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GMB Entertainment B.V.

Gaming OperatorRegistered June 4, 2025
2
Applications
0
Domains
11
Related Entities
0
Locations

CGA/2025/2594/1322

Rejected
Submitted: October 7, 2025End Date: April 22, 2026

Customer

Contact
Jeanne-Marie Palm
Email
gmb@xcm.cw
Company
GMB Entertainment B.V.

Review Timeline

Verification
SCSarah Cathalina-Labbe (CGA user 10)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
AAAnton Axiaq (AAX)
Verification
STSarah Tua (ST)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)
Verification
AAAnton Axiaq (AAX)
Verification
MMMarilisa Mathew (CGA User 1)

Compliance Checklists

Phase 1Critical54 items
Business and Corporate Information Form - Page 3: Question 12QuestionCriticalDue Oct 7, 2025

The answer to question 12 is missing. Please note that in section 12.1, all individuals holding key positions and their respective roles (even if the role is held by a UBO, ex. CEO/CTO, etc.) must be added. It is also mandatory to list a compliance officer.

<p>The answer to question 12 is missing. Please note that in section 12.1, all individuals holding key positions and their respective roles (even if the role is held by a UBO, ex. CEO/CTO, etc.) must be added. It is also mandatory to list a compliance officer.</p>

Business and Corporate Information Form - Page 3: Question 13QuestionCriticalDue Oct 7, 2025

Please note that the answer to question 13 is missing. Kindly complete question 13 and resubmit the form.

Please note that the answer to question 13 is missing. Kindly complete question 13 and resubmit the form.

GMB Entertainment B.V. - Company StructureMiscellaneousCriticalDue Oct 20, 2025

The information in the company structure does not reflect the qualifying persons added in the portal. Please submit an updated company structure signed by the managing director.

<p>The information in the company structure does not reflect the qualifying persons added in the portal, nor is it signed by the Director. Please submit an updated company structure signed by the managing director.</p>

Applicant reply: The Corporate structure as per law, reflects the person holding the shares and the (Corporate) Director representing the company. In case you want to see full organogram of the company, this is available in the Business plan. There is a difference between legally required documents as per the guidelines of the central bank and the requirement set forth by CGA. The provided document is the legal one on file. If needed, we can create an additional organogram reflecting personal directors plus C-Level employees. If this is what you refer to, we will happily create Another one although already available in the business plan as per the guidelines of the CGA.
GMB Entertainment B.V. - Share LedgerShare LedgerCriticalDue Oct 7, 2025

The information in the share ledger does not reflect the qualifying persons added in the portal. Please submit an updated share ledger certified as a true copy.

The information in the share ledger does is not certified. It also does not reflect the qualifying persons added in the portal. Please submit an updated share ledger certified as a true copy.

GMB Entertainment B.V. - Directors ListDirector's ListCriticalDue Oct 7, 2025

Please note that the directors list must be certified as a true copy. Kindly submit a certified copy of the directors list.

Please note that the directors list must be certified as a true copy. Kindly submit a certified copy of the directors list.

GMB Entertainment B.V. - Business PlanBusiness PlanCriticalDue Oct 7, 2025

Please submit an updated business plan that includes the proprietary IP, 3-year business forecast, and high-level overview of excluded markets.

Please submit an updated business plan that includes the proprietary IP, 3-year business forecast, and high-level overview of excluded markets.

GMB Entertainment B.V. - goAML RegistrationMiscellaneousCriticalDue Mar 25, 2026

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. To do this, 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.

<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. To do this, 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.</p><p><b><u>UPDATE:</u></b></p><p>Please note that the incorrect screenshot was submitted. The screenshot uploaded shows 'Active Users,' not 'Active Organizations.'</p><p>Kindly submit a screenshot of the admin page when logged in to the goAML portal. To do this, log in to the goAML portal, click Admin, <b><u>select Active Organizations</u></b> and take a screenshot of the page. Please upload the screenshot in the Extra Documentation section.</p>

GMB Entertainment - Declaration of Good StandingMiscellaneousCriticalDue Mar 25, 2026

The Declaration of GMB Entertainment B.V. was not provided. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the document issued by the Tax Authorities and have the stamp of 'ontvanger' and the 'invorderaar'. If the document is not in English, a certified English translation must also be submitted together with the original document.

