#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Apalonik B.V.

Gaming OperatorRegistered July 24, 2025Visit Website ↗
1
Applications
0
Domains
8
Related Entities
0
Locations

CGA/2025/2629/1332

In Progress
Submitted: July 31, 2025End Date: July 29, 2026

Customer

Contact
Maya Baroud
Email
apalonikbv@gmail.com
Company
Apalonik 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)

Compliance Checklists

Online Gaming Application FormCritical34 items
PAGE 3: QUESTION 14QuestionMinorDue May 27, 2026

If question 14 is filled out, then all 3rd party B2B services providers must be registered in the portal.

PAGE 3: QUESTION 15QuestionMinorDue May 27, 2026

If question 15 is filled out, we must verify the responsible gaming policy from the website(s) provided.

PAGE 3: QUESTION 16QuestionMinorDue May 27, 2026

If question 16 is filled out, we must verify the AML policy from the website(s) if provided.

PAGE 3: QUESTION 17QuestionMinorDue May 27, 2026

If question 17 is filled out, we must verify the terms and conditions using the domains list provided.

PAGE 3: QUESTION 18QuestionMinorDue May 27, 2026

Question 18 must be filled out. We must verify the operator has a complaint procedure that aligns with our regulations and conditions (if) provided.

PAGE 3: QUESTION 19QuestionMinorDue May 27, 2026

Question 19 must be filled out. Verify after if there is an alternative dispute resolution (ADR) in place for escalating player complaints. (mandatory requirement after July 2025).

Correct Application VersionIncomplete FormMinorDue Jun 3, 2026

The application must be similar to the one attached in the appendix and must contain the same number of pages. Inspect all pages to ensure that there are no blank pages and visually the application is similar to the one in the Appendix.

The Online gaming application form is not the official form supplied by CGA. Kindly download the appropriate form, refill and resubmit.

Application is Filled DigitallyIncomplete FormMinorDue Jun 3, 2026

The applications must be filled in digitally. No forms shall be accepted where the form is handwritten. Check the form and make sure there are no ink marks or handwritten notes.

The Online gaming application form contains handwritten information or has been inked. Kindly resubmit the form without handwritten information or marks.

PAGE 1: APPLICATION NUMBERQuestionMinorDue Jun 3, 2026

Make sure that this is filled and the same as that shown on the portal.

The application number of the Online gaming application form is missing or has an incorrect application number. Kindly resubmit the form with the correct application number.

PAGE 1: APPLICATION DATEQuestionCriticalDue Jul 28, 2026

The application date must be filled and within six month's of today's date.

The application date must be no more than six months old. Please update the application date.

PAGE 1: QUESTION 1QuestionMinorDue Jun 3, 2026

The Brand Name field must be filled.

The brand name in question 1 is missing. Kindly fill in question 1 and resubmit the form.

PAGE 1: QUESTION 2QuestionMinorDue Jun 3, 2026

The Company Name field must be filled as registered with the chamber of commerce of Curacao. Check if the company name matches the registered name on the excerpt of the Chamber of Commerce of Curacao.

The company name filled as registered with the chamber of commerce of Curacao is missing. Kindly fill in question 2 and resubmit the form.

PAGE 1: QUESTION 3QuestionMinorDue Jun 3, 2026

At least one Gaming Activity must be selected.

The response to question 3 is missing. Kindly select at least one gaming activity for question 3 and resubmit the form.

PAGE 1: QUESTION 3QuestionMinorDue Jun 3, 2026

If 3.9 is selected then the Other field must be filled.

The response to question 3.9 is missing. Kindly fill details of the type gaming activity that the applicant will offer in question 3.9 and resubmit the form.

PAGE 2: QUESTION 4QuestionMinorDue Jun 3, 2026

Check the document.

The response to question 4 is missing. Kindly fill out and resubmit the form.

PAGE 2: QUESTION 5QuestionMinorDue Jun 3, 2026

Check the document.

The response to question 5 is missing. Kindly fill out and resubmit the form.

PAGE 2: QUESTIONS 6 AND 7QuestionMinorDue Jun 3, 2026

Question 6 or 7 must have at least one entry completed.

The currency details in questions 6 and/or question 7 are missing. Kindly fill currency details and resubmit the form.

PAGE 2: QUESTION 8QuestionMinorDue Jun 3, 2026

At least one option must be selected.

