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Luxsoft N.V.

Gaming OperatorRegistered April 19, 2024
2
Applications
1
Domains
7
Related Entities
0
Locations

CGA/2025/1683/1268

Granted
Submitted: November 17, 2025End Date: January 22, 2026

Customer

Contact
Vivian Ersilia
Email
smessolutions+luxsoftgcb@gmail.com
Company
Luxsoft N.V.

Review Timeline

Verification
SLShamira Leolina (User_81)
Verification
DFDesiree Francisco (CGA User 6)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)
Suitability
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
MMMarilisa Mathew (CGA User 1)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)
Suitability
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Approval
GHGisah Hollander (GH)
Conditionally Issued
GHGisah Hollander (GH)

Compliance Checklists

Phase1Critical15 items
Luxsoft N.V- goAML registrationMiscellaneousCriticalDue Jul 3, 2025

The screenshot of the goAML registration of the applicant is missing, kindly submit the requested document under the extra documentation section and name the file GoAML Registration

The email confirmation of the goAML registration of the applicant is missing, kindly submit the requested document under the extra documentation section and name the file GoAML Registration

Anatolli Snehirov: Personal History Disclosure Enclosure: Reference LetterMiscellaneousCriticalDue May 26, 2025

The enclosed document, bank reference letter is invalid. Kindly submit a valid bank reference letter

The enclosed document, bank reference letter is invalid. Kindly submit a valid bank reference letter

Vivian Ersilia - Personal History Disclosure FormMiscellaneousCriticalDue May 26, 2025

The enclosed Personal History Disclosure Form is the old GCB form. Kindly use the new CGA Personal History Disclosure Short Form available on our website.

The enclosed Personal History Disclosure Form is the old GCB form. Kindly use the new CGA Personal History Disclosure Short Form available on our website.

Business Plan - financial projectionsBusiness PlanCriticalDue May 26, 2025

The financial projections are expected to indicate a detailed 3 year break down of the initial/any investments, the projected marketing expenses, wages, any commissions paid, any loans paid and/or benefits provided by any third-party provider. Resubmit detailed financial projections as an annex to the business plan.

The financial projections are expected to indicate a detailed 3 year break down of the initial/any investments, the projected marketing expenses, wages, any commissions paid, any loans paid and/or benefits provided by any third-party provider. Resubmit detailed financial projections as an annex to the business plan.

Anatolli Snehirov: Personal History Disclosure Form Enclosures: Criminal RecordCriminal RecordCriticalDue Jun 27, 2025

The enclosed criminal record is not valid . Kindly resubmit a valid certificate.

The enclosed criminal record is not valid . Kindly resubmit a valid certificate.

Igor Basistii - Letter of EngagementMiscellaneousCriticalDue Aug 22, 2025

We are missing the engagement letter of Igor Basistii as compliance officer of Luxsoft N.V. Kindly note the letter needs to be signed by the managing director and the compline officer.

We are missing the engagement letter of Igor Basistii as compliance officer of Luxsoft N.V. Kindly note the letter needs to be signed by the managing director and the compline officer.

Igor Basistii - CVMiscellaneousCriticalDue Aug 22, 2025

Kindly submit the CV of Igor Basistii in his base application (QPA/2024/01738) in the section Letter of Appointment/Engagement as a Key Person.

Kindly submit the <b><u>CV of Igor Basistii in his base application (QPA/2024/01738) in the section Letter of Appointment/Engagement as a Key Person.</u></b>

Igor Basistii - Personal History Disclosure Short Form Page: 1 Original Application NumberMiscellaneousCriticalDue Aug 22, 2025

The Personal History Disclosure Short Form of Igor Basistii has incorrect Original Application Number on page 1. Kindly resubmit the form with the correct Original Application Number.

The Personal History Disclosure Short Form of Igor Basistii has incorrect Original Application Number on page 1. Kindly resubmit the form with the correct Original Application Number.