<p>The Declaration of GMB Entertainment B.V. was not provided. Kindly submit the requested Declaration of Good Standing (verzoek verklaring betalingsgedrag) in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the document issued by the Tax Authorities and have the stamp of 'ontvanger' and the 'invorderaar'. </p><p>If the document is not in English, a certified English translation must also be submitted together with the original document.</p><p><b><u>UPDATE:</u></b></p><p>Please be informed that the Declaration of Good Standing can be accepted in Dutch. However, the document must be <u><b>certified as a true copy</b></u>. Please resubmit a certified copy of the Declaration of Good Standing.</p>

Applicant reply: there are HUGE controversies going on with this since our laws are in Dutch and you cannot simply deny a Dutch document. Translations take loads of time and are expensive. Our tax office simply will not comply and give it in english. Please make an exception to this weird rule. PLEASE. Thanks.
Frederico Perez Gonçalves Pereira - Personal History Disclosure FormMiscellaneousCriticalDue Oct 7, 2025

Please note that Frederico Perez Gonçalves Pereira must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Please note that Frederico Perez Gonçalves Pereira must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Frederico Perez Gonçalves Pereira - Birth CertificateBirth CertificateCriticalDue Oct 7, 2025

Please submit a certified true copy of the birth certificate of Frederico Perez Gonçalves Pereira. If the birth certificate is not in English, a certified English translated must be submitted together with the certified copy of the original document.

Please submit a certified true copy of the birth certificate of Frederico Perez Gonçalves Pereira. If the birth certificate is not in English, a certified English translated must be submitted together with the certified copy of the original document.

Frederico Perez Gonçalves Pereira - Criminal RecordCriminal RecordCriticalDue Mar 25, 2026

Please submit a criminal record certified as a true copy for every jurisdiction where Frederico Perez Gonçalves Pereira has lived for more than six months in the last two years. The criminal record must be no more than six months old. If the criminal record is not in English, a certified English translation must be submitted together with the original document.

<p>Please submit a criminal record certified as a true copy for every jurisdiction where Frederico Perez Gonçalves Pereira has lived for more than six months in the last two years. The criminal record must be no more than six months old. If the criminal record is not in English, a certified English translation must be submitted together with the original document.</p><p><b><u>UPDATE</u></b></p><p>Please note that background screening reports from private companies are not accepted.<b> Please provide a national criminal record from the local authority in Portugal.</b> The criminal record must have been issued with the last six months and be certified as a true copy. </p><p>If the criminal record is not in English, a certified English translation must be submitted together with the original document.</p>

Frederico Perez Gonçalves Pereira - Proof of AddressProof of AddressCriticalDue Mar 25, 2026

Please be informed that the document submitted as proof of address cannot be submitted. Kindly submit a certified copy of one of the following types of documents: utility bill, landline phone bill, internet bill, cable bill, or government-issued document. Please note that the document must have been issued no more than six months ago 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 document.

<p>Please be informed that the document submitted as proof of address cannot be submitted. Kindly submit a certified copy of one of the following types of documents: utility bill, landline phone bill, internet bill, cable bill, or government-issued document. </p><p>Please note that the document must have been issued no more than six months ago 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 document.</p><p><b><u>UPDATE:</u></b></p><p>The type of document submitted (health insurance bill) <b><u>cannot be accepted</u></b> as proof of address. </p><p><b>Please submit a certified copy of one of the following types of documents: utility bill, landline phone bill (mobile bills not accepted), internet bill, cable bill, or government-issued document.</b></p><p>Please note that the document must have been issued no more than six months ago and must be certified as a true copy. If the document is not in English, an English translation certified by the translator must be submitted together with the original document.</p>

Frederico Perez Gonçalves Pereira - Letter of EngagementMiscellaneousCriticalDue Nov 19, 2025

Please submit a letter of engagement for the Compliance Officer Frederico Perez Gonçalves Pereira. The letter of engagement must be signed by the Managing Director and the Compliance Officer.

Please submit a letter of engagement for the Compliance Officer Frederico Perez Gonçalves Pereira. The letter of engagement must be signed by the Managing Director and the Compliance Officer.

