#CasinoSecrets

Investigating the Offshore Online Gambling Industry

Before you search

Please read this statement before searching.

The inclusion of a person, company, domain, or other entity in the CasinoSecrets database does not imply illegal or improper conduct. The data was extracted directly from relevant gambling authorities and official registers on the basis of a significant public interest and reflects information available up to August 2026.

Records may be incomplete, outdated, or contain errors from the underlying source systems. Please verify identities using company numbers, addresses, domains, licence details, or other identifying information before drawing conclusions. The database is intended to make information of significant public interest accessible for journalistic and research purposes. Individual records should be understood in the context of the underlying data and the reporting published alongside them.

A2F B.V.

Gaming OperatorRegistered January 4, 2024
1
Applications
18
Domains
9
Related Entities
0
Locations

OGL/2024/298/0109

Granted
Submitted: September 3, 2024End Date: April 14, 2025

Customer

Contact
Rudsel Lucas
Email
s.adekyafiu001@gmail.com
Company
A2F B.V.

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Verification
PWPhilippe Warzee (PW)
Verification
KMKevin Mallia (KM)
Due Diligence
KMKevin Mallia (KM)
Background Check
KMKevin Mallia (KM)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
KMKieran McLean (KMC)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
MMMario Marques Ricardo (CGA User 60)
Conditionally Issued
DIDenneth Isidora (DEI)

Compliance Checklists

Application Verification ReviewCritical18 items
Application formMiscellaneousMinorDue Jul 31, 2024

The application form has parts with ink marks or is handwritten.

Check the form and make sure that it is fully digitally filled.

Page 6 Question 34QuestionMinorDue Jul 31, 2024

The name of the contact person is not correct

Kindly change the name to the appointed contact person and resubmit the form.

Page 6 Question 36QuestionMinorDue Jul 31, 2024

Passport number is incorrect.

Kindly change passport number to that of the contact person as in the portal

Page 6 Question 37QuestionMinorDue Jul 31, 2024

The passport country of issue is not correct.

Kindly Change passport country of issue to that of the contact person in the portal.

Page 6 Question 39QuestionMinorDue Jul 31, 2024

The email address is not correct.

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

Page 6 Question 38QuestionMinorDue Jul 31, 2024

The address is not correct.

Kindly change the address to that of the contact person

Page 7 Declaration and Data PrivacyMiscellaneousCriticalDue Jul 17, 2024

The name and sign is not correct.

Change to the name and sign of the contact person.

Handwritten Application formMiscellaneousMinorDue Jul 31, 2024

The application form has handwritten parts.

The form must be digitally filled. Kindly fill in and resubmit.

Polbra Holdings - Share LedgerShare LedgerCriticalDue Jul 17, 2024

Share ledger of Polbra Holdings Limited has not been provided.

Kindly submit the Share Ledger of Polcra Holdings Limited.

Polbra Holdings Limited - Directors ListDirector's ListCriticalDue Jul 17, 2024

Directors List of Polbra Holdings Limited has not been provided

Kindly submit directors list of Polbra Holdings Limited.

Marcin WasikMiscellaneousCriticalDue Jul 17, 2024

Application number is handwritten.

Kindly resubmit the application form digitally filled.

Adriano Von Pfuhl RodriguesMiscellaneousMinorDue Jul 31, 2024

Application has handwritten sections

Kindly resubmit the form digitally

Adriano Von Pfuhl RodriguesQuestionMinorDue Jul 31, 2024

Page 2 Question 13: Response to Question 13 is missing.

Kindly complete question 13 and resubmit the form.

Rishabh SharmaCriminal RecordMinorDue Jul 31, 2024

The enclosed criminal record is not valid.

Kindly resubmit a valid (within last six months) criminal record certificate.

Rishabh SharmaMiscellaneousCriticalDue Jul 17, 2024

Personal History Disclosure form has handwritten sections.

Kindly resubmit the form without handwritten information or marks.

Rishabh SharmaMiscellaneousCriticalDue Jul 31, 2024

Personal History Disclosure form has handwritten sections.

Kindly resubmit the form without handwritten information or marks.

Adriano Von Pfuhl RodriguesQuestionMinorDue Jul 31, 2024

Page 2 question 17: The form has the incorrect passport date of issue.

Kindly correct and resubmit the form.

Adriano Von Pfuhl RodriguesQuestionMinorDue Jul 31, 2024

Page 2 question 18: The form has the incorrect passport date of expiry.

Kindly correct and resubmit the form.

Application Due Diligence ReviewCritical0 items
Application Due Diligence ReviewCritical18 items
QPA/2024/01626 - Rishabh Sharma - PHDFMiscellaneousCriticalDue Dec 12, 2024

The PHDF must be filled out, signed and verified digitally. Please resubmit.

The PHDF must be filled out, signed and verified digitally. Please resubmit.

