Kindly fill in question 19 on page 3 and resubmit form.

Kindly fill in question 19 on page 3 and resubmit form.

Kindly have the Structure Chart certified.

Kindly have the Structure Chart certified.

Kindly provide a share ledger signed by the current managing director. The share ledger must also be certified as a true copy.

Kindly provide a share ledger signed by the current managing director. The share ledger must also be certified as a true copy.

Kindly provide an updated share ledger for Veshtinnu Ltd certified as a true copy.

Kindly provide an updated share ledger for Veshtinnu Ltd certified as a true copy.

Please provide a directors list for Veshtinnu Ltd signed by the managing director and certified as a true copy.

Please provide a directors list for Veshtinnu Ltd signed by the managing director and certified as a true copy.

Kindly have the Business Plan certified.

Kindly have the Business Plan certified.

Please submit the signed financial statements of Usoftgaming N.V. for 2023 and 2024.

<p>Please submit the signed financial statements of Usoftgaming N.V. for 2023 and 2024, as well as signed financials in whatever form for the first six months of 2025</p><p><b><u>UPDATE</u></b></p><p>Please submit the signed financials in whatever form for the first six months of 2025.</p>

Please provide the Declaration of Good Standing (verzoek verklaring betalingsgedrag) of Usoftgaming N.V. Kindly upload the document in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the official document issued by the Tax Authorities with the stamp of 'ontvanger' and the 'invorderaar' and it must be certified as a true copy.

<p>Please provide the Declaration of Good Standing (verzoek verklaring betalingsgedrag) of Usoftgaming N.V. Kindly upload the document in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the official document issued by the Tax Authorities with the stamp of 'ontvanger' and the 'invorderaar' and it must be certified as a true copy.</p><p><b><u>UPDATE</u></b></p><p>In the document submitted, the notary's statement indicates that the document was seen for the legalization of the signature of the translator. However, the original Declaration of Good Standing document (in Dutch) must be certified as a true copy. Please submit a certified true copy of the Declaration of Good Standing. </p>

Kindly upload a source of funds not older than 6 months.

Kindly upload a source of funds not older than 6 months.

Kindly complete question 7 and resubmit the form.

<p>Kindly complete question 7 and resubmit the form.</p><p><b><u>UPDATE</u></b></p><p>The response to question 7 is still missing and "N/A" has been entered. If none of the options are applicable, please provide an explanation regarding this. </p>

Kindly upload a shot screen of the registration in the GoAML in Portal under tab "Extra Documentation".

Kindly upload a shot screen of the registration in the GoAML in Portal under tab "Extra Documentation".

Please note that in section 12.1, all individuals holding key positions and their respective roles must be added (even if the role is held by a UBO, for example CEO/CTO, etc.). It is also mandatory to list a compliance officer in question 12.1. Kindly complete questions 12 and 12.1 and resubmit the form.

Please note that in section 12.1, all individuals holding key positions and their respective roles must be added (even if the role is held by a UBO, for example CEO/CTO, etc.). It is also mandatory to list a compliance officer in question 12.1. Kindly complete questions 12 and 12.1 and resubmit the form.

Kindly upload a certified updated Birth Certificate not older than 6 months. The one in Portal has been expired.

Kindly upload a certified updated Birth Certificate not older than 6 months. The one in Portal has been expired.

Passport has been expired. Kindly upload a updated certified copy passport.

Passport has been expired. Kindly upload a updated certified copy passport.

Kindly upload a certified updated Criminal Record not older than 6 months. The one in Portal has been expired.

Kindly upload a certified updated Criminal Record not older than 6 months. The one in Portal has been expired.

Kindly upload a certified updated (Bank) Reference Letter not older than 6 months. The one in Portal has been expired.

Kindly upload a certified updated (Bank) Reference Letter not older than 6 months. The one in Portal has been expired.

Kindly upload a certified updated Source of Wealth not older than 6 months.

Kindly upload a certified updated Source of Wealth not older than 6 months.

Please note that question 13 was not completed correctly. The information on the first line should be the information of the applicant company. This should then be followed by the information for each interstitial company up to the UBOs.

Please note that question 13 was not completed correctly. The information on the first line should be the information of the applicant company. This should then be followed by the information for each interstitial company up to the UBOs.

Please provide a certified copy of the share ledger of Orion Trust.

Please provide a certified copy of the share ledger of Orion Trust.

Please provide a directors list for Orion Trust signed by the managing director and certified as a true copy.

Please provide a directors list for Orion Trust signed by the managing director and certified as a true copy.

Please submit a certified true copy of the Articles of Incorporation of Orion Trust. If the document is not in English, an English translation (certified by the translator) must also be submitted.

Please submit a certified true copy of the Articles of Incorporation of Orion Trust. If the document is not in English, an English translation (certified by the translator) must also be submitted.

Please note that a compliance officer must be added in the portal and the Personal History Disclosure Form (or Personal History Disclosure Short Form if applicable) must be uploaded as well as all enclosures. A letter of engagement (signed by the managing director and the compliance officer) and the CV of the compliance officer must also be uploaded.

Please note that a compliance officer must be added in the portal and the Personal History Disclosure Form (or Personal History Disclosure Short Form if applicable) must be uploaded as well as all enclosures. A letter of engagement (signed by the managing director and the compliance officer) and the CV of the compliance officer must also be uploaded.

According to the business plan, in addition to being the UBO, Nicos Constandinou is also the CEO, CFO, and COO. If this information is still accurate, both UBO and Other Key Function Holder must be selected for question 6. The applicable roles must be listed in the space provided next to Other Key Function Holder.

According to the business plan, in addition to being the UBO, Nicos Constandinou is also the CEO, CFO, and COO. If this information is still accurate, both UBO and Other Key Function Holder must be selected for question 6. The applicable roles must be listed in the space provided next to Other Key Function Holder.

