#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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The inclusion of a person, company, domain, or other entity in the CasinoSecrets database does not imply illegal or improper conduct. The data was extracted directly from relevant gambling authorities and official registers on the basis of a significant public interest and reflects information available up to August 2026.

Records may be incomplete, outdated, or contain errors from the underlying source systems. Please verify identities using company numbers, addresses, domains, licence details, or other identifying information before drawing conclusions. The database is intended to make information of significant public interest accessible for journalistic and research purposes. Individual records should be understood in the context of the underlying data and the reporting published alongside them.

Soft Entertainment N.V.

Gaming OperatorRegistered April 15, 2024
1
Applications
2
Domains
6
Related Entities
0
Locations

OGL/2024/1625/0862

Granted
Submitted: May 1, 2025End Date: June 4, 2025

Customer

Contact
Boy Hendriks
Email
softentertainmentnv@outlook.com
Company
Soft Entertainment N.V.

Review Timeline

Verification
MBMonica Botero (GCB User 7)
Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
SPSulmahine Penza-Kwidama (CGA USER 59)

Compliance Checklists

Application Verification ReviewCritical0 items
Application Due Diligence ReviewCritical9 items
QPA/2024/01251 - Pavels Kozlovz - Birth CertificateMiscellaneousCriticalDue Feb 5, 2025

A certified translation of the document should be provided.

A certified translation of the document should be provided.

QPA/2024/01251 - Pavels Kozlovz - PassportPassportCriticalDue Apr 23, 2025

Please provide a better scan of the passport and certify the scan.

Please provide a colour scan of the passport as well as a photo of yourself holding the passport that shows all of the information on it.

Corporate StructureMiscellaneousMediumDue Apr 16, 2025

Resubmit signed by director (and not just be certifier)

Resubmit signed by director (and not just be certifier)

AML PolicyMiscellaneousCriticalDue Apr 23, 2025

The AML Policy must adhere to Curacao AML laws. Please submit.

The AML Policy must adhere to Curacao AML laws. Please submit.

Responsible GamingOperationsCriticalDue Apr 23, 2025

It was noted that there is no Responsible Gaming policy available on the site apart from no 18+ signs available in the footer. The registered domain must have a RG policy available to its players, indicating at minimum, the procedure for self-exclusion, the procedure for any gaming limits available on the site and links to problem gambling organisations. Kindly amend.

It was noted that there is no Responsible Gaming policy available on the site apart from no 18+ signs available in the footer. The registered domain must have a RG policy available to its players, indicating at minimum, the procedure for self-exclusion, the procedure for any gaming limits available on the site and links to problem gambling organisations. Kindly amend.

Player RegistrationPlayer RegistrationCriticalDue Apr 23, 2025

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

Prohibited JurisdictionsProhibiited CountriesCriticalDue Apr 23, 2025

It was observed that players are allowed to register an account while accessing the registered domain from a Netherlands IP address. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register. Kindly amend.

It was observed that players are allowed to register an account while accessing the registered domain from a Netherlands IP address. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register. Kindly amend.

QPA/2024/02435 - Derek Hendriks- Letter of engagementMiscellaneousCriticalDue Dec 10, 2025

Please upload the letter of engagement.

Please upload the letter of engagement.

Source of FundsSource of FundsCriticalDue May 19, 2026

This is a reminder to comply with the request to submit certified documentation as to how the company is/will be funded including documents which show funding/loans by the shareholder or third parties. Please be advised that non-compliance may affect whether the license is granted.

This is a reminder to comply with the request to submit certified documentation as to how the company is/will be funded including documents which show funding/loans by the shareholder or third parties. Please be advised that non-compliance may affect whether the license is granted.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 21, 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 May 21, 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 May 21, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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 May 21, 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

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 18, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 18, 2026

List Position:

Native NameQuestionCriticalDue May 18, 2026

Please list the native name.

Pavel Dmitriyevich Kozlov
[Philippe Warzee - 11-05-2026 10:35]
PHDFQuestionCriticalDue May 18, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 18, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 18, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Bank Account Statement are not valid as Proof of Address. Please, provide a proper Utility Bill ( water, electricity, internet or telephone fixed line )
[Philippe Warzee - 11-05-2026 10:39]
Reference LetterQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 18, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 18, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 18, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 18, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 18, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 18, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 18, 2026

List Position:

Native NameQuestionCriticalDue May 18, 2026

Please list the native name.

PHDFQuestionCriticalDue May 18, 2026

Approved or not. If no list, why?

Not signed digitally
[Philippe Warzee - 11-05-2026 11:47]
PassportPassportCriticalDue May 18, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 18, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 18, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 18, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 18, 2026

Approved or if not, list why.

CV missing
[Philippe Warzee - 11-05-2026 11:48]
PEP or family of PEPQuestionCriticalDue May 18, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 18, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 18, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 18, 2026

List Position:

Native NameQuestionCriticalDue May 18, 2026

Please list the native name.

PHDFQuestionCriticalDue May 18, 2026

Approved or not. If no list, why?

PHDF not digitally signed
[Philippe Warzee - 11-05-2026 11:59]
PassportPassportCriticalDue May 18, 2026

Approved, or if not, list why.

Expired in 2025 . Invalid document
[Philippe Warzee - 11-05-2026 12:01]
Birth CertificateBirth CertificateCriticalDue May 18, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 18, 2026

Approved, or if not, list why.

Reference letter issued in the name of the company. To provide a personal letter of reference
[Philippe Warzee - 11-05-2026 12:05]
SOW - Source of WealthSource of WealthCriticalDue May 18, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 18, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 18, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 18, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 18, 2026

Add the URL and give a small summary.

DomainCritical1 item
DomainWebsiteCriticalDue May 15, 2026

The domain twocards.com appears to be operated by SoftSpark Services S.R.L., a company established under the laws of Costa Rica and licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros. It operates under License No. ALSI-202409048-FI2. A domain listed in an application for a CGA license cannot be licensed under another regime. Please confirm and list the domain intended for this application.

The domain twocards.com appears to be operated by SoftSpark Services S.R.L., a company established under the laws of Costa Rica and licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros. It operates under License No. ALSI-202409048-FI2. A domain listed in an application for a CGA license cannot be licensed under another regime. Please confirm and list the domain intended for this application.