#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Atlas Tech Solutions B.V.

Gaming OperatorRegistered January 19, 2024
1
Applications
1
Domains
13
Related Entities
0
Locations

OGL/2024/457/0562

Granted
Submitted: October 7, 2024End Date: April 16, 2025

Customer

Contact
Rudsel Lucas
Email
sadekya.fiu.0.03@gmail.com
Company
Atlas Tech Solutions B.V.

Review Timeline

Verification
MBMonica Botero (GCB User 7)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
KMKevin Mallia (KM)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
CCChris Cooke (CC)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
JWJulienne Wilsoe (JW)

Compliance Checklists

Application Verification ReviewCritical7 items
Omar HrikQuestionCriticalDue Aug 5, 2024

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

Omar HrikSource of WealthCriticalDue Aug 5, 2024

Document is missing

Kindly submit the requested document

Omar HrikBirth CertificateCriticalDue Aug 5, 2024

Birth Certificate is missing, kindly submit the requested document

Birth Certificate is missing, kindly submit the requested document

Omar HrikMiscellaneousCriticalDue Aug 5, 2024

Document is outdated (January 2023)

Please submit the requested document

Abdeljalil MouslimMiscellaneousCriticalDue Aug 5, 2024

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.

Omar HrikCriminal RecordCriticalDue Aug 29, 2024

No criminal record is outdated (January 2023), kindly submit an updated document

No criminal record is outdated (January 2023), kindly submit an updated document

Omar HrikProof of AddressCriticalDue Aug 29, 2024

Proof of Address is outdated (2023).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
QPA/2024/00912 - Abdeljalil Mouslim - PHDFQuestionCriticalDue Sep 16, 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/2024/00554 - Omar Hrik - PassportPassportCriticalDue Mar 20, 2025

Please provide a certified colour scan of the passport.

Please provide a certified colour scan of the passport.

director's register and corporate structure and articles of incorporationDirector's ListCriticalDue Mar 20, 2025

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 CertificationShare LedgerCriticalDue Mar 20, 2025

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

Business Plan - organisational structureBusiness PlanCriticalDue Mar 20, 2025

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

Source of funds of businessSource of FundsCriticalDue Mar 20, 2025

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.

Financial StatementsFinancial AuditCriticalDue Mar 20, 2025

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

Player RegistrationPlayer RegistrationCriticalDue Mar 20, 2025

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.

AML PolicyMiscellaneousCriticalDue Mar 20, 2025

The AML policy must adhere to Curacao AML laws. Kindly amend.

The AML policy must adhere to Curacao AML laws. Kindly amend.

Server LocationServer LocationCriticalDue Mar 20, 2025

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.

QPA/2024/00554 - Omar Hrik - SOWSource of WealthCriticalDue Mar 20, 2025

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 procedurePolicy DocumentCriticalDue Jun 4, 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 Jun 4, 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 Jun 4, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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 Jun 4, 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