#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Aquarius Entertainment N.V.

Gaming OperatorRegistered April 15, 2024
2
Applications
1
Domains
11
Related Entities
0
Locations

CGA/2025/1634/1347

In Progress
Submitted: August 18, 2026End Date: N/A

Customer

Contact
Jonathan Heymans
Email
aquariusentertainment@keyfin-management.com
Company
Aquarius Entertainment N.V.

Review Timeline

Verification
SCSarah Cathalina-Labbe (CGA user 10)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Suitability
HSHilary Stewart Jones (HSJ)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)

Compliance Checklists

Phase 1Critical16 items
Online Gaming License Application FormQuestionCriticalDue Mar 9, 2026

Please correct the below issues on the Online Gaming License Application Form and resubmit the form. Questions 20 - 25: The information entered must be that of the portal administrator. The email address entered in question 25 must match the email address of the portal administrator as registered in the portal. Declaration and Data Privacy: The managing director's name must appear at the top of the page and the form must be digitally signed by the managing director (copy/pasted signatures are not accepted).

<p>Please correct the below issues on the Online Gaming License Application Form and resubmit the form.</p><ol><li><b>Questions 20 - 25: </b>The information entered must be that of the portal administrator. The email address entered in question 25 must match the email address of the portal administrator as registered in the portal.</li><li><b>Declaration and Data Privacy: </b>The managing director's name must appear at the top of the page and the form must be digitally signed by the managing director (copy/pasted signatures are not accepted).</li></ol>

Share LedgerShare LedgerCriticalDue Jun 9, 2026

Please submit a certified true copy of the share ledger of Aquarius Entertainment N.V.

<p>Please submit a certified true copy of the share ledger of Aquarius Entertainment N.V.</p><p>Furthermore, please resubmit the share purchase agreement between the former and current UBO, duly certified and completed, wherein the purchase price paid is indicated</p><p><b><u>UPDATE</u></b></p><ol><li>The share ledger submitted is not certified. Please submit a certified true copy of the share ledger of Aquarius Entertainment N.V.</li><li>Please resubmit the share purchase agreement between the former and current UBO, duly certified and completed, wherein the purchase price paid is indicated.</li></ol>

Directors ListDirector's ListCriticalDue Apr 13, 2026

Please provide a certified true copy of the directors list for Aquarius Entertainment N.V.

Please provide a certified true copy of the directors list for Aquarius Entertainment N.V.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 15:49]
Business PlanBusiness PlanCriticalDue Apr 13, 2026

The business plan is outdated. Please submit an updated business plan that includes the company management structure showing key management roles and reporting lines and a detailed 3-year forecast. The management structure must indicate the names of those holding key management roles or whether the role is to be hired.

The business plan is outdated. Please submit an updated business plan that includes the company management structure showing key management roles and reporting lines and a revised detailed 3-year forecast. The management structure must indicate the names of those holding key management roles or whether the role is to be hired.  A Compliance Officer must be appointed and identified.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 16:02]
goAML RegistrationMiscellaneousCriticalDue Apr 13, 2026

Please note that the proof of goAML registration is missing. Kindly submit a screenshot of the admin page when logged in to the goAML portal. To do this, log in to the goAML portal, click Admin, select Active Organizations and take a screenshot of the page. Please upload the screenshot in the Extra Documentation section.

Please note that the proof of goAML registration is missing. Kindly submit a screenshot of the admin page when logged in to the goAML portal. To do this, log in to the goAML portal, click Admin, select Active Organizations and take a screenshot of the page. Please upload the screenshot in the Extra Documentation section.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 16:05]
Source of Funds of BusinessSource of FundsCriticalDue Apr 13, 2026

Please submit a certified copy of the loan agreement, which is expected to outline the key terms, including the funding and any interest on the loan and the repayment terms (if applicable). The loan agreement must be signed by all parties and certified. Kindly upload it in the Source of Funding Section.