The response to question 8 is missing. Kindly select at least one hosting platform for the Player Account Management in question 8 and resubmit the form.

PAGE 2: QUESTION 9QuestionMinorDue Jun 3, 2026

Must be filled out.

The response to question 9 is missing. Kindly list the countries where the servers are located (use a comma separated list) and resubmit the form.

PAGE 2: QUESTION 10QuestionMinorDue Jun 3, 2026

If yes is selected, then answer 10.1. must be filled.

Question 10 and/or 10.1. is not filled out. Kindly fill out question 10 and question 10.1.

PAGE 2: QUESTION 11QuestionMinorDue Jun 3, 2026

At least one option has to be selected.

The response to question 11 is missing. Kindly fill Question 11 and resubmit the form.

PAGE 2: QUESTION 11QuestionMinorDue Jun 3, 2026

If Third party service provider is selected then 11.1. and 11.2. must be filled.

The response to question 11.1. and/or 11.2. is missing. Kindly fill in and resubmit the form.

PAGE 3: QUESTION 12QuestionMinorDue Jun 3, 2026

At least one option must be checked.

The response to question 12 is missing. Kindly select at least on item and resubmit the form.

PAGE 3: QUESTION 13QuestionMinorDue Jun 3, 2026

If question 13.1. is selected, then 13.1.1. must be filled out.

The response to question 13.1.1. is missing.

PAGE 4: QUESTION 20QuestionMinorDue Jun 3, 2026

The full name of the contact person must be filled.

The first and or last name of the contact person in Question 20 is missing. Kindly fill and resubmit the form.

PAGE 4: QUESTION 20QuestionMinorDue Jul 28, 2026

The name of the contact person must be the same as the portal.

The contact person entered in question 20 must be the portal administrator. Please update the contact person's name to that of the portal administrator.

PAGE 4: QUESTION 21QuestionMinorDue Jul 28, 2026

Must be filled out.

The information entered must match that of the portal administrator.

PAGE 4: QUESTION 22QuestionMinorDue Jul 28, 2026

The contact person passport number is required.

The information entered must match that of the portal administrator.

PAGE 4: QUESTION 23QuestionMinorDue Jul 28, 2026

The contact person passport country of issue is required.

The information entered must match that of the portal administrator.

PAGE 4: QUESTION 24QuestionMinorDue Jul 28, 2026

The contact person contact address is required in full: STREET NAME, BUILDING NUMBER, CITY/TOWN, STATE/COUNTY/PROVINCE, COUNTRY ZIP CODE/POST CODE

The information entered must match that of the portal administrator.

PAGE 4: QUESTION 25QuestionMinorDue Jun 3, 2026

The email address is required.

The email address is missing in Question 25. Kindly fill Question 25 and resubmit the form.

PAGE 4: QUESTION 25QuestionMinorDue Jul 28, 2026

The email address must be the same as that of the portal user.

The email address entered must match the email address of the portal administrator as registered in the portal.

PAGE 5: DECLARATION AND DATA PRIVACYQuestionMinorDue Jul 28, 2026

The name and surname along with the signature of the official representative must be filled.

The name of the managing director Jonathan Heymans must appear at the top of the page. Also, the form must be digitally signed by Jonathan Heymans (copy/pasted signatures are not accepted).

PAGE 3: QUESTION 19QuestionCriticalDue Jul 28, 2026

Please complete questions 19.1.1 and 19.1.2.

Please complete questions 19.1.1 and 19.1.2.

Business and Corporate Information FormCritical33 items
Missing PagesIncomplete FormCriticalDue Jun 3, 2026

Check if all pages are in the submitted form

The form has missing pages. Please refill the complete form and resubmit.

PAGE 1: APPLICATION NUMBERQuestionCriticalDue Jun 3, 2026

Make sure that this is filled in and the same as that shown on the portal.

The application number of the Business and corporate application form is missing or has an incorrect application number. Kindly resubmit the form with the correct application number.

PAGE 1: APPLICATION DATEQuestionCriticalDue Jul 28, 2026

The application date must be filled and within six month's of today's date.

The application date must be no more than six months old. Please update the application date.

PAGE 1: QUESTION 1QuestionCriticalDue Jun 3, 2026

The Brand Name field must be filled.

The brand name in Question 1 is missing. Kindly fill in Question 1 and resubmit the form.

