#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Starx Software Solutions N.V.

Gaming OperatorRegistered October 28, 2025
2
Applications
0
Domains
10
Related Entities
0
Locations

CGA/2025/2702/1359

In Progress
Submitted: January 21, 2026End Date: July 8, 2026

Customer

Contact
Stefanie C.J. Hardeman Knoester
Email
starx@igamingcompliance.com
Company
Starx Software Solutions N.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
HSHilary Stewart Jones (HSJ)
Suitability
HSHilary Stewart Jones (HSJ)
Verification
MMMarilisa Mathew (CGA User 1)
Verification
KMKevin Mallia (KM)

Compliance Checklists

Phase 1Critical20 items
Online Gaming License Application FormQuestionCriticalDue May 27, 2026

Please correct the below issues on the Online Gaming License Application Form and resubmit the form.

<p>Please correct the below issues on the Online Gaming License Application Form and resubmit the form.</p><ol><li><b>Question 19: </b>Questions 19.1.1 and 19.1.2 must be completed. The ADR entity list is available on the License Register on the CGA website in the 'Certificates' section. </li><li><b>Question 20: </b>The first name must appear in the first field and the last names in the second field.</li><li><b>Question 21: </b>As per the Curaçao Chamber of Commerce excerpt, George van Zinnicq Bergmann is no longer the managing director of eMoore N.V. Please enter the current role. </li><li><b>Declaration and Data Privacy: </b>The name of the current managing director must appear at the top of the page and the form must be digitally signed by the current managing director. (Note: copy/pasted signatures are not accepted).</li></ol>

No longer applicable, applicant is applying for a B2B license.
[Sarah Cathalina-Labbe - 29-05-2026 14:28]
Closed - applicant has switched to B2B.
[Sarah Cathalina-Labbe - 13-05-2026 13:45]
Business PlanBusiness PlanCriticalDue May 27, 2026

Please submit an updated business plan.

<p>Please submit an updated business plan.</p><ol><li>The business plan submitted reflects B2B activities. Since the applicant is applying for a B2C license, the business plan must reflect B2C activities. It is not permitted for one entity to conduct both B2C and B2B operations.</li><li>The company management structure must include the compliance officer.</li><li>The financial forecast must include projections for three years.</li></ol>

Completed.
[Sarah Cathalina-Labbe - 29-05-2026 15:16]
Source of Funds of BusinessSource of FundsCriticalDue Jun 23, 2026

Please submit:

<p>Please submit:</p><ol><li>A <u>certified true copy of the loan agreement</u> 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 <u>certified as a true copy</u>. </li><li>If Universal Software Solutions N.V. is providing the loan and/or funding, the signed 2024 financial statements and the 2025 financials in whatever form of Universal Software Solutions N.V.</li></ol><p><b><u>UPDATE</u></b></p><p>Please upload a certified true copy of the loan agreement duly signed by all parties.</p>

Burak Basel - Personal History Disclosure SHORT FormMiscellaneousCriticalDue Jun 23, 2026

Please submit the Personal History Disclosure SHORT Form in this application (QPA/2025/04334).

<p>Please submit the Personal History Disclosure <u>SHORT</u> Form in this application (QPA/2025/04334).</p><p><b><u>UPDATE</u></b></p><p>Please submit the Personal History Disclosure <u>SHORT</u> Form in this application (QPA/2025/04334). Note that the form must be digitally signed.</p>

Burak Basel - Proof of EmploymentMiscellaneousCriticalDue Mar 24, 2026

Please provide proof of current employment. All documents submitted must be certified as true copies. Please upload the document(s) in the Ancillary Documents section of the base application QPA/2024/00747.

Please provide proof of current employment. All documents submitted must be certified as true copies. Please upload the document(s) in the <u>Ancillary Documents </u>section of the <u><b>base application QPA/2024/00747</b></u>.

George BergmannMiscellaneousCriticalDue Apr 13, 2026

According to the Curaçao Commercial Register, George Bergmann is no longer the managing director of the CSP eMoore N.V. Please remove his role in the portal accordingly.