QPA/2024/01629 - Adriano Von Pfuhl Rodrigues - PHDFMiscellaneousCriticalDue Dec 12, 2024

The PHDF must be filled out, signed and verified digitally. Please resubmit.

The PHDF must be filled out, signed and verified digitally. Please resubmit.

QPA/2024/01629 - Adriano Von Pfuhl Rodrigues - Birth CertificateMiscellaneousCriticalDue Dec 12, 2024

Translation of the birth certificate and an improved scan .

Translation of the birth certificate and an improved scan .

QPA/2024/01629 - Adriano Von Pfuhl Rodrigues - SOWSource of WealthCriticalDue Dec 12, 2024

SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.

<p class="MsoNormal">SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.<o:p></o:p></p>

QPA/2024/01635 - Marcin Wasik - PHDFMiscellaneousCriticalDue Dec 12, 2024

The PHDF must be signed and verified digitally. Please resubmit.

The PHDF must be signed and verified digitally. Please resubmit.

QPA/2024/01635 - Marcin Wasik - Birth certificate & Criminal recordMiscellaneousCriticalDue Dec 12, 2024

Please translate these two certificates and upload.

Please translate these two certificates and upload.

QPA/2024/01635 - Marcin Wasik - SOWSource of WealthCriticalDue Dec 12, 2024

SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.

SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.

Share Ledger CertificationShare LedgerMediumDue Jan 27, 2025

The share ledger certification is outdated. Provide the share ledger of the applicant company with a recent certifiction.

The share ledger certification is outdated. Provide the share ledger of the applicant company with a recent certification.

Director's RegisterDirector's ListHighDue Jan 27, 2025

The director's register is outdated, including its certification. Submit a certified copy of a recent extract from the commercial register of curacao clearly indicating the directors of the company.

The director's register is outdated, including its certification. Submit a certified copy of a recent extract from the Curacao commercial register clearly indicating the directors of the company.

Financial StatementsFinancial AuditCriticalDue Jan 27, 2025

Submit FS for year ending 2023 and management accounts for year ending 2024.

Submit FS for year ending 2023 and management accounts for year ending 2024.

Polbra Holdings LtdShare LedgerCriticalDue Dec 1, 2025

Submit a certified copy of the following documents in relation to the above captioned company: 1. Articles of Association 2. Director's ledger 3. Share ledger, clearly identifying the UBOs and their % share holding.

Submit a certified copy of the following documents in relation to the above captioned company: 1. Articles of Association 2. Director's ledger 3. Share ledger, clearly identifying the UBOs and their % share holding.

Customer Reply This has been submitted through a ticket item (item #SP-11057) Dear RCL Team, please review items in said ticket, as client was not able to upload accordingly despite request. PHDF + enclosures requested on local Director to Polbra Holdings RCL: It is a necessity that the documents are uploaded in the portal. Kindly ensure that the applicant is marked 'On Hold' and request that the documents are uploaded once again in the portal (Note, that if the application is not pressed to 'On Hold' , applicant is unable to upload the documents. In the meantime RCL has reviewed the docs in the tkt and they are in order (But cannot be accepted, since not in portal). To be noted that director of Hold Co Polbra, Charalambos Herodotou is to submit PHDSF
Articles of IncorporationArticles of IncorporationMediumDue Jan 27, 2025

Resubmit the AIs of the applicant company, with a certification which is no older than 6 months.

Resubmit the AIs of the applicant company, with a certification which is no older than 6 months.

Prohibited & Sanctioned CountiresProhibiited CountriesCriticalDue Jan 30, 2025

Prohibited countries found in registration page . Please ensure Netherlands, Curacao residents are and USA are not allowed to register together with sanctioned countries.

Prohibited countries found in registration page . Please ensure Netherlands, Curacao residents are and USA are not allowed to register together with sanctioned countries.

Master LicenseMiscellaneousCriticalDue Jan 30, 2025

Some Terms relate to Antiliphone license please amend to remove accordingly.

Some Terms relate to Antiliphone license please amend to remove accordingly.

Closed as no longer required
Company informationMiscellaneousCriticalDue Jan 30, 2025

No company details on approved domains. Please include company name, address and license number on each domain.

No company details on approved domains. Please include company name, address and license number on each domain.

Terms and ConditionsMiscellaneousCriticalDue Jan 30, 2025

Enhance Terms and conditions to reflect AML requirements in Curacao.

Enhance Terms and conditions to reflect AML requirements in Curacao.

Responsible GamingMiscellaneousCriticalDue Jan 30, 2025

Please include responsible Gaming information, Over 18 banner and links to RG associations on all websites falling under the company.

Please include responsible Gaming information, Over 18 banner and links to RG associations on all websites falling under the company.

Self ExclusionQuestionCriticalDue Jan 30, 2025

Please inform how players are able to self exclude.

Please inform how players are able to self exclude.

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 19, 2026

ID verification procedure

The RG policy must outline the procedure carried out by the operator to verify the player's age.

