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.

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.

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.

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

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

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

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.

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.

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.

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

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.

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>

ID verification procedure

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

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-keeping

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

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.

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.

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.

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

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Adopt RBA to determine level of monitoring and intervention

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

Record all RG interactions in PAM system

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

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

Operator must offer players option to activate a cooling-off period

The operator must offer players the option to activate a cooling-off period

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

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

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

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

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

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.

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

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 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

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.

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.

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.

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.

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.

Check and list the Application Date.

List Position:

Please list the native name.

Approved or not. If no list, why?

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved or if not, list why.

Approved or if not, list why.

If yes, list the place and role.

Add the URL and give a small summary.

Check and list the Application Date.

List Position:

Please list the native name.

Approved or not. If no list, why?

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved or if not, list why.

Approved or if not, list why.

If yes, list the place and role.

Add the URL and give a small summary.

Check and list the Application Date.

List Position:

Please list the native name.

Approved or not. If no list, why?

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved, or if not, list why.

Approved or if not, list why.

Approved or if not, list why.

If yes, list the place and role.

Add the URL and give a small summary.