Please submit a certified copy of the loan agreement, which is expected to outline the key terms, including the funding, and any interest on the loan and the repayment terms (if applicable). The loan agreement must be signed by all parties and certified. Kindly upload it in the Source of Funding Section.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 16:36]
Chien-Tang Liang - Roles in PortalMiscellaneousCriticalDue Mar 9, 2026

In the portal it is indicated that Chien-Tang Liang is the UBO and managing director, however, he does not appear as a managing director on the Curaçao Chamber of Commerce Register excerpt. Please remove the role of managing director if no longer applicable.

In the portal it is indicated that Chien-Tang Liang is the UBO and managing director, however, he does not appear as a managing director on the Curaçao Chamber of Commerce Register excerpt. Please remove the role of managing director if no longer applicable.

Chien-Tang Liang - Birth CertificateBirth CertificateCriticalDue Apr 13, 2026

Please submit a copy of the birth certificate that has been certified as a true copy by an independent and authorized certifier.

Please submit a copy of the birth certificate that has been certified as a true copy by an independent and authorized certifier.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 19:57]
Chien-Tang Liang - Criminal RecordCriminal RecordCriticalDue Apr 13, 2026

Please submit a certified copy of the criminal record.

Please submit a certified copy of the criminal record.

Completed.
[Sarah Cathalina-Labbe - 15-04-2026 20:15]
Chien-Tang Liang - Proof of EmploymentMiscellaneousCriticalDue May 1, 2026

Please provide proof of current employment as indicated in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be certified as true copies.

<p>Please provide proof of current employment as indicated in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be certified as true copies.</p><p><b><u>UPDATE</u></b></p><p>The Certificate of Incumbency submitted for FunCube Corp. cannot be accepted as proof of current employment because it is not certified as a true copy. Please resubmit a certified copy of the document.</p>

Jonathan Heymans - PassportPassportCriticalDue Mar 9, 2026

Please upload a certified copy of your passport in the base application QPA/2024/02337.

Please upload a certified copy of your passport in the <u><b>base application QPA/2024/02337</b></u>.

Compliance OfficerMiscellaneousCriticalDue Apr 13, 2026

Appointment of a compliance officer is required. Please add the compliance officer to the portal and upload the Personal History Disclosure Forms and enclosures (with the exception of source of wealth). The compliance officer must also submit a letter of engagement (signed by the compliance officer and the managing director) and a CV in English (both documents to be uploaded in the Letter of Engagement section of the portal).

<p>Appointment of a compliance officer is required. Please add the compliance officer to the portal and upload the Personal History Disclosure Forms and enclosures (with the exception of source of wealth). </p><p>The compliance officer must also submit a letter of engagement (signed by the compliance officer and the managing director) and a CV in English (both documents to be uploaded in the Letter of Engagement section of the portal).</p>

Compliance officer added. Separate checklist items will be created for any missing/rejected documents as necessary.
[Sarah Cathalina-Labbe - 16-04-2026 14:17]
C-Suite Level PositionsMiscellaneousCriticalDue Apr 13, 2026

Any person holding a c-suite level position (CEO, CFO, CTO, etc.) must be added to the portal and the Personal History Disclosure Form and enclosures uploaded (with the exception of source of wealth).

Any person holding a c-suite level position (CEO, CFO, CTO, etc.) must be added to the portal and the Personal History Disclosure Form and enclosures uploaded (with the exception of source of wealth).

NFA
[Sarah Cathalina-Labbe - 15-04-2026 15:18]
Sarunas Masalas - PassportPassportCriticalDue May 1, 2026

The copy of the passport submitted cannot be accepted because it is not certified. Please resubmit a certified true copy of the passport.

The copy of the passport submitted cannot be accepted because it is not certified. Please resubmit a certified true copy of the passport.

Sarunas Masalas - Bank Reference LetterReference LetterCriticalDue May 1, 2026

Please submit a bank reference letter. The reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Please submit a bank reference letter. The reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Sarunas Masalas - Letter of EngagementMiscellaneousCriticalDue May 1, 2026

The letter of engagement submitted cannot be accepted because it is not signed by the compliance officer. Please resubmit the letter of engagement signed by both the managing director and the compliance officer.

