#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Playlotto N.V.

Gaming OperatorRegistered March 27, 2024
1
Applications
1
Domains
9
Related Entities
0
Locations

OGL/2024/1440/0677

Rejected
Submitted: September 24, 2024End Date: October 31, 2025

Customer

Contact
Ann Mary Requa
Email
ann@playlottoglobal.com
Company
Playlotto N.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
DFDesiree Francisco (CGA User 6)
Due Diligence
KMKevin Mallia (KM)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Approval
HSHilary Stewart Jones (HSJ)
Approval
CPCedric Pietersz (Managing Director GCB)

Compliance Checklists

Application Verification ReviewCritical4 items
Directors List SMTM Global LLCDirector's ListCriticalDue Aug 15, 2024

We are missing the directors list of SMTM Global LLC.

Kindly submit the requested document.

Todd PoindexterMiscellaneousMinorDue Aug 15, 2024

Page 1: The form is missing Personal Application Number.

Kindly resubmit the form with the correct personal application number.

Source Consulting Worldwide LLC - Share Ledger + Directors List/ Operating AgreementShare LedgerCriticalDue Oct 4, 2024

We are missing the share ledger and directors list of Source Consulting Worldwide LLC.

<p>We are missing the share ledger of Source Consulting Worldwide LLC. Kindly submit the requested document.</p><p>Can you upload it now?<br></p>

Intrepid Family Holdings LLC - Sher Ledger+ Directors List / Operating agreementShare LedgerCriticalDue Oct 4, 2024

We are missing the share ledger and directors list of Intrepid Family Holdings LLC

<p>We are missing the share ledger and directors list of Intrepid Family Holdings LLC. Kindly submit the requested document.</p><p>Can you upload it now?<br></p>

Application Due Diligence ReviewCritical14 items
QPA/2024/00967 - Ann Requa - SOWSource of WealthCriticalDue Oct 28, 2024

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/2024/01830 - Todd Poindexter - PHDFMiscellaneousCriticalDue Oct 28, 2024

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/2024/01830 - Todd Poindexter - SOWSource of WealthCriticalDue Oct 28, 2024

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/2024/01832 - Gabriel Fortuny Requa - Proof of addressMiscellaneousCriticalDue Oct 28, 2024

Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.

<p class="MsoNoSpacing">Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.<o:p></o:p></p>

Corporate StructureMiscellaneousCriticalDue Jul 17, 2025

The corporate structure does not align with the share ledgers provided, which indicate two more interstitial companies above SMTM Global LLC. Kindly amend and resubmit corporate structure signed by the director and duly dated. Signatory should be identifiable

The corporate structure does not align with the share ledgers provided, which indicate two more interstitial companies above SMTM Global LLC. Kindly amend and resubmit corporate structure signed by the director and duly dated. Identity of signatory should also be included

Local directorDirector's ListCriticalDue Jul 17, 2025

No local director appointed. At least one local executive director is required. Appoint a local director (TSP) and submit the PHDF and enclosures of its representatives. Resubmit an updated director's register of the applicant company following the said appointment

No local director appointed. At least one local executive director is required. Appoint a local director (TSP) and submit the PHDF and enclosures of its representatives. Resubmit an updated director's register of the applicant company following the said appointment

Financial StatementsFinancial AuditCriticalDue Jul 17, 2025

Resubmit the FS submitted for 2022 duly signed and approved by the director. Submit also FS 2023 and signed financials in whatever form for year ending 2024

Resubmit the FS submitted for 2022 duly signed and approved by the director. Submit also FS 2023 and signed financials in whatever form for year ending 2024

Share LedgerShare LedgerCriticalDue Jul 17, 2025

A share ledger of the applicant company is required as opposed to a share certificate, indicating the % holding of the share holder. This document must be duly certified as a true copy.

A share ledger of the applicant company is required as opposed to a share certificate, indicating the % holding of the share holder. This document must be duly certified as a true copy.

Share LedgerShare LedgerCriticalDue Jul 17, 2025

Resubmit the amending and reinstating resolutions of SMTM Global LLC, as well as those of Interpid Family Holdings LLC and Source Consulting Worldwide LLC evidencing the shareholders and directors of each company, duly certified as true copies by an independent and authorised certifier. which indicate the shareholders and directors, duly certified. Resubmit the same for

Resubmit the amending and reinstating resolutions of SMTM Global LLC, as well as those of Interpid Family Holdings LLC and Source Consulting Worldwide LLC evidencing the shareholders and directors of each company, duly certified as true copies by an independent and authorised certifier.

Source of funds of businessSource of FundsCriticalDue Jul 17, 2025

1. Submit certified documentation as to how the company is funded and by whom, including evidence of loans from shareholders or third parties 2. The Convertible Promissory is incomplete and unsigned. Clarify its relevance 3. Resubmit the 2 year Convertible Loan safe note duly certified. Submit the most recent Financial statements of Tasso Partners LLC as a funding party as well as a certified copy of its director's register.

1. Submit certified documentation as to how the company is funded and by whom, including evidence of loans from shareholders or third parties to the applicant company 2. The Convertible Promissory is incomplete and unsigned. Clarify its relevance 3. Resubmit the 2 year Convertible Loan safe note duly certified. Submit the most recent Financial statements of Tasso Partners LLC as a funding party as well as a certified copy of its director's register. 4. Resubmit the bank statement of SMTM Global LLC duly certified

Compliance officerMiscellaneousCriticalDue Jul 17, 2025

Ann Requa may not hold the office of a Compliance Officer due to conflicting interests. Appoint am alternative CO fluent in AML and submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV . No SOW required

Ann Requa may not hold the office of a Compliance Officer due to conflicting interests. Appoint am alternative CO fluent in AML and submit their PHDF, together with relevant enclosures, as well as a Letter of engagement and CV . No SOW required

Company Details and CGA Dynamic SealOperationsCriticalDue Jul 23, 2025

The registered domain must display the Curacao registered applicant entity's details on the homepage footer. Furthermore, the CGA's dynamic seal must also be displayed on the homepage footer. Kindly amend, and refer to the following page for the proper display of the dynamic seal: https://portal.gamingcontrolcuracao.org/

The registered domain must display the Curacao registered applicant entity's details on the homepage footer. Furthermore, the CGA's dynamic seal must also be displayed on the homepage footer. Kindly amend, and refer to the following page for the proper display of the dynamic seal: https://portal.gamingcontrolcuracao.org/

Prohibited JurisdictionsProhibited CountriesCriticalDue Jul 23, 2025

It was noted that players are allowed to register an account by choosing the Netherlands/Curacao as their country of residence. Furthermore, the T&Cs do not contain a prohibited jurisdictions list. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), US, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

It was noted that players are allowed to register an account by choosing the Netherlands/Curacao as their country of residence. Furthermore, the T&Cs do not contain a prohibited jurisdictions list. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), US, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Player RegistrationPlayer RegistrationCriticalDue Jul 23, 2025

The registration form does not require the player's DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.

The registration form does not require the player's DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.