Igor Basistii - Personal History Disclosure Short Form Page 3: Declaration and Data PrivacyMiscellaneousCriticalDue Aug 22, 2025

The Personal History Disclosure Short Form of Igor Basistii must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

The Personal History Disclosure Short Form of Igor Basistii must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

Sergiu Cravcenco - Personal History Disclosure Short Form Page 3: Declaration and Data PrivacyMiscellaneousCriticalDue Aug 22, 2025

The Personal History Disclosure Short Form of Sergiu Cravcenco must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

The Personal History Disclosure Short Form of Sergiu Cravcenco must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

Luxsoft N.V. - goAML RegistartionMiscellaneousCriticalDue Aug 22, 2025

We are missing confirmation of the goAML registration of the applicant. Kindly submit the requested document under the extra documentation section and name the file GoAML Registration

We are missing confirmation of the goAML registration of the applicant. Kindly submit the requested document under the extra documentation section and name the file GoAML Registration

Vivian Ersilia - Personal History Disclosure Short Form Page 3: Declaration and Data PrivacyMiscellaneousCriticalDue Aug 22, 2025

The Personal History Disclosure Short Form of Vivian Ersilia must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

The Personal History Disclosure Short Form of Vivian Ersilia must have the Declaration and Data Privacy on page 3 digitally signed. Kindly resign and resubmit the form.

Anatolii Snehirov - Criminal RecordCriminal RecordCriticalDue Aug 22, 2025

Kindly submit the criminal letter under the criminal record section and not under the extra documentation section.

Kindly submit the criminal letter under the criminal record section and not under the extra documentation section.

Luxsoft N.V. - Funding AgreementMiscellaneousCriticalDue Aug 22, 2025

The evidence of 3rd party or shareholder loans is missing. Kindly submit the loan agreement under the extra documentation section and name the file Loans Agreements Answer: There is no Loan Agreement, company will be funded solely by UBO. Update: Submit a funding agreement between the UBO and the company, including any repayment and/or interest terms

The evidence of 3rd party or shareholder loans is missing. Kindly submit the loan agreement under the extra documentation section and name the file Loans Agreements Answer: There is no Loan Agreement, company will be funded solely by UBO. Update: Submit a funding agreement between the UBO and the company, including any repayment and/or interest terms

Anatolli Snehirov - Proof Of AddressProof of AddressCriticalDue Aug 22, 2025

Please note that the address on your criminal record and bank reference letter is different from the address on your Personal History Disclosure Form and Proof of Address document. Please clarify what your current address is and explain the discrepancy. Kindly note that if the address on the Proof of Address document and the Personal History Disclosure Form is no longer your current address, this will need to be updated on the Personal History Disclosure Form and a new Proof of Address Document submitted.

Please note that the address on your criminal record and bank reference letter is different from the address on your Personal History Disclosure Form and Proof of Address document. Please clarify what your current address is and explain the discrepancy. Kindly note that if the address on the Proof of Address document and the Personal History Disclosure Form is no longer your current address, this will need to be updated on the Personal History Disclosure Form and a new Proof of Address Document submitted.

Phase 1 - Due DiligenceCritical10 items
Luxsoft N.V. - Funding AgreementSource of FundsCriticalDue Oct 1, 2025

The evidence of 3rd party or shareholder loans is missing. Kindly submit the loan agreement under the extra documentation section and name the file Loans Agreements Answer: There is no Loan Agreement, company will be funded solely by UBO. Update: Submit a funding agreement between the UBO and the company, including any repayment and/or interest terms

<p>The evidence of 3rd party or shareholder loans is missing. Kindly submit the loan agreement under the extra documentation section and name the file Loans Agreements.</p><p><b><u>UPDATE:</u></b></p><p>Please submit a copy of the investment agreement certified as a true copy.<br> </p>

Answer: There is no Loan Agreement, company will be funded solely by UBO. Update: Submit a funding agreement between the UBO and the company, including any repayment and/or interest terms
Vivian Ersilia - Personal History Disclosure Short Form - Page 1: Question 7QuestionCriticalDue Oct 1, 2025

Kindly complete questions 7 and 7.1 and resubmit the form.

Kindly complete questions 7 and 7.1 and resubmit the form.

Anatolli Snehirov - PositionMiscellaneousCriticalDue Oct 1, 2025

On the Personal History Disclosure Form of Anatolli Snehirov, it is noted that he is also the CTO. If this is accurate, please add CTO to his positions listed in the portal. If this is not accurate, please remove it from the Personal History Disclosure Form on question 27 and resubmit the form.

On the Personal History Disclosure Form of Anatolli Snehirov, it is noted that he is also the CTO. If this is accurate, please add CTO to his positions listed in the portal. If this is not accurate, please remove it from the Personal History Disclosure Form on question 27 and resubmit the form.