According to the Curaçao Commercial Register, George Bergmann is no longer the managing director of the CSP eMoore N.V. Please remove his role in the portal accordingly.

Done.
[Sarah Cathalina-Labbe - 16-04-2026 18:49]
Jared Vivas - Personal History Disclosure SHORT FormMiscellaneousCriticalDue Apr 13, 2026

Please add Jared Vivas to the portal and submit the Personal History Disclosure SHORT Form in this application.

Please add Jared Vivas to the portal and submit the Personal History Disclosure SHORT Form in this application.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 18:56]
Jared Vivas - Personal History Disclosure FormMiscellaneousCriticalDue Apr 13, 2026

Please upload the Personal History Disclosure Form in the base application QPA/2026/04704.

Please upload the <u>Personal History Disclosure Form (long form)</u> in the <u><b>base application QPA/2026/04704</b></u>.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:07]
Jared Vivas - Criminal RecordCriminal RecordCriticalDue Apr 13, 2026

Please upload a certified true copy of a criminal record in the base application QPA/2026/04704. The criminal record must have been issued within the last six months and certified as a true copy. If the criminal record is not in English, an English translation certified by the translator must also be submitted. Please note that a criminal record is required for every jurisdiction where the person has lived for more than six months in the last two years.

<p>Please upload a certified true copy of a criminal record in the<b><u> base application QPA/2026/04704</u></b>. The criminal record must have been issued within the last six months and certified as a true copy. If the criminal record is not in English, an English translation certified by the translator must also be submitted. </p><p><i>Please note that a criminal record is required for every jurisdiction where the person has lived for more than six months in the last two years.</i></p>

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:11]
Jared Vivas - Bank Reference LetterReference LetterCriticalDue Apr 13, 2026

Please submit a certified true copy of a bank reference letter in the base application QPA/2026/04704. The bank reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Please submit a certified true copy of a bank reference letter in the <b><u>base application QPA/2026/04704</u></b>. The bank reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:19]
Stefanie Knoester - Personal History Disclosure SHORT FormMiscellaneousCriticalDue Apr 13, 2026

Please add Stefanie Knoester to the portal and submit the Personal History Disclosure SHORT Form in this application.

Please add Stefanie Knoester to the portal and submit the Personal History Disclosure SHORT Form in this application.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:26]
Stefanie Knoester - Personal History Disclosure FormMiscellaneousCriticalDue Apr 13, 2026

Please upload the Personal History Disclosure Form in the base application QPA/2026/04634.

Please upload the Personal History Disclosure Form in the <b><u>base application QPA/2026/04634</u></b>.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:30]
Stefanie Knoester - Criminal RecordCriminal RecordCriticalDue Apr 13, 2026

The criminal record submitted in the base application QPA/2026/04634 cannot be accepted because it was issued more than six months ago.

<p>The criminal record submitted in the base application QPA/2026/04634 cannot be accepted because it was issued more than six months ago.</p><p>The criminal record uploaded in the base application is for Malta, however, the proof of address document  uploaded in the base application is for Curaçao. If Stefanie Knoester currently lives in Curaçao and has also lived in Malta for more than six months in the last two years, a criminal record is required for both jurisdictions. </p><p><b style="">Please submit in the <u>base application QPA/2026/04634:</u></b></p><ol><li>A <u>certified true copy</u> of a criminal record for every jurisdiction where Stefanie Knoester has lived for more than six months in the last two years. </li><li>If the criminal record is not in English, an English translation <u>certified by the translator</u>.</li></ol><p><b><u>UPDATE</u></b></p><p>The certified criminal record for Curaçao was received in the base application. </p><p><b><u>Please submit</u></b> a certified copy of a criminal record for Malta issued within the last 6 months and certified as a true copy.</p>

Completed.
[Sarah Cathalina-Labbe - 29-04-2026 18:22]
Stefanie Knoester - Bank Reference LetterReference LetterCriticalDue Apr 13, 2026

Please submit a certified true copy of a bank reference letter in the base application QPA/2026/04634. The bank reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Please submit a certified true copy of a bank reference letter in the <b><u>base application QPA/2026/04634</u></b>. The bank reference letter must be on bank letterhead, must have been issued within the last six months, and must be certified as a true copy.

