4 AM QTF N.V.
CGA/2025/2611/1324
GrantedCustomer
- Contact
- George van Zinnicq Bergmann
- 4amqtf@igamingcompliance.com
- Company
- 4 AM QTF N.V.
Review Timeline
DFDesiree Francisco (CGA User 6)
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)
KMKevin Mallia (KM)
KMKevin Mallia (KM)
KMKevin Mallia (KM)
AAAnton Axiaq (AAX)
HSHilary Stewart Jones (HSJ)
HSHilary Stewart Jones (HSJ)
MMMarilisa Mathew (CGA User 1)
KMKevin Mallia (KM)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
CPCedric Pietersz (Managing Director GCB)
Compliance Checklists
Phase 1Critical40 items
We are missing information of the Compliance Officer (Ruth Cliff) of 4 AM QTF N.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer in the Qualifying Person Tab
We are missing information of the Compliance Officer of 4 AM QTF N.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer in the Qualifying Person Tab. No Source of Wealth required. Note also that the CO cannot be the CFO due to conflicting roles
The Online Gaming License Application Form is missing response in question 8. Kindly select at least one hosting platform for the Player Account Management in question 8 and resubmit the form.
The Online Gaming License Application Form is missing response in question 8. Kindly select at least one hosting platform for the Player Account Management in question 8 and resubmit the form.
The Online Gaming License Application Form is missing response in question 11.1. Kindly fill question 11.1 in and resubmit the form.
The Online Gaming License Application Form is missing response in question 11.1. Kindly fill question 11.1 in and resubmit the form.
The Online Gaming License Application Form is missing response in question 12. Kindly fill question 12 in and resubmit the form.
The Online Gaming License Application Form is missing response in question 12. Kindly fill question 12 in and resubmit the form.
The Declaration and Data Privacy on page 5 must be digitally signed by the managing director. Kindly sign and resubmit.
The Declaration and Data Privacy on page 5 must be digitally signed by the managing director. Kindly sign and resubmit.
The Business and Corporate Information Form is missing company tax identification number (Crib number) in question 4. Kindly fill the company tax identification number in question 4 and resubmit the form.
The Business and Corporate Information Form is missing company tax identification number (Crib number) in question 4. Kindly fill the company tax identification number in question 4 and resubmit the form.
The Business and Corporate Information Form is has incorrect answer in question 1. Kindly fill the brand name or company name in question 1 and resubmit the form.
The Business and Corporate Information Form is has incorrect answer in question 1. Kindly fill the brand name or company name in question 1 and resubmit the form.
The Business and Corporate Information Form is missing response in question 10. Kindly note that the applicant must registered and check the yes box regarding the goAML registration.
The Business and Corporate Information Form is missing response in question 10. Kindly note that the applicant must registered and check the yes box regarding the goAML registration.
The Business and Corporate Information Form is missing response in question 12. Kindly ensure that 'Yes' is checked for question 12. For question 12.1, please enter the full information of the Compliance Officer, CEO/COO and CCO as indicated on the form.
The Business and Corporate Information Form is missing response in question 12. Kindly ensure that 'Yes' is checked for question 12. For question 12.1, please enter the full information of the Compliance Officer, CEO/COO and CCO as indicated on the form. Please also note that the Compliance officer may not also hold the role of CFO as indicated on the business plan, due to conflicting roles
The Declaration and Data Privacy Page in the Business and Corporate Information Form must be named and digitally signed by the Managing Director. Kindly named and digitally signed the form and resubmit.
The Declaration and Data Privacy Page in the Business and Corporate Information Form must be named and digitally signed by the Managing Director. Kindly named and digitally signed the form and resubmit.
The enclosed share ledger document is not certified. Kindly have the document certified and resubmit.
The enclosed share ledger document is not certified. Kindly have the document certified and resubmit.
We are missing screenshot of the goAML registration of 4 AM QTF N.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.