The letter of engagement submitted cannot be accepted because it is not signed by the compliance officer. Please resubmit the letter of engagement signed by both the managing director and the compliance officer.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 4, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 4, 2026

List Position:

Native NameQuestionCriticalDue May 4, 2026

Please list the native name.

PHDFQuestionCriticalDue May 4, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 4, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 4, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 4, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 4, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 4, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 4, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 4, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 4, 2026

Check and list the Application Date.

<p><br></p>

March 2026
[Philippe Warzee - 27-04-2026 15:18]
Position/RoleQuestionCriticalDue May 4, 2026

List Position:

Compliance Officer
[Philippe Warzee - 27-04-2026 15:18]
Native NameQuestionCriticalDue May 4, 2026

Please list the native name.

PHDFQuestionCriticalDue May 4, 2026

Approved or not. If no list, why?

YES
[Philippe Warzee - 27-04-2026 15:20]
YES
[Philippe Warzee - 27-04-2026 15:20]
PassportPassportCriticalDue May 4, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 4, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 4, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 4, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 4, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 4, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 4, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 4, 2026

Add the URL and give a small summary.

AML PolicyCritical5 items
Signature of CO and Managing directorPolicy DocumentHighDue May 31, 2026

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.

Business Risk Assessment (BRA)Policy DocumentCriticalDue May 31, 2026

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

Customer Risk Assessment (CRA)Policy DocumentCriticalDue May 31, 2026

The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.

The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.

Crypto PolicyPolicy DocumentCriticalDue May 31, 2026

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.

Compliance with Internal PolicyPolicy DocumentCriticalDue May 31, 2026

The policy must describe the risks and potential consequences of violating the policy, including disciplinary actions, legal implications, or busines risks. All staff must confirm awareness and compliance with the AML policy.

The policy must describe the risks and potential consequences of violating the policy, including disciplinary actions, legal implications, or busines risks. All staff must confirm awareness and compliance with the AML policy.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 12, 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 12, 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 12, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue May 12, 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 12, 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 12, 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 12, 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 12, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue May 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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 12, 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

Player ComplaintsCritical26 items
Lodging a complaintPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that players may lodge a complaint free of charge at any time up to six months of the settlement of the bet or the incident about which they are making a complaint.

The policy must state that players may lodge a complaint free of charge at any time up to six months of the settlement of the bet or the incident about which they are making a complaint.

Lodging a complaint (P2P)Policy DocumentCriticalDue Jul 3, 2026

The policy must state that in the case of P2P (such as poker) or ante post fixed odds betting the six month clock begins after the bet settlement or conclusion of a specific event rather than the placement of the wager after the bet settlement or conclusion of a specific event rather than the placement of the wager.

The policy must state that in the case of P2P (such as poker) or ante post fixed odds betting the six month clock begins after the bet settlement or conclusion of a specific event rather than the placement of the wager after the bet settlement or conclusion of a specific event rather than the placement of the wager.

Lodging a complaint (live betting)Policy DocumentCriticalDue Jul 3, 2026

The policy must state that in the case of complaints about in-running sports betting, customers must be advised that while they may submit a complaint within six months, prompt action may be necessary if the investigation may depend on data specific to the complaint which — due to the nature of in-running betting.

The policy must state that in the case of complaints about in-running sports betting, customers must be advised that while they may submit a complaint within six months, prompt action may be necessary if the investigation may depend on data specific to the complaint which — due to the nature of in-running betting.

Eligibility to make a complaintPolicy DocumentCriticalDue Jul 3, 2026

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.

Customer supportPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that in the first instance the operator must offer customer support via email and/or live chat.

The policy must state that in the first instance the operator must offer customer support via email and/or live chat.

Complaint formPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that an official Complaint Submission Form must be available to the player. a. This form must be either a downloadable form that can be completed and emailed or otherwise uploaded by the player, and/or a form that is fully completed and submitted online b. The form must include at a minimum the following sections i. Complainant's name, address, and place of residence. ii. Complainant's account number (if applicable) iii. Date of the complaint and date of the disputed event. iv. Description of the conduct being disputed (using a selection of predetermined category topics if/as applicable). c. The form must be available in English and in the language of the website/domain that the player is using. d. The operator may request supporting documentation the player requires to include as part of the complaint. Any additional information or documentation requested by the operator must be a reasonable in the context of complaint resolution.

