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Investigating the Offshore Online Gambling Industry

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88gaming B.V.

Gaming OperatorRegistered October 8, 2024
2
Applications
4
Domains
6
Related Entities
0
Locations

CGA/2025/2280/1247

Rejected
Submitted: June 17, 2025End Date: December 22, 2025

Customer

Contact
Jonathan Heymans
Email
billing@88gaming.com
Company
88gaming B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
AAAnton Axiaq (AAX)
Background Check
AAAnton Axiaq (AAX)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
KMKevin Mallia (KM)
Suitability
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Verification
MMMarilisa Mathew (CGA User 1)

Compliance Checklists

Phase 1Critical31 items
88gaming B.V. - Company StructureMiscellaneousCriticalDue Jun 23, 2025

The enclosed company structure diagram is not signed by the managing director. Kindly sign and resubmit the company structure.

The enclosed company structure diagram is not signed by the managing director. Kindly sign and resubmit the company structure.

Sangeetha Ahilan - Personal History Disclosure FormMiscellaneousCriticalDue Jun 23, 2025

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

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

Jonathan Heymans - Personal History Disclosure FormMiscellaneousCriticalDue Jun 23, 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.

88gaming B.V. - Compliance OfficerMiscellaneousCriticalDue Jun 23, 2025

We are missing information of the Compliance Officer of 88gaming B.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.

We are missing information of the Compliance Officer of 88Gaming N.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.

Sangeetha Ahilan - Criminal RecordCriminal RecordCriticalDue Jun 23, 2025

The enclosed criminal record document is expired (1 Jul 2022). Kindly resubmit a valid (not older than 6 month) certified in English criminal record.

The enclosed criminal record document is expired (1 Jul 2022). Kindly resubmit a valid (not older than 6 month) certified in English criminal record.

Sangeetha Ahilan - Bank Reference LetterMiscellaneousCriticalDue Jun 23, 2025

The enclosed bank reference letter document is expired (8 May 2024). Kindly resubmit a valid (not older than 6 months) certified bank reference letter.

The enclosed bank reference letter document is expired (8 May 2024). Kindly resubmit a valid (not older than 6 months) certified bank reference letter.

Sangeetha Ahilan - Proof of AddressProof of AddressCriticalDue Aug 20, 2025

The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address.

The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address.

88gaming B.V. - goAML RegistrationMiscellaneousCriticalDue Jun 23, 2025

We are missing the registration email confirmation of the goAML registration of 88gaming B.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.

We are missing the registration email confirmation of the goAML registration of 88gaming B.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.

Sangeetha Ahilan - PassportPassportCriticalDue Jun 23, 2025

Please provide a colour scan of the passport and certify it.

Please provide a colour scan of the passport and certify it.

Sangeetha Ahilan - SOWSource of WealthCriticalDue Aug 28, 2025

Please provide more certified evidence to support the business.

Please provide more certified evidence to support the business.

Online Gaming License Application Form - Page 3: Question 19QuestionCriticalDue Oct 7, 2025

The Online Gaming License Application Form is missing response in question 19. Kind fill question 19 in and resubmit the form.

The Online Gaming License Application Form is missing response in question 19. Kind fill question 19 in and resubmit the form.

Business and Corporate Information Form - Page 2: Question 11.1.1QuestionCriticalDue Aug 28, 2025

The Business and Corporate Information Form is missing amount of the shareholder loan in question 11.1.1. Kindly fill the shareholder loan amount in question 11.1.1 and resubmit the form.

The Business and Corporate Information Form is missing amount of the shareholder loan in question 11.1.1. Kindly fill the shareholder loan amount in question 11.1.1 and resubmit the form.

Moved to CL Phase 1.0
Business and Corporate Information Form - Page 3: Questions 12 and 12.1.QuestionCriticalDue Aug 28, 2025

Kindly note that a response is required for question 12, as all individuals holding key positions must be listed in question 12.1. It is also mandatory to list a CEO in question 12.1. Please complete questions 12 and 12.1 and resubmit the form.

Kindly note that a response is required for question 12, as all individuals holding key positions must be listed in question 12.1. It is also mandatory to list a CEO in question 12.1. Please complete questions 12 and 12.1 and resubmit the form.

Business and Corporate Information Form - Page 3: Question 13QuestionCriticalDue Aug 28, 2025

Kindly note that question 13 was not completed. A percentage must be listed for each company, including the applicant company. Also, the company name of the holding company must be listed in the Holder column. Please complete question 13 and resubmit the form.

Kindly note that question 13 was not completed. A percentage must be listed for each company, including the applicant company. Also, the company name of the holding company must be listed in the Holder column. Please complete question 13 and resubmit the form.

Moved to CL Phase 1.0
88gaming B.V. - Share LedgerShare LedgerCriticalDue Aug 28, 2025

Kindly upload the certified share ledger in the Share Ledger section and refrain from uploading documents in other section where they do not belong.