We are missing screenshot of the goAML registration of 4 AM QTF N.V. Kindly submit the confirmation under the extra documentation section and name the file goAML registration.
We are missing the Declaration of Good Standing (verzoek verklaring betalingsgedrag) confirming compliance with tax and social contribution obligations (can be requested from the tax authorities). Kindly submit an in English certified declaration of good standing under the extra documentation section and name the file Declaration of Good Standing.
We are missing the Declaration of Good Standing (verzoek verklaring betalingsgedrag) confirming compliance with tax and social contribution obligations (can be requested from the tax authorities). Kindly submit an in English certified declaration of good standing under the extra documentation section and name the file Declaration of Good Standing.
We are missing the Personal History Disclosure Short Form of George van Zinnicq Bergmann (Managing Directior). Kindly submit the requested document.
We are missing the Personal History Disclosure Short Form of George van Zinnicq Bergmann (Managing Directior). Kindly submit the requested document.
We are missing information of the Compliance Officer of 4 AM QTF N.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.
We are missing information of the Compliance Officer of 4 AM QTF N.V. Kindly submit the Personal History Disclosure Form, Enclosures, Engagement Letter and Curriculum Vitae (CV) of the Compliance Officer.
The provided birth certificate is not certified. Kindly submit a certified copy of the birth certificate.
The provided birth certificate is not certified. Kindly submit a certified copy of the birth certificate.
Kindly provide us with better certified color copy of the passport. Kindly note that the compliance officer cannot certify the documents.
Kindly provide us with better certified color copy of the passport. Kindly note that the compliance officer cannot certify the documents.
Please note that the bank reference letter must make reference to the person's standing at the bank and it must be certified. Kindly provide a bank reference letter that meets these requirements.
Please note that the bank reference letter must make reference to the person's standing at the bank and it must be certified. Kindly provide a bank reference letter that meets these requirements.
The provided proof of address is incorrect. Kindly provide a certified in English proof of address (utility bill).
The provided proof of address is incorrect. Kindly provide a certified in English proof of address (utility bill).
The provided source of wealth documents, bank statements are not certified. Kindly certified provide bank statements and resubmit them.
The provided source of wealth documents, bank statements are not certified. Kindly certified provide bank statements and resubmit them.
We are missing information of the Chief Commercial Officer (Jessica Watson) of 4 AM QTF N.V. Kindly add and submit the Personal History Disclosure Form and Enclosures of the Chief Commercial Officer under the Qualifying Person Section.
We are missing information of the Chief Commercial Officer (Jessica Watson) of 4 AM QTF N.V. Kindly add and submit the Personal History Disclosure Form and Enclosures of the Chief Commercial Officer under the Qualifying Person Section.
Kindly note that the certified documents can't be certified by the company's compliance officer as its conflict of interest. Certification needs to be done by an independent and authorized certifier.
Kindly note that the certified documents can't be certified by the company's compliance officer as its conflict of interest. Certification needs to be done by an independent and authorized certifier. (Please review the notes on Certification of Documents found at the bottom of the PHDF and which are applicable for all documents requiring certification)
Kindly submit a criminal record from Colombia certified by an independent and authorized certifier. Kindly note that the Compliance Officer cannot certify documents. Please upload it to the Criminal Record section. If the document is not in English, a certified English translation must also be submitted.
Kindly submit a criminal record from Colombia certified by an independent and authorized certifier. Kindly note that the Compliance Officer cannot certify documents. Please upload it to the Criminal Record section. If the document is not in English, a certified English translation must also be submitted.
The Online Gaming License Application Form is missing response in question 19. Kindly check the yes box as this Requirement is now mandatory. 'Yes' should be selected with 19.1.1 and 19.1.2 to be completed once the approved ADR entity list is published by CGA.
The Online Gaming License Application Form is missing response in question 19. Kindly check the yes box as this Requirement is now mandatory. 'Yes' should be selected with 19.1.1 and 19.1.2 to be completed once the approved ADR entity list is published by CGA.
