#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Code Harbor N.V.

Gaming OperatorRegistered January 24, 2024
1
Applications
3
Domains
12
Related Entities
0
Locations

OGL/2024/486/0261

Granted
Submitted: November 4, 2024End Date: November 26, 2024

Customer

Contact
Roland De Mei
Email
codeharbornv@relianceassociates.biz
Company
Code Harbor N.V.

Review Timeline

Verification
RTRowenne Tweed (GCB User 4)
Background Check
RTRowenne Tweed (GCB User 4)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
LCLuca Camilleri (LC)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
CHCeline Houareau (CLHR)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
JLJulivienne Leito (JL)
Conditionally Issued
HSHilary Stewart Jones (HSJ)

Compliance Checklists

Application Verification ReviewCritical5 items
Jonathan HeymansCriminal RecordCriticalDue Aug 1, 2024

The enclosed criminal record of Jonathan Heymans is expired.

Kindly resubmit a valid criminal record of Jonathan Heymans no older than six months.

Jonathan HeymansBirth CertificateCriticalDue Aug 1, 2024

The enclosed document provided as Certified True Copy of Birth Certificate is not valid.

Kindly submit Certified True Copy of Birth Certificate.

Jonathan HeymansMiscellaneousCriticalDue Aug 1, 2024

The enclosed document provided as Reference Letter is not valid.

Kindly submit a valid Bank reference letter no older than six months.

Jonathan HeymansSource of WealthCriticalDue Aug 1, 2024

The enclosed document provided as Source of Wealth is not valid.

Kindly submit a valid Source of Wealth no older than six months.

Online Gaming Application Form - PAGE 6: QUESTION 39QuestionMinorDue Sep 30, 2024

PAGE 6: QUESTION 39: The email address must be the same as that of the portal user. Kindly change the email address and resubmit the form.

PAGE 6: QUESTION 39: The email address must be the same as that of the portal user. Kindly change the email address and resubmit the form.

Application Due Diligence ReviewCritical8 items
Monitor - QPA/2024/00208 - Andrii Pozdniakov - SOWSource of WealthCriticalDue Nov 6, 2024

We would require tax returns from the most recent two years, rather than those from five or six years ago. It is important that all SOWs be certified.

We would require tax returns from the most recent two years, rather than those from five or six years ago. It is important that all SOWs be certified.

Customer Reply no updated tax returns can be provided, alternative SOW will be uploaded. Not yet uploaded please monitor
Share Ledger CertificationShare LedgerLowDue Oct 22, 2024

The share ledger submitted is uncertified. Resubmit certified.

The share ledger submitted is uncertified. Resubmit certified.

Director's Register CertificationDirector's ListLowDue Oct 22, 2024

The director's register submitted is uncertified. Resubmit certified.

The director's register submitted is uncertified. Resubmit certified.

Source of Funds of BusinessSource of FundsCriticalDue Nov 6, 2024

Submit documentation as to how the business is/will be funded and by whom, including any declarations deemed necessary and/or documents showing funding/loans by the shareholder or third parties.

Submit documentation as to how the business is/will be funded and by whom, including any declarations and/or documents showing funding/loans by the shareholder or third parties.

Customer Reply The source of funds deposited under the management of Concord Capital Investment Company is income from the video terminal business generated during 2010-2019. All tax returns in English, certified - were provided in March 2024 when applying to GCB. The total amount of income for 2010-2019 is about 1.8 million euros (calculation based on declarations in Excel file, I have attached for your reference). In 2019, the VLT business and the UBO private entrepreneur with it were closed, so there are no updated tax returns for them. 2) The source of funds in the account is the return of previously invested funds + income from Concord Capital Investment Company. I will attach here agreements with attachments, as well as confirmation of a bank transfer of this amount to an account in Accordbank. The funds were invested in December 2019, returned – August 2023: - Asset management agreement + annex 1 - showing that there was an investment of 3 900 000 UAH (approx. 87000 EUR) from Mr.Pozdniakov side. - Summary report of the manager (under the Asset management agreement) - showing the portfolio structure and the value of assets as of August 2023 + the total value in cash (7 234 803 UAH) to be transferred to the truster (Mr. Pozdniakov) - Personal Account statement - showing the transfer of 7 234 803 UAH (approx 161 000 Eur) from the accumulated assets value.
Business Plan Financial projectionsSource of FundsCriticalDue Nov 6, 2024

Kindly submit detailed 3 year financial projections (not just one), which also include the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider.

Kindly submit detailed 3 year financial projections (not just one), which also include the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider.

Customer Reply updated business plan is updated in the portal
Compliance OfficerMiscellaneousCriticalDue Oct 22, 2024

The applicant is required to identify a compliance officer, fluent in AML and to submit their PHDF

The applicant is required to identify a compliance officer, fluent in AML and to submit their PHDF

Underage PlayersPlayer RegistrationCriticalDue Nov 13, 2024

The registration form does not require the user's DOB and a sentence confirming the user is over 18 and accepting the T&Cs is ticked by default. The registration form should cater for underage players.

The registration form does not require the user's DOB and a sentence confirming the user is over 18 and accepting the T&Cs is ticked by default. The registration form should cater for underage players.

Customer Reply the registration page has been updated accordingly.
Prohibited JurisdictionsQuestionCriticalDue Nov 13, 2024

The Terms & Conditions only mention prohibited jurisdictions as dictated by each game provider, however there is no general list of prohibited jurisdictions for the website. Users from Curacao, The Netherlands, US and sanctioned/blacklisted jurisdictions should be prohibited from registering and using the website.

The Terms & Conditions only mention prohibited jurisdictions as dictated by each game provider, however there is no general list of prohibited jurisdictions for the website. Users from Curacao, The Netherlands, US and sanctioned/blacklisted jurisdictions should be prohibited from registering and using the website.

Customer Reply the registration page has been updated accordingly. Confirmed. To be tested again during audit.