PAGE 1: QUESTION 2QuestionCriticalDue Jun 3, 2026

The Company Registered Name field must be filled.

The Business and corporate information form is missing the response to Question 2. Kindly fill Question 2 and resubmit the form.

PAGE 1: QUESTION 3QuestionCriticalDue Jun 3, 2026

The Company Registered Number must filled.

The Company Registered Number is missing or incorrect. Kindly fill Question 3 and resubmit the form.

PAGE 1: QUESTION 4QuestionCriticalDue Jun 3, 2026

Check if the company Tax ID is correct, based on the declaration of Good Standing. The Company Tax ID Number must be filled.

The Company Tax ID Number is incorrect/ missing. Kindly fill Question 4 and resubmit the form.

PAGE 1: QUESTION 5QuestionCriticalDue Jun 3, 2026

The Company Date of Incorporation must be filled. Date must be DD-MMM-YYYY format

The date of incorporation is missing. Kindly fill Question 5 and resubmit the form.

PAGE 1: QUESTION 6QuestionCriticalDue Jun 3, 2026

The Company Corporate Address must be filled.

The Company corporate address is missing . Kindly fill Question 6 and resubmit the form.

PAGE 1: QUESTION 7QuestionCriticalDue Jun 3, 2026

One option must be selected.

A response is to question 7 is missing. Please select an option and resubmit the form.

PAGE 1: QUESTION 7QuestionCriticalDue Jun 3, 2026

If option 7.2 is selected, then 7.2.1 must be completed

A response is to Question 7.2.1. is missing. Please select an option and resubmit the form.

PAGE 1: QUESTION 7QuestionCriticalDue Jun 3, 2026

If option 7.3 is selected, then 7.3.1 must be completed.

A response is to Question 7.3.1. is missing. Please select an option and resubmit the form.

'PAGE 1: QUESTION 10QuestionCriticalDue Jul 28, 2026

Please note that registration with goAML is a requirement. Once the registration with goAML has been completed, kindly check 'Yes' for question 10 and resubmit the form.

Please note that registration with goAML is a requirement. Once the registration with goAML has been completed, kindly check 'Yes' for question 10 and resubmit the form.

PAGE 2: QUESTIONS 8 & 9QuestionCriticalDue Jul 28, 2026

Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.

<div>Questions 8 and 9 have been left blank. Question 11.1 indicates that the company will be funded through shareholder loans. Please clarify as to where the company will be receiving the funds from the loan.</div>

PAGE 2: QUESTION 9QuestionCriticalDue Jun 3, 2026

If question 9 is selected, then question 9.1 must be filled.

A response to question 9.1 is missing. Please fill in and resubmit the form.

PAGE 2: QUESTION 11QuestionCriticalDue Jun 3, 2026

One option must be selected.

Question 11 is not filled out. Please select an option in question 11 and resubmit the form.

PAGE 2: QUESTION 11QuestionCriticalDue Jun 3, 2026

If question 11.1 is selected then question 11.1.1. must be filled.

The response to question 11.1.1 not filled out. Please complete and resubmit the form.

PAGE 2: QUESTION 11QuestionCriticalDue Jun 3, 2026

If question 11.2. is selected then questions 11.2.1. and 11.2.2. or 11.2.3. must be selected.

The response to question 11.2.1. and/or 11.2.2./11.2/3 is missing or incorrect.

PAGE 3: QUESTION 12QuestionCriticalDue Jul 28, 2026

Yes must be selected, if B2C as it must always have a compliance officer, therefore 12.1 must be filled.

Please note that 'Yes' must be selected for question 12 and the information of the compliance officer must be added in question 12.1. This is a requirement for a B2C application.

PAGE 3: QUESTION 13QuestionCriticalDue Jul 28, 2026

Must be filled.

Please correct the information entered in question 13. In the 'Name of Company' column the name of the applicant entity must be entered. In the 'Holder' column the name of the UBO must be entered.

PAGE 4: DECLARATION AND DATA PRIVACYQuestionCriticalDue Jul 28, 2026

The document must contain name and surname of the official representative and must be digitally signed and verified.

The name of the managing director Jonathan Heymans must appear at the top of the page. Also, the form must be digitally signed by Jonathan Heymans (copy/pasted signatures are not accepted).

