Please note that questions 19, 19.1.1 and 19.1.2 must be completed. This requirement is in effect as of August 1, 2025. Please complete questions 19, 19.1.1 and 19.1.2 and resubmit the form.

Please note that questions 19, 19.1.1 and 19.1.2 must be completed. This requirement is in effect as of August 1, 2025. Please complete questions 19, 19.1.1 and 19.1.2 and resubmit the form.

Please note that the name of the contact person entered in question 20 and all information entered in questions 21 - 24 must be that of the portal administrator. In addition, the email address in question 25 must match that of the portal administrator as registered in the portal. Kindly complete questions 20 - 25 with the information of the portal administrator and resubmit the form.

Please note that the name of the contact person entered in question 20 and all information entered in questions 21 - 24 must be that of the portal administrator. In addition, the email address in question 25 must match that of the portal administrator as registered in the portal. Kindly complete questions 20 - 25 with the information of the portal administrator and resubmit the form.

Please note that the name and digital signature on the Declaration and Data Privacy page must be that of the Managing Director. Kindly resubmit the form with the name and digital signature of the Managing Director.

Please note that the name and digital signature on the Declaration and Data Privacy page must be that of the Managing Director. Kindly resubmit the form with the name and digital signature of the Managing Director.

Please note that the application number entered is not correct. Kindly enter the correct application number and resubmit the form.

Please note that the application number entered is not correct. Kindly enter the correct application number and resubmit the form.

Please note that the number entered in question 4 is not the company tax identification number. Please enter the company Tax ID number (CRIB number) as issued by the Inspectorate of Taxes Crib Department and resubmit the form.

Please note that the number entered in question 4 is not the company tax identification number. Please enter the company Tax ID number (CRIB number) as issued by the Inspectorate of Taxes Crib Department and resubmit the form.

Please note that the name and digital signature on the Declaration and Data Privacy page must be that of the Managing Director. Kindly resubmit the form with the name and digital signature of the Managing Director.

Please note that the name and digital signature on the Declaration and Data Privacy page must be that of the Managing Director. Kindly resubmit the form with the name and digital signature of the Managing Director.

Please note that the Share Ledger must be certified. Kindly submit a certified copy of the Share Ledger.

<p>Please note that the Share Ledger must be certified. Kindly submit a certified copy of the Share Ledger.</p><p><b><u>UPDATE</u></b></p><p>Please note that the certification on the document is incorrect. The certification is of the authenticity of the signature of Roland de Mei and not a certification of the document as a true copy.</p><p>Please submit the share ledger certified as a true copy. </p>

Please note that the proof of goAML registration is missing. Kindly submit a screenshot of the admin page when logged in to the goAML portal - Log in to the goAML portal, click Admin, select Active Organizations and take a screenshot of the page. Please upload the screenshot in the Extra Documentation section.

Please note that the proof of goAML registration is missing. Kindly submit a screenshot of the admin page when logged in to the goAML portal - Log in to the goAML portal, click Admin, select Active Organizations and take a screenshot of the page. Please upload the screenshot in the Extra Documentation section.

Please note that the application number entered was incorrect. Kindly fill in the correct application number and resubmit the form.

Please note that the application number entered was incorrect. Kindly fill in the correct application number and resubmit the form.

Please provide proof of employment for Look Jun Chern. Kindly note that all documents must be certified as a true copy.

<p>Please provide proof of employment for Look Jun Chern. Kindly note that all documents must be certified as a true copy.</p><p><b><u>UPDATE:</u></b></p><p>Please note that no document related to proof of employment for Look Jun Chern was found in the Extra Documentation section.</p><p>Kindly upload the document in the source wealth section for Look Jun Chern. Also, please ensure that the document is certified as a true copy.</p>

Please note that the original proof of address document must be certified as a true copy. Kindly submit a certified copy of the original proof of address document together with the certified English translation.

<p>Please note that the original proof of address document must be certified as a true copy. Kindly submit a certified copy of the original proof of address document together with the certified English translation.</p><p><br></p>

Please note that an incorrect application number was entered. Kindly enter the correct application number and resubmit the form.

Please note that an incorrect application number was entered. Kindly enter the correct application number and resubmit the form.

Please note that the bank reference letter must reference the person's standing at the bank. Kindly provide a new bank reference letter that meets this requirement, also ensuring that the bank reference letter was issued no more than 6 months ago and is certified as a true copy. If the letter is not in English, a certified English translation must be provided together with the original letter.

