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Records may be incomplete, outdated, or contain errors from the underlying source systems.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

Rawingo NV

Gaming OperatorRegistered February 20, 2024
2
Applications
4
Domains
7
Related Entities
0
Locations

OGL/2024/682/0178

Rejected
Submitted: March 28, 2024End Date: October 3, 2025

Customer

Contact
Vineta Turkmena
Email
compliance@rawingo.com
Company
Rawingo NV

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Background Check
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
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)

Compliance Checklists

Application Verification ReviewCritical6 items
Online Gaming Application Form - Page 1 Question 1QuestionMinorDue Sep 19, 2024

The Brand Name field is not filled. Kindly fill in Brand Name and resubmit the form.

The Brand Name field is not filled. Kindly fill in Brand Name and resubmit the form.

Online Gaming Application Form - Page 1 Question 3QuestionMinorDue Sep 19, 2024

Page 1: Question 3 is not filled in. Kindly fill in question 3 and resubmit the form.

Page 1: Question 3 is not filled in. Kindly fill in question 3 and resubmit the form.

Online Gaming Application Form - Page 7 Declaration and Data PrivacyMiscellaneousCriticalDue Sep 19, 2024

The name and the signature on the Declaration and Data Privacy is not correct. Kindly change the name and signature to that of portal user and resubmit the form.

The name and signature on the Declaration and Data Privacy is not correct. Kindly change the name and signature  to that of portal user and resubmit the form.

Business and Corporate Information Form - Page 1 Question 4QuestionMinorDue Sep 19, 2024

Company Tax ID Number is not provided. Kindly fill in Company Tax number and resubmit the form.

Company Tax ID Number is not provided. Kindly fill in Company Tax number and resubmit the form.

Frank Lammers - Personal History Disclosure FormMiscellaneousCriticalDue Sep 19, 2024

The Personal History Disclosure of Mr. Frank Lemmers is missing. Kindly submit the Personal History Disclosure.

The Personal History Disclosure  of Mr. Frank Lemmers is missing. Kindly  submit the Personal History Disclosure.

Michael Burford - Birth CertificateBirth CertificateMinorDue Sep 19, 2024

The enclosed birth certificate document is incomplete. Kindly resubmit a birth certificate of Mr. Michael Burford.

The enclosed birth certificate document is incomplete. Kindly resubmit a birth certificate of Mr. Michael Burford.

Application Due Diligence ReviewCritical9 items
QPA/2024/00722 - Michael Guy Burford - SOWSource of WealthCriticalDue Dec 31, 2024

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.

Share LedgerShare LedgerCriticalDue Oct 16, 2024

Submit an update share ledger, which must be duly certified.

Submit an updated share ledger, which must be duly certified.

Financial StatementsFinancial AuditCriticalDue Oct 16, 2024

FS 2021 submitted, is unsigned. Resubmit signed by a director of the company FS 2022 and 2023 not yet submitted. Submit once finalised.

FS 2021 submitted, is unsigned. Resubmit signed by a director of the company FS 2022 and 2023 are missing. Submit once finalised.

DomainsMiscellaneousCriticalDue Dec 31, 2024

The registered domains all seem to be inactive apart from losteden.io. Furthermore, a number of the domains have been registered multiple times. Kindly clarify whether these domains will be used in relation to the company's operations.

The registered domains all seem to be inactive apart from losteden.io. Furthermore, a number of the domains have been registered multiple times. Kindly clarify whether these domains will be used in relation to the company's operations.

Player RegistrationPlayer RegistrationCriticalDue Dec 31, 2024

The registration form does not require the user's name, address, country or DOB. This information must be collected prior to the first deposit at the very latest.

The registration form does not require the user's name, address, country or DOB. This information must be collected prior to the first deposit at the very latest.

Company DetailsOperationsCriticalDue Dec 31, 2024

The site footer refers to a Curacao company, Lost Eden B.V. which is not the applicant entity. Furthermore, the T&Cs refer to another Curacao company, Jack's House B.V. and make further reference to a domain jackshouse.com, which is not the domain on which the T&Cs are published, and neither is the domain registered under the applicant. Kindly clarify and amend.

The site footer refers to a Curacao company, Lost Eden B.V. which is not the applicant entity. Furthermore, the T&Cs refer to another Curacao company, Jack's House B.V. and make further reference to a domain jackshouse.com, which is not the domain on which the T&Cs are published, and neither is the domain registered under the applicant. Kindly clarify and amend.

Player Account & Funds ManagementOperationsCriticalDue Dec 31, 2024

The applicant indicate in the OGLAF that the player account and funds management is carried out by a 3rd party. The 3rd party was not identified neither in the OGLAF or the BP and it was not specified whether they are licensed in any jurisdiction. Kindly submit the agreement for this service.

The applicant indicate in the OGLAF that the player account and funds management is carried out by a 3rd party. The 3rd party was not identified neither in the OGLAF or the BP and it was not specified whether they are licensed in any jurisdiction. Kindly submit the agreement for this service.

Business ModelOperationsCriticalDue Dec 31, 2024

The applicant indicate in the OGLAF that its business model is that of a B2C (including white labelling sites) and B2B (game supply). 1. Kindly indicate whether the applicant intends to operate both a B2C operation and a B2B2C (white labelling) operation. 2. It was noted that although the applicant indicated it is applying for a B2B (game supply) license, it also indicated that it does not own any of the games. Please clarify what B2B service the company intends to offer.

The applicant indicate in the OGLAF that its business model is that of a B2C (including white labelling sites) and B2B (game supply). 1. Kindly indicate whether the applicant intends to operate both a B2C operation and a B2B2C (white labelling) operation. 2. It was noted that although the applicant indicated it is applying for a B2B (game supply) license, it also indicated that it does not own any of the games. Please clarify what B2B service the company intends to offer.

AML PolicyMiscellaneousCriticalDue Dec 31, 2024

Although the applicant indicate that it has an AML policy in place, it was not available on the website. Kindly submit an AML policy compliant with Curacao AML laws.

Although the applicant indicate that it has an AML policy in place, it was not available on the website. Kindly submit an AML policy compliant with Curacao AML laws.