Company StructureQuestionCriticalDue Jul 28, 2026

An updated company structure diagram showing direct and indrect equity and control percentages signed by a company director of the applicant company.

The company structure must reference both CSPs. Also, the company structure must be signed by the managing director Jonathan Heymans.

Number of Qualifying PersonsQuestionCriticalDue Jun 19, 2026

Determine how many UBO(s), Qualifying Interest Holder(s) and listed UBO(s). Calculate fee ((Total UBO(s) + Qualifying Interest Holder(s) + listed UBO(s) - one UBO EUR 150) Inform Finance to Issue an Invoice.

<p>Inform Finance to Issue an Invoice.</p><p>1 UBO</p>

Share Ledger DocumentQuestionCriticalDue Jun 19, 2026

Check Share ledger Document of the applicant company including companies holding 10% or more shareholding in the applicant company.

Please submit a certified true copy of the share ledger.

Completed.
[Sarah Cathalina-Labbe - 22-06-2026 16:24]
Share Ledger of Intermediate CompaniesQuestionCriticalDue Jun 3, 2026

Share ledger of intermediate company(ies) or holding company(ies) 10% or more shareholding in the applicant company.

The enclosed document, Share ledger of the company/holdings is not certified/ missing. Kindly resubmit.

Directors ListQuestionCriticalDue Jun 19, 2026

Check document, must be signed by the managing director unless it is an stamped excerpt from the Chamber of Commerce.

Please submit a certified true copy of the directors list.

Completed.
[Sarah Cathalina-Labbe - 22-06-2026 16:25]
Directors list of Intermediate companiesQuestionCriticalDue Jun 3, 2026

Directors list for of intermediate company(ies) or holding company(ies) 10% or more shareholding in the applicant company.

The enclosed document is incomplete or not certified.

Articles of Incorporation of the applicant Company.QuestionCriticalDue Jun 3, 2026

Make sure that the Articles of Incorporation of the applicant company is complete and verify if it is the latest date of document with Chamber of Commerce.

The enclosed document, Articles of Incorporation of the Applicant Company is incomplete or missing details. Kindly resubmit.

Articles of Incorporation for intermediate company(ies)QuestionCriticalDue Jun 3, 2026

Articles of Incorporation for intermediate company(ies) or holding company (ies) 10% or more shareholding in the applicant company

The enclosed document, Articles of Incorporation of the Company/holding is incomplete or missing details. Kindly resubmit.

Business PlanQuestionCriticalDue Jul 28, 2026

Reviewed if the business plan contains at least: 1. An overview of the business products and services/brands as well as proprietary IP 2. Company management structure showing key management roles and reporting lines. 3. Business forecasts for 3 years. 4. Overview of intended strategy for the business growth and to secure/maintain/grow market share with specific financial and marketing plans

<p>Please resubmit the business plan according to the below:</p><ol><li>The company structure must reference both CSPs.</li><li>The role of compliance officer must be included in the company management structure and the name of the compliance officer must be indicated.</li><li>A more detailed 3-year forecast providing a break down of the investments and funding to be made, as well as a break down of expenses involved. </li></ol>

goAML RegistrationQuestionCriticalDue Jul 28, 2026

A screenshot of the goAML registration of the Curacao entity.

Registration with goAML is mandatory. Once registered with goAML, proof of registration must be provided. Please 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.

Source of Funds of BusinessQuestionCriticalDue Jul 28, 2026

If applicable, evidence of 3rd party or shareholder loans is missing.

Please provide a certified copy of the shareholder loan agreement, which is expected to outline the key terms, including the funding, and any interest on the loan and the repayment terms (if applicable). The loan agreement must be signed by all parties and certified as a true copy. Kindly upload it in the Source of Funding section.

Agree the amount is too low to run a B2C.
[Support Admin - 22-05-2026 07:51]
To RCL: There is a concern that the amount of the shareholder loan (EUR 22k) is low. Please update the checklist item as necessary.
[Sarah Cathalina-Labbe - 20-05-2026 20:21]
Declaration of Good StandingMiscellaneousCriticalDue Jul 28, 2026

Please provide the Declaration of Good Standing (verzoek verklaring betalingsgedrag) of XYZ N.V. Kindly upload the document in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the official document issued by the Tax Authorities with the stamp of 'ontvanger' and the 'invorderaar' and it must be certified as a true copy.