Account closure procedurePolicy DocumentCriticalDue May 19, 2026

Account closure procedure upon the operator becoming aware that the player is a minor post-registration.

The RG policy must outline the procedure for post-registration account closure upon the operator becoming aware that the player is a minor.

Record-keepingPolicy DocumentCriticalDue May 19, 2026

Record-keeping

The RG policy must state the operator's record-keeping policy.

Contacting the operatorPolicy DocumentCriticalDue May 19, 2026

Procedure on how the player can contact the operator regarding RG concerns via email or chat

The RG policy must describe the procedure for how the player can contact the operator regarding RG concerns via email or chat.

LanguagePolicy DocumentCriticalDue May 19, 2026

Must be available in English and target market language

The RG page/policy must be available in English and the site's target market language.

Vulnerable gamblersPolicy DocumentCriticalDue May 19, 2026

RG policy should include a structured process on flagging potential vulnerable gamblers

The RG policy must include a structured process on flagging potential vulnerable gamblers.

Indicators of problem gamblingPolicy DocumentCriticalDue May 19, 2026

Must have a structured process for responding to indicators of problem gambling

The RG policy must contain a structured process for responding to indicators of problem gambling. The key monitoring factors include: - Deposit and wagering frequency - Repeated failed transactions due to insufficient funds - Reversing withdrawals - A pattern of inexplicable extended play sessions - Unreasonable increased communication with customer support, including requests for bonuses - Frequent changes to RG tools - Players maxing out a credit card - Attempts to open multiple accounts to bypass deposit or loss limits

Player profiling and Risk AssessmentPolicy DocumentCriticalDue May 19, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue May 19, 2026

Adopt RBA to determine level of monitoring and intervention

The RG policy must adopt RBA to determine level of monitoring and intervention

Recording RG interactionsPolicy DocumentCriticalDue May 19, 2026

Record all RG interactions in PAM system

The RG policy must state that the operators records all RG interactions in the PAM system

Identification of vulnerable personsPolicy DocumentCriticalDue May 19, 2026

Procedure to follow for players identified as vulnerable persons

The RG policy must define the procedure to be followed for players identified as vulnerable persons

Cooling-off periodPolicy DocumentCriticalDue May 19, 2026

Operator must offer players option to activate a cooling-off period

The operator must offer players the option to activate a cooling-off period

Cooling-off optionsPolicy DocumentCriticalDue May 19, 2026

Options for cooling-off must include duration and marketing opt-out at minimum

The options for cooling-off may include Duration, brand, vertical and marketing, of which the duration and marketing opt-out are mandatory. Furthermore, the duration must be for a minimum of at least 24 hours

Self-ExclusionPolicy DocumentCriticalDue May 19, 2026

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Operator must offer players the option to self-exclude themselves for a duration of at least 1 year

Deposit LimitsPolicy DocumentCriticalDue May 19, 2026

Players must be able to set limits on the total amount they deposit

Players must be able to set limits on the total amount they deposit

Training and Staff ReadinessPolicy DocumentCriticalDue May 19, 2026

Operators must train customer service and Responsible Gaming staff to handle player interaction profesionally and effectively

Training should cover, at least: - Recognizing signs of gambling distress - Conducting sensitive and structured conversations with at-risk players - Directing players to appropriate support resources and RG tools

Consumer Advertising and MarketingPolicy DocumentCriticalDue May 19, 2026

Operators must not engage in irresponsible advertising

The RG policy must state that the operator must not engage in irresponsible advertising, including: - No targeting of Vulnerable Groups - No portrayal of Gambling as an Investment - No misrepresentation of Skill vs Chance - No Emotional Manipulation - Marketing materials must not feature minors or depict them engaging with gambling content - No explicit content - No encouragement of Unrelated Harmful Behaviours - Bonuses and promotions must be communicated transparently - Operators must not use bonuses to encourage excessive gambling - Operator is responsible for materials provided to affiliates, representatives, sponsorships, ambassadors, social media influencers - Operator must make any contracted third-party aware of their RG policy - All advertising must include a clearly visible RG message or slogan

Internet Filtering ToolsPolicy DocumentLowDue May 19, 2026

The operator is advised to remind adults that they should take precautions when sharing devices with minors

The operator is advised to remind adults that they should take precautions when sharing devices with minors, such as safeguarding usernames, passwords and payment details.

Notifications for concerning behavioursPolicy DocumentHighDue May 19, 2026

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

Operators may employ automatic or manual pop-up notifications in response to concerning behaviours

Initiating direct contactPolicy DocumentCriticalDue May 19, 2026

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

When a player exhibits behaviour that reasonably suggests they may be a Vulnerable Player, the operator must initiate direct contact

Other LimitsPolicy DocumentHighDue May 19, 2026

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market

Other limits may be considered including loss limits, time limits or wager limits, in line wth the operator's target player and/or market