New Origin B.V.
CGA/2025/2574/1294
GrantedCustomer
- Contact
- Philip Humme
- neworigin@allyant-group.com
- Company
- New Origin B.V.
Review Timeline
SCSarah Cathalina-Labbe (CGA user 10)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
MMMarilisa Mathew (CGA User 1)
AAAnton Axiaq (AAX)
MMMarilisa Mathew (CGA User 1)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
AAAnton Axiaq (AAX)
HSHilary Stewart Jones (HSJ)
MMMarilisa Mathew (CGA User 1)
LCLuca Camilleri (LC)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
MMMarilisa Mathew (CGA User 1)
CPCedric Pietersz (Managing Director GCB)
CPCedric Pietersz (Managing Director GCB)
Compliance Checklists
Phase 1Critical16 items
Kindly note that the response to question 9 is missing. Please complete question 9 and resubmit the form.
Kindly note that the response to question 9 is missing. Please complete question 9 and resubmit the form.
Kindly upload a screenshot of the goAML registration confirmation email in the Extra Documentation section and name the file goAML registration.
Kindly upload a screenshot of the goAML registration confirmation email in the Extra Documentation section and name the file goAML registration.
Please submit a certified copy of the loan agreement. Kindly note that the loan agreement must be certified as a true copy by an independent and authorized certifier.
<p>Please submit a certified copy of the share holder loan agreement showing how the business is funded and by whom. Kindly note that the loan agreement must be certified as a true copy by an independent and authorized certifier.</p><p>UPDATE:</p><p>Please note that the loan agreement must be certified as a true copy. Kindly submit a certified copy of the loan agreement.</p>
The Declaration of Good Standing confirming compliance with tax and social contribution obligations is missing. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) in the Extra Documentation section and name the file Declaration of Good Standing.
The Declaration of Good Standing confirming compliance with tax and social contribution obligations is missing. Kindly submit the requested <b><u>Declaration of Good Standing (verzoek verklaring betalingsgedrag) (can be obtain at the Tax Authority) in the Extra Documentation section and name the file Declaration of Good Standing.</u></b>
An accurate estimated net worth must be entered for question 9. Please note, however, that it is not necessary to provide source of wealth documents for Philip Humme.
An accurate figure for Philip Humme's estimated net worth must be entered for question 9. Please note, however, that it is not necessary to provide source of wealth documents for Philip Humme.
Kindly note that the company name must be entered for question 35. Please complete question 35 with the company name and resubmit the form.
Kindly note that the company name must be entered for question 35. Please complete question 35 with the company name and resubmit the form.
It appears that an incorrect amount was entered for Raúl Lopez's annual income in question 41. Please enter the correct amount for question 41 and resubmit the form.
It appears that an incorrect amount was entered for Raúl Lopez's annual income in question 41. Please enter the correct amount for question 41 and resubmit the form.
Kindly note that there is a typo in the last name (Lpez) entered in the Declaration and Data Privacy section on page 9. Please correct the spelling of the last name and resubmit the form.
Kindly note that there is a typo in the last name (Lpez) entered in the Declaration and Data Privacy section on page 9. Please correct the spelling of the last name and resubmit the form.
The birth certificate provided is in a language other than English. In this case, a certified copy of the original birth certificate must be provided accompanied by a certified translation of the document in English. Kindly note that all certifications must be in English.
The birth certificate provided is in a language other than English. In this case, a certified copy of the original birth certificate must be provided accompanied by a certified translation of the document in English. Kindly note that all certifications must be in English.
The Declaration of Good Standing confirming compliance with tax and social contribution obligations is missing. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) (can be obtain at the Tax Authority) in the Extra Documentation section and name the file Declaration of Good Standing.
<p>The Declaration of Good Standing confirming compliance with tax and social contribution obligations is missing. Kindly submit the requested <b><u>Declaration of Good Standing (verzoek verklaring betalingsgedrag) (can be obtain at the Tax Authority) in the Extra Documentation section and name the file Declaration of Good Standing.</u></b></p><p>UPDATE:</p><p>Please note that the original Declaration of Good Standing document (in Dutch) must be certified as a true copy. Please resubmit the original document certified as a true copy together with the certified translation.</p>
Please note that the letter of engagement must be signed by both the managing director and the compliance officer. Kindly submit the letter or engagement signed by both parties.
Please note that the letter of engagement must be signed by both the managing director and the compliance officer. Kindly submit the letter or engagement signed by both parties.
Kindly note that 'Yes' must be selected for question 12, as all individuals holding key positions must be listed in question 12.1. It is also mandatory to list a Compliance Officer in question 12.1. Please complete questions 12 and 12.1 and resubmit the form.