Please provide the Declaration of Good Standing (verzoek verklaring betalingsgedrag) of XYZ N.V. Kindly upload the document in the Extra Documentation section and name the file Declaration of Good Standing. Please note that the Declaration of Good Standing must be the official document issued by the Tax Authorities with the stamp of 'ontvanger' and the 'invorderaar' and it must be certified as a true copy.

Qualifying PersonsCritical3 items
Maya Baroud - Managing DirectorMiscellaneousCriticalDue Jul 28, 2026

Please add managing director Maya Baroud to the portal as a qualifying person and submit the Personal History Disclosure Form and enclosures (with the exception of source of wealth).

Please add managing director Maya Baroud to the portal as a qualifying person and submit the Personal History Disclosure Form and enclosures (with the exception of source of wealth).

Jonathan Heymans - Managing DirectorMiscellaneousCriticalDue Jul 28, 2026

Please add managing director Jonathan Heymans to the portal as a qualifying person and submit the Personal History Disclosure SHORT Form.

Please add managing director Jonathan Heymans to the portal as a qualifying person and submit the Personal History Disclosure SHORT Form.

Compliance OfficerMiscellaneousCriticalDue Jul 28, 2026

For a B2C application, it is required to appoint a compliance officer. Please add the compliance officer as a qualifying person in the portal and upload the Personal History Disclosure Form and enclosures (with the exception of source of wealth). A letter of engagement (signed by both the managing director Jonathan Heymans and the compliance officer) as well as a CV in English must also be submitted. Note: If the Compliance Officer already has a base application in the portal, upload the Personal History Disclosure Short Form and the letter of engagement in this application. The CV and all other enclosures must be submitted in the base application.

<p>For a B2C application, it is required to appoint a compliance officer. Please add the compliance officer as a qualifying person in the portal and upload the Personal History Disclosure Form and enclosures (with the exception of source of wealth). A letter of engagement (signed by both the managing director Jonathan Heymans and the compliance officer) as well as a CV in English must also be submitted. </p><p><i>Note: If the Compliance Officer already has a base application in the portal, upload the Personal History Disclosure Short Form and the letter of engagement in this application. The CV and all other enclosures must be submitted in the base application.</i></p>

Personal History Disclosure FormCritical36 items
CGA Personal History Disclosure FormIncomplete FormCriticalDue Jun 3, 2026

Check document.Inspect all pages to ensure that there are no blank pages The applications must be filled in digitally. No forms shall be accepted where the customer has completed any section of the form handwritten. Check the forms and make sure there are no ink marks or handwritten notes.

The Personal History Disclosure form is not the official form supplied by CGA. Kindly download the appropriate form, refill digital and resubmit.

Page 1: Application NumberIncomplete FormCriticalDue Jun 3, 2026

Check document. Make sure that this is filled and the same as that shown on the portal

The personal application number is missing or has an incorrect application number. Kindly resubmit the forms with the correct application number.

Page 1: Application DateQuestionCriticalDue Jun 3, 2026

Check document. The application date must be filled and within six month`s of today`s date.

The application date is missing or has an incorrect application date. Kindly resubmit the forms with the correct application date.

Page 1: Personal Information Section - Question 1: First NameQuestionCriticalDue Jun 3, 2026

Check if information matches the passport.

The applicant`s first name is incorrect or does not match.Kindly resubmit the form with the correct first name.

Page 1: Personal Information Section - Question 2: Last NameQuestionCriticalDue Jun 3, 2026

Check if information matches the passport.

The applicant`s last name is incorrect or does not match.Kindly resubmit the form with the correct lasr=t name.

Page 1: Personal Information Section - Question 6: DOBQuestionCriticalDue Jun 3, 2026

Check if information matches the passport.

The Date of birth (DOB) of the applicant is missing or incorrect. Kindly resubmit the forms with the correct DoB.

Page 1: Personal Information Section - Question 7 and 8: Former namesQuestionCriticalDue Jun 3, 2026

Check if applicant has submitted certified proof of previous names.

Kindly provide certified proof of name change documents.

Page 1:Personal Information Section - Question 11QuestionCriticalDue Jun 3, 2026

Must not be blank.

The response to Question 11 is missing. Kindly complete Question 11 and resubmit the form.