Anatolli Snehirov - Personal History Disclosure Form - Page 5: Question 29QuestionCriticalDue Oct 1, 2025

One of the numbers listed in question 29.1, OGL/2024/611/0233, is not correct. Please remove it and resubmit the form.

One of the numbers listed in question 29.1, OGL/2024/611/0233, is not correct. Please remove it and resubmit the form.

QPA/2025/03278 - Igor Basistii - Proof of AddressProof of AddressCriticalDue Oct 8, 2025

Please submit a proof of address document (utility bill) for Igor Basistii. The original proof of address document must be certified as a true copy. If the document is not in English, an English translation (certified by the translator) must be submitted together with the certified true copy of the original document. (Please note that the translator cannot certify the original document, only the translation.)

<p>Please submit a proof of address document (utility bill) for Igor Basistii. The original proof of address document must be certified as a true copy. </p><p>If the document is not in English, an English translation (certified by the translator) must be submitted together with the certified true copy of the original document. (Please note that the translator cannot certify the original document, only the translation.)</p>

Sergiu CravcencoMiscellaneousCriticalDue Oct 1, 2025

There is a potential conflict of interest with Sergiu Cravcenco due to his various roles/business interests. Specifically, his involvement as the UBO/CEO or Promotech N.V. and Fortuna Games N.V. Please provide an explanation regarding this.

There is a potential conflict of interest with Sergiu Cravcenco due to his various roles/business interests. Specifically, his involvement as the UBO/CEO or Promotech N.V. and Fortuna Games N.V. Please provide an explanation regarding this.

Anatolii Snehirov - Source of WealthSource of WealthCriticalDue Oct 1, 2025

Please provide the following information/documentation: 1. Evidence that the UBO can make the capital contributions needed as per the business plan and as per the investment agreement, which specifices that he will contribute EUR 200,000. 2. Please specify who is part of the group pocket listed on the Revolut statement provided by Anatollii Snehirov and how the group pocket is established.

Please provide the following information/documentation: 1. Evidence that the UBO can make the capital contributions needed as per the business plan and as per the investment agreement, which specifices that he will contribute EUR 200,000. 2. Please specify who is part of the group pocket listed on the Revolut statement provided by Anatollii Snehirov and how the group pocket is established.

QPA/2024/03147 - Anatolii Snehirov - PHDFMiscellaneousCriticalDue Oct 17, 2025

The PHDF must be filled out, signed and verified digitally. Please resubmit.

<p>The PHDF must be filled out, signed and verified digitally.</p><p>One of the numbers listed in question 29.1, OGL/2024/611/0233, is not correct.</p><p>On the Personal History Disclosure Form of Anatolli Snehirov, it is noted that he is also the CTO. If this is accurate, please add CTO to his positions listed in the portal. If this is not accurate, please remove it from the Personal History Disclosure Form on question 27</p><p> Please update it and resubmit the form.</p><p>Please include the date and application number in the form.</p>

QPA/2024/03147 - Anatolii Snehirov - PHDFMiscellaneousCriticalDue Oct 8, 2025

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/2025/03280 - Serghei Medusevschii - Short PHDFMiscellaneousCriticalDue Oct 23, 2025

Please upload the New Short PHDF

Please upload the New Short PHDF

Phase 2Critical5 items
Anti-money Laundering PolicyMiscellaneousCriticalDue Dec 4, 2025

Please upload the Anti-money Laundering Policy, in the designated policy section.

Please upload the Anti-money Laundering Policy, in the designated policy section.

Know Your Customer PolicyMiscellaneousCriticalDue Dec 4, 2025

Please upload the Know Your Customer Policy, in the designated policy section.

Please upload the Know Your Customer Policy, in the designated policy section.

Responsible Gaming PolicyMiscellaneousCriticalDue Dec 4, 2025

Please upload the Responsible Gaming Policy, in the designated policy section.

Please upload the Responsible Gaming Policy, in the designated policy section.

Information Security PolicyMiscellaneousCriticalDue Dec 4, 2025

Please upload the Information Security Policy, in the designated policy section.

Please upload the Information Security Policy, in the designated policy section.

Player Complaints PolicyMiscellaneousCriticalDue Dec 4, 2025

Please upload the Player Complaints Policy, in the designated policy section.

Please upload the Player Complaints Policy, in the designated policy section.