#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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MIBS N.V.

Gaming OperatorRegistered April 23, 2024
1
Applications
30
Domains
8
Related Entities
0
Locations

OGL/2024/1718/0938

Granted
Submitted: August 9, 2024End Date: October 4, 2024

Customer

Contact
Glenn C. Rellum
Email
mibs-gm-clients@decc-management.com
Company
MIBS N.V.

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Due Diligence
KMKevin Mallia (KM)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
STSarah Tua (ST)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
KMKevin Mallia (KM)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DIDarvey Isidora (CGA User DI)
Conditionally Issued
HSHilary Stewart Jones (HSJ)

Compliance Checklists

Application Due Diligence ReviewCritical9 items
Corporate StructureMiscellaneousCriticalDue Sep 29, 2025

The corporate structure is required to be signed by the director of the company. Sign accordingly and resubmit.

The corporate structure is required to be signed by the director of the company. Sign accordingly and resubmit.

Update: 9/16/2025 Hi Team, The duly signed corporate structure has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate. Customer Reply: Updated document has been uploaded.
Source of Funds of BusinessSource of FundsCriticalDue Sep 29, 2025

Submit documentation as to how the company and its operations are being funded and by whom, including documents evidencing funds owned by the company through cashflow or other means.

Submit documentation as to how the company and its operations are being funded and by whom, including documents evidencing funds owned by the company through cashflow or other means.<br><br><b><u>Update: 9/16/2025</u></b><br>Dear Applicant,<br>The requested information is still outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:07]
Condition Failed RCL: No further SOF documentation submitted
QPA/2024/01564 - Aleksandar Gligorov - PHDFQuestionCriticalDue Sep 9, 2024

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

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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:07]
Update: 9/16/2025 Hi Team, The duly completed PHDF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate. Has an Anjouan licence Customer Reply: Document has been resubmitted
QPA/2024/01564 - Aleksandar Gligorov - Reference LetterQuestionCriticalDue Sep 29, 2025

The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.<br><br><b><u>Update: 9/16/2025</u></b><br>Dear Applicant,<br>The requested information is still outstanding. Kindly ensure that it is duly submitted at your earliest convenience. Thank you for your cooperation.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:07]
Financial ProjectionsBusiness PlanCriticalDue Sep 29, 2025

The GGR and NGR figures provided in the financial projections are unclear. Kindly clarify why NGR is at times lower and other times higher than GGR. Furthermore, the projections do not include a cashflow statement and balance sheet. Please update the projections accordingly.

The GGR and NGR figures provided in the financial projections are unclear. Kindly clarify why NGR is at times lower and other times higher than GGR. Furthermore, the projections do not include a cashflow statement and balance sheet. Please update the projections accordingly.<br><br><b><u>Update: 9/16/2025</u></b><br>Dear Applicant,<br>The requested information is still outstanding. Kindly ensure that it is duly submitted at your earliest convenience.<br>Thank you for your cooperation.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:10]
Domain ownershipOperationsCriticalDue Sep 29, 2025

Most of the registered domains refer to a Costa Rica entity EOD Code SRL, with no apparent license, when accessed through a Netherlands IP address, even though MIBS N.V.'s terms and conditions state that the Netherlands is a prohibited jurisdiction. Furthermore, it was noted that a few of the domains registered under MIBS N.V. refer to other entities in the site footer. For example, luckyblock.com refers to Igloo Ventures SRL, another Costa Rica entity, as the site owner/operator, seemingly an Anjouan licensed entity, however upon logging in it refers to Entretenimiento Rojo B.V., which is another GCB license applicant. Please ensure that all domains registered with the GCB correspond to MIBS N.V.

