#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.

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Spinola Ventures B.V.

Gaming OperatorRegistered August 30, 2024
1
Applications
1
Domains
10
Related Entities
0
Locations

OGL/2024/2086/1138

Granted
Submitted: May 22, 2025End Date: June 4, 2025

Customer

Contact
Gouloud Hammoud
Email
spinolaventuresbv@g-force-corporate-services.com
Company
Spinola Ventures B.V.

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Due Diligence
MGMario Galea (CGA Admin 1)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Due Diligence
KMKevin Mallia (KM)
Background Check
KMKevin Mallia (KM)
Background Check
AAAnton Axiaq (AAX)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
JCJoann Canosa (JC)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
SPSulmahine Penza-Kwidama (CGA USER 59)
Conditionally Issued
SPSulmahine Penza-Kwidama (CGA USER 59)

Compliance Checklists

Application Verification ReviewCritical2 items
Michael Gatt -Criminal RecordCriminal RecordHighDue Oct 18, 2024

The criminal record is expired. Kindly resubmit a recent and valid certificate of criminal record.

The criminal record is expired. Kindly resubmit a recent and valid certificate of criminal record.

PAGE 2: QUESTION 8 - Business and Corporate Information FormQuestionMinorDue Oct 18, 2024

The response to Question 8.1.2 is incorrect . Please correct Questions 8.1.2 and resubmit the form.

The response to Question 8.1.2 is incorrect . Please correct Questions 8.1.2 and resubmit the form.

Application Due Diligence ReviewCritical10 items
QPA/2024/02607 - Nicholas Gatt - Letter of Engagement and CVCuriculum VitaeCriticalDue Mar 5, 2025

Kindly submit a curriculum vitae and an engagement letter for the position of compliance officer.

Kindly submit a curriculum vitae and an engagement letter for the position of compliance officer.

No longer CO
[Sulmahine Penza-Kwidama - 26-05-2026 14:39]
Share Ledger CertificationShare LedgerHighDue Mar 27, 2025

Certification requires an independent certified. View PHDF for certification guidelines. Resubmit duly certified

Certification requires an independent certified. View PHDF for certification guidelines. Resubmit duly certified

Source of funds of businessSource of FundsCriticalDue Jun 10, 2026

Submit documentation as to how the company is or will be funded and by whom, including documents which show funding by the shareholder or third parties.

<p>Submit documentation as to how the company is or will be funded and by whom, including documents which show funding by the shareholder or third parties.</p><p><b><u>Update 27 May 2026:</u></b><br>Although the applicant has indicated that they intend to use "previous earnings" to fund the operations of the company, the latest financial statements submitted show accumulated losses of EUR 14,682 and no previous operations. Please indicate the source of the funds for the operation. If the funds originate from a third-party entity's previous earnings, please indicate how it is intended for such funds to be transferred to the applicant and provide the appropriate documentation. If the company has now become profitable, please provide the latest available financial statements.</p>

The FS do not indicate any "previous earnings" and appears to be a startup venture with accumulated losses of ~EUR 15,000 at the end of 2024. If the company intends to use "previous earnings" to fund the business they must provide the latest available financial statements which show a significant change in the company's financial position or indicate which operation's previous earnings will be used and how they intend to transfer such earnings to the applicant entity, either via loan or other forms of capital injection. Checklist re-opened and updated accordingly.
[Luca Camilleri - 27-05-2026 08:20]
AML PolicyMiscellaneousCriticalDue Mar 27, 2025

The AML policy must adhere to Curacao AML laws. Kindly amend.

The AML policy must adhere to Curacao AML laws. Kindly amend.

Responsible GamingOperationsCriticalDue Mar 27, 2025

The RG policy available on the website refers to the MGA (Malta Gaming Authority). Please remove any mention of the MGA from the domain.

The RG policy available on the website refers to the MGA (Malta Gaming Authority). Please remove any mention of the MGA from the domain.

Registered DomainOperationsCriticalDue Mar 27, 2025

The domain listed in the submitted brand and domain licence agreement is currently operated by a CGA/GCB licensee, Sunflower Seed B.V. Please submit any available revocation of the the current licence agreement between Playtech Software Limited and Sunflower Seed B.V. If this is to be done after Spinola Ventures receives its CGA/GCB license, kindly indicate so in your reply.

