#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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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Records may be incomplete, outdated, or contain errors from the underlying source systems.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.

Complex Technologies B.V.

Gaming OperatorRegistered January 8, 2024
1
Applications
1
Domains
12
Related Entities
0
Locations

OGL/2024/334/0243

Granted
Submitted: December 3, 2024End Date: December 24, 2024

Customer

Contact
Rudsel Lucas
Email
sadeky.afiu.0.0.2@gmail.com
Company
Complex Technologies B.V.

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Ended May 11, 2024
Background Check
SMSaura Maurera (CGA user 5)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
GCGerald Chocolaad (CGA User 25)
Conditionally Issued
HSHilary Stewart Jones (HSJ)

Compliance Checklists

Application Verification ReviewCritical13 items
Question 36: Passport number contact personQuestionLowDue Sep 18, 2024

The passport number is not correct. Kindly fill in passport number of the portal user and resubmit the form.

The passport number is not correct. Kindly fill in passport number of the portal user and resubmit the form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:33]
Question 37: Passport country of issue contact personQuestionMinorDue Sep 18, 2024

The passport country of issue is not correct. Kindly fill in the passport number of the portal user and resubmit the form.

The passport country of issue is not correct. Kindly fill in the passport number of the portal user and resubmit the form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:33]
Question 38: Contact person addressQuestionMinorDue Sep 18, 2024

The contact address is not correct. Kindly fill in the address of the portal user and resubmit the form.

The contact address is not correct. Kindly fill in the address of the portal user and resubmit the form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:33]
Question 39: Email Address portal userQuestionMinorDue Sep 18, 2024

The email address is not correct. The email address must be the same as that of the portal user. Kindly fill in email address and resubmit the form.

The email address is not correct. The email address must be the same as that of the portal user. Kindly fill in email address and resubmit the form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:35]
Declaration and Data Privacy: Name and SignatureMiscellaneousCriticalDue Sep 18, 2024

The name and signature of the contact person is not correct. The name of the contact person must be the same as the portal. Kindly fill in and signed the Declaration and Data Privacy and resubmit the Form.

The name and signature of the contact person is not correct. The name of the contact person must be the same as the portal. Kindly fill in and signed the Declaration and Data Privacy and resubmit the Form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:35]
Pavlo Cherepenchuk: Date of BirthQuestionCriticalDue Sep 18, 2024

Question 6. The Date Of Birth can not be verified because the copy of passport is not clear. Kindly resubmit a clear copy of the passport.

Question 6. The Date Of Birth can not be verified because the copy of passport is not clear. Kindly resubmit a clear copy of the passport.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:36]
Pavlo Cherepenchuk: Civil statusQuestionMinorDue Sep 18, 2024

Question 11. The civil status is not filled. Kindly fill in Question 11 and resubmit the form.

Question 11. The civil status is not filled. Kindly fill in Question 11 and resubmit the form.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:36]
EnclosuresPassportCriticalDue Jul 1, 2024

Passport

The enclosed copy of passport is not clear. Can not be verified. Kindly resubmit a clear Original or Certified True Copy of Passport.

Pavlo Cherepenchuk: PassportPassportCriticalDue Sep 18, 2024

The enclosed copy of passport is not clear. It can not be verified. Kindly resubmit a clear copy of Passport with a clear photo.

The enclosed copy of passport is not clear. It can not be verified. Kindly resubmit a clear copy of Passport with a clear photo.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:37]
Pavlo Cherepenchuk: Criminal RecordCriminal RecordMinorDue Dec 1, 2025

The enclosed Criminal Record is expired. Kindly resubmit a valid criminal record certificate.

<p>11/09/2025: Final reminder: The enclosed criminal record certificate has expired. Kindly resubmit a valid criminal record certificate. Ultimate submission date: November 15, 2025.</p><p>11/24/2025: Dear applicant, we have noticed that you have not acted upon our previous request to resubmit a valid criminal record certificate. Please receive this message as a final reminder that the enclosed certificate has expired. Kindly upload a valid criminal record certificate in the designated section.</p>

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:38]
11/09/2025: Final reminder: The enclosed criminal record certificate has expired. Kindly resubmit a valid criminal record certificate. Ultimate submission date: November 15, 2025.
Pavlo Cherepenchuk: Bank Reference LetterMiscellaneousCriticalDue Dec 1, 2025

The enclosed Bank Reference Letter is expired. Kindly resubmit a valid bank reference letter or bank statement.