Frederico Perez Gonçalves Pereira - CV (Curriculum Vitae)Curiculum VitaeCriticalDue Oct 7, 2025

Please submit a CV in English for Frederico Perez Gonçalves Pereira. Please upload the CV in the Letter of Engagement section in the portal.

Please submit a CV in English for Frederico Perez Gonçalves Pereira. Please upload the CV in the Letter of Engagement section in the portal.

Alexander Lo - Personal History Disclosure FormMiscellaneousCriticalDue Oct 7, 2025

Please note that Alexander Lo must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Please note that Alexander Lo must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Alexander Lo - Birth CertificateBirth CertificateCriticalDue Oct 7, 2025

Please submit a certified true copy of the birth certificate of Alexander Lo.

Please submit a certified true copy of the birth certificate of Alexander Lo.

Daniel Mukhamedaliyev - Personal History Disclosure FormMiscellaneousCriticalDue Oct 7, 2025

Please note that Daniel Mukhamedaliyev must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Please note that Daniel Mukhamedaliyev must submit the correct Personal History Disclosure Form, specifically the long form (not the short form). Kindly complete the form and submit it.

Daniel Mukhamedaliyev - Birth CertificateBirth CertificateCriticalDue Oct 7, 2025

Please submit a certified true copy of the birth certificate of Daniel Mukhamedaliyev.

Please submit a certified true copy of the birth certificate of Daniel Mukhamedaliyev.

Daniel Mukhamedaliyev - PassportPassportCriticalDue Mar 25, 2026

Please note that the passport of Daniel Mukhamedaliyev is not signed. Please submit a certified true copy of the signed passport.

<p>Please note that the passport of Daniel Mukhamedaliyev is not signed. Please submit a certified true copy of the signed passport.</p><p><b><u>UPDATE:</u></b></p><p>Please note that the passport itself must be signed by the passport holder Daniel Mukhamedaliyev on the "signature of bearer" line. Please submit a certified copy of the passport signed by Daniel Mukhamedaliyev on the "signature of bearer" line.</p>

Daniel Mukhamedaliyev - Bank Reference LetterReference LetterCriticalDue Oct 7, 2025

Please submit a certified bank reference letter issued no more than 6 months ago. If the bank reference letter is not in English, a certified English translation must be submitted together with the original document.

Please submit a certified bank reference letter issued no more than 6 months ago. If the bank reference letter is not in English, a certified English translation must be submitted together with the original document.

Daniel Mukhamedaliyev - Source of WealthSource of WealthCriticalDue Mar 25, 2026

Please submit evidence/documentation of source of wealth for Daniel Mukhamedaliyev.

<p>Please submit evidence/documentation of source of wealth for Daniel Mukhamedaliyev.</p><p><b><u>UPDATE:</u></b></p><p>Please submit:</p><ol><li>The signed source of wealth declaration.</li><li><u>Certified</u> copies of documents evidencing the declared source of wealth. This can include, as applicable, recent tax returns, salary slips, bank statements, P&L statement, proof of dividend payments received, or any other relevant documentation, depending on the origin of the wealth.</li></ol>

Applicant reply: Daniel is the owner of the Brand. May you please advise what we can use as source of wealth ? Standard declaration will suffice or would you need something like Tax return ?
Pawel Krzyspiak - Personal History Disclosure Form - Page 1: Question 4QuestionCriticalDue Oct 7, 2025

Please note that incorrect information was entered for question 4. Please enter the correct information (if applicable) and resubmit the form.

Please note that incorrect information was entered for question 4. Please enter the correct information (if applicable) and resubmit the form.

Pawel Krzyspiak - Personal History Disclosure Form - Page 5: Question 27QuestionCriticalDue Oct 7, 2025

Please note that since information was entered in the 'Other' section, the box next to 'Other Key Function Holder' must be checked.

Please note that since information was entered in the 'Other' section, the box next to 'Other Key Function Holder' must be checked.

Pawel Krzyspiak - Proof of EmploymentQuestionCriticalDue Mar 25, 2026

Please submit proof of current employment as indicated in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be recent and certified as a true copy. If the document is not in English, an English translation certified by the translator must also be submitted.

