#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.

Records may be incomplete, outdated, or contain errors from the underlying source systems. Please verify identities using company numbers, addresses, domains, licence details, or other identifying information before drawing conclusions. The database is intended to make information of significant public interest accessible for journalistic and research purposes. Individual records should be understood in the context of the underlying data and the reporting published alongside them.

Sprut Group B.V.

Gaming OperatorRegistered December 28, 2023
1
Applications
1
Domains
14
Related Entities
0
Locations

OGL/2024/228/0604

Granted
Submitted: November 1, 2024End Date: May 23, 2025

Customer

Contact
Rudsel Lucas
Email
sad.ekyafiu.0.0.2@gmail.com
Company
Sprut Group B.V.

Review Timeline

Verification
JPJemy-Ree Pilgrim (GCB User 3)
Background Check
JPJemy-Ree Pilgrim (GCB User 3)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
CHCeline Houareau (CLHR)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
JLJulivienne Leito (JL)

Compliance Checklists

Application Verification ReviewCritical2 items
Andrii IudintsevCriminal RecordMinorDue Sep 5, 2024

Criminal record: The enclosed criminal record is expired. Kindly resubmit a valid certificate not older than 6 months.

Criminal record: The enclosed criminal record is expired. Kindly resubmit a valid certificate not older than 6 months.

Andrii IudintsevProof of AddressCriticalDue Aug 29, 2024

Proof of Address: The enclosed proof of address document is expired. Kindly resubmit a recent proof of address document or bank statement not older than 6 months.

Proof of Address: The enclosed proof of address document is expired. Kindly resubmit a recent proof of address document or bank statement not older than 6 months.

Application Due Diligence ReviewCritical5 items
QPA/2024/01700 - Volodymyr Bakotskyi - PHDFMiscellaneousCriticalDue Oct 16, 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.

New CCO was appointed
[Julivienne Leito - 06-05-2026 16:21]
Financial StatementsFinancial AuditCriticalDue May 29, 2026

FS 2022 submitted are not signed by director. Resubmit signed. Submit also FS 2023 and the latest available management accounts for 2024.

<p>FS 2022 submitted are not signed by director. Resubmit signed. Submit also FS 2023 and the latest available management accounts for 2024.</p><p><b><u>Update 07/05/2026:</u><br>Submit the signed FS for 2024.</b></p>

2022 and 2023 FS submitted accordingly, duly signed. No uploads for 2024 accounts. Checklist re-opened and re-assigned.
[Luca Camilleri - 07-05-2026 11:10]
Share Ledger CertificationShare LedgerHighDue Apr 8, 2025

Share ledger is uncertified. Resubmit certified

Share ledger is uncertified. Resubmit certified

AML PolicyMiscellaneousCriticalDue Apr 16, 2025

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

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

Duplicate Item
[Julivienne Leito - 06-05-2026 18:02]
Prohibited JurisdictionsProhibiited CountriesCriticalDue Apr 16, 2025

The T&Cs do not contain an exhaustive prohibited jurisdictions list. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register. Kindly amend.

The T&Cs do not contain an exhaustive prohibited jurisdictions list. Players residing in Curacao, the Netherlands (and any country forming part of the kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register. Kindly amend.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue May 19, 2026

Check and list the Application Date.

no PHDF
[Philippe Warzee - 12-05-2026 13:26]
Position/RoleQuestionCriticalDue May 19, 2026

List Position:

no PHDF
[Philippe Warzee - 12-05-2026 13:27]
Native NameQuestionCriticalDue May 19, 2026

Please list the native name.

PHDF missing
[Philippe Warzee - 12-05-2026 13:27]
PHDFQuestionCriticalDue May 19, 2026

Approved or not. If no list, why?

MISSING
[Philippe Warzee - 12-05-2026 13:29]
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.

Bank Account Statement ( showing only 24h of time ) INVALID
[Philippe Warzee - 12-05-2026 13:31]
Reference LetterQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

Bank account statement showing 24h of transactions. Must be minimum of 6 months if not a proper bank reference
[Philippe Warzee - 12-05-2026 13:33]
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.

CV not signed , not signed digitally , not CTC
[Philippe Warzee - 12-05-2026 13:26]
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.

2023 old Certificate ...Recent one requested
[Philippe Warzee - 12-05-2026 13:49]
Proof of AddressQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

approved
[Philippe Warzee - 12-05-2026 13:55]
Reference LetterQuestionCriticalDue May 19, 2026

Approved, or if not, list why.

First from 2024 is not CTC Second is from 2026..Cannot be accepted
[Philippe Warzee - 12-05-2026 13:54]
SOW - Source of WealthSource of WealthCriticalDue May 19, 2026

Approved, or if not, list why.

Personal declaration too short & no evidences
[Philippe Warzee - 12-05-2026 13:58]
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.

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?

PHDF not signed digitally
[Philippe Warzee - 12-05-2026 14:11]
PassportPassportCriticalDue May 19, 2026

Approved, or if not, list why.

Expired January 2026
[Philippe Warzee - 12-05-2026 14:14]
Expired January 2026
[Philippe Warzee - 12-05-2026 14:13]
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.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue Jun 9, 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 Jun 9, 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 Jun 9, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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 Jun 9, 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

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jun 29, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jun 29, 2026

List Position:

Native NameQuestionCriticalDue Jun 29, 2026

Please list the native name.

PHDFQuestionCriticalDue Jun 29, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jun 29, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jun 29, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jun 29, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue Jun 29, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue Jun 29, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jun 29, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue Jun 29, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jun 29, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jun 29, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jun 29, 2026

Add the URL and give a small summary.