Atlas Tech Solutions B.V.
OGL/2024/457/0562
GrantedCustomer
- Contact
- Rudsel Lucas
- sadekya.fiu.0.03@gmail.com
- Company
- Atlas Tech Solutions B.V.
Review Timeline
MBMonica Botero (GCB User 7)
PWPhilippe Warzee (PW)
AAAnton Axiaq (AAX)
KMKevin Mallia (KM)
STSarah Tua (ST)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
CCChris Cooke (CC)
CPCedric Pietersz (Managing Director GCB)
CPCedric Pietersz (Managing Director GCB)
JWJulienne Wilsoe (JW)
Compliance Checklists
Application Verification ReviewCritical7 items
Page no.9: The form must be filled in digitally and must be digitally signed by the person submitting the form. Please insert a digital signature and resubmit the form
Page no.9: The form must be filled in digitally and must be digitally signed by the person submitting the form. Please insert a digital signature and resubmit the form
Document is missing
Kindly submit the requested document
Birth Certificate is missing, kindly submit the requested document
Birth Certificate is missing, kindly submit the requested document
Document is outdated (January 2023)
Please submit the requested document
Page no.9: The form must be filled in digitally and must be digitally signed by the person submitting the form. Please insert a digital signature and resubmit the form.
Page no.9: The form must be filled in digitally and must be digitally signed by the person submitting the form. Please insert a digital signature and resubmit the form.
No criminal record is outdated (January 2023), kindly submit an updated document
No criminal record is outdated (January 2023), kindly submit an updated document
Proof of Address is outdated (2023). Kindly submit an updated document
Proof of Address is outdated (2023). Kindly submit an updated document
Application Due Diligence ReviewCritical11 items
The PHDF must be filled out, signed, and verified digitally. Please resubmit.
The PHDF must be filled out, signed, and verified digitally. Please resubmit.
Please provide a certified colour scan of the passport.
Please provide a certified colour scan of the passport.
1. Executive director unverified. Update with executive director shown in curacao commercial register. Submit their PHDF and relevant enclosures. 2. Director's register uncertified. Update and resubmit duly certified. 3. Update corporate structure 4. The two corporate local directors are non-executive. At least one local executive director required. Articles of Incorporation provide that only TSPs shall be non-executive directors. Update AIs to all for executive directors. Update position of at least one local director to executive
1. Executive director unverified. Update with executive director shown in curacao commercial register. Submit their PHDF and relevant enclosures. 2. Director's register uncertified. Update and resubmit duly certified. 3. Update corporate structure 4. The two corporate local directors are non-executive. At least one local executive director required. Articles of Incorporation provide that only TSPs shall be non-executive directors. Update AIs to all for executive directors. Update position of at least one local director to executive
Share ledger is uncertified. Resubmit share ledger, with updates, if any, with a certification not older than 3 months
Share ledger is uncertified. Resubmit share ledger, with updates, if any, with a certification not older than 3 months
Submit full details of key persons involved. Compliance officer is omitted. Submit a management structure showing controls
Submit full details of key persons involved. Compliance officer is omitted. Submit a management structure showing controls
Submit certified documentation as to how the business is funded and by whom, including certified documents which show funding/loans by the shareholder or third parties.
Submit certified documentation as to how the business is funded and by whom, including certified documents which show funding/loans by the shareholder or third parties.
Submit financials in whatever form signed by the director, for year ending 2023 as well as financials as aforesaid, which must not be older than 6 months
Submit financials in whatever form signed by the director, for year ending 2023 as well as financials as aforesaid, which must not be older than 6 months
The registration form does not require the player's name, address or DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.
The registration form does not require the player's name, address or DOB. This information must be collected at the latest prior to the first deposit. Kindly amend.
The AML policy must adhere to Curacao AML laws. Kindly amend.
The AML policy must adhere to Curacao AML laws. Kindly amend.
The applicant has not answered Q16 of the OGLAF. Kindly confirm the location of the servers for the player account management platform, fill in the OGLAF and resubmit.
The applicant has not answered Q16 of the OGLAF. Kindly confirm the location of the servers for the player account management platform, fill in the OGLAF and resubmit.
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.
Responsible GamingCritical21 items
ID verification procedure
The RG policy must outline the procedure carried out by the operator to verify the player's age.
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-keeping
The RG policy must state the operator's record-keeping policy.
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.
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.
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.
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
Establish player profiles to assess risk levels
The RG policy must establish player profiles to assess risk levels
Adopt RBA to determine level of monitoring and intervention
The RG policy must adopt RBA to determine level of monitoring and intervention
Record all RG interactions in PAM system
The RG policy must state that the operators records all RG interactions in the PAM system
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
Operator must offer players option to activate a cooling-off period
The operator must offer players the option to activate a cooling-off period
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
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
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
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
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
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.
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
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 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