The policy must state that an official Complaint Submission Form must be available to the player. a. This form must be either a downloadable form that can be completed and emailed or otherwise uploaded by the player, and/or a form that is fully completed and submitted online b. The form must include at a minimum the following sections i. Complainant's name, address, and place of residence. ii. Complainant's account number (if applicable) iii. Date of the complaint and date of the disputed event. iv. Description of the conduct being disputed (using a selection of predetermined category topics if/as applicable). c. The form must be available in English and in the language of the website/domain that the player is using. d. The operator may request supporting documentation the player requires to include as part of the complaint. Any additional information or documentation requested by the operator must be a reasonable in the context of complaint resolution.

Prioritising RG-related complaintsPolicy DocumentCriticalDue Jul 3, 2026

Complaints related to responsible gaming should be prioritized due to potential impacts on player well-being. Complaints should be categorized as related to responsible gaming in any case when it regards targeting of Vulnerable Players, the availability and/or timely implementation of self-exclusion and/or cooling-off and the mandated consequences therein as outlined in the Responsible Gaming policy.

Complaints related to responsible gaming should be prioritized due to potential impacts on player well-being. Complaints should be categorized as related to responsible gaming in any case when it regards targeting of Vulnerable Players, the availability and/or timely implementation of self-exclusion and/or cooling-off and the mandated consequences therein as outlined in the Responsible Gaming policy.

Timeline for RG-related complaintsPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that the operator will use their best efforts to resolve RG-related cases within five business days.

The policy must state that the operator will use their best efforts to resolve RG-related cases within five business days.

RG-related complaints processPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that within two days of receiving a RG-related complaint, the operator will: - Confirm receipt of the complaint in writing. - Provide an explanation of how the complaint will be processed. - Provide notice of the average timeline for resolution of such complaints.

The policy must state that within two days of receiving a RG-related complaint, the operator will: - Confirm receipt of the complaint in writing. - Provide an explanation of how the complaint will be processed. - Provide notice of the average timeline for resolution of such complaints.

Extension of timeline for RG-related complaintsPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that if more time is needed by the operator to make a reasonable and informed decision, players must be informed of the delay, which cannot exceed two weeks. If a delay is due to a lack of or a slow response from the player, the resolution period may be extended by no more than a further two weeks.

The policy must state that if more time is needed by the operator to make a reasonable and informed decision, players must be informed of the delay, which cannot exceed two weeks. If a delay is due to a lack of or a slow response from the player, the resolution period may be extended by no more than a further two weeks.

Timeline for all other complaint typesPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that the operator will assess and respond to complaints within four weeks. If necessary, due to complexity or lack of information, this period may be extended once by an additional four weeks, with prior written notice to the player.

The policy must state that the operator will assess and respond to complaints within four weeks. If necessary, due to complexity or lack of information, this period may be extended once by an additional four weeks, with prior written notice to the player.

Process for all other complaint typesPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that within one week of receiving a complaint, the operator will: - Confirm receipt of the complaint in writing. - Provide an explanation of how the complaint will be processed. - Provide notice of the average timeline for resolution of such complaints.

The policy must state that within one week of receiving a complaint, the operator will: - Confirm receipt of the complaint in writing. - Provide an explanation of how the complaint will be processed. - Provide notice of the average timeline for resolution of such complaints.

Final determination letterPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that a player will always receive a final determination of their complaint in writing. The response will either be: 1. A reasoned final assessment of the outcome/resolution of the complaint with supporting evidence if necessary or applicable. 2. Detailed reasons for not handling the complaint. If additional information is reasonably required to address the complaint fully, the operator must have requested this information within the initial four week time period. Should the complainant not provide the necessary within the initial four week time period, the operator may reject the complaint. 3. If the player is unsatisfied with the resolution and makes a further complaint to that effect, the player is informed that they may escalate the matter to an independent ADR entity.