As per your reply in the checklist item regarding source of funds, "the company is not currently being funded through cash flow yet". If 11.3 is no longer correct, please update the form and resubmit it.
As per your reply in the checklist item regarding source of funds, "the company is not currently being funded through cash flow yet". If 11.3 is no longer correct, please update the form and resubmit it.
The answer to question 3 is missing. Kindly complete question 3 and resubmit the form.
The answer to question 3 is missing. Kindly complete question 3 and resubmit the form.
The answer to question 7 is missing. Please select 'Yes' for question 7. In question 7.1, please indicate that the person is a managing director involved with other Curaçao gaming licenses.
The answer to question 7 is missing. Please select 'Yes' for question 7. In question 7.1, please indicate that the person is a managing director involved with other Curaçao gaming licenses.
Please complete questions 34 - 39 with the current employment information and resubmit the form.
Please complete questions 34 - 39 with the current employment information and resubmit the form.
Please note that the form must be digitally signed. Kindly sign the form digitally and resubmit it (note that copied/pasted signatures are not permitted).
Please note that the form must be digitally signed. Kindly sign the form digitally and resubmit it (note that copied/pasted signatures are not permitted).
Please submit a certified true copy of the birth certificate of Jessica Watson.
Please submit a certified true copy of the birth certificate of Jessica Watson.
Please note that the copy of the passport must be certified. Kindly submit a certified true copy of Jessica Watson's passport.
Please note that the copy of the passport must be certified. Kindly submit a certified true copy of Jessica Watson's passport.
Please submit a certified true copy of the criminal record for Jessica Watson for the UAE. Kindly note that the criminal record must have been issued within the last six months.
Please submit a certified true copy of the criminal record for Jessica Watson for the UAE. Kindly note that the criminal record must have been issued within the last six months.
Please note that the proof of address document (utility bill) must be certified as a true copy. Kindly resubmit a certified copy of the proof of address document.
Please note that the proof of address document (utility bill) must be certified as a true copy. Kindly resubmit a certified copy of the proof of address document.
Please note that the application number is missing. Kindly fill in the application number and resubmit the form.
Please note that the application number is missing. Kindly fill in the application number and resubmit the form.
Please submit a certified true copy of the birth certificate of Ruth Cliff.
<p>Please submit a certified true copy of the birth certificate of Ruth Cliff.</p><p><b><u>UPDATE</u></b></p><p>Please note that the quality of the copy of the birth certificate of Ruth Cliff is very poor and much of the document (typed text) is illegible. <b><u>Please provide a better quality copy (certified) of the birth certificate.</u></b></p>
Please note that the copy of the passport must be certified. Kindly submit a certified true copy of Ruth Cliff's passport.
Please note that the copy of the passport must be certified. Kindly submit a certified true copy of Ruth Cliff's passport.
Please submit a certified true copy of the criminal record for Ruth Cliff for the UK. Kindly note that the criminal records check must have been issued within the last six months.
Please submit a certified true copy of the criminal record for Ruth Cliff for the UK. Kindly note that the criminal records check must have been issued within the last six months.
Please submit a certified copy of the bank reference letter for Ruth Cliff. Please note that the letter must have been issued with the last six months.
<p>Please submit a certified copy of the bank reference letter for Ruth Cliff. Please note that the letter must have been issued with the last six months.</p>
Please note that the proof of address document (utility bill) must be certified as a true copy. Kindly resubmit a certified copy of the proof of address document.
Please note that the proof of address document (utility bill) must be certified as a true copy. Kindly resubmit a certified copy of the proof of address document.
Please note that the form must be digitally signed. Kindly sign the form digitally and resubmit it (note that copied/pasted signatures are not permitted).
Please note that the form must be digitally signed. Kindly sign the form digitally and resubmit it (note that copied/pasted signatures are not permitted).