<p>Please submit proof of current employment as indicated in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be recent and certified as a true copy. If the document is not in English, an English translation certified by the translator must also be submitted.</p>

Applicant reply: Mr. Krzyspiak was with vacation and we couldn't get these document in time, we did provide all the rest of the needed in order to beat the deadline. Rest of the Document will follow shortly. Thank you for understanding.
Daniel Mukhamedaliyev - Proof of EmploymentQuestionCriticalDue Mar 25, 2026

Please submit documentation as proof of employment for Daniel Mukhamedaliyev. Kindly note that all documents must be recent and certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the original document.

<p>Please submit documentation as proof of employment for Daniel Mukhamedaliyev. Kindly note that all documents must be recent and certified as a true copy. If the document is not in English, a certified English translation must be submitted together with the original document.</p><p><b><u>UPDATE</u></b></p><p>Kindly submit proof of ownership of the brand. Please note that all documents submitted must be certified as a true copy. </p>

Applicant reply: He is the owner of the brand and works for this own company. Current operating under an Anjouan License. Is there any other supporting document we can use instead ?
Pawel Krzyspiak - Birth CertificateBirth CertificateCriticalDue Mar 25, 2026

Please submit a certified true copy of the birth certificate and a certified English translation of the birth certificate. Kindly note that the certification on the original document and translation must be in English.

<p>Please submit:</p><ol><li>A certified true copy of the original birth certificate.</li><li>An English translation of the birth certificate certified by the translator.</li></ol><p>Note: All certifications must be in English.</p>

Applicant reply: please accept our apology for this one as well, it is being arranged
Pawel Krzyspiak - PassportPassportCriticalDue Mar 25, 2026

Please submit a better (color) copy of the passport certified as a true copy.

<p>Please submit a better (color) copy of the passport certified as a true copy.</p><p><b><u>UPDATE:</u></b></p><p>Please submit a better quality color copy of the passport certified as a true copy. Please note that the <b><u>certification statement of the certifier must be in English</u></b>. </p><p>If the certification statement is not in English, an English translation (certified by the translator) must be submitted. </p>

Pawel Krzyspiak - Criminal RecordCriminal RecordCriticalDue Mar 25, 2026

Please note that the criminal record must be certified as a true copy. A certified English translation must also be provided together with the original document.

<p>Please submit: </p><ol><li>The original criminal record document certified as a true copy.</li><li> An English translation of the criminal record certified by the translator.</li></ol>

Applicant reply: please allow us a few extra days since we had to order a new one and it took longer than the deadline
Pawel Krzyspiak - Bank Reference LetterReference LetterCriticalDue Mar 25, 2026

Please note that a bank statement cannot be accepted as the bank reference letter. Kindly provide a bank reference letter confirming the person's standing at the bank. The letter must have been issued no more than six months ago and certified as a true copy. If the letter is not in English, a certified English translation must be provided together with the original document.

<p>Please note that a bank statement cannot be accepted as the bank reference letter. Kindly provide a bank reference letter confirming the person's standing at the bank. The letter must have been issued no more than six months ago and certified as a true copy. If the letter is not in English, a certified English translation must be provided together with the original document.</p><p><b><u>UPDATE:</u></b></p><p>In the case the the Polish banks do not issue a bank reference letter, a bank statement can be submitted. </p><p><u>The bank statement previously submitted, however, cannot be accepted because it is not certified as a true copy. It is also not in English and no translation was provided.</u></p><p>Please submit an official bank statement that is <b>certified as a true copy and no more than 6 months old</b>. If the bank statement is not in English, an <b>English translation</b> (certified by the translator) must also be submitted. </p>

Applicant reply: Kindly note that Polish banks do not issue reference letter. On the PHDF states Reference letter OR Bank Statement and therefore, we did provide the bank statement. Please let us know if there are any alternatives ?
Pawel Krzyspiak - Proof of AddressProof of AddressCriticalDue Mar 25, 2026

Please note that the original document must be certified as a true copy. A certified English translation must also be provided together with the original document.