The policy must state that a player will always receive a final determination of their complaint in writing. The response will either be: 1. A reasoned final assessment of the outcome/resolution of the complaint with supporting evidence if necessary or applicable. 2. Detailed reasons for not handling the complaint. If additional information is reasonably required to address the complaint fully, the operator must have requested this information within the initial four week time period. Should the complainant not provide the necessary within the initial four week time period, the operator may reject the complaint. 3. If the player is unsatisfied with the resolution and makes a further complaint to that effect, the player is informed that they may escalate the matter to an independent ADR entity.

Use of AI for complaints processPolicy DocumentCriticalDue Jul 3, 2026

The use of AI is permissible under this Complaints Policy Guideline subject to the following terms: 1. Once a player complaint has been identified as pertaining to Responsible Gaming (Clause 4.1), communications with the player should be conducted by a human, not AI. 2. Complaints that can be reasonable considered as complex should be dealt with by a human, not AI. 3. The AI records must be monitored to ensure that they are reasonable in their solutions/recommendations and consistent across players with like-for-like complaints.

The use of AI is permissible under this Complaints Policy Guideline subject to the following terms: 1. Once a player complaint has been identified as pertaining to Responsible Gaming (Clause 4.1), communications with the player should be conducted by a human, not AI. 2. Complaints that can be reasonable considered as complex should be dealt with by a human, not AI. 3. The AI records must be monitored to ensure that they are reasonable in their solutions/recommendations and consistent across players with like-for-like complaints.

Alternative Dispute ResolutionPolicy DocumentCriticalDue Jul 3, 2026

The operator must offer an ADR option for the players, subject to the requirements of Clause 5 of the Player Complaints Policy Guidelines.

The operator must offer an ADR option for the players, subject to the requirements of Clause 5 of the Player Complaints Policy Guidelines.

Legal action restrictionsPolicy DocumentCriticalDue Jul 3, 2026

Except if mutually agreed under specific terms of ADR (Clause 5 of the Player Complaints Policy Guideline), the policy must state that the operator does not restrict the rights of the player him/herself to take legal action.

Except if mutually agreed under specific terms of ADR (Clause 5 of the Player Complaints Policy Guideline), the policy must state that the operator does not restrict the rights of the player him/herself to take legal action.

Escalation to ADRPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that if a complaint cannot be resolved internally, the operator must provide players with an independent ADR service, of which the operator will bear all costs.

The policy must state that if a complaint cannot be resolved internally, the operator must provide players with an independent ADR service, of which the operator will bear all costs.

Recommencing ADR process with a different entityPolicy DocumentCriticalDue Jul 3, 2026

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.

Recommencing dropped ADR processesPolicy DocumentCriticalDue Jul 3, 2026

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

Restrictions on ADR escalationPolicy DocumentCriticalDue Jul 3, 2026

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

Compliance with ADR decisionsPolicy DocumentCriticalDue Jul 3, 2026

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.

Periodic reportingPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that the operator will submit reports to the CGA on January 15th and June 15th based on complaints submitted to the operator since the previous reporting period by players using the Complaints Submission Form.

The policy must state that the operator will submit reports to the CGA on January 15th and June 15th based on complaints submitted to the operator since the previous reporting period by players using the Complaints Submission Form.

Report detailsPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that 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 policy must state that 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

Record-Keeping of unresolved complaintsPolicy DocumentCriticalDue Jul 3, 2026

The operator will ensure that records of unresolved complaints and/or complaints that have been escalated to ADR or legal proceedings will be kept for the lesser of five years or the relevant time stipulated by data protection, statute of limitations or other relevant laws or guidelines.

The operator will ensure that records of unresolved complaints and/or complaints that have been escalated to ADR or legal proceedings will be kept for the lesser of five years or the relevant time stipulated by data protection, statute of limitations or other relevant laws or guidelines.

