#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Winholding B.V.

Gaming OperatorRegistered March 21, 2024
1
Applications
2
Domains
12
Related Entities
0
Locations

OGL/2024/1290/0515

Granted
Submitted: August 19, 2024End Date: November 25, 2025

Customer

Contact
Willem Mink
Email
win@viraemanagement.com
Company
Winholding B.V.

Review Timeline

Verification
JPJemy-Ree Pilgrim (GCB User 3)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
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 ReviewCritical6 items
PAGE 6: QUESTION 34QuestionMinorDue Aug 28, 2024

The Online gaming application form has a different contact person than the local director from the coc excerpt. Amend your responses to question 35, 36, 37 and 38 to match the changes made to question 34.

Kindly change to the appointed contact person and resubmit the form.

PAGE 6: QUESTION 35QuestionMinorDue Aug 28, 2024

Please adapt your response to question 35 if needed

according to the changes made to question 34.

PAGE 6: QUESTION 36QuestionMinorDue Aug 28, 2024

Please adapt your response to question 36 if needed

according to the changes made to question 34.

PAGE 6: QUESTION 37QuestionMinorDue Aug 28, 2024

Please adapt your response to question 37 if needed

according to the changes made to question 34.

PAGE 6: QUESTION 38QuestionMinorDue Aug 28, 2024

Please adapt your response to question 38 if needed

according to the changes made to question 34.

David BlundellMiscellaneousCriticalDue Aug 21, 2024

PAGE 9: The Personal History Disclosure Form has the wrong person on the Declaration and Data Privacy Form. The form must be completed by the person submitting the form (First and last name instead of first and middle name).

Kindly resubmit with the correct information.

Application Due Diligence ReviewCritical12 items
QPA/2024/00555 - Nathan Abel - PassportPassportCriticalDue May 19, 2025

Please provide all pages of the passport scanned in colour and certified.

Please provide all pages of the passport scanned in colour and certified.

QPA/2024/00555 - Nathan Abel - Reference LetterMiscellaneousCriticalDue May 19, 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/2024/00555 - Nathan Abel - SOWSource of WealthCriticalDue May 19, 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>

QPA/2024/01730 - David Blundell - PassportPassportCriticalDue May 19, 2025

Please provide a certified copy of the passport's full first page and bio. Also, please explain why on the certificate you have London listed as a place of birth while on the passport Nuneaton.

Please provide a certified copy of the passport's full first page and bio. Also, please explain why on the certificate you have London listed as a place of birth while on the passport Nuneaton.

QPA/2024/01730 - David Blundell - Reference LetterMiscellaneousCriticalDue May 19, 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.

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.

QPA/2024/01730 - David Blundell - PassportPassportCriticalDue May 19, 2025

Please provide a certified copy of the passport's full first page and bio. Also, please explain why on the certificate you have London listed as a place of birth while on the passport Nuneaton.

Please provide a certified copy of the passport's full first page and bio. Also, please explain why on the certificate you have London listed as a place of birth while on the passport Nuneaton.

Share Ledger CertificationShare LedgerCriticalDue May 20, 2025

Resubmit the share ledger duly certified

Resubmit the share ledger duly certified

Financial StatementsFinancial AuditCriticalDue May 20, 2025

Resubmit FS 2022, duly signed, as well as FS 2023 and signed financials, in whatever form which are not older than 6 months

Resubmit FS 2022, duly signed, as well as FS 2023 and signed financials, in whatever form which are not older than 6 months

Corporate Structure - QueryMiscellaneousCriticalDue May 20, 2025

Confirm whether Winholdings UK Ltd is still a fully owned subsidiary of the applicant company. If affirmative, provide share ledger. If negative, resubmit updated corporate structure

Confirm whether Winholdings UK Ltd is still a fully owned subsidiary of the applicant company. If affirmative, provide share ledger. If negative, resubmit updated corporate structure

Business PlanBusiness PlanCriticalDue May 20, 2025

Resubmit a detailed 3 year financial forecast, indicating a breakdown of key figures, such as any investments, loans, wages, marketing expenses and any commissions or benefits to any third party

Resubmit a detailed 3 year financial forecast, indicating a breakdown of key figures, such as any investments, loans, wages, marketing expenses and any commissions or benefits to any third party

AML PolicyMiscellaneousCriticalDue May 22, 2025

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

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

Prohibited JurisdictionsProhibiited CountriesCriticalDue May 22, 2025

It was observed that players are allowed to register an account by choosing Netherlands Antilles as their country of residence. Furthermore, the general prohibited jurisdictions list in the T&Cs does not include the Netherlands. Players 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.

It was observed that players are allowed to register an account by choosing Netherlands Antilles as their country of residence. Furthermore, the general prohibited jurisdictions list in the T&Cs does not include the Netherlands. Players 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.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jul 15, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jul 15, 2026

List Position:

Native NameQuestionCriticalDue Jul 15, 2026

Please list the native name.

PHDFQuestionCriticalDue Jul 15, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jul 15, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jul 15, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jul 15, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue Jul 15, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue Jul 15, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jul 15, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue Jul 15, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jul 15, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jul 15, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jul 15, 2026

Add the URL and give a small summary.

https://mt.bold.pro/my/trevor-mallia https://whoswho.mt/en/i-don-t-tell-people-what-to-do-but-guide-them-to-be-better-on-a-personal-and-professional-level-trevor-mallia
[Support Admin - 08-07-2026 11:26]
https://mt.bold.pro/my/trevor-mallia https://whoswho.mt/en/i-don-t-tell-people-what-to-do-but-guide-them-to-be-better-on-a-personal-and-professional-level-trevor-mallia
[Support Admin - 08-07-2026 11:26]