<p>Please note that the original document must be certified as a true copy. A certified English translation must also be provided together with the original document.</p><p><b><u>UPDATE:</u></b></p><p>Please note that the proof of address documents submitted <b>cannot be accepted</b> as the <b><u>original document</u> is not certified as a true copy</b>. </p><p>Please submit:</p><ol><li>The original proof of address document in Polish <u>certified as a true copy</u> by an independent and authorized certifier. </li><li>An English translation of the document certified by the translator.</li></ol>

Pawel Krzyspiak - Source of WealthSource of WealthCriticalDue Mar 25, 2026

Please submit evidence/documentation of source of wealth for Pawel Krzyspiak.

<p>Please submit evidence/documentation of source of wealth for Pawel Krzyspiak.</p><p><b><u>UPDATE</u></b></p><p>Since Pawel Krzyspiak is the current UBO of the company, he must provide full evidence of source of wealth. This is applicable even if he is a nominee shareholder.</p><p>Please submit certified copies of documents evidencing source of wealth. Evidence can include, as applicable, pay slips, tax returns, bank statements, proof of investments/virtual assets, or any other relevant documentation, depending on the origin of the wealth. </p><p>Any document not in English must be accompanied by an English translation that is certified by the translator. </p>

Applicant reply: He is just nominee and will be removed shortly. What shall we provide in the meantime?
Christopher van Rosberg - PassportPassportCriticalDue Oct 7, 2025

Please upload a certified copy of the passport of Christopher van Rosberg in the base application QPA/2024/00076.

Please upload a certified copy of the passport of Christopher van Rosberg in the <b><u>base application QPA/2024/00076</u></b>.

Christopher van Rosberg - Personal History Disclosure Short Form - Page 1: Question 6QuestionCriticalDue Oct 7, 2025

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Christopher van Rosberg - Personal History Disclosure Form - Page 1: Questions 7 and 7.1QuestionCriticalDue Nov 19, 2025

The answer to question 7 and 7.1 are missing. Kindly complete questions 7 and 7.1 and resubmit the form.

<p>The answer to question 7 and 7.1 are missing. Kindly complete questions 7 and 7.1 and resubmit the form.</p><p><b><u>UPDATE:</u></b></p><p>For question 7, please check the 'Yes' box.</p><p>For question 7.1, please indicate that Christopher van Rosberg is a CSP/managing director involved with many other granted Curaçao Gaming Licenses (it is not necessary to list them individually).</p>

Applicant reply: Christopher is Director OBO Xecutive Corporate Management B.V. a CSP whom represents countless of Companies. It is not possible to list all. Furthermore the CGA is the one keeping track of all licenses, we currently have more or less 60 licenses. Should we mention them all ?
Lorenza Godett - Personal History Disclosure Short Form - Page 1: Question 6QuestionCriticalDue Oct 7, 2025

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Analissa Heiland - Personal History Disclosure Short Form - Page 1: Question 6QuestionCriticalDue Oct 7, 2025

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Please select Local Executive Director and enter the name of the local service provider in the corresponding field.

Analissa Heiland - Birth CertificateBirth CertificateCriticalDue Oct 7, 2025

Please note that a certified copy of the birth certificate of Analissa Heiland has not been provided. Please upload a certified copy of the birth certificate in English in Analissa Heiland's base application QPA/2025/03355. Kindly note that if the birth certificate is not in English, both a certified copy of the birth certificate and a certified English translation must be provided. All certifications must also be in English.

Please note that a certified copy of the birth certificate of Analissa Heiland has not been provided. Please upload a certified copy of the birth certificate in English in Analissa Heiland's base application QPA/2025/03355. Kindly note that if the birth certificate is not in English, both a certified copy of the birth certificate and a certified English translation must be provided. All certifications must also be in English.

Analissa Heiland - Proof of AddressProof of AddressCriticalDue Mar 25, 2026

Please note that a proof of address document (utility bill) is required for Analissa Heiland. Please upload a certified copy of the proof of address document (utility bill) in English and issued within the last 6 months in Analissa Heiland's base application QPA/2025/03355. Kindly note that bank statements are not accepted as proof of address.

