Intelligent Innovations N.V.
OGL/2024/767/0360
GrantedCustomer
- Contact
- George Van Zinnincq Bergmann
- intelligentinnov@igamingcompliance.com
- Company
- Intelligent Innovations N.V.
Review Timeline
MBMonica Botero (GCB User 7)
SMSaura Maurera (CGA user 5)
MGMario Galea (CGA Admin 1)
AAAnton Axiaq (AAX)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
SBSimon Burden (SMB)
CPCedric Pietersz (Managing Director GCB)
CPCedric Pietersz (Managing Director GCB)
DEDennis Engelhardt (CGA User DE)
SPSulmahine Penza-Kwidama (CGA USER 59)
Compliance Checklists
Application Verification ReviewCritical4 items
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
Passport number is missing
Kindly insert the passport number
Country of Issue is missing
Please insert the country of issue
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
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
Please provide a full scan of the bio and first page .
Please provide a full scan of the bio and first page .
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>
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.
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.
The PHDF must be signed and verified digitally. Please resubmit.
The PHDF must be signed and verified digitally. Please resubmit.
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
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
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
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.
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.
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 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.
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
Player ComplaintsCritical5 items
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.
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.
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.
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.
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