CGA's right to access recordsPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

The policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

Right to make a complaintPolicy DocumentCriticalDue Jul 3, 2026

The policy must state that the player has the right to make a complaint regarding any part of their relationship with the operator, or any incident related to their participation in a game of chance. This includes (but is not limited to): 1. Deposit issues 2. Withdrawal issues 3. Bonus terms and conditions 4. Account closures or restrictions 5. Alleged errors or unfairness in game outcomes 6. Responsible gaming issues 7. Treatment of player balances 8. KYC and Verification 9. Data Protection 10. Technical or Software issues 11. AML concerns 12. Issues with minors 13. Fraudulent games 14. Fraudulent practices 15. License or regulation 16. Unfair terms and conditions

The policy must state that the player has the right to make a complaint regarding any part of their relationship with the operator, or any incident related to their participation in a game of chance. This includes (but is not limited to): 1. Deposit issues 2. Withdrawal issues 3. Bonus terms and conditions 4. Account closures or restrictions 5. Alleged errors or unfairness in game outcomes 6. Responsible gaming issues 7. Treatment of player balances 8. KYC and Verification 9. Data Protection 10. Technical or Software issues 11. AML concerns 12. Issues with minors 13. Fraudulent games 14. Fraudulent practices 15. License or regulation 16. Unfair terms and conditions

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 13, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 13, 2026

List Position:

Native NameQuestionCriticalDue May 13, 2026

Please list the native name.

PHDFQuestionCriticalDue May 13, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 13, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 13, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 13, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 13, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 13, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 13, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 13, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 13, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 13, 2026

List Position:

Native NameQuestionCriticalDue May 13, 2026

Please list the native name.

PHDFQuestionCriticalDue May 13, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 13, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 13, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Not approved as only bank account statement for a month (UBO)
[Philippe Warzee - 06-05-2026 09:41]
SOW - Source of WealthSource of WealthCriticalDue May 13, 2026

Approved, or if not, list why.

Personal Declaration requires either a digital signature or to be CTC as UBO.
[Philippe Warzee - 06-05-2026 09:43]
Letter of EngagementQuestionMediumDue May 13, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 13, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 13, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 13, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 13, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 13, 2026

List Position:

Native NameQuestionCriticalDue May 13, 2026

Please list the native name.

PHDFQuestionCriticalDue May 13, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 13, 2026

Approved, or if not, list why.

Not CTC
[Philippe Warzee - 06-05-2026 09:52]
Birth CertificateBirth CertificateCriticalDue May 13, 2026

Approved, or if not, list why.

Not CTC
[Philippe Warzee - 06-05-2026 09:52]
Criminal RecordQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Not CTC
[Philippe Warzee - 06-05-2026 09:53]
Proof of AddressQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

Not CTC & not translated
[Philippe Warzee - 06-05-2026 09:53]
Reference LetterQuestionCriticalDue May 13, 2026

Approved, or if not, list why.

reference letter updated
[Support Admin - 25-05-2026 14:36]
Bank account statement not CTC
[Philippe Warzee - 06-05-2026 09:54]
SOW - Source of WealthSource of WealthCriticalDue May 13, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 13, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 13, 2026

Approved or if not, list why.

Not signed digitally or CTC
[Philippe Warzee - 06-05-2026 09:55]
PEP or family of PEPQuestionCriticalDue May 13, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 13, 2026

Add the URL and give a small summary.

Personal History Disclosure FormCritical34 items
CGA Personal History Disclosure FormIncomplete FormCriticalDue Jun 9, 2026

Check document.Inspect all pages to ensure that there are no blank pages The applications must be filled in digitally. No forms shall be accepted where the customer has completed any section of the form handwritten. Check the forms and make sure there are no ink marks or handwritten notes.

The Personal History Disclosure form is not the official form supplied by CGA. Kindly download the appropriate form, refill digital and resubmit.

Page 1: Application NumberIncomplete FormCriticalDue Jun 9, 2026

Check document. Make sure that this is filled and the same as that shown on the portal

The personal application number is missing or has an incorrect application number. Kindly resubmit the forms with the correct application number.

Page 1: Application DateQuestionCriticalDue Jun 9, 2026

Check document. The application date must be filled and within six month`s of today`s date.

The application date is missing or has an incorrect application date. Kindly resubmit the forms with the correct application date.

