#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Intelligent Innovations N.V.

Gaming OperatorRegistered March 4, 2024
1
Applications
85
Domains
12
Related Entities
0
Locations

OGL/2024/767/0360

Granted
Submitted: October 7, 2024End Date: May 19, 2025

Customer

Contact
George Van Zinnincq Bergmann
Email
intelligentinnov@igamingcompliance.com
Company
Intelligent Innovations N.V.

Review Timeline

Verification
MBMonica Botero (GCB User 7)
Ended Mar 27, 2024
Verification
SMSaura Maurera (CGA user 5)
Due Diligence
MGMario Galea (CGA Admin 1)
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
SBSimon Burden (SMB)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
SPSulmahine Penza-Kwidama (CGA USER 59)

Compliance Checklists

Application Verification ReviewCritical4 items
Page no. 6, question 34QuestionMinorDue Aug 28, 2024

The name is not correct, it should be the same as the one registered as portal administrator.

Kindly insert the correct name and resubmit the form

Page no. 6, question 36QuestionMinorDue Aug 28, 2024

Passport number is missing

Kindly insert the passport number

Page no. 6, question no.37QuestionMinorDue Aug 28, 2024

Country of Issue is missing

Please insert the country of issue

Page no. 7 Declaration and Data PrivacyQuestionCriticalDue Aug 21, 2024

The name is not correct, it should be the same as the one registered as portal administrator

Kindly insert the correct name and resubmit the form

Application Verification StageCritical1 item
PAGE 3: QUESTION 17 - Online Gaming Application FormQuestionCriticalDue Oct 15, 2024

One check box of Question 17 is not filled out. Kindly select the one and specify jurisdiction of Question 17.1 and resubmit the form.

One check box of Question 17 is not filled out. Kindly select the one and specify jurisdiction of Question 17.1 and resubmit the form.

Application Due Diligence ReviewCritical11 items
QPA/2024/00370 - Dmytro Basii - PassportPassportCriticalDue Mar 10, 2025

Please provide a full scan of the bio and first page .

Please provide a full scan of the bio and first page .

QPA/2024/00370 - Dmytro Basii - SOWSource of WealthCriticalDue Apr 21, 2026

SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.

<p>SOW is not valid. Please submit a SOW along with certified supporting evidence in order to support the business.</p><p><br></p><p>SOW not certified. Please certify the SOW as true copy.</p>

QPA/2024/00370 - Dmytro Basii - Criminal RecordCriminal RecordCriticalDue Mar 10, 2025

Please submit a criminal record that is not more than six months old.

Please submit a criminal record that is not more than six months old.

QPA/2024/00370 - Dmytro Basii - SOWSource of WealthCriticalDue Mar 10, 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.

QPA/2024/02350 - George Van Zinnicq Bergmann - PHDFMiscellaneousCriticalDue Mar 10, 2025

The PHDF must be signed and verified digitally. Please resubmit.

The PHDF must be signed and verified digitally. Please resubmit.

Compliance OfficerMiscellaneousCriticalDue Mar 12, 2025

No CO identified. CO, fluent in AML, to submit PHDF and relevant documentation, including a CV and letter of engagement

No CO identified. CO, fluent in AML, to submit PHDF and required documentation, including a CV and letter of engagement

Business and Corporate Information FormMiscellaneousMediumDue Mar 12, 2025

Applicant company was found to exist under a Master license. Amend question 7 accordingly and resubmit form

Applicant company was found to exist under a Master license. Amend question 7 accordingly and resubmit form

local directorDirector's ListCriticalDue Mar 12, 2025

At least one Local director required to be an executive director. Update role in portal

At least one Local director required to be an executive director. Update role in portal

Company DetailsOperationsCriticalDue Mar 13, 2025

The registered domains must be operated by the Curacao registered applicant company and this must be stated correctly in the footer of each domain. Kindly amend.

The registered domains must be operated by the Curacao registered applicant company and this must be stated correctly in the footer of each domain. Kindly amend.

Player RegistrationPlayer RegistrationCriticalDue Mar 13, 2025

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

Prohibited JurisdictionsProhibiited CountriesCriticalDue Mar 13, 2025

Although the registered domains implement geo-blocking for restricted jurisdictions, players on hotspincasino are still allowed to choose Netherlands as their country of residence. Players residing in Curacao, the Netherlands (and any other countries part of the Kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Although the registered domains implement geo-blocking for restricted jurisdictions, players on hotspincasino are still allowed to choose Netherlands as their country of residence. Players residing in Curacao, the Netherlands (and any other countries part of the Kingdom of the Netherlands), USA, UN sanctioned countries and FATF blacklisted countries must not be allowed to register an account. Kindly amend.

Responsible GamingCritical20 items
ID verification procedurePolicy DocumentCriticalDue Apr 30, 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 Apr 30, 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 Apr 30, 2026

Record-keeping

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

LanguagePolicy DocumentCriticalDue Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue Apr 30, 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 May 8, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 Apr 30, 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 May 8, 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 Apr 30, 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 May 8, 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

Player ComplaintsCritical5 items
Recommencing ADR process with a different entityPolicy DocumentCriticalDue May 8, 2026

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

The policy must state that once the ADR process is completed it cannot be recommenced by either the player or the operator with another different ADR entity.

Recommencing dropped ADR processesPolicy DocumentCriticalDue May 8, 2026

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

The policy must state that in the event that the player drops out of the ADR process (but it has already begun) the player should not have the right to resurface the dispute in the future.

Restrictions on ADR escalationPolicy DocumentCriticalDue May 8, 2026

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

Provision of ADR services by the operator is mandatory. If the operator sets ADR parameters in order to prevent abuse (such as whether ADR must be undertaken before a player can initiate legal proceedings, the binding nature of the ADR outcome on the player, or whether there is a minimum claim value required for escalation to ADR), the CGA advises the operator to carefully consider these conditions and seek independent legal advice regarding any applicable civil legislation.

CGA's right to access recordsPolicy DocumentCriticalDue May 8, 2026

The policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

The policy must state that in light of the fact that the CGA reserves the right to request, at any time, access to records of complaints received as well as any disputes that are pending resolution, the operator shall ensure that such records are readily available at all times.

Right to make a complaintPolicy DocumentCriticalDue May 8, 2026

The policy must state that the player has the right to make a complaint regarding any part of their relationship with the operator, or any incident related to their participation in a game of chance. This includes (but is not limited to): 1. Deposit issues 2. Withdrawal issues 3. Bonus terms and conditions 4. Account closures or restrictions 5. Alleged errors or unfairness in game outcomes 6. Responsible gaming issues 7. Treatment of player balances 8. KYC and Verification 9. Data Protection 10. Technical or Software issues 11. AML concerns 12. Issues with minors 13. Fraudulent games 14. Fraudulent practices 15. License or regulation 16. Unfair terms and conditions

The policy must state that the player has the right to make a complaint regarding any part of their relationship with the operator, or any incident related to their participation in a game of chance. This includes (but is not limited to): <br>1. Deposit issues <br>2. Withdrawal issues <br>3. Bonus terms and conditions <br>4. Account closures or restrictions <br>5. Alleged errors or unfairness in game outcomes <br>6. Responsible gaming issues <br>7. Treatment of player balances <br>8. KYC and Verification <br>9. Data Protection <br>10. Technical or Software issues <br>11. AML concerns <br>12. Issues with minors <br>13. Fraudulent games <br>14. Fraudulent practices <br>15. License or regulation <br>16. Unfair terms and conditions