2024).

We request a new passport for Gonzalo Perez Silva due to the expiry of the current provided passport 19 nov 2024).

Online Gaming Application Form - PAGE 6: QUESTION 36QuestionMinorDue Feb 5, 2025

The passport number of the contact person is missing. Kindly fill the passport number in Question 36 and resubmit the form.

The passport number of the contact person is missing. Kindly fill the passport number in Question 36 and resubmit the form.

Gonzalo Perez Silva - Personal History Disclosure FormQuestionCriticalDue Feb 5, 2025

PAGE 2: QUESTIONS 17–19 The responses to Questions 17–19 are incorrect. Kindly update the responses to Questions 17–19 in the PHDF for Gonzalo Perez Silva using the updated passport information.

PAGE 2: QUESTIONS 17–19 The responses to Questions 17–19 are incorrect. Kindly update the responses to Questions 17–19 in the PHDF for Gonzalo Perez Silva using the updated passport information.

Application Due Diligence ReviewCritical13 items
QPA/2024/01728 - Walter Cortes Baldwin - PHDFMiscellaneousCriticalDue May 15, 2025

The PHDF must be signed and verified digitally. Please resubmit.

The PHDF must be signed and verified digitally. Please resubmit.

QPA/2024/01728 - Walter Cortes Baldwin - SOWSource of WealthCriticalDue May 15, 2025

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

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

QPA/2024/01727 - Pedro Britto Aitken - SOWSource of WealthCriticalDue May 15, 2025

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

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

PA/2024/01726 - Gonzalo Perez Silva - SOWSource of WealthCriticalDue May 15, 2025

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

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

PA/2024/01726 - Gonzalo Perez Silva - PHDFMiscellaneousCriticalDue May 15, 2025

The PHDF must be signed and verified digitally. Please resubmit.

The PHDF must be signed and verified digitally. Please resubmit.

QPA/2024/01727 - Pedro Britto Aitken - PHDFMiscellaneousCriticalDue May 15, 2025

The PHDF must be signed and verified digitally. Please resubmit.

The PHDF must be signed and verified digitally. Please resubmit.

Share Ledger CertificationShare LedgerCriticalDue May 28, 2025

Resubmit share ledger duly certified by an independent certifier.

Resubmit share ledger duly certified by an independent certifier.

Financial StatementsFinancial AuditCriticalDue May 28, 2025

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

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

Compliance officerMiscellaneousCriticalDue May 28, 2025

The CO is required to submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV showing fluency in AML . No SOW required

The CO is required to submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV showing fluency in AML . No SOW required

Source of funds of businessSource of FundsCriticalDue May 28, 2025

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

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

Prohibited and Sanctioned countriesQuestionCriticalDue May 28, 2025

Prohibited & sanctions countries found in registration page. Remove immediately. Despite this site seems solely focused on Peru please confirm.

Prohibited & sanctions countries found in registration page. Remove immediately. Despite this site seems solely focused on Peru please confirm.

Segregation of fundsMiscellaneousCriticalDue May 28, 2025

Since segregation of funds not selected please upload funds manaagemnt procedure explaining how funds will be segregated.

Since segregation of funds not selected please upload funds manaagemnt procedure explaining how funds will be segregated.

T&C/ PoliciesMiscellaneousCriticalDue May 28, 2025

Please upgrade T&C and all policies to reflect Curacao guideline including AML and RG policies.

Please upgrade T&C and all policies to reflect Curacao guideline including AML and RG policies.