Page 1: Personal Information Section - Question 12QuestionCriticalDue Jun 3, 2026

Must not be blank. personal email address

The response to Question 12 is missing. Kindly complete Question 12 and resubmit the form.

Page 2: Contact Details Section - Question 13QuestionCriticalDue Jun 3, 2026

Must not be blank. Email address

The response to Question 13 is missing. Kindly complete Question 13 and resubmit the form.

Page 2: Contact Details Section - Question 14QuestionCriticalDue Jun 3, 2026

Must not be blank. Mobile number

The response to Question 14 is missing. Kindly complete Question 14 and resubmit the form.

Page 2: Citizenship Section - Question 15QuestionCriticalDue Jun 3, 2026

Check if matches the passport. Place of Birth must not be blank.

The response to Question 15 is missing. Kindly complete Question 15 and resubmit the form.

Page 2: Citizenship Section - Question 16QuestionCriticalDue Jun 3, 2026

Must not be blank and check if matches the passport. Passport number must not be blank.

The response to Question 16 is missing. Kindly complete Question 16 and resubmit the form.

Page 2: Citizenship Section - Question 17QuestionCriticalDue Jun 3, 2026

Check if matches the passport. Country of Issue must not be blank.

The response to Question 17 is missing. Kindly complete Question 17 and resubmit the form.

Page 2: Citizenship Section - Question 18QuestionCriticalDue Jun 3, 2026

Check if matches the passport. Date of Issue must not be blank.

The response to Question 18 is missing. Kindly complete Question 18 and resubmit the form.

Page 2: Citizenship Section - Question 19QuestionCriticalDue Jun 3, 2026

Check if matches the passport. Date of Expiry must not be blank.

The response to Question 19 is missing. Kindly complete Question 19 and resubmit the form.

Page 2: Citizenship Section - Question 20QuestionCriticalDue Jun 3, 2026

Check if matches the passport. Nationality/ Citizenship

The response to Question 20 is missing. Kindly complete Question 20 and resubmit the form.

Page 5: Key Person Involvement Section - Question 27QuestionCriticalDue Jun 3, 2026

Must be filled. If the Local Executive Director(official representative) is selected the name of the local service provider must be filled in. If other Key Function Holder is selected, then the function must be filled.

The name of the local service provider or the function of the person in the company is missing. Kindly fill in and resubmit the form.

Page 5: Key Person Involvement Section - Question 28QuestionCriticalDue Jun 3, 2026

If question 28 is filled then question 28.1. must be filled.

The response to question 28.1 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 30QuestionCriticalDue Jun 3, 2026

Must be filled.

The response to question 30 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 31QuestionCriticalDue Jun 3, 2026

Must be filled.

The response to question 31 is missing. Kindly fill in and resubmit.

Page 7: Present Employment Section - Question 34 and 39QuestionCriticalDue Jun 3, 2026

They must provide evidence of present employment.

The proof for question 34 and 39 is missing. Kindly upload in the section of extra documentation.

Page 8: Source of Wealth Section - Question 41 - 42QuestionCriticalDue Jun 3, 2026

Must be filled.

The response for question 41 and or 42 is missing. Kindly fill in and resubmit.

Page 8: Source of Wealth Section - Question 43QuestionCriticalDue Jun 3, 2026

Must be filled. At least one must be selected, if 43.11 is selected then other Income must be filled.

The response to question 43 is missing. (if applies 43.11 must be filled) Kindly fill in and resubmit the form.

Page 8: Question 44QuestionCriticalDue Jun 3, 2026

If yes is selected, 44.1. must be filled.

The response to 44.1. is missing. Kindly fill in and resubmit the form.

Page 9: Declaration and Data PrivacyMiscellaneousCriticalDue Jun 3, 2026

The document must contain the name and surname and digital signature of the person that filled the form on Page 9.

The DECLARATION AND DATA PRIVACY is missing the name and/or is not digitally signed. Kindly fill in the name and/or surname /sign and resubmit the form.

PassportPassportCriticalDue Jul 28, 2026

Check date and make sure the passport is not expired.Make sure that persons photo is clear and recognizable.

<p>The copy of the passport submitted cannot be accepted due to the poor copy quality. Please submit a high-quality color copy of the passport with a clear photo. It must be duly certified as a true copy by an independent and authorized certifier.</p>

Criminal RecordCriminal RecordCriticalDue Jun 19, 2026

Check the document and make sure it is in english language or if translated from another language, the translated document, must be certified. Check date and make sure the certificate is not expired (not older than 6 months). It must be submitted for every jurisdiction whereby the applicant resided for more than six months in the last two years.

