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Swervy International B.V.

Gaming OperatorRegistered March 22, 2024
1
Applications
38
Domains
13
Related Entities
0
Locations

OGL/2024/1340/0996

Granted
Submitted: January 23, 2025End Date: June 6, 2025

Customer

Contact
Kerry-Ann Monte
Email
swervy@xcm.cw
Company
Swervy International B.V.

Review Timeline

Verification
JPJemy-Ree Pilgrim (GCB User 3)
Verification
JPJemy-Ree Pilgrim (GCB User 3)
Due Diligence
AAAnton Axiaq (AAX)
Background Check
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
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 ReviewCritical19 items
Online Gaming License Application Form - PAGE 6: QUESTION 34QuestionCriticalDue May 22, 2026

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

The Online gaming application form has a different contact person than that of the portal administrator. 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.<br><br><div><b><u>Update: 5/11/2026</u></b></div><div>Dear Applicant,</div><div>The requested information remains outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.<br><br></div>

Gemmy Holding Ltd - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 14, 2025

Share ledger for Gemmy Holding Ltd is missing. Kindly submit document.

Share ledger for Gemmy Holding Ltd is missing. Kindly submit document.

Share Ledger has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 14:51]
Chiefsystems Holding LTD - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 14, 2025

Share ledger of Chiefsystems Holding LTD is missing.

Share ledger of Chiefsystems Holding LTD is missing.

Share Ledger for Chiefsystems Holding LTD has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 14:54]
Freestyle Group Holdings Limited - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 14, 2025

Share ledger of Freestyle Group Holdings Limited is missing.

Share ledger of Freestyle Group Holdings Limited is missing.

Share Ledger for Freestyle Group Holdings Limited has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 14:59]
Gemmy Holding Ltd - Directors list (reviewed and approved)Director's ListCriticalDue Jan 14, 2025

Directors list for Gemmy Holding Ltd is missing.

Directors list for Gemmy Holding Ltd is missing.

Directors List for Gemmy Holding Ltd has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:04]
Chiefsystems Holding LTD - Directors list (reviewed and approved)Director's ListCriticalDue Jan 14, 2025

Directors list for Chiefsystems Holding LTD is missing.

Directors list for Chiefsystems Holding LTD is missing.

Directors List for Chiefsystems Holdings Ltd has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:05]
Freestyle Group Holdings Limited - Directors list (reviewed and approved)Director's ListCriticalDue Jan 14, 2025

Directors list for Freestyle Group Holdings Limited is missing. Kindly submit document.

Directors list for Freestyle Group Holdings Limited is missing. Kindly submit document.

Directors List for Freestyle Group Holdings Ltd has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:07]
Alessandro Pelizzon - PAGE 9QuestionMinorDue Jan 23, 2025

The Personal History Disclosure Form must be digitally signed by the person submitting the form. Kindly resign and resubmit.

The Personal History Disclosure Form must be digitally signed by the person submitting the form. Kindly resign and resubmit.

Christopher van Rosberg - Personal History Disclosure Form (reviewed and approved)MiscellaneousCriticalDue Nov 20, 2024

Personal History Disclosure Form for Christopher van Rosberg is missing.

Please submit a personal history disclosure form for Christopher van Rosberg.

Christopher Van Rosberg has been removed from his role/position. This checklist item is therefore closed.
[Darvey Isidora - 11-05-2026 15:15]
Lorenza Godett - Personal History Disclosure Form (reviewed and approved)MiscellaneousCriticalDue Nov 20, 2024

Personal History Disclosure Form for Lorenza Godett is missing.

Please submit a personal history disclosure form for Lorenza Godett.

The PHDF for Lorenza Godett has already been reviewed and approved. This checklist item has therefore been closed.
[Darvey Isidora - 11-05-2026 15:17]
Online Gaming License Application Form - PAGE 6: QUESTION 35QuestionCriticalDue May 22, 2026

Please adapt your response to question 35 if needed according to the changes made to question 34.