The domain listed in the submitted brand and domain licence agreement is currently operated by a CGA/GCB licensee, Sunflower Seed B.V. Please submit any available revocation of the the current licence agreement between Playtech Software Limited and Sunflower Seed B.V. If this is to be done after Spinola Ventures receives its CGA/GCB license, kindly indicate so in your reply.

Company DetailsOperationsCriticalDue Mar 27, 2025

The domain's footer refers to Sunflower Seed. The footer must refer to the correct company once the brand and domain licence agreement becomes effective.

The domain's footer refers to Sunflower Seed. The footer must refer to the correct company once the brand and domain licence agreement becomes effective.

Eliyahu Hassett - Source of Wealth (SOW)Source of WealthCriticalDue May 25, 2026

It has been identified that, for the Source of Wealth declared for Brasiltech N.V., an annual income of GBP 1,000,000 and a net worth of GBP 10,000,000 were reported (accumulated through properties, inheritance, dividends, stock market investments, and employment). However, for the current application, an annual income of EUR 100,000 and a net worth of EUR 5,000,000 have been declared (accumulated through savings from employment income, other professional income, dividends, sale of property, and rental or lease income). Kindly provide an explanation for the above-mentioned discrepancy and resubmit the Source of Wealth documentation, taking into consideration the following requirements: - Must be certified and not older than 6 months - Certification must have been completed within the last 6 months Supporting evidence must clearly demonstrate: - How the wealth was generated - The timeframe over which the wealth was accumulated - The scale and consistency of the wealth - Proof of ownership of relevant assets, businesses, or investments - Evidence of funds received that links to the wealth-generating activities - The declared funds remain available and accessible

It has been identified that, for the Source of Wealth declared for Brasiltech N.V., an annual income of GBP 1,000,000 and a net worth of GBP 10,000,000 were reported (accumulated through properties, inheritance, dividends, stock market investments, and employment). However, for the current application, an annual income of EUR 100,000 and a net worth of EUR 5,000,000 have been declared (accumulated through savings from employment income, other professional income, dividends, sale of property, and rental or lease income). Kindly provide an explanation for the above-mentioned discrepancy and resubmit the Source of Wealth documentation, taking into consideration the following requirements: - Must be certified and not older than 6 months - Certification must have been completed within the last 6 months Supporting evidence must clearly demonstrate: - How the wealth was generated - The timeframe over which the wealth was accumulated - The scale and consistency of the wealth - Proof of ownership of relevant assets, businesses, or investments - Evidence of funds received that links to the wealth-generating activities - The declared funds remain available and accessible

DomainWebsiteCriticalDue May 21, 2026

The currently listed domain indicates that it is closed for business and is registered under Sunflower Seed B.V. Please clarify and list the intended domain for this application.

The currently listed domain indicates that it is closed for business and is registered under Sunflower Seed B.V. Please clarify and list the intended domain for this application.

Compliance Officer- Ron BrochsteinCuriculum VitaeCriticalDue May 26, 2026

Dear Applicant, Please do submit an engagement letter for the appointed Compliance Officer.

<p>Dear Applicant,Please do submit an engagement letter for the appointed Compliance Officer.</p>

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

Player ComplaintsCritical5 items
Lodging a complaint (P2P)Policy DocumentCriticalDue May 22, 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 May 22, 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.

Recommencing ADR process with a different entityPolicy DocumentCriticalDue May 22, 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 May 22, 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.

Compliance with ADR decisionsPolicy DocumentCriticalDue May 22, 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.

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?

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.

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 19, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 19, 2026

List Position:

Native NameQuestionCriticalDue May 19, 2026

Please list the native name.

PHDFQuestionCriticalDue May 19, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 19, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 19, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

Proof of Address must be a Utility Bill [ no Bank account Statement accepted]
[Philippe Warzee - 12-05-2026 12:13]
Reference LetterQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 19, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 19, 2026

Approved or if not, list why.

MIssing
[Philippe Warzee - 12-05-2026 12:14]
CVCuriculum VitaeHighDue May 19, 2026

Approved or if not, list why.

CV must be signed by Applicant or CTC
[Philippe Warzee - 12-05-2026 12:14]
PEP or family of PEPQuestionCriticalDue May 19, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 19, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 19, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue May 19, 2026

List Position:

Native NameQuestionCriticalDue May 19, 2026

Please list the native name.

PHDFQuestionCriticalDue May 19, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue May 19, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue May 19, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue May 19, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue May 19, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue May 19, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue May 19, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue May 19, 2026

Add the URL and give a small summary.