<p>Please note that a proof of address document (utility bill) is required for Analissa Heiland. <b>Please upload a certified copy of the proof of address document (utility bill) in English and issued within the last 6 months in Analissa Heiland's <u>base application QPA/2025/03355</u>. </b></p><p> Kindly note that bank statements are not accepted as proof of address.</p><p><b><u>UPDATE:</u></b></p><p>Please upload a certified copy of a <b><u>proof of address document (utility bill, cable/internet bill, landline phone bill (mobile bills not accepted))</u></b> in the corresponding section of the <b><u>new base application of Analissa Heiland QPA/2025/03697</u></b>. Please note that the proof of address document must have been issued within the last six months and be certified as a true copy. </p><p>If the document is not in English, an English translation (certified by the translator) must also be submitted.</p>

Alexander Lo - Personal History Disclosure Form - Page 2: Question 21QuestionCriticalDue Nov 19, 2025

Since an answer was entered for 21.1, please select 'Yes' for question 21 and resubmit the form.

Since an answer was entered for 21.1, please select 'Yes' for question 21 and resubmit the form.

Alexander Lo - Personal History Disclosure Form - Page 2: Question 22QuestionCriticalDue Nov 19, 2025

Since an answer was entered for 22.1, please select 'Yes' for question 22 and resubmit the form.

Since an answer was entered for 22.1, please select 'Yes' for question 22 and resubmit the form.

Alexander Lo - Personal History Disclosure Form - Page 5: Question 27QuestionCriticalDue Nov 19, 2025

The position indicated in question 27 (Head of Finance) does match that which is stated in the portal and in the business plan (CFO). Please correct the information in question 27 and resubmit the form.

The position indicated in question 27 (Head of Finance) does match that which is stated in the portal and in the business plan (CFO). Please correct the information in question 27 and resubmit the form.

Alexander Lo - Personal History Disclosure Form - Page 5: Question 29QuestionCriticalDue Nov 19, 2025

In question 29, it is indicated that Alexander Lo is involved as a key person with Raw Entertainment B.V. as Head of Finance. However, Alexander Lo is not part of that application. Kindly correct questions 29 and 29.1 and resubmit the form.

In question 29, it is indicated that Alexander Lo is involved as a key person with Raw Entertainment B.V. as Head of Finance. However, Alexander Lo is not part of that application. Kindly correct questions 29 and 29.1 and resubmit the form.

Alexander Lo - Personal History Disclosure Form - Page 8: Question 44QuestionCriticalDue Nov 19, 2025

The information entered in question 44.1 is not clear. Please clarify the information in question 44.1 and resubmit the form.

The information entered in question 44.1 is not clear. Please clarify the information in question 44.1 and resubmit the form.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 1: Question 2QuestionCriticalDue Nov 19, 2025

The spelling of the last name in question 2 does not match the spelling of the last name on the passport. Kindly make the necessary correction and resubmit the form.

The spelling of the last name in question 2 does not match the spelling of the last name on the passport. Kindly make the necessary correction and resubmit the form.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 7: Questions 35 - 40QuestionCriticalDue Nov 19, 2025

Please enter the current employment information in questions 36 - 39. In question 40, please list any other positions you currently hold or held in the last 5 years.

Please enter the current employment information in questions 36 - 39. In question 40, please list any other positions you currently hold or held in the last 5 years.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 8: Question 43QuestionCriticalDue Nov 19, 2025

Please complete question 43.

Please complete question 43.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 9: Declaration and Data PrivacyQuestionCriticalDue Nov 10, 2025

Please note that the form must be digitally signed (copy/pasted signatures are not permitted). Kindly sign the form digitally and resubmit it.

Please note that the form must be digitally signed (copy/pasted signatures are not permitted). Kindly sign the form digitally and resubmit it.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 1: Questions 9 & 10QuestionCriticalDue Nov 19, 2025

Please note that the spelling of the mother's and father's last names in questions 9 and 10 does not match that on Daniel Mukhamedaliyev's birth certificate. Please make the necessary corrections and resubmit the form.

Please note that the spelling of the mother's and father's last names in questions 9 and 10 does not match that on Daniel Mukhamedaliyev's birth certificate. Please make the necessary corrections and resubmit the form.