Please adapt your response to question 35 if needed according to the changes made to question 34.<br><br><div><b><u>Update: 5/11/2026</u></b></div><div>Dear Applicant,</div><div>The requested information remains outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.<br><br><br></div>

Gemmy Holding Ltd - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 23, 2025

Share ledger for Gemmy Holding Ltd is a certificate of incorporation. Kindly resubmit share ledger document in share ledger section.

Share ledger for Gemmy Holding Ltd is a certificate of incorporation. Kindly resubmit share ledger document in share ledger section.

The Share Ledger for Gemmy Holding Ltd has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:31]
Chiefsystems Holding LTD - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 23, 2025

Share ledger of Chiefsystems Holding LTD is uploaded in extra documentation. Kindly resubmit document in share ledger section.

Share ledger of Chiefsystems Holding LTD is uploaded in extra documentation. Kindly resubmit document in share ledger section.

The Share Ledger for Chiefsystems Holding LTD has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:33]
Freestyle Group Holdings Limited - Share ledger (reviewed and approved)Share LedgerCriticalDue Jan 23, 2025

Share ledger of Freestyle Group Holdings Limited is uploaded in extra documentation. Kindly resubmit document in share ledger section.

Share ledger of Freestyle Group Holdings Limited is uploaded in extra documentation. Kindly resubmit document in share ledger section.

The Share Ledger for Freestyle Group Holdings Limited has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:37]
Gemmy Holding Ltd - Directors list (reviewed and approved)Director's ListCriticalDue Jan 23, 2025

Directors list for Gemmy Holding Ltd is uploaded in extra documentation. Kindly resubmit document in director list section.

Directors list for Gemmy Holding Ltd is uploaded in extra documentation. Kindly resubmit document in director list section.

The Directors List for Gemmy Holding Ltd has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:38]
Chiefsystems Holding LTD - Directors list (reviewed and approved)Director's ListCriticalDue Jan 23, 2025

Directors list for Chiefsystems Holding LTD is uploaded in extra documentation. Kindly resubmit document in director list section.

Directors list for Chiefsystems Holding LTD is uploaded in extra documentation. Kindly resubmit document in director list section.

The Directors List for Chiefsystems Holding LTD has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:40]
Freestyle Group Holdings Limited - Directors list (reviewed and approved)Director's ListCriticalDue Jan 23, 2025

Directors list for Freestyle Group Holdings Limited is uploaded in extra documentation. Kindly resubmit document in director list section.

Directors list for Freestyle Group Holdings Limited is uploaded in extra documentation. Kindly resubmit document in director list section.

The Directors List for Freestyle Group Holdings Limited has already been reviewed and approved.
[Darvey Isidora - 11-05-2026 15:42]
Personal History Disclosure Form- Jean-Gabriel GoyetMiscellaneousCriticalDue Jan 23, 2025

Personal History Disclosure Forms and the pertaining enclosures for Jean-Gabriel Goyet are missing. Please submit a personal history disclosure form including the pertaining enclosures for Jean-Gabriel Goyet.

Personal History Disclosure Forms and the pertaining enclosures for Jean-Gabriel Goyet are missing. Please submit a personal history disclosure form including the pertaining enclosures for Jean-Gabriel Goyet.

Swervy International B.V. - Directors List (reviewed and approved)Director's ListCriticalDue May 22, 2026

Swervy International B.V. - Directors List

<b><u>Update: 5/11/2026:</u></b> <br>Dear Applicant, <br>Kindly resubmit the Directors List for Swervy International B.V. An extract from the Curaçao Chamber of Commerce bearing the “KVK” stamp will be accepted. Alternatively, any other document submitted must be duly certified. Thank you for your cooperation.<br><br>

Directors List has been reviewed and approved. This item is therefore closed.
[Darvey Isidora - 15-05-2026 20:03]
Application Due Diligence ReviewCritical12 items
Corporate Structure (reviewed and approved)MiscellaneousCriticalDue May 28, 2025