Please note that the bank reference letter must reference the person's standing at the bank. Kindly provide a new bank reference letter that meets this requirement, also ensuring that the bank reference letter was issued no more than 6 months ago and is certified as a true copy. If the letter is not in English, a certified English translation must be provided together with the original letter.

Please note that the proof of address document must include both the person's name and address. Ihor Kradonov's name does not appear on the utility bill submitted. Kindly submit a new proof of address document with both his name and address. Please keep in mind that the document must be no more than 6 months old and must be certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the original.

<p>Please note that the proof of address document must include both the person's name and address. Ihor Kradonov's name does not appear on the utility bill submitted. Kindly submit a new proof of address document with both his name and address. </p><p>Please keep in mind that the document must be no more than 6 months old and must be certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the original.</p>

Please note that the Letter of Engagement for the Compliance Officer, Ihor Kradonov, must be signed by both the Compliance Officer and the Managing Director. Kindly submit a new Letter of Engagement signed by both the Compliance Officer and the Managing Director.

<p>Please note that the Letter of Engagement for the Compliance Officer, Ihor Kradonov, must be signed by both the Compliance Officer and the Managing Director. Kindly submit a new Letter of Engagement signed by both the Compliance Officer and the Managing Director.</p><p><b><u>UPDATE</u></b></p><p>It is noted on the letter of engagement that contract concluded on November 15, 2025, subject to renewal upon mutual agreement. Please provide a new letter of engagement, signed by both the managing director and the compliance officer, showing that Ihor Kradonov is currently contracted as the compliance officer of Apollo Sync B.V. </p>

Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.

Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.

Please note that we are missing the CV of Ihor Kradonov. Kindly upload the CV in the Letter of Engagement section. Please keep in mind that the CV must be in English.

Please note that we are missing the CV of Ihor Kradonov. Kindly upload the CV in the Letter of Engagement section. Please keep in mind that the CV must be in English.

As indicated in the business plan, in addition to being the UBO, Look Jun Chern is also the CEO, CFO, and CTO. Please add these roles in the portal.

As indicated in the business plan, in addition to being the UBO, Look Jun Chern is also the CEO, CFO, and CTO. Please add these roles in the portal.

Please upload a certified copy of the new valid passport in the base application QPA/2024/02186.

Please upload a certified copy of the new valid passport in the base application QPA/2024/02186.

Please note that the Declaration of Good Standing document issued by the Tax Authorities is missing. The Declaration of Good Standing (verzoek verklaring betalingsgedrag) can be requested in person at the Tax Authority office or online. The document must be stamped with the stamp of 'ontvanger' and the 'invorderaar'. Kindly note that if the document is not in English, a certified English translation (certified by the translator) must also be submitted together with the original document. Please upload the Declaration of Good Standing in the Extra Documentation section.

<p>Please note that the Declaration of Good Standing document issued by the Tax Authorities is missing. The Declaration of Good Standing (verzoek verklaring betalingsgedrag) can be requested in person at the Tax Authority office or online. The document must be stamped with the stamp of 'ontvanger' and the 'invorderaar'. </p><p>Kindly note that if the document is not in English, a certified English translation (certified by the translator) must also be submitted together with the original document. </p><p> Please upload the Declaration of Good Standing in the Extra Documentation section.</p><p><b><u>UPDATE</u></b></p><p>Please note that the Declaration of Good Standing must be certified as a true copy. Please submit the Declaration of Good Standing certified as a true copy.</p>

Please note that questions 7 and 7.1 must be completed. As a CSP, it's not necessary to list all licenses individually and instead indicate that you are CSP involved in other granted Curaçao gaming licenses.

<p>Please note the base application needs to be updated and note that questions 7 and 7.1 must be completed.</p><p><br></p><p>Please note that questions 7 and 7.1 must be completed. As a CSP, it's not necessary to list all licenses individually and instead indicate that you are CSP involved in other granted Curaçao gaming licenses.</p>

Please note that questions 7 and 7.1 must be completed. As a CSP, it's not necessary to list all licenses individually and instead indicate that you are CSP involved in other granted Curaçao gaming licenses.

<p>Please note the base application needs to be updated and note that questions 7 and 7.1 must be completed.</p><p>Please note that questions 7 and 7.1 must be completed. As a CSP, it's not necessary to list all licenses individually and instead indicate that you are CSP involved in other granted Curaçao gaming licenses.</p>

Please upload the Anti-money Laundering Policy, in the designated policy section.

