#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Zozo Technology B.V.

Gaming OperatorRegistered March 28, 2024
1
Applications
2
Domains
9
Related Entities
0
Locations

OGL/2024/1519/0809

Granted
Submitted: September 25, 2024End Date: October 16, 2024

Customer

Contact
Gouloud Hammoud
Email
zozotechnologybv@g-force-corporate-services.com
Company
Zozo Technology B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
KMKieran McLean (KMC)
Suitability
CHCeline Houareau (CLHR)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DIDenneth Isidora (DEI)
Fully Issued
DIDenneth Isidora (DEI)

Compliance Checklists

Application Verification ReviewCritical3 items
Micheal GattQuestionMinorDue Jul 26, 2024

Page1: The application number is incorrect.

Kindly resubmit the forms with the correct application number.

Micheal GattQuestionMinorDue Jul 26, 2024

Page1: The personal application number is incorrect

Kindly resubmit the forms with the correct personal application number.

Nicholas GattQuestionMinorDue Jul 26, 2024

Page 1: The application number is incorrect

Kindly resubmit the forms with the correct application number.

Application Due Diligence ReviewCritical8 items
Share Ledger CertificationShare LedgerLowDue Aug 13, 2024

The share ledger submitted is uncertified.

<p>The share ledger submitted is uncertified.<br></p><p>Kindly resubmit duly certified.</p>

Business PlanBusiness PlanMediumDue Aug 13, 2024

The business plan does not make reference to the name of the applicant company.

<p>The business plan does not make reference to the name of the applicant company.</p><p>Kindly update the company name in the business plan or provide an annexed signed declaration to this effect.</p>

Source of funds of businessSource of FundsCriticalDue Jan 19, 2026

Kindly submit documentation as to how the company is being funded and by whom, including any declarations, as well as any documents evidencing any funding by shareholders or third parties. Kindly note that documents must be duly certified.

<p>Kindly submit documentation as to how the company is being funded and by whom, including any necessary declarations/documents evidencing any funding by shareholders or third parties. Kindly note that documents must be duly certified.</p><p>Dear Applicant, the documents submitted refer to the SOW of the UBO and not the SOF of the Company. If the company has any funds and/or is being funded, please provide evidence of the same. If the company has no funds/is not being funded, please provide a declaration to this effect</p>

Customer Reply Source of the Wealth support of the buyer (new owner of the shares) has been submitted 29 July 2025. The new owner will loan the company funds. Please advise RCL: New BCIF states that company will be funded by shareholders loan in the amount of circa Eur 194k. A letter to CGA, submitted, signed by the director, states that UBO has undertaken to fund this amount from personal funds. An unsigned/uncertified loan agreement between new UBO and app co, was submitted for this amount. The final draft and uncertified share ledger shows an even 'newer' UBO (who also submitted PHDF). A draft SPA (and unsigned SPA) was submitted between the 2nd and 3rd UBOs for the consideration of circa Eur 42k. This applicant is to be transferred to Team A for verification of new UBO and SOW. CGA is also to obtain i) certified updated share ledger ii) Trail of certified and fully executed SPAs from original UBO Michael Gatt to current UBO iii) Full executed and certified loan agreement between current UBO and app co Further note: FS 2024 submitted. Does not indicate trading or revenue, however indicates shares at a premium
AML Policy (See Provisional License Conditions under LOK)OperationsMediumDue Oct 7, 2025

It was observed that an AML policy is in place and is available on the website, however this is not compliant with Curacao AML laws. This needs to be updated accordingly.

It was observed that an AML policy is in place and is available on the website, however this is not compliant with Curacao AML laws. This needs to be updated accordingly.

30 Sept 2025: This has already been addressed as a Provisional License Condition under Lok. Customer Reply The AMPL policy has been updated. The AML Policy to comply with the Curacao AML Laws has been submitted on 07.08.2025.
Responsible Gaming PolicyPlayer AccountCriticalDue Aug 23, 2024

A responsible gaming policy is in place, however there is no mention of any limits that can be set by the player and they are not available on the player profile, even though it is marked as such in the application form. Session time limits and loss limits need to be in place and the player must be able to set these up through their account.

A responsible gaming policy is in place, however there is no mention of any limits that can be set by the player and they are not available on the player profile, even though it is marked as such in the application form. Session time and loss limits need to be in place and the player must be able to set these up through their account.

QPA/2025/03930 - Yeh Tai-Chun - Birth CertificateBirth CertificateCriticalDue Oct 14, 2025

A birth certificate has not been submitted. Kindly submit a certified true copy of the birth certificate.

A birth certificate has not been submitted. Kindly submit a certified true copy of the birth certificate.

QPA/2025/03930 - Yeh Tai-Chun - Reference LetterReference LetterCriticalDue Oct 14, 2025

Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

QPA/2025/03930 - Yeh Tai-Chun - SOWSource of WealthCriticalDue Nov 27, 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.</p><p class="MsoNormal"><o:p><br></o:p></p><p class="MsoNormal"><o:p>Not Valid SOW.</o:p></p>