Kindly upload the certified share ledger in the Share Ledger section and refrain from uploading documents in other section where they do not belong.

Sangeetha Ahilan - Personal History Disclosure Form Page 7: Question 34QuestionCriticalDue Oct 7, 2025

Kindly select the yes box in question 34 and resubmit the form.

Kindly select the yes box in question 34 and resubmit the form.

Chiranjeet Bhatt - Personal History Disclosure Form Page 2: Question 18QuestionCriticalDue Oct 7, 2025

The Personal History Disclosure Form of Chiranjeet Bhatt has incorrect passport date of issue in question 18. Kindly resubmit the form with the correct passport date of issue in question 18

The Personal History Disclosure Form of Chiranjeet Bhatt has incorrect passport date of issue in question 18. Kindly resubmit the form with the correct passport date of issue in question 18

Chiranjeet Bhatt - Personal History Disclosure Form Page 7: Question 37QuestionCriticalDue Oct 7, 2025

The Personal History Disclosure Form of Chiranjeet Bhatt is missing response in question 37. Kindly fill in question 37 and resubmit the form.

The Personal History Disclosure Form of Chiranjeet Bhatt is missing response in question 37. Kindly fill in question 37 and resubmit the form.

Chiranjeet Bhatt - Criminal RecordCriminal RecordCriticalDue Oct 7, 2025

We are missing the actual criminal record. Kindly provide us the English (translated if needed) certified criminal record.

We are missing the actual criminal record. Kindly provide us the English (translated if needed) certified criminal record.

Chiranjeet Bhatt - Engagement LetterMiscellaneousCriticalDue Oct 7, 2025

We are missing the engagement letter of Chiranjeet Bhatt as Compliance Officer of 88gaming B.V. Kindly provide the engagement letter signed by both the managing Director and the Compliance Officer.

We are missing the engagement letter of Chiranjeet Bhatt as Compliance Officer of 88gaming B.V. Kindly provide the engagement letter signed by both the managing Director and the Compliance Officer.

Chiranjeet Bhatt - Curriculum Vitae (CV)MiscellaneousCriticalDue Oct 7, 2025

We are missing the Curriculum Vitae (CV) of Chiranjeet Bhatt. Kindly submit the Curriculum Vitae (CV) in English under the Letter of Appointment/Engagement as a Key Person section.

We are missing the Curriculum Vitae (CV) of Chiranjeet Bhatt. Kindly submit the Curriculum Vitae (CV) in English under the Extra Documentation section.

Chiranjeet Bhatt - Bank Reference LetterReference LetterCriticalDue Oct 7, 2025

The provided bank reference letter is missing issue date. Kindly provide an in English certified bank reference letter with an issue date on it.

The provided bank reference letter is missing issue date. Kindly provide an in English certified bank reference letter with an issue date on it.

Chiranjeet Bhatt - Birth CertificateBirth CertificateCriticalDue Oct 7, 2025

The provided birth certificate document is incorrect. Kindly provide us with a in English certified birth certificate document of Chiranjeet Bhatt.

The provided birth certificate document is incorrect. Kindly provide us with a in English certified birth certificate document of Chiranjeet Bhatt.

Sangeetha Ahilan - Proof of AddressProof of AddressCriticalDue Sep 30, 2025

The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address.

<p>The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address.</p><p><b><u>UPDATE:</u></b></p><p><b>Please confirm where Sangeetha Ahilan is currently living.</b> Please provide a proof of address document (utility bill) for the address where she is currently living. Please note that mobile phone bills are not accepted.</p><p>The proof of address document must be certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the certified copy of the original document.</p>

Sangeetha Ahilan - India Criminal RecordCriminal RecordCriticalDue Sep 30, 2025

Please provide a national criminal record from India for Sangeetha Ahilan.

Please provide a national criminal record from India for Sangeetha Ahilan.

Sangeetha Ahilan - Philippines Criminal RecordCriminal RecordCriticalDue Sep 30, 2025

Please note that a criminal record must be provided for all jurisdictions where the person has lived for more than six months in the last two years. If Sangeetha Ahilan has lived in the Philippines for more than six months in the last two years, please provide a national criminal record from the Philippines for her.

Please note that a criminal record must be provided for all jurisdictions where the person has lived for more than six months in the last two years. If Sangeetha Ahilan has lived in the Philippines for more than six months in the last two years, please provide a national criminal record from the Philippines for her.

Sangeetha Ahilan - Marriage CertificateMiscellaneousCriticalDue Sep 30, 2025

Please provide a certified copy of the marriage certificate of Sangeetha Ahilan. If the marriage certificate is not in English, a certified English translation must be provided together with the certified copy of the original document.

Please provide a certified copy of the marriage certificate of Sangeetha Ahilan. If the marriage certificate is not in English, a certified English translation must be provided together with the certified copy of the original document.