<div>Most of the registered domains refer to a Costa Rica entity EOD Code SRL, with no apparent license, when accessed through a Netherlands IP address, even though MIBS N.V.'s terms and conditions state that the Netherlands is a prohibited jurisdiction.</div><div><br></div><div>Furthermore, it was noted that a few of the domains registered under MIBS N.V. refer to other entities in the site footer. For example, luckyblock.com refers to Igloo Ventures SRL, another Costa Rica entity, as the site owner/operator, seemingly an Anjouan licensed entity, however upon logging in it refers to Entretenimiento Rojo B.V., which is another GCB license applicant.</div><div><br></div><div>Please ensure that all domains registered with the GCB correspond to MIBS N.V.<br><br><b><u>Update: 9/16/2025</u></b><br>Dear Applicant,<br>Kindly confirm if this requirement has been duly rectified.<br>Thank you for your cooperation.<br><br></div>

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:11]
AML Policy (duplicate ticket)OperationsCriticalDue Sep 9, 2024

It was noted on most of the registered sites that there is an AML policy available, however this makes reference to EU AML directives. The AML policy must be compliant with Curacao AML laws.

It was noted on most of the registered sites that there is an AML policy available, however this makes reference to EU AML directives. The AML policy must be compliant with Curacao AML laws.

Update: 9/16/2025 Anti-money Laundering Policy. Duplicate Ticket. This ticket is now closed.
Responsible GamingOperationsCriticalDue Sep 29, 2025

The RG policy available on the domains only mentions self-exclusion as an available RG tool (in some of the sites not even that). Users must be able to self-exclude and also set session time limits and loss limits through their profile settings.

The RG policy available on the domains only mentions self-exclusion as an available RG tool (in some of the sites not even that). Users must be able to self-exclude and also set session time limits and loss limits through their profile settings.<br><br><b><u>Update: 9/16/2025</u></b><br>Dear Applicant,<br>Kindly confirm whether this requirement has been addressed accordingly.<br>Thank you for your cooperation.

1/12/2025 No policy uploaded.
Technical SetupBusiness PlanCriticalDue Sep 29, 2025

The Business Plan lacks information regarding the company's technical setup. Please upload as an annex to the Business Plan.

The Business Plan lacks information regarding the company's technical setup. Please upload as an annex to the Business Plan.<br><br><u><b>Update: 9/16/2025</b></u><br>Dear Applicant,<br>The requested information is still outstanding. Kindly ensure that it is duly submitted at your earliest convenience.<br>Thank you for your cooperation.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:11]
Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 14, 2026

ID verification procedure

The RG policy must outline the procedure carried out by the operator to verify the player's age.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:12]
Account closure procedurePolicy DocumentCriticalDue May 14, 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.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:12]
Record-keepingPolicy DocumentCriticalDue May 14, 2026

Record-keeping

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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:13]
Contacting the operatorPolicy DocumentCriticalDue May 14, 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.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:13]
Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:13]
LanguagePolicy DocumentCriticalDue May 14, 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.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:13]
Vulnerable gamblersPolicy DocumentCriticalDue May 14, 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.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:13]
Indicators of problem gamblingPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:14]
Player profiling and Risk AssessmentPolicy DocumentCriticalDue May 14, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:14]
Monitoring and interventionPolicy DocumentCriticalDue May 14, 2026

Adopt RBA to determine level of monitoring and intervention

The RG policy must adopt RBA to determine level of monitoring and intervention

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:14]
Recording RG interactionsPolicy DocumentCriticalDue May 14, 2026

Record all RG interactions in PAM system

The RG policy must state that the operators records all RG interactions in the PAM system

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:14]
Identification of vulnerable personsPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:15]
Cooling-off periodPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:15]
Cooling-off optionsPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:15]
Self-ExclusionPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:16]
Deposit LimitsPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:16]
Training and Staff ReadinessPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:17]
Consumer Advertising and MarketingPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:17]
Internet Filtering ToolsPolicy DocumentLowDue May 14, 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.

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:18]
Notifications for concerning behavioursPolicy DocumentHighDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:18]
Initiating direct contactPolicy DocumentCriticalDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:19]
Other LimitsPolicy DocumentHighDue May 14, 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

Closed due to rejection.
[Sulmahine Penza-Kwidama - 12-05-2026 16:19]