The criminal record provided is not certified as a true copy and was issued more than six months ago. Please provide a new criminal record issued within the last six months and duly certified by an independent and authorized certifier.

Completed.
[Sarah Cathalina-Labbe - 22-06-2026 16:36]
Birth CertificateProof of AddressCriticalDue Jul 28, 2026

Check the document and make sure it is in English Language or orginal document with translation. Both have to be certified. (In some cases we accept the Marriage Certificate)

<p>The birth certificate submitted cannot be accepted because the handwritten information is not legible, the handwritten information is not in English, and the document is not certified as a true copy. </p><p>Please submit:</p><ol><li>A certified copy of the original birth certificate.</li><li>An English translation of the birth certificate certified by the translator. The translator's statement must confirm that the document is a true translation from the original language, and must include the translator's full name, contact details, signature, and must be dated within the last six months.</li></ol>

Proof of AddressProof of AddressCriticalDue Jun 19, 2026

Make sure that this document is in English or translated in English language and certified. Check if the address is a residential address. Check date and make sure the date is within the last six months.

The proof of address document provided was issued more than six months ago. Please provide a new proof of address document issued within the last six months and duly certified by an independent and authorized certifier.

Completed.
[Sarah Cathalina-Labbe - 22-06-2026 16:39]
Bank Reference LetterReference LetterCriticalDue Jul 28, 2026

Make sure that it is in the applicant name verifying their personal account.Check date and make sure the certificate is not expired (not older than 6 months).

The bank reference letter provided is not certified as a true copy and was issued more than six months ago. Please provide a new bank reference letter issued on official bank letterhead within the last six months and duly certified by an independent and authorized certifier.

Letter of appointment/ Engagement agreement as Key Person.Reference LetterCriticalDue Jun 3, 2026

Check document. (mandatory for compliance officers)

The letter of appointment/ engagement agreement is missing/incomplete. Kindly resubmit/ submit.

Personal Gaming Authorisations from Other JurisdictionsReference LetterMediumDue Jun 3, 2026

Certified true copies of any Gaming License issued in favor of the applicant in a personal capacity from any jurisdiction ( eg. UK Personal Management License)

The Certified true copies of Gaming License issued in favor of personal capacity is missing/incomplete. Kindly submit.

Curriculum Vitae (CV)Curiculum VitaeCriticalDue Jun 3, 2026

Check document. (mandatory for compliance officers)

Source of WealthSource of WealthCriticalDue Jul 28, 2026

The Source of Wealth must demonstrate the UBO`s financial standing and confirm their ability to operate and support the company.

<p>The bank statement submitted as source of wealth cannot be accepted because it is not certified as a true copy and it is not recent. Also, most of the information is not in English, and a certified English translation was not provided. In addition, the name on the bank statement does not match the UBO's name as stated on his passport. If this bank statement is resubmitted, please provide an explanation for the discrepancy. </p><p>Please submit: </p><ol><li>Signed and certified source of wealth declaration. </li><li>Certified copies of documents evidencing the income and net worth as declared on the Personal History Disclosure Form. </li></ol><p>Evidence of source of wealth can include certified bank statements clearly displaying amounts and dividends, tax returns evidencing earnings, or any other certified documentation demonstrating the source of wealth of the UBO.</p><p>Keep in mind that as a SOW, you must demonstrate your ability to support the business and what you have stated is insufficient.</p>

I completely agree with your comments and I will add that you must demonstrate that you can handle the running of the business.
[Support Admin - 22-05-2026 07:44]
To RCL: There are concerns with low income and net worth declared on the PHDF. Both were declared as EUR 20k, raising possible concerns with liquidity. Declared net worth is also less than the amount of the shareholder loan of EUR 22k. Please update the checklist item as necessary.
[Sarah Cathalina-Labbe - 20-05-2026 20:20]
Proof of EmploymentMiscellaneousCriticalDue Jul 28, 2026

Please provide evidence of current employment as declared in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be certified as true copies.

Please provide evidence of current employment as declared in questions 34 - 39 on the Personal History Disclosure Form. All documents submitted must be certified as true copies.