#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Kromstex B.V

Gaming OperatorRegistered January 4, 2024
2
Applications
3
Domains
16
Related Entities
0
Locations
OGL/2024/313/0336NewOGL/2024/313/0337Granted

OGL/2024/313/0337

Granted
Submitted: April 24, 2024End Date: September 9, 2024

Customer

Contact
Rudsel Lucas
Email
sadeky.a.fiu003@gmail.com
Company
Kromstex B.V

Review Timeline

Verification
MBMonica Botero (GCB User 7)
Due Diligence
MBMonica Botero (GCB User 7)
Due Diligence
STSarah Tua (ST)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
KMKieran McLean (KMC)
Suitability
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DIDenneth Isidora (DEI)
Fully Issued
DIDenneth Isidora (DEI)

Compliance Checklists

Application Verification ReviewCritical5 items
Question no. 19QuestionMinorDue Jul 31, 2024

Answer is missing

Kindly tick an option

Page no. 7MiscellaneousCriticalDue Jul 31, 2024

Missing name and signature

Kindly Insert name and signature

Financial StatementsFinancial AuditCriticalDue Jul 31, 2024

Document is missing

Kindly submit the requested document

Oksana PonomarenkoSource of FundsCriticalDue Jul 31, 2024

The provided document belongs to another UBO

Kindly provide the requested document

Dear RCL, It is unclear what documents is referred in this request. The operator seems to have provided all the required documents
Oksana PonomarenkoMiscellaneousCriticalDue Jul 31, 2024

Document is missing

Kindly submit the requested document

Dear RCL, It is unclear what documents is referred in this request. The operator seems to have provided all the required documents
Application Due Diligence ReviewCritical8 items
Share Ledger CertificationShare LedgerCriticalDue Aug 18, 2025

The share ledger submitted is uncertified. Resubmit duly certified.

<p>The share ledger submitted is uncertified. </p><p>The document is required to be certified as a true copy of the original by an independent professional.  Certify and resubmit</p>

11 Aug 2025: Dear RCL Team, See below feedback. The company seems to have submitted a certified copy of the document. Please review and update this item. Customer Reply: A certified share register has been uploaded
Business PlanBusiness PlanCriticalDue Aug 6, 2024

The organisational structure shows the UBO as a director of the company and also responsible KYC/AML. The UBO and AML roles are conflicting. Another compliance officer, fluent in AML, is required to be appointed and to submit their personal history and disclosure form.

The organisational structure shows the UBO as the director of the company and also responsible for KYC/AML. The UBO and AML roles are conflicting. Another compliance officer, fluent in AML, is required to be appointed and to submit their personal history and disclosure form.

Source of Funds of BusinessSource of FundsCriticalDue Aug 18, 2025

The SOF document submitted is invalid. Kindly resubmit an updated SOF document with updated details of the applicant company and the UBO.Also please submit any loan agreements or financial agreements in the event of a shortfall in funds.

please submit any loan agreements or financial agreements in the event of a shortfall in funds.

11 Aug 2025: Dear RCL, Please check if the documents provided by the applicant is sufficient. Customer Reply: A loan agreement between the UBO (Oksana Ponomarenko) and the company (Kromstex) has been submitted. RCL: An uncertified loan agreement for Eur 100,000 has been submitted. No FS/documentati0on in the event of a shortfall in funds has been provided. In LC on SOF/W applicant has provided an explanatory note on this. The SLA should be certified. Otherwise this CL can be closed.
Compliance OfficerOperationsCriticalDue Aug 18, 2025

The compliance officer is representing a number of other entities. Please advise how he will be overlooking such operations.

<p>The compliance officer is representing a number of other entities. Please advise how he will be overlooking such operations.</p><p>The organisational chart in the business plan also indicated the UBO as responsible for KYC/AML. This is a conflicting role. Update and resubmit.</p>

Dear RCL Team, The company seems to have appointed a new CCO. Please review and get back to the company. Customer Reply Dear Sirs, Many businesses outsource specific duties to specialized businesses. We would like to let you know that the Gaming Companies have outsourced the compliance services to Mr. Sergey Volf who is the Chief of Compliance of the outsourced company. As a result, Mr. Sergey Volf is the head of the Compliance Team, which in turn manages the compliance operations for numerous online casinos. Furthermore, an amended version of the business plan has been uploaded for your review.
AML policyMiscellaneousCriticalDue Aug 18, 2025

AML Policy relates to EU law this must be updated to reflect Curacao Obligations.

AML Policy relates to EU law this must be updated to reflect Curacao Obligations.

11 Aug 2025: Dear RCL Team, Please review the AML Policy provided by the company and update the item! Customer Reply Dear Sirs, The client has received the new AML regulation of Curacao just recently and are diligently amending their policies to reflect these accordingly.
Sanctioned CountriesPlayer AccountCriticalDue Aug 18, 2025

Registration allows for sanctioned countries together with no age verification. Please advise how players are verified.

Registration allows for sanctioned countries together with no age verification. Please advise how players are verified.

Dear RCL Team, Please check if the respond from the company is sufficient and update the item! Customer Reply Dear Sirs, When registering, both the date of both and country (and personal address) are required KM 18/11 response sufficient and verified online.,
Financial StatementsFinancial AuditCriticalDue Nov 21, 2025

Submit financial statements for year ending 2023.

<p>Submit financial statements for year ending 2023.</p><p>Update 17/11/2025:</p><p>The FS for 2024 were uploaded but are not signed. Please upload the signed FS 2024.</p>

11 Aug 2025: Dear RCL, Please review the financial Statement provided by the company! Customer Reply: Financial statements have been uploaded RCL: Clarify. FS are not uploaded on portal RCL Note 17/11/2025: FS 2024 uploaded but not signed. Checklist re-opened.
QPA/2024/02751 - Inna Honcharuk - CVCuriculum VitaeCriticalDue Dec 22, 2025

Please upload the CV for the compliance officer.

Please upload the CV for the compliance officer.