<p>The enclosed Bank Reference Letter is expired. Kindly resubmit a valid bank reference letter or bank statement.</p><p>11/09/2025: Final reminder: The enclosed Bank Reference Letter has expired. Please resubmit a recent bank reference letter (not older than 3 months) or a recent bank statement. Submit on or before November 15, 2025. </p><p>11/24/2025: Dear applicant, we have noticed that you have not acted upon our previous request to resubmit a valid Bank Reference Letter. Please receive this message as a final reminder that the enclosed letter has expired. Kindly upload a recent bank reference letter (not older than 3 months) or a recent bank statement in the designated section.</p>

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:38]
11/09/2025: Final reminder: The enclosed Bank Reference Letter has expired. Please resubmit a recent bank reference letter (not older than 3 months) or a recent bank statement. Submit on or before November 15, 2025.
Pavlo Cherepenchuk: Proof of AddressProof of AddressCriticalDue Sep 18, 2024

The enclosed Proof of Address is expired. Kindly resubmit a recent proof of address document or bank statement.

The enclosed Proof of Address is expired. Kindly resubmit a recent proof of address document or bank statement.

Closed due to rejection
[Dennis Engelhardt - 12-05-2026 16:39]
Rudsel LucasCriminal RecordCriticalDue Jul 1, 2024

Criminal record

The enclosed criminal record is missing. Kindly resubmit a valid certificate.

Application Due Diligence ReviewCritical7 items
QPA/2024/00452 - Jekaterina Baranova - PHDFQuestionCriticalDue Nov 9, 2025

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

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

11/02/2025: Applicant`s reply: Jekaterina Baranova has dificulty signing the document digitally, we have attached a digitaly stamped PHDF. 11/02/2025: PHDF contains digitally stamped.
Director's Register CertificationDirector's ListMediumDue Nov 15, 2025

Director's register is uncertified. Resubmit certified.

<p>Director's register is uncertified. Resubmit certified.</p><p>Dear, As mentioned in our correspondance with the GCB. Rudsel Lucas has been approved by the Central Bank to certify company enclosures such as Share registers</p><p>11/02/2025: Please be advised that documents should not be certified by the company’s own managing director. Kindly resubmit the certified Director`s Register at your earliest convenience.</p><p>11/08/2025: Please be advised that the Director's Register is not certified. Please resubmit certified DR. Important Note: The Director's Register must be certified by an independent authorized certifier. An individual involved in the application process may not certify the document, as this could be considered a conflict of interest. Ultimate date to submit: November 15, 2025</p>

11/02/2025: Applicant`s reply: Dear, As mentioned in our correspondance with the GCB. Rudsel Lucas has been approved by the Central Bank to certify company enclosures such as Share registers 11/02/2025: Please be advised that documents should not be certified by the company’s own managing director. Kindly resubmit the certified Director`s Register at your earliest convenience.
Business PlanBusiness PlanCriticalDue Nov 9, 2025

Resubmit business plan to include: Detailed 3 year financial forecasts Management structure with controls and key responsibilities

Resubmit business plan to include: Detailed 3 year financial forecasts Management structure with controls and key responsibilities Provide information about payment gateways, contractual and financial model with key suppliers

11/02/2025: Applicant`s reply: Amended Businessplan is uploaded. 11/02/2025: BP resubmitted for review.
Financial Statements - APPROVEDFinancial AuditCriticalDue Nov 9, 2025

Resubmit FS 2022 duly signed by the directors of the company. Submit FS 2023.

Resubmit FS 2022 duly signed by the directors of the company. Submit FS 2023.

11/02/2025: Applicant`s reply: The Signed F.S for 2023 has been uploaded. 11/02/2025: Signed FS for 2022 has been signed and resubmitted. FS for 2023 has been uploaded for review. RCL Note 12/01/2026: Checklist requirements satisfied. Checklist closed.
Sanctioned / Prohibited CountiresQuestionCriticalDue Nov 9, 2025

Since registration does not require country of registration please advise how players are checked for prohibited and sanctioned countries.

Since registration does not require country of registration please advise how players are checked for prohibited and sanctioned countries.

KYC procedure requested in 2 other checklists . WIll follow reply
[Kevin Mallia - 17-02-2026 14:09]
11/02/2025: Applicant`s reply: Sumsub agreement attached. For player verification, we use this service.
Underage PlayersQuestionCriticalDue Feb 27, 2026

Since no DOB is required at registration stage at what stage are players verified for age identification.

<p>Since no DOB is required at registration stage at what stage are players verified for age identification.</p><p><br></p><p>Please upload Know your client procedure including age verification. </p>

11/02/2025: Applicant`s reply: Sumsub agreement attached. For player verification, we use this service.
RG HelplineMiscellaneousCriticalDue Mar 9, 2026

RG policy states :If you would like to talk to someone here about problem gambling please contact us toll free on 07xxxxxxxx. Please correct accordingly.

<p>RG policy states :If you would like to talk to someone here about problem gambling please contact us toll free on 07xxxxxxxx. Please correct accordingly.</p><p><br></p><p>Website reviewed again and still not updated !</p>

11/02/2025: Applicant`s reply: corrected.