Page 1: Personal Information Section - Question 1: First NameQuestionCriticalDue Jun 9, 2026

Check if information matches the passport.

The applicant`s first name is incorrect or does not match.Kindly resubmit the form with the correct first name.

Page 1: Personal Information Section - Question 2: Last NameQuestionCriticalDue Jun 9, 2026

Check if information matches the passport.

The applicant`s last name is incorrect or does not match.Kindly resubmit the form with the correct lasr=t name.

Page 1: Personal Information Section - Question 6: DOBQuestionCriticalDue Jun 9, 2026

Check if information matches the passport.

The Date of birth (DOB) of the applicant is missing or incorrect. Kindly resubmit the forms with the correct DoB.

Page 1: Personal Information Section - Question 7 and 8: Former namesQuestionCriticalDue Jun 9, 2026

Check if applicant has submitted certified proof of previous names.

Kindly provide certified proof of name change documents.

Page 1:Personal Information Section - Question 11QuestionCriticalDue Jun 9, 2026

Must not be blank.

The response to Question 11 is missing. Kindly complete Question 11 and resubmit the form.

Page 1: Personal Information Section - Question 12QuestionCriticalDue Jun 9, 2026

Must not be blank. personal email address

The response to Question 12 is missing. Kindly complete Question 12 and resubmit the form.

Page 2: Contact Details Section - Question 13QuestionCriticalDue Jun 9, 2026

Must not be blank. Email address

The response to Question 13 is missing. Kindly complete Question 13 and resubmit the form.

Page 2: Contact Details Section - Question 14QuestionCriticalDue Jun 9, 2026

Must not be blank. Mobile number

The response to Question 14 is missing. Kindly complete Question 14 and resubmit the form.

Page 2: Citizenship Section - Question 15QuestionCriticalDue Jun 9, 2026

Check if matches the passport. Place of Birth must not be blank.

The response to Question 15 is missing. Kindly complete Question 15 and resubmit the form.

Page 2: Citizenship Section - Question 16QuestionCriticalDue Jun 9, 2026

Must not be blank and check if matches the passport. Passport number must not be blank.

The response to Question 16 is missing. Kindly complete Question 16 and resubmit the form.

Page 2: Citizenship Section - Question 17QuestionCriticalDue Jun 9, 2026

Check if matches the passport. Country of Issue must not be blank.

The response to Question 17 is missing. Kindly complete Question 17 and resubmit the form.

Page 2: Citizenship Section - Question 18QuestionCriticalDue Jun 9, 2026

Check if matches the passport. Date of Issue must not be blank.

The response to Question 18 is missing. Kindly complete Question 18 and resubmit the form.

Page 2: Citizenship Section - Question 19QuestionCriticalDue Jun 9, 2026

Check if matches the passport. Date of Expiry must not be blank.

The response to Question 19 is missing. Kindly complete Question 19 and resubmit the form.

Page 2: Citizenship Section - Question 20QuestionCriticalDue Jun 9, 2026

Check if matches the passport. Nationality/ Citizenship

The response to Question 20 is missing. Kindly complete Question 20 and resubmit the form.

Page 5: Key Person Involvement Section - Question 27QuestionCriticalDue Jun 9, 2026

Must be filled. If the Local Executive Director(official representative) is selected the name of the local service provider must be filled in. If other Key Function Holder is selected, then the function must be filled.

The name of the local service provider or the function of the person in the company is missing. Kindly fill in and resubmit the form.

Page 5: Key Person Involvement Section - Question 28QuestionCriticalDue Jun 9, 2026

If question 28 is filled then question 28.1. must be filled.

The response to question 28.1 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 30QuestionCriticalDue Jun 9, 2026

Must be filled.

The response to question 30 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 31QuestionCriticalDue Jun 9, 2026

Must be filled.

The response to question 31 is missing. Kindly fill in and resubmit.

Page 7: Present Employment Section - Question 34 and 39QuestionCriticalDue Jun 9, 2026

They must provide evidence of present employment.

The proof for question 34 and 39 is missing. Kindly upload in the section of extra documentation.