Please upload the Anti-money Laundering Policy, in the designated policy section.

Please upload the Know Your Customer Policy, in the designated policy section.

Please upload the Know Your Customer Policy, in the designated policy section.

Please upload the Responsible Gaming Policy, in the designated policy section.

Please upload the Responsible Gaming Policy, in the designated policy section.

Please upload the Information Security Policy, in the designated policy section.

Please upload the Information Security Policy, in the designated policy section.

Please upload the Player Complaints Policy, in the designated policy section.

Please upload the Player Complaints Policy, in the designated policy section.

The policy must be signed by the Compliance Officer and Managing Director of the Applicant

The policy must be signed by the Compliance Officer and Managing Director of the Applicant

The policy must identify the office responsible for updates and review of the policy

The policy must identify the office responsible for updates and review of the policy

The policy must state that it will be reviewed periodically, at minimum, once a year

The policy must state that it will be reviewed periodically, at minimum, once a year

The policy must make reference to Curacao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance and Criminal Code

The policy must make reference to Curacao laws, specifically the following: LOK, NORUT, NOIS, CGA Guidelines, Sanctions Ordinance and Criminal Code

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The operator must conduct a comprehensive risk assessment of business operations which is to be included in the AML Policy. This should outline the assessment carried out to identify the ML/TF risks the operator is exposed to and ensure that the policies, controls and procedures adopted are adequate to prevent and mitigate those risks. The risk assessment should address the ways in which the casino’s products and services, type of customers, delivery channels and geographical factors could be used to launder money, finance terrorism and finance proliferation, and the extent of the risk that this will happen. In this respect the casino should indicate risk it is prepared to accept. Furthermore, it should indicate how effectiveness of the measures to mitigate risks are monitored and improved. Revision of the BRA should happen whenever changes occur to the operating environment, otherwise once a year. The BRA should be documented and approved by management. Technological development risk assessment should be carried out prior to launch of new products, business practices, delivery mechanism or new technologies.

The policy must describe timing and which measures are used for customer due diligence including PEP and sanction screening. Further describe the actions taken when XCG 4,000 is reached, but not all documents have been submitted by the player. Describe what happens if the requested information is still not received within 30 days of reaching the threshold. Describe the process if the business relationship needs to be terminated. Describe the timing of ongoing sanctions screening (UN and EU list) and the procedure followed for freezing of funds and reporting to competent authorities in Curacao. Describe how threshold is calculated.

The policy must describe timing and which measures are used for customer due diligence including PEP and sanction screening. Further describe the actions taken when XCG 4,000 is reached, but not all documents have been submitted by the player. Describe what happens if the requested information is still not received within 30 days of reaching the threshold. Describe the process if the business relationship needs to be terminated. Describe the timing of ongoing sanctions screening (UN and EU list) and the procedure followed for freezing of funds and reporting to competent authorities in Curacao. Describe how threshold is calculated.

The policy must define the rules and risk controls around virtual assets and crypto usage

The policy must define the rules and risk controls around virtual assets and crypto usage

The policy must define the set automated triggers for suspicious transaction patterns and how the operator analyses patterns to detect structuring or other suspicious behaviour

The policy must define the set automated triggers for suspicious transaction patterns and how the operator analyses patterns to detect structuring or other suspicious behaviour

The policy must describe the process in place to recognise and report unusual transactions to the Curacao FIU when the threshold of XCG 5,000 is reached. It is important to note the prohibition to disclose a report filed to the FIU. The record keeping requirements for CDD information and transactions also need to be described.

The policy must describe the process in place to recognise and report unusual transactions to the Curacao FIU when the threshold of XCG 5,000 is reached. It is important to note the prohibition to disclose a report filed to the FIU. The record keeping requirements for CDD information and transactions also need to be described.

