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Klavitorix B.V.

Gaming OperatorRegistered December 12, 2024
1
Applications
1
Domains
10
Related Entities
0
Locations

CGA/2025/2443/1249

Granted
Submitted: October 28, 2025End Date: February 10, 2026

Customer

Contact
Claire Godschalk Olmtak
Email
klavitorixbv@igagroup.com
Company
Klavitorix B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
GHGisah Hollander (GH)

Compliance Checklists

Phase 1Critical12 items
Klavitorix B.V. - goAML RegistrationMiscellaneousCriticalDue Jul 8, 2025

Kindly provide us with the registration confirmation email where Klavitorix B.V. is clearly stated.

Kindly provide us with the registration confirmation email where Klavitorix B.V. is clearly stated.

Klavitorix B.V. - Declaration of Good StandingMiscellaneousCriticalDue Jul 10, 2025

The enclosed declaration of Good Standing document is incorrect. Kindly provide us with a declaration of Good standing (verzoek verklaring betalingsgedrag) from the tax office confirming Klavitorix B.V. compliance with tax and social contribution obligations.

The enclosed declaration of Good Standing document is incorrect. Kindly provide us with a declaration of Good standing (verzoek verklaring betalingsgedrag) from the tax office confirming Klavitorix B.V. compliance with tax and social contribution obligations.

Customer Reply: awaiting from IGA trust
Klavitorix B.V. - Share LedgerShare LedgerCriticalDue Jun 2, 2025

Kindly provide us with an updated certified, signed by the actual manager director share ledger document.

Kindly provide us with an updated certified, signed by the actual manager director share ledger document.

Max Raadelius - Letter of EngagementMiscellaneousCriticalDue Jul 8, 2025

We are missing the Letter of Engagement of Max Raadelius as Compliance Officer for Klavitorix B.V. Kindly provide the requested document.

We are missing the Letter of Engagement of Max Raadelius as Compliance Officer for Klavitorix B.V. Kindly provide the requested document.

Nana Gugeshashvili - Personal History Disclosure Form Page 5: Question 29QuestionCriticalDue Jul 8, 2025

We are missing a response in question 29 and 29.1. Kindly complete question 29 and resubmit the form.

We are missing a response in question 29 and 29.1. Kindly complete question 29 and resubmit the form.

Nana Gugeshashvili - Personal History Disclosure Form Page 5: Question 30QuestionCriticalDue Jul 8, 2025

We are missing the checked yes box (☑ yes) in question 30. Kindly checked the yes box in question 30 and resubmit the form.

We are missing the checked yes box (☑ yes) in question 30. Kindly checked the yes box in question 30 and resubmit the form.

Nana Gugeshashvili - Personal History Disclosure Form Page 5: Question 43QuestionCriticalDue Jul 8, 2025

In the Personal History Disclosure Form of Nana Gugeshasvili we are missing response in question 43. Kindly complete question 43 and resubmit the form.

In the Personal History Disclosure Form of Nana Gugeshasvili we are missing response in question 43. Kindly complete question 43 and resubmit the form.

Business Plan - organisational structureBusiness PlanCriticalDue Jun 2, 2025

Submit an organisational structure as an annex to the business plan , identifying all key persons, including the CO and/or state whether any key persons are yet to be hired

Submit an organisational structure as an annex to the business plan , identifying all key persons, including the CO and/or state whether any key persons are yet to be hired

Klavitorix B.V.- Declaration of Good StandingMiscellaneousCriticalDue Aug 19, 2025

The provided Declaration of Good Standing is incorrect. The Declaration of Good Standing (verzoek verklaring betalings gedrag) confirms compliance with tax and social contribution obligations. (to be obtain from the tax authority). Kindly submit the requested document in English and certified under the extra documentation section and name the file Declaration of Good Standing.

The provided Declaration of Good Standing is incorrect. <b>The Declaration of Good Standing (verzoek verklaring betalings gedrag)</b> confirms compliance with tax and social contribution obligations. <b>(<u>to be obtain from the tax authority</u></b>). Kindly submit the requested document in <b>English and Certified</b> under the extra documentation section and name the file Declaration of Good Standing.

Trevor De Giorgio - Engagement Letter Klavitorix B.V.MiscellaneousCriticalDue Aug 19, 2025

We are missing the engagement letter of Trevor De Giorgio as compliance officer of Klavitorix B.V. Kindly note the letter needs to be signed by the managing director and the compline officer.

We are missing the engagement letter of Trevor De Giorgio as compliance officer of Klavitorix B.V. Kindly note the letter needs to be signed by the managing director and the compline officer.

Trevor De Giorgio - Birth CertificateBirth CertificateCriticalDue Aug 19, 2025

The provided birth certificate is incorrect. Please provide a certified copy of the birth certificate issued by the relevant authority in Saudi Arabia. Kindly note that if the birth certificate is not in English, a certified translation in English must also be provided. The document certification(s) must in English and not be older than 6 months.

The provided birth certificate is incorrect. Please provide a certified copy of the birth certificate issued by the relevant authority in Saudi Arabia. Kindly note that if the birth certificate is not in English, a certified translation in English must also be provided. The document certification(s) must in English and not be older than 6 months.

Klavitorix B.V.- Declaration of Good StandingMiscellaneousCriticalDue Oct 7, 2025

The provided Declaration of Good Standing is incorrect. The Declaration of Good Standing (verzoek verklaring betalings gedrag) confirms compliance with tax and social contribution obligations. (to be obtained from the tax authority). Kindly submit a certified true copy of the document under the extra documentation section and name the file Declaration of Good Standing. If the document is not in English, an English translation (certified by the translator) must also be submitted.

<p>The provided Declaration of Good Standing is incorrect. The Declaration of Good Standing (verzoek verklaring betalings gedrag) confirms compliance with tax and social contribution obligations. (to be obtained from the tax authority). Kindly submit a certified true copy of the document under the extra documentation section and name the file Declaration of Good Standing. If the document is not in English, an English translation (certified by the translator) must also be submitted.</p><p><b><u>UPDATE:</u></b></p><p>Please provide the Declaration of Good Standing document as it is now, regardless of any fine that may be currently in dispute.</p>

Phase 1 - Due DiligenceCritical2 items
Compliance OfficerMiscellaneousCriticalDue Oct 17, 2025

Please provide an explanation regarding the conflicts of Trevor De Giorgio being a UBO and compliance officer for other competing companies.

<p><br></p><p>Please note that the compliance officer needs to be changed.</p>

QPA/2025/03407 - Nana Gugeshashvili - Short PHDFMiscellaneousCriticalDue Oct 24, 2025

The PHDF submitted was not the Short PHDF.

The PHDF submitted was not the Short PHDF.

AML PolicyCritical0 items
KYC PolicyCritical0 items
Responsible Gaming PolicyCritical4 items
Indicators of problem gamblingPolicy DocumentCriticalDue May 1, 2026

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

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

Internet Filtering ToolsPolicy DocumentLowDue May 1, 2026

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.

Notifications for concerning behavioursPolicy DocumentHighDue May 1, 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.

Other LimitsPolicy DocumentHighDue May 1, 2026

Other limits may be considered including loss limits, time limits or wager limits, in line with the operator's target player and/or market.

Other limits may be considered including loss limits, time limits or wager limits, in line with the operator's target player and/or market.

Player Complaints PolicyCritical0 items