Page 8: Source of Wealth Section - Question 41 - 42QuestionCriticalDue Jun 9, 2026

Must be filled.

The response for question 41 and or 42 is missing. Kindly fill in and resubmit.

Page 8: Source of Wealth Section - Question 43QuestionCriticalDue Jun 9, 2026

Must be filled. At least one must be selected, if 43.11 is selected then other Income must be filled.

The response to question 43 is missing. (if applies 43.11 must be filled) Kindly fill in and resubmit the form.

Page 8: Question 44QuestionCriticalDue Jun 9, 2026

If yes is selected, 44.1. must be filled.

The response to 44.1. is missing. Kindly fill in and resubmit the form.

Page 9: Declaration and Data PrivacyMiscellaneousCriticalDue Jun 9, 2026

The document must contain the name and surname and digital signature of the person that filled the form on Page 9.

The DECLARATION AND DATA PRIVACY is missing the name and/or is not digitally signed. Kindly fill in the name and/or surname /sign and resubmit the form.

PassportPassportCriticalDue Jun 9, 2026

Check date and make sure the passport is not expired.Make sure that persons photo is clear and recognizable.

The enclosed passport document is expired or unclear. Kindly resubmit a valid passport with a clear picture and certified.

Criminal RecordCriminal RecordCriticalDue Jun 9, 2026

Check the document and make sure it is in english language or if translated from another language, the translated document, must be certified. Check date and make sure the certificate is not expired (not older than 6 months). It must be submitted for every jurisdiction whereby the applicant resided for more than six months in the last two years.

The enclosed criminal record document is expired and/or not certified and/or not translated into English.Kindly resubmit a valid, certified certificate translated into English.

Birth CertificateProof of AddressCriticalDue Jun 9, 2026

Check the document and make sure it is in English Language or orginal document with translation. Both have to be certified. (In some cases we accept the Marriage Certificate)

The enclosed document, Certified True Copy of Birth Certificate is missing or not certified or in english language. Kindly resubmit.

Bank Statement /Reference LetterReference LetterCriticalDue Jun 9, 2026

Make sure that it is in the applicant name verifying their personal account.Check date and make sure the certificate is not expired (not older than 6 months).

The enclosed reference document is expired or not valid. Kindly resubmit a valid reference letter or bank statement showing more than 6 months activity and certify it.

Letter of appointment/ Engagement agreement as Key Person.Reference LetterCriticalDue Jun 9, 2026

Check document. (mandatory for compliance officers)

The letter of appointment/ engagement agreement is missing/incomplete. Kindly resubmit/ submit.

Personal Gaming Authorisations from Other JurisdictionsReference LetterMediumDue Jun 9, 2026

Certified true copies of any Gaming License issued in favor of the applicant in a personal capacity from any jurisdiction ( eg. UK Personal Management License)

The Certified true copies of Gaming License issued in favor of personal capacity is missing/incomplete. Kindly submit.

Curriculum Vitae (CV)Curiculum VitaeCriticalDue Jun 9, 2026

Check document. (mandatory for compliance officers)

Source of Wealth for the UBO OnlySource of WealthCriticalDue Jun 9, 2026

The Source of Wealth must demonstrate the UBO`s financial standing and confirm their ability to operate and support the company.

The Source of Wealth documentation for the Shareholders/UBO was not provided/or is invalid.Kindly resubmit the required documents, including certified bank statements clearly displaying amounts and dividends, tax returns evidencing earnings, or any other certified documentation demonstrating the source of wealth of the UBO,and ensure that all certifications are made as true copies by authorized persons such as legal or accountancy professionals, regulated financial institutions, or other duly empowered authorities within the relevant jurisdiction.

Information Security PolicyCritical1 item
Information Security PolicyPolicy DocumentCriticalDue Sep 9, 2026

The Information Security Policy document submitted is in fact an AML/CFT/CFP policy and not an Information Security Policy. Please submit the Information Security Policy.

The Information Security Policy document submitted is in fact an AML/CFT/CFP policy and not an Information Security Policy. Please submit the Information Security Policy.