Phase 1 - Due DiligenceCritical4 items
Kindly note that there is conflicting information regarding the position of Simon Nicholls. On the Business and Corporate Information Form, Personal History Disclosure Form and in the portal, Simon Nicholls is listed as the UBO only. However, in the business plan, he is listed as the UBO, CEO, and COO. Please clarify whether the UBO also holds the positions of CEO and COO and ensure that the information is consistent on the business plan, in the portal and on all forms.
<p>Kindly note that there is conflicting information regarding the position of Simon Nicholls. On the Business and Corporate Information Form, Personal History Disclosure Form and in the portal, Simon Nicholls is listed as the UBO only. However, in the business plan, he is listed as the UBO, CEO, and COO. Please clarify whether the UBO also holds the positions of CEO and COO and ensure that the information is consistent on the business plan, in the portal and on all forms.</p><p><b><u>UPDATE</u></b></p><p>Please add the roles of CEO and COO for Simon Nicholls in the portal. </p>
Please note that the date of application is missing. Kindly enter the date and resubmit the form.
Please note that the date of application is missing. Kindly enter the date and resubmit the form.
The response to question 11 is missing. Please complete question 11 and resubmit the form.
The response to question 11 is missing. Please complete question 11 and resubmit the form.
UBO to clarify his relationship with Centrum Global BV and disclose any conflicts
<p>UBO to clarify his relationship with Centrum Global BV and disclose any conflicts with the applicant company</p><p>Please upload this agreement in the Extra Documentation section.</p>
Phase 2Critical5 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 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.
AML PolicyCritical4 items
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 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 operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.
The operator must conduct a Customer Risk Assessment which will assess the particular risks the casino will be exposed to when providing its services or products to players. The information collected to draw up the CRA will formulate the customer's risk profile. The customer specific risk assessment has to be carried out during establishing a business relationship. The categories follow from the BRA.
On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.
On the basis of the CRA, the AML & KYC Policy must include a Customer Acceptance Policy, on which the proper level of CDD can then be applied. When drawing up its CAP the casino has to comply with its obligations with regard to Politically Exposed Persons (PEP) and Sanctions Screening. The CAP should address the type of players that pose higher than average risk and also indicate the circumstances under which a player is denied.
KYC PolicyCritical2 items
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.
Responsible Gaming PolicyCritical1 item
The RG policy must state that the operator records all RG interactions in the PAM system.
The RG policy must state that the operator records all RG interactions in the PAM system.
Player Complaints PolicyCritical2 items
The policy must state that a player will always receive a final determination of their complaint in writing. The response will either be: 1. A reasoned final assessment of the outcome/resolution of the complaint with supporting evidence if necessary or applicable. 2. Detailed reasons for not handling the complaint. If additional information is reasonably required to address the complaint fully, the operator must have requested this information within the initial four week time period. Should the complainant not provide the necessary within the initial four week time period, the operator may reject the complaint. 3. If the player is unsatisfied with the resolution and makes a further complaint to that effect, the player is informed that they may escalate the matter to an independent ADR entity.
The policy must state that a player will always receive a final determination of their complaint in writing. <br>The response will either be: <br>1. A reasoned final assessment of the outcome/resolution of the complaint with supporting evidence if necessary or applicable. <br>2. Detailed reasons for not handling the complaint. If additional information is reasonably required to address the complaint fully, the operator must have requested this information within the initial four week time period. Should the complainant not provide the necessary within the initial four week time period, the operator may reject the complaint. <br>3. If the player is unsatisfied with the resolution and makes a further complaint to that effect, the player is informed that they may escalate the matter to an independent ADR entity.
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.
Personal Background ChecksCritical14 items
Check and list the Application Date.
List Position:
Please list the native name.
Approved or not. If no list, why?
Approved, or if not, list why.
Approved, or if not, list why.
Approved, or if not, list why.
Approved, or if not, list why.
[Philippe Warzee - 08-05-2026 08:53]
Approved, or if not, list why.
Approved, or if not, list why.
Approved or if not, list why.
Approved or if not, list why.
If yes, list the place and role.
Add the URL and give a small summary.