Daniel Mukhamedaliyev - Personal History Disclosure Form - Page 2: Question 23QuestionCriticalDue Nov 19, 2025

It is indicated in question 23 that Daniel Mukhamedaliyev has been living at the address listed since 8/4/2025. Please list all other addresses where he has lived for more than six months in the past 8 years. Also, please verify if the 'from date' of 8/4/2025 is correct as this date contradicts the information on the proof of address document for this address, which is dated June 2025.

<p>It is indicated in question 23 that Daniel Mukhamedaliyev has been living at the address listed since 8/4/2025. <b>Please list all other addresses where he has lived for more than six months in the past 8 years. </b></p><p><b><u>Also</u></b>, please verify if the 'from date' of 8/4/2025 is correct as this date contradicts the information on the proof of address document for this address, which is dated June 2025.</p>

Jurisdiction migrationQuestionCriticalDue Mar 25, 2026

Since the company will be acquiring a brand and database currently licensed in another jurisdiction, please detail the process of the migration of clients from its current jurisdiction including the acceptance of player data and monies together with the relevant terms and domain.

Since the company will be acquiring a brand and database currently licensed in another jurisdiction, please detail the process of the migration of clients from its current jurisdiction including the acceptance of player data and monies together with the relevant terms and domain.

GMB Entertainment B.V. - Fiduciary AgreementSource of FundsCriticalDue Mar 25, 2026

Please provide a copy of the signed trust agreement between Daniel Mukhamedaliyev and the shareholder of GMB Entertainment N.V. Kindly note that the trust agreement must be certified as a true copy. In addition, please provide further source of funds showing that Gamba is self-sustaining.

Resubmit a the fiduciary agreement signed by all parties to it. Resubmit if also as a certified true copy.

Frederico Perez Gonçalves Pereira - Letter of EngagementMiscellaneousCriticalDue Mar 25, 2026

Please submit a letter of engagement for the Compliance Officer Frederico Perez Gonçalves Pereira. The letter of engagement must be signed by the Managing Director and the Compliance Officer.

Please submit a letter of engagement for the Compliance Officer Frederico Perez Gonçalves Pereira. The letter of engagement must be signed by the Managing Director and the Compliance Officer.

Applicant reply: XCM is currently working on new Draft for Compliance Engagement. As soon as done, we will let Frederico sign this one. He did sign the PHDF in the meantime to give consent to act as the Compliance Officer.
[Sarah Cathalina-Labbe - 24-02-2026 20:41]
Alexander Lo - Personal History Disclosure FormQuestionCriticalDue Mar 25, 2026

Please correct the below issues on the Personal History Disclosure Form and resubmit the form.

<p>Please correct the below issues on the Personal History Disclosure Form and resubmit the form.</p><ol><li><b>Question 21: </b>Since an answer was entered for 21.1, please select 'Yes' for question 21.</li><li><b>Question 22:</b> Since an answer was entered for 22.1, please select 'Yes' for question 22.</li><li><b>Question 29: </b>Alexander Lo is not listed as a qualifying person in that application. Please correct the information entered and leave the question blank if not applicable.</li><li><b>Question 44.1: </b>The information entered is not clear. Please clarify the information entered.</li></ol>

Daniel Mukhamedaliyev - Personal History Disclosure FormQuestionCriticalDue Mar 25, 2026

Please correct the below errors on the Personal History Disclosure Form and resubmit the form.

<p>Please correct the below errors on the Personal History Disclosure Form and resubmit the form.</p><ol><li><b>Question 2: </b>The spelling of the last name does not match the spelling of the last name on the passport. Please correct it.</li><li><b>Questions 9 & 10: T</b>he spelling of the mother and father's last names does not match the spelling on Daniel Mukhamedaliyev's birth certificate. Please make the necessary corrections.</li><li><b>Question 23: </b>a) It is indicated that Daniel Mukhamedaliyev has been living at the address listed since 8/4/2025. Please list all other addresses where he has lived for more than six months in the past 8 years. b) Please verify if the 'from date' of 8/4/2025 is correct as this date contradicts the information on the proof of address document for this address, which is dated June 2025.</li><li><b>Questions 35 - 39: </b>These questions are mandatory. Please complete the questions with the information of the present employment. </li><li><b>Question 40: </b>Please list any other positions you currently hold or held in the last 5 years.</li><li><b>Question 43: </b>This question is mandatory. Please complete the question.</li></ol>