Completed.
[Sarah Cathalina-Labbe - 16-04-2026 19:37]
Murat Ceylan - Managing DirectorMiscellaneousCriticalDue May 27, 2026

As per the business plan, Murat Ceylan is the managing director. Please add him to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

As per the business plan, Murat Ceylan is the managing director. Please add him to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

No longer applicable.
[Sarah Cathalina-Labbe - 01-06-2026 15:56]
Janus Pienaar - CTOMiscellaneousCriticalDue May 27, 2026

Please add the CTO Janus Pienaar to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

Please add the CTO Janus Pienaar to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

No longer applicable.
[Sarah Cathalina-Labbe - 01-06-2026 16:00]
Ali Inal - CIOMiscellaneousCriticalDue May 27, 2026

Please add the CIO Ali Inal to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

Please add the CIO Ali Inal to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

No longer applicable.
[Sarah Cathalina-Labbe - 01-06-2026 16:01]
Christo Bezuidenhout - CPOMiscellaneousCriticalDue May 27, 2026

Please add the CPO Christo Bezuidenhout to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

Please add the CPO Christo Bezuidenhout to the portal and upload the Personal History Disclosure Form and all enclosures (with the exception of source of wealth).

No longer applicable.
[Sarah Cathalina-Labbe - 01-06-2026 16:01]
Compliance OfficerMiscellaneousCriticalDue May 27, 2026

Please add the Compliance Officer to the portal and submit the Personal History Disclosure Form, enclosures, letter of engagement (signed by the Compliance Officer and the Managing Director), and Curriculum Vitae (CV). Appointment of a compliance officer is mandatory. 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>Please add the Compliance Officer to the portal and submit the Personal History Disclosure Form, enclosures, letter of engagement (signed by the Compliance Officer and the Managing Director), and Curriculum Vitae (CV). Appointment of a compliance officer is mandatory.</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 uploaded in the base application.</i></p>

Closed - applicant has switched to B2B.
[Sarah Cathalina-Labbe - 13-05-2026 13:46]
Business PlanBusiness PlanCriticalDue May 27, 2026

In accordance with your request, submitted via ticket SP-26641 on May 11, 2026, to change the application type to B2B, please submit an updated business plan reflecting B2B operations.

In accordance with your request, submitted via ticket SP-26641 on May 11, 2026, to change the application type to B2B, please submit an updated business plan reflecting B2B operations.

Completed.
[Sarah Cathalina-Labbe - 29-05-2026 15:17]
Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jun 25, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jun 25, 2026

List Position:

Native NameQuestionCriticalDue Jun 25, 2026

Please list the native name.

PHDFQuestionCriticalDue Jun 25, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jun 25, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jun 25, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jun 25, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue Jun 25, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jun 25, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jun 25, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jun 25, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jun 25, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jun 25, 2026

List Position:

Native NameQuestionCriticalDue Jun 25, 2026

Please list the native name.

PHDFQuestionCriticalDue Jun 25, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jun 25, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jun 25, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jun 25, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue Jun 25, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jun 25, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jun 25, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jun 25, 2026

Add the URL and give a small summary.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jun 25, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jun 25, 2026

List Position:

Native NameQuestionCriticalDue Jun 25, 2026

Please list the native name.

PHDFQuestionCriticalDue Jun 25, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jun 25, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jun 25, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Proof of AddressQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

Reference LetterQuestionCriticalDue Jun 25, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jun 25, 2026

Approved, or if not, list why.

Letter of EngagementQuestionMediumDue Jun 25, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jun 25, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jun 25, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jun 25, 2026

Add the URL and give a small summary.