#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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JarvisDelivery B.V.

Gaming OperatorRegistered December 28, 2023
1
Applications
3
Domains
13
Related Entities
0
Locations

OGL/2024/244/0341

Granted
Submitted: January 14, 2025End Date: March 12, 2025

Customer

Contact
Maksym Shcholkin
Email
sharkscode@gflolaw.com
Company
JarvisDelivery B.V.

Review Timeline

Verification
RTRowenne Tweed (GCB User 4)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
JLJulivienne Leito (JL)

Compliance Checklists

Application Verification StageCritical5 items
PAGE 6: QUESTION 34 - QUESTION 39QuestionMinorDue Oct 10, 2024

In the Online gaming application form has a different contact person than that of the portal administrator.

Kindly change to the appointed contact person and resubmit the form or contact the GCB for changes in the contact person.

PAGE 7: DECLARATION AND DATA PRIVACYQuestionCriticalDue Oct 10, 2024

The name of the contact person must be on the form. The Online gaming application form must have the Declaration and data privacy on page 7 named by the contact person. The Online gaming application form must be signed by the contact person

Kindly fill the Declaration and resubmit the Form. Kindly resign and resubmit.

Company structure diagramMiscellaneousCriticalDue Oct 10, 2024

The enclosed document, a company structure diagram, is missing details regarding the share percentages.

Kindly correct this and resubmit.

Yaroslav HusynetsPassportCriticalDue Oct 10, 2024

The enclosed passport document is not clear.

Kindly resubmit another copy with a clear picture.

Maria de Mei v. CampenMiscellaneousCriticalDue Oct 10, 2024

A Personal History disclosure form and enclosures for Maria de Mei v. Campen are missing.

Kindly complete and provide the requested documents for this applicant.

Application Due Diligence ReviewCritical14 items
QPA/2024/00850 - Oleksandr Zaitsev -Proof of AddressProof of AddressCriticalDue Aug 14, 2024

If possible, kindly provide another Utility Bill.

If possible, kindly provide another Utility Bill.

QPA/2024/00854 - Iryna Dashkovska – PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

QPA/2024/00859 - Artem Kroitor – PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

QPA/2024/00866 - Vasyl Shcherbatiuk – PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

QPA/2024/00874 - Daria Ulianitska– PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

QPA/2024/00882 - Zakhar Ryzhov– PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

QPA/2024/00882 - Zakhar Ryzhov– SOWSource of WealthCriticalDue Aug 14, 2024

Please submit a SOW along with supporting evidences in order to support the business(like tax returns).

Please submit a SOW along with supporting evidences in order to support the business(like tax returns).

QPA/2024/00859 - Artem Kroitor - Bank ReferenceQuestionCriticalDue Aug 14, 2024

The bank reference is from 2019. Please submit a more recent one.

The bank reference is from 2019. Please submit a more recent one.

QPA/2024/00859 - Artem Kroitor - SOWSource of WealthCriticalDue Aug 14, 2024

SOW is from 2019. Please submit a more recent one (like a tax return).

SOW is from 2019. Please submit a more recent one (like a tax return).

QPA/2024/00869 - Yaroslav Husynets– PassportPassportCriticalDue Aug 14, 2024

Kindly submit a passport that is more clear and of better quality.

Kindly submit a passport that is more clear and of better quality.

QPA/2024/00869 - Yaroslav Husynets– PHDFQuestionCriticalDue Nov 14, 2024

Kindly note that the PHDF is not signed. Please submit a signed copy.

<p>Kindly note that the PHDF is not signed. Please submit a signed copy.</p><p class="MsoNoSpacing">The PHDF must be filled out, signed and verified digitally. Please resubmit.<o:p></o:p></p>

Financial StatementsFinancial AuditCriticalDue Aug 7, 2024

Kindly submit financial statements for year ending 2023. If these are not yet drawn up, kindly submit management accounts in their stead.

<p>Kindly submit financial statements for year ending 2023. If these are not yet drawn up, kindly submit management accounts in their stead.<br></p>

Source of funds of businessSource of FundsCriticalDue Jan 14, 2025

Kindly submit documentation as to how the business and its operations are being funded and by whom, as well as any documents evidencing any funding by shareholders or third parties and cashflows owned by the company. Kindly note that documents must be duly certified.

<p>Kindly submit documentation as to how the business and its operations are being funded and by whom, as well as any documents evidencing any funding by shareholders or third parties and cashflows owned by the company. Kindly note that documents must relate to the applicant company, not any other entity or its UBO(s) and be duly certified.</p>

AML PolicyMiscellaneousCriticalDue Dec 24, 2024

The AML Policy must be compliant with Curacao AML laws. Kindly amend.

The AML Policy must be compliant with Curacao AML laws. Kindly amend.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 28, 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 28, 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 28, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue May 28, 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 28, 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 28, 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 28, 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 28, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue May 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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 28, 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