Corporate structure is unsigned. Resubmit signed by director

Corporate structure is unsigned. Resubmit signed by director

Company Structure has been reviewed and approved. This item is therefore closed.
[Darvey Isidora - 15-05-2026 16:20]
QPA/2025/04228 - Craig Murugan - Compliance OfficerMiscellaneousCriticalDue May 22, 2026

The CO is 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 to submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV showing fluency in AML . No SOW required<br><br><div><b><u>Update: 5/15/2026</u></b></div><div>Dear Applicant,</div><div>The requested information remains outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.<br><br></div>

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

Articles of IncorporationArticles of IncorporationCriticalDue May 28, 2025

1. Update the AIs of Swervy International BV to include 'all kinds of remote gaming' in its Object Clause 2. Submit a certified copy of the AIs of Gemmy Holdings Ltd 3. Submit a certified copy of the AIs of Freestyle Group Holdings Ltd

1. Update the AIs of Swervy International BV to include 'all kinds of remote gaming' in its Object Clause 2. Submit a certified copy of the AIs of Gemmy Holdings Ltd 3. Submit a certified copy of the AIs of Freestyle Group Holdings Ltd

Source of funds of businessSource of FundsCriticalDue May 28, 2025

Submit enhanced recent and certified documentation showing how the operations of the business are funded and by whom, including documents which show funds owned by the company through cashflow or other means

Submit enhanced recent and certified documentation showing how the operations of the business are funded and by whom, including documents which show funds owned by the company through cashflow or other means

QPA/2024/01933 - Alessandro Pelizzon - PHDFMiscellaneousCriticalDue May 28, 2025

The PHDF must be filled out, signed and verified digitally. Please resubmit.

The PHDF must be filled out, signed and verified digitally. Please resubmit.

QPA/2024/01933 - Alessandro Pelizzon - SOWSource of WealthCriticalDue May 22, 2026

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.<br><br><b><u>Update: 5/15/2026</u></b><br>Dear Applicant,<br>The requested information remains outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.<br><br></p><p class="MsoNormal"><br></p><p class="MsoNormal"><o:p></o:p></p>

Terms & ConditionsMiscellaneousCriticalDue May 28, 2025

Please ensure all sites include terms and conditions and polices. T&C should include company details.

Please ensure all sites include terms and conditions and polices. T&C should include company details.

AML Policy (duplicate item)MiscellaneousCriticalDue May 28, 2025

Enhance AML policy to reflect Curacao AML Guidelines.

Enhance AML policy to reflect Curacao AML Guidelines.

Duplicate checklist item. This item is therefore closed.
[Darvey Isidora - 15-05-2026 16:36]
Responsible Gaming (duplicate item)MiscellaneousCriticalDue May 28, 2025

Upgrade RG and Self Exclusion policy to reflect CGA Guidelines

Upgrade RG and Self Exclusion policy to reflect CGA Guidelines

Duplicate checklist item. This item is therefore closed.
[Darvey Isidora - 15-05-2026 16:37]
English VersionMiscellaneousCriticalDue May 28, 2025

Please ensure an English version is available on all domains. The English language prevails.

Please ensure an English version is available on all domains. The English language prevails.

DomainsMiscellaneousCriticalDue May 28, 2025

The company has 29 domains registered with the GCB, kindly ensure that all domains fall under the full responsibility of the company and terms and conditions and policies reflect the same guidelines.

The company has 29 domains registered with the GCB, kindly ensure that all domains fall under the full responsibility of the company and terms and conditions and policies reflect the same guidelines.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue Jun 9, 2026

ID verification procedure

The RG policy must outline the procedure carried out by the operator to verify the player's age.

Account closure procedurePolicy DocumentCriticalDue Jun 9, 2026

Account closure procedure upon the operator becoming aware that the player is a minor post-registration.

The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor.

Record-keepingPolicy DocumentCriticalDue Jun 9, 2026

Record-keeping

The RG policy must state the operator's record-keeping policy.