The policy must assign a trained and independent AML Compliance Officer

The policy must assign a trained and independent AML Compliance Officer

The policy mist indicate whether it is a new policy or if it supersedes an existing one. Previous versions must be listed with effective dates and revisions, if applicable

The policy mist indicate whether it is a new policy or if it supersedes an existing one. Previous versions must be listed with effective dates and revisions, if applicable

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person

The document must provide contact information for any questions regarding the policy which must include the name and email address of the designated contact person

The policy must state that players who do not register themselves will not be allowed to play

The policy must state that players who do not register themselves will not be allowed to play

The policy must specify the point in time between the establishment of the business relationship and when the deposit threshold is met in which customer due diligence (CDD) will be initiated, and if it is undertaken upon the deposit threshold being met, the procedures shall indicate how the deposit threshold will be calculated

The policy must specify the point in time between the establishment of the business relationship and when the deposit threshold is met in which customer due diligence (CDD) will be initiated, and if it is undertaken upon the deposit threshold being met, the procedures shall indicate how the deposit threshold will be calculated

The policy must outline the procedure that needs to be followed in instances where, following the lapse of 30 days from when the deposit threshold is met, the CDD/KYC identification and verification cannot be completed

The policy must outline the procedure that needs to be followed in instances where, following the lapse of 30 days from when the deposit threshold is met, the CDD/KYC identification and verification cannot be completed

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out

The policy must specify that screening for PEP status should be carried out within 30 days from when a player reaches the deposit threshold even if PEP screening would have already been carried out

The policy must lay down the procedure to be adopted to ensure that any player related documents, data or information held by the Licensee are reviewed and kept up-to-date

The policy must lay down the procedure to be adopted to ensure that any player related documents, data or information held by the Licensee are reviewed and kept up-to-date

The policy must list the procedures and measures to be applied when carrying out scrutiny of transactions based on the level of customer risk, as well as the timing intervals to carry out the scrutiny of transactions based on the level of customer risk

The policy must list the procedures and measures to be applied when carrying out scrutiny of transactions based on the level of customer risk, as well as the timing intervals to carry out the scrutiny of transactions based on the level of customer risk

The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor

The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor

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

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

The RG policy must describe the procedure for 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

The RG policy must include a structured process on flagging potential vulnerable gamblers

The RG policy must include a structured process on flagging potential vulnerable gamblers

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

<p>The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: <br>- Deposit and wagering frequency<br>- Repeated failed transactions due to insufficient funds <br>- Reversing withdrawals <br>- A pattern of inexplicable extended play sessions <br>- Unreasonable increased communication with customer support, including requests for bonuses <br>- Frequent changes to RG tools <br>- Players maxing out a credit card <br>- Attempts to open multiple accounts to bypass deposit or loss limits</p>

The RG policy must establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

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

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

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

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

The RG policy must define the procedure to be followed for players identified as vulnerable persons

The RG policy must define the procedure to be followed for players identified as vulnerable persons

The operator must not engage in irresponsible advertising. Namely: - 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 must not engage in irresponsible advertising. Namely: <br>- No targeting of Vulnerable Groups <br>- No portrayal of Gambling as an Investment <br>- No misrepresentation of Skill vs Chance <br>- No Emotional Manipulation <br>- Marketing materials must not feature minors or depict them engaging with gambling content <br>- No explicit content <br>- No encouragement of Unrelated Harmful Behaviours <br>- Bonuses and promotions must be communicated transparently <br>- Operators must not use bonuses to encourage excessive gambling <br>- Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers <br>- Operator must make any contracted third-party aware of their RG policy <br>- 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, such as safeguarding usernames, passwords and payment details

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

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 - may no longer be available after a short period, insofar as the operator cannot reasonably be expected to preserve such data any longer

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 - may no longer be available after a short period, insofar as the operator cannot reasonably be expected to preserve such data any longer

Complaints can only be made by the registered player. Article 1.3 section c of the LOK mandates that a player is not allowed to sell, donate, rent out, lease, pawn, or pledge, under any title, any of their claims against the holder of a gaming license from the CGA

The complaints procedure must state that complaints can only be made by the registered player

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) - it should be noted 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) - it should be noted the player should not have the right to resurface the dispute in the future

The periodic report will summarise the following: a. Total number of complaints made b. Total number of settled complaints (upheld and rejected) c. Number of pending or unresolved complaints d. Number of complaints by category e. Number referred to ADR f. Number and detail of complaints for which a player has taken legal action

The periodic report will summarise the following: <br>a. Total number of complaints made <br>b. Total number of settled complaints (upheld and rejected) <br>c. Number of pending or unresolved complaints <br>d. Number of complaints by category <br>e. Number referred to ADR <br>f. Number and detail of complaints for which a player has taken legal action

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

The policy must state that ADR service providers will have their own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA

The policy must state that ADR service providers will have their own reporting requirements in accordance with the Alternative Dispute Resolution policy issued by the CGA