Swervy International B.V.
OGL/2024/1340/0996
GrantedCustomer
- Contact
- Kerry-Ann Monte
- swervy@xcm.cw
- Company
- Swervy International B.V.
Review Timeline
JPJemy-Ree Pilgrim (GCB User 3)
JPJemy-Ree Pilgrim (GCB User 3)
AAAnton Axiaq (AAX)
AAAnton Axiaq (AAX)
PWPhilippe Warzee (PW)
AAAnton Axiaq (AAX)
KMKevin Mallia (KM)
HSHilary Stewart Jones (HSJ)
CHCeline Houareau (CLHR)
CPCedric Pietersz (Managing Director GCB)
CPCedric Pietersz (Managing Director GCB)
DEDennis Engelhardt (CGA User DE)
DIDarvey Isidora (CGA User DI)
Compliance Checklists
Application Verification ReviewCritical19 items
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>
Share ledger for Gemmy Holding Ltd is missing. Kindly submit document.
Share ledger for Gemmy Holding Ltd is missing. Kindly submit document.
[Darvey Isidora - 11-05-2026 14:51]
Share ledger of Chiefsystems Holding LTD is missing.
Share ledger of Chiefsystems Holding LTD is missing.
[Darvey Isidora - 11-05-2026 14:54]
Share ledger of Freestyle Group Holdings Limited is missing.
Share ledger of Freestyle Group Holdings Limited is missing.
[Darvey Isidora - 11-05-2026 14:59]
Directors list for Gemmy Holding Ltd is missing.
Directors list for Gemmy Holding Ltd is missing.
[Darvey Isidora - 11-05-2026 15:04]
Directors list for Chiefsystems Holding LTD is missing.
Directors list for Chiefsystems Holding LTD is missing.
[Darvey Isidora - 11-05-2026 15:05]
Directors list for Freestyle Group Holdings Limited is missing. Kindly submit document.
Directors list for Freestyle Group Holdings Limited is missing. Kindly submit document.
[Darvey Isidora - 11-05-2026 15:07]
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.
Personal History Disclosure Form for Christopher van Rosberg is missing.
Please submit a personal history disclosure form for Christopher van Rosberg.
[Darvey Isidora - 11-05-2026 15:15]
Personal History Disclosure Form for Lorenza Godett is missing.
Please submit a personal history disclosure form for Lorenza Godett.
[Darvey Isidora - 11-05-2026 15:17]
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>
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.
[Darvey Isidora - 11-05-2026 15:31]
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.
[Darvey Isidora - 11-05-2026 15:33]
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.
[Darvey Isidora - 11-05-2026 15:37]
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.
[Darvey Isidora - 11-05-2026 15:38]
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.
[Darvey Isidora - 11-05-2026 15:40]
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.
[Darvey Isidora - 11-05-2026 15:42]
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
<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>
[Darvey Isidora - 15-05-2026 20:03]
Application Due Diligence ReviewCritical12 items
Corporate structure is unsigned. Resubmit signed by director
Corporate structure is unsigned. Resubmit signed by director
[Darvey Isidora - 15-05-2026 16:20]
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>
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
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
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
The PHDF must be filled out, signed and verified digitally. Please resubmit.
The PHDF must be filled out, signed and verified digitally. Please resubmit.
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>
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.
Enhance AML policy to reflect Curacao AML Guidelines.
Enhance AML policy to reflect Curacao AML Guidelines.
[Darvey Isidora - 15-05-2026 16:36]
Upgrade RG and Self Exclusion policy to reflect CGA Guidelines
Upgrade RG and Self Exclusion policy to reflect CGA Guidelines
[Darvey Isidora - 15-05-2026 16:37]
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.
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 procedure
The RG policy must outline the procedure carried out by the operator to verify the player's age.
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-keeping
The RG policy must state the operator's record-keeping policy.
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.
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.
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.
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
Establish player profiles to assess risk levels
The RG policy must establish player profiles to assess risk levels
Adopt RBA to determine level of monitoring and intervention
The RG policy must adopt RBA to determine level of monitoring and intervention
Record all RG interactions in PAM system
The RG policy must state that the operators records all RG interactions in the PAM system
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
Operator must offer players option to activate a cooling-off period
The operator must offer players the option to activate a cooling-off period
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
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
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
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
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
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.
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
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 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