<p>Kindly note that 'Yes' must be selected for question 12, as all individuals holding key positions must be listed in question 12.1. It is also mandatory to list a Compliance Officer in question 12.1. Please complete questions 12 and 12.1 and resubmit the form.</p><p><b><u>UPDATE:</u></b></p><p>According to the business plan, the UBO Raúl Lopez is also the COO (Chief Operating Officer). Please add this information in the '<i>Role'</i> field next to his name on question 12.1.</p>
Kindly note that the responses to questions 7 and 7.1 are missing. Please complete questions 7 and 7.1 and resubmit the form.
<p>Kindly note that the responses to questions 7 and 7.1 are missing. Please complete questions 7 and 7.1 and resubmit the form.</p><p><b><u>UPDATE:</u></b></p><p>Please check the box for question 7 and resubmit the form.</p>
Please note that the bank reference letter must be on the official bank letterhead and it must be certified. Kindly provide a certified copy of the bank reference letter on bank letterhead dated within the last 6 months.
<p>Please note that the bank reference letter must be on the official bank letterhead and it must be certified. Kindly provide a certified copy of the bank reference letter on bank letterhead dated within the last 6 months. </p><p><b><u>UPDATE: </u></b></p><p>Please note that the bank reference letter must be certified as a true copy.</p>
Please submit the criminal record once it is received. Kindly note that the criminal record must be certified as a true copy. If the criminal record is not in English, an English translation (certified by the translator) must also be submitted.
Please submit the criminal record once it is received. Kindly note that the criminal record must be certified as a true copy. If the criminal record is not in English, an English translation (certified by the translator) must also be submitted.
Please note that a bank reference letter is required for the Compliance Officer. Please submit a bank reference letter for Amanda Klok that was issued within the last six months and is certified as a true copy. If the letter is not in English, an English translation (certified by the translator) must also be submitted.
<p>Please note that a <b><u>bank reference letter is required for the Compliance Officer</u></b>. Please submit a bank reference letter for Amanda Klok that was issued within the last six months and is certified as a true copy. </p><p>If the letter is not in English, an English translation (certified by the translator) must also be submitted.</p>
Phase 1 - Due DiligenceCritical2 items
"N/A" was indicated for question 40. However, the CV of Amanda Klok shows she has held other positions with other entities within the last five years. In question 40, please list all positions currently or previously held with other entities in the last five years and resubmit the form.
<p>"N/A" was indicated for question 40. However, the CV of Amanda Klok shows she has held other positions with other entities within the last five years. </p><p>In question 40, please list all positions currently or previously held with other entities in the last five years and resubmit the form.</p><p>Please fill out the form with the requested information and do not add text.</p>
Please fill out the form with the requested information. Keep in mind that the base application and application number should be visible, and you must fill everything out and sign digitally.
Please fill out the form with the requested information. Keep in mind that the base application and application number should be visible, and you must fill everything out and sign digitally.
Phase 2Critical3 items
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 Responsible Gaming Policy, in the designated policy section.
Please upload the Responsible Gaming 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.
AML PolicyCritical4 items
The policy must be signed by the Compliance officer and managing director of the applicant.
<p>The policy must be signed by the Compliance officer and managing director of the applicant.</p><p><b><u>Update 3 Jun 2026:</u></b><br>The MLRO signing the document is not the same person as the appointed Compliance Officer of the applicant.</p>
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 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 define the set automated triggers for suspicious transaction patterns and how the operator analyzes patterns to detect structuring or other suspicious behaviour.
The policy must define the set automated triggers for suspicious transaction patterns and how the operator analyzes patterns to detect structuring or other suspicious behaviour.
KYC PolicyCritical2 items
The policy must outline the documentary evidence required for verification of a player's identity and residential address and specify that the evidence obtained for verification of residential address should not be more than 6 months old.
The policy must outline the documentary evidence required for verification of a player's identity and residential address and specify that the evidence obtained for verification of residential address should not be more than 6 months old.
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.
Responsible GamingCritical12 items
ID verification procedure
The RG policy must outline the procedure carried out by the operator to verify the player's age.
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-keeping
The RG policy must state the operator's record-keeping policy.
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.
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.
Record all RG interactions in PAM system
The RG policy must state that the operators records all RG interactions in the PAM system
Operator must offer players option to activate a cooling-off period
The operator must offer players the option to activate a cooling-off period
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
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
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
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
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
Player ComplaintsCritical9 items
The policy must state that 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.
The policy must state that 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.
The policy must state that in the first instance the operator must offer customer support via email and/or live chat.
The policy must state that in the first instance the operator must offer customer support via email and/or live chat.
Except if mutually agreed under specific terms of ADR (Clause 5 of the Player Complaints Policy Guideline), the policy must state that the operator does not restrict the rights of the player him/herself to take legal action.
Except if mutually agreed under specific terms of ADR (Clause 5 of the Player Complaints Policy Guideline), the policy must state that the operator does not restrict the rights of the player him/herself to take legal action.
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) 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) the player should not have the right to resurface the dispute in the future.
Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.
Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.
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 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 policy must state that 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 policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.
The policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.