Contacting the operatorPolicy DocumentCriticalDue Jun 9, 2026

Procedure on how the player can contact the operator regarding RG concerns via email or chat

The RG policy must describe the procedure for how the player can contact the operator regarding RG concerns via email or chat.

LanguagePolicy DocumentCriticalDue Jun 9, 2026

Must be available in English and target market language

The RG page/policy must be available in English and the site's target market language.

Vulnerable gamblersPolicy DocumentCriticalDue Jun 9, 2026

RG policy should include a structured process on flagging potential vulnerable gamblers

The RG policy must include a structured process on flagging potential vulnerable gamblers.

Indicators of problem gamblingPolicy DocumentCriticalDue Jun 9, 2026

Must have a structured process for responding to indicators of problem gambling

The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: - Deposit and wagering frequency - Repeated failed transactions due to insufficient funds - Reversing withdrawals - A pattern of inexplicable extended play sessions - Unreasonable increased communication with customer support, including requests for bonuses - Frequent changes to RG tools - Players maxing out a credit card - Attempts to open multiple accounts to bypass deposit or loss limits

Player profiling and Risk AssessmentPolicy DocumentCriticalDue Jun 9, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue Jun 9, 2026

Adopt RBA to determine level of monitoring and intervention

The RG policy must adopt RBA to determine level of monitoring and intervention

Recording RG interactionsPolicy DocumentCriticalDue Jun 9, 2026

Record all RG interactions in PAM system

The RG policy must state that the operators records all RG interactions in the PAM system

Identification of vulnerable personsPolicy DocumentCriticalDue Jun 9, 2026

Procedure to follow for players identified as vulnerable persons

The RG policy must define the procedure to be followed for players identified as vulnerable persons

Cooling-off periodPolicy DocumentCriticalDue Jun 9, 2026

Operator must offer players option to activate a cooling-off period

The operator must offer players the option to activate a cooling-off period

Cooling-off optionsPolicy DocumentCriticalDue Jun 9, 2026

Options for cooling-off must include duration and marketing opt-out at minimum

The options for cooling-off may include Duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory. Furthermore, the duration must be for a minimum of at least 24 hours

Self-ExclusionPolicy DocumentCriticalDue Jun 9, 2026

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Deposit LimitsPolicy DocumentCriticalDue Jun 9, 2026

Players must be able to set limits on the total amount they deposit

Players must be able to set limits on the total amount they deposit

Training and Staff ReadinessPolicy DocumentCriticalDue Jun 9, 2026

Operators must train customer service and Responsible Gaming staff to handle player interaction profesionally and effectively

Training should cover, at least: - Recognizing signs of gambling distress - Conducting sensitive and structured conversations with at-risk players - Directing players to appropriate support resources and RG tools

Consumer Advertising and MarketingPolicy DocumentCriticalDue Jun 9, 2026

Operators must not engage in irresponsible advertising

The RG policy must state that the operator must not engage in irresponsible advertising, including: - No targeting of Vulnerable Groups - No portrayal of Gambling as an Investment - No misrepresentation of Skill vs Chance - No Emotional Manipulation - Marketing materials must not feature minors or depict them engaging with gambling content - No explicit content - No encouragement of Unrelated Harmful Behaviours - Bonuses and promotions must be communicated transparently - Operators must not use bonuses to encourage excessive gambling - Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers - Operator must make any contracted third-party aware of their RG policy - All advertising must include a clearly visible RG message or slogan

Internet Filtering ToolsPolicy DocumentLowDue Jun 9, 2026

The operator is advised to remind adults that they should take precautions when sharing devices with minors

The operator is advised to remind adults that they should take precautions when sharing devices with minors, such as safeguarding usernames, passwords and payment details.

Notifications for concerning behavioursPolicy DocumentHighDue Jun 9, 2026

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

Initiating direct contactPolicy DocumentCriticalDue Jun 9, 2026

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

Other LimitsPolicy DocumentHighDue Jun 9, 2026

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market