Sangeetha Ahilan - Proof of AddressProof of AddressCriticalDue Oct 7, 2025

The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address.

The enclosed proof of address document is not correct. Kindly resubmit a valid (not older than 6 months) certified utility bill (no mobile phone plan) showing the current residential address. UPDATE: Please confirm where Sangeetha Ahilan is currently living. Please provide a proof of address document (utility bill) for the address where she is currently living. Please note that mobile phone bills are not accepted. The proof of address document must be certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the certified copy of the original document.

Sangeetha Ahilan - India Criminal RecordCriminal RecordCriticalDue Oct 7, 2025

Please provide a national criminal record from India for Sangeetha Ahilan.

Please provide a national criminal record from India for Sangeetha Ahilan.

Sangeetha Ahilan - Philippines Criminal RecordCriminal RecordCriticalDue Oct 7, 2025

Please note that a criminal record must be provided for all jurisdictions where the person has lived for more than six months in the last two years. If Sangeetha Ahilan has lived in the Philippines for more than six months in the last two years, please provide a national criminal record from the Philippines for her.

Please note that a criminal record must be provided for all jurisdictions where the person has lived for more than six months in the last two years. If Sangeetha Ahilan has lived in the Philippines for more than six months in the last two years, please provide a national criminal record from the Philippines for her.

Sangeetha Ahilan - Marriage CertificateMiscellaneousCriticalDue Oct 7, 2025

Please provide a certified copy of the marriage certificate of Sangeetha Ahilan. If the marriage certificate is not in English, a certified English translation must be provided together with the certified copy of the original document.

Please provide a certified copy of the marriage certificate of Sangeetha Ahilan. If the marriage certificate is not in English, a certified English translation must be provided together with the certified copy of the original document.

Phase 1 BCritical0 items
Phase 1.0 - Due DiligenceCritical5 items
88gaming B.V. -Declaration of Good StandingMiscellaneousCriticalDue Oct 17, 2025

We are missing the Declaration of Good Standing (verzoek verklaring betalingsgedrag) confirming compliance with tax and social contribution obligations (can be requested from the tax authorities). Kindly submit an in english certified declaration of good standing under the extra documentation section and name the file Declaration of Good Standing.

<p>We are missing the <b>Declaration of Good Standing (verzoek verklaring betalingsgedrag)</b> confirming compliance with tax and social contribution obligations <b><u>(can be requested from the tax authorities)</u></b>. Kindly submit an in <b><u>English certified</u></b>  declaration of good standing under the <b><u>extra documentation section</u></b> and <b>name the file Declaration of Good Standing.</b></p><p><b><br></b></p><p>Update: Extended to a final deadline, Following which the application will be sent for review on whether it will progress to Phase 2. <b></b></p>

Business Plan - Organisational StructureBusiness PlanCriticalDue Oct 17, 2025

The Second business plan uploaded does not provide a detailed management and organisational structure. As an annex to the business plan, submit a detailed management structure, showing alllocated responsibilities and controls, also identifying all Key Persons (C Level) including any CEO , as per original business plan submitted. All Key Persons are required to submit a PHDF and relevant enclosures.

<p>The Second business plan uploaded does not provide a detailed management and organisational structure. As an annex to the business plan, submit a detailed management structure, showing allocated responsibilities and controls, also identifying all Key Persons (C Level) including any CEO , as per original business plan submitted. All Key Persons are required to submit a PHDF and relevant enclosures.</p><p>Update: Extended to a final deadline, Following which the application will be sent for review on whether it will progress to Phase 2. </p>

GamingBusiness PlanCriticalDue Oct 8, 2025

Gaming

QPA/2025/03725 - Chiranjeet Bhatt - ApplicationMiscellaneousCriticalDue Oct 17, 2025

Please note that the application is not valid, and you must upload everything in colour and certified. The PHDF needs to be digitally signed, including the engagement letter, which must be uploaded and signed by the managing director or UBO as well as yourself. Furthermore, you must include a CV in the extra section that demonstrates your eligibility to be a compliance officer.

Please note that the application is not valid, and you must upload everything in colour and certified. The PHDF needs to be digitally signed, including the engagement letter, which must be uploaded and signed by the managing director or UBO as well as yourself. Furthermore, you must include a CV in the extra section that demonstrates your eligibility to be a compliance officer.

QPA/2024/02828 - Sangeetha Ahilan - ApplicationMiscellaneousCriticalDue Oct 17, 2025

The PHDF must be digitally signed by the applicant as well. A better copy of the passport must be uploaded, along with a certified copy of the proof of address (utility bill), and if the proof of address is not in English, a certified translation must also be provided.

The PHDF must be digitally signed by the applicant as well. A better copy of the passport must be uploaded, along with a certified copy of the proof of address (utility bill), and if the proof of address is not in English, a certified translation must also be provided.