Please provide additional evidence of source of wealth in the base application QPA/2024/00818. Documents provided should be recent and must be certified as a true copy.

<p>Please provide additional evidence of source of wealth in the base application QPA/2024/00818. Documents provided should be recent and must be certified as a true copy.</p><p><b><u>UPDATE</u></b></p><p>Please provided a copy of a recent bank statement (no older than six months) certified as a true copy. Please upload the document in the base application QPA/2024/00818.</p>

According to the business plan, in addition to being the UBO, Francois Casgrain is also the CEO, CFO, CTO, and COO. If this information is still accurate, both UBO and Other Key Function Holder must be selected for question 6. The applicable roles must be listed in the space provided next to Other Key Function Holder.

According to the business plan, in addition to being the UBO, Francois Casgrain is also the CEO, CFO, CTO, and COO. If this information is still accurate, both UBO and Other Key Function Holder must be selected for question 6. The applicable roles must be listed in the space provided next to Other Key Function Holder.

The country code of the mobile phone number is missing. Please enter the complete mobile phone number including the country code and resubmit the form.

The country code of the mobile phone number is missing. Please enter the complete mobile phone number including the country code and resubmit the form.

According to the business plan, Francois Casgrain is the UBO, CEO, CFO, CTO, and COO. If this information is still accurate, please add these roles to his profile in the portal.

According to the business plan, Francois Casgrain is the UBO, CEO, CFO, CTO, and COO. If this information is still accurate, please add these roles to his profile in the portal.

According to the business plan, Nicos Constandinou is the UBO, CEO, CFO, and COO. If this information is still accurate, please add these roles to his profile in the portal.

According to the business plan, Nicos Constandinou is the UBO, CEO, CFO, and COO. If this information is still accurate, please add these roles to his profile in the portal.

Kindly fill in Qs 8 and 9 of the BCIF relating to the in/direct bank accounts / wallets held by the applicant company, noting that it is currently trading

Kindly fill in Qs 8 and 9 of the BCIF relating to the in/direct bank accounts / wallets held by the applicant company, noting that it is currently trading

Submit enhanced and certified documentation showing how the operations of the company are currently being funded and by whom, including documents which show funds owned by the company

Submit enhanced and certified documentation showing how the operations of the company are currently being funded and by whom, including documents which show funds owned by the company

Please submit the Letter of Engagement signed by both the Managing Director and the Compliance Officer.

<p>Please submit the Letter of Engagement signed by both the Managing Director and the Compliance Officer.</p><p><b><u>UPDATE</u></b></p><p>In your reply it was indicated that the letter of engagement was submitted on 19.12.2025, however, no letter was found. Please upload the letter of engagement in the "Letter of Appointment/Engagement as a Key Person" section in this application.</p>

The corporate structure indicates the UBOs as holding in a 60%-40% ratio. The Trust deed submitted defines the Principle Beneficiaries as 'equally proportionally'. Kindly provide a substantiated clarification as to the % holdings of the UBOs as indicated in the corporate structure.

The corporate structure indicates the UBOs as holding in a 60%-40% ratio. The Trust deed submitted defines the Principle Beneficiaries as 'equally proportionally'. Kindly provide a substantiated clarification as to the % holdings of the UBOs as indicated in the corporate structure.

The policy must be signed by the Compliance Officer and Managing Director of the Applicant

The policy must be signed by the Compliance Officer and Managing Director of the Applicant

The policy must identify the office responsible for updates and review of the policy

The policy must identify the office responsible for updates and review of the policy

The policy must state that it will be reviewed periodically, at minimum, once a year

The policy must state that it will be reviewed periodically, at minimum, once a year

The policy must define the rules and risk controls around virtual assets and crypto usage

The policy must define the rules and risk controls around virtual assets and crypto usage

The policy must define the set automated triggers for suspicious transaction patterns and how the operator analyses patterns to detect structuring or other suspicious behaviour

The policy must define the set automated triggers for suspicious transaction patterns and how the operator analyses patterns to detect structuring or other suspicious behaviour

The policy must state that the operator retains records of CDD, transactions, and UTR (objective and subjective) for at least 5 years

The policy must state that the operator retains records of CDD, transactions, and UTR (objective and subjective) for at least 5 years

The policy must assign a trained and independent AML Compliance Officer

The policy must assign a trained and independent AML Compliance Officer

The policy must outline the annual audit plan of the AML program and internal controls

The policy must outline the annual audit plan of the AML program and internal controls

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person

The policy must state that players who do not register themselves will not be allowed to play

The policy must state that players who do not register themselves will not be allowed to play

The complaints procedure must state that complaints can only be made by the registered player

The complaints procedure must state that complaints can only be made by the registered player

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) - it should be noted the player should not have the right to resurface the dispute in the future

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) - it should be noted the player should not have the right to resurface the dispute in the future

The periodic report will summarise the following: a. Total number of complaints made b. Total number of settled complaints (upheld and rejected) c. Number of pending or unresolved complaints d. Number of complaints by category e. Number referred to ADR f. Number and detail of complaints for which a player has taken legal action

The periodic report will summarise the following: <br>a. Total number of complaints made <br>b. Total number of settled complaints (upheld and rejected) <br>c. Number of pending or unresolved complaints <br>d. Number of complaints by category <br>e. Number referred to ADR <br>f. Number and detail of complaints for which a player has taken legal action

The policy must state that the operator will ensure transparency and compliance with ADR decisions and regulatory updates

The policy must state that the operator will ensure transparency and compliance with ADR decisions and regulatory updates

The policy must state that ADR service providers will have their own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA

The policy must state that ADR service providers will have their own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA