#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Tech Synergy B.V.

Gaming OperatorRegistered March 7, 2024
2
Applications
2
Domains
7
Related Entities
0
Locations

OGL/2024/806/0275

Granted
Submitted: June 25, 2024End Date: March 12, 2025

Customer

Contact
Norine Clifton
Email
tech.synergy@morganite-cs.com
Company
Tech Synergy B.V.

Review Timeline

Verification
SMSaura Maurera (CGA user 5)
Ended Apr 22, 2024
Due Diligence
STSarah Tua (ST)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
PWPhilippe Warzee (PW)
Due Diligence
AAAnton Axiaq (AAX)
Due Diligence
LCLuca Camilleri (LC)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Suitability
KMKieran McLean (KMC)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
JLJulivienne Leito (JL)

Compliance Checklists

Application Verification ReviewCritical1 item
Dariko Danelia: Proof of AddressProof of AddressCriticalDue Sep 18, 2024

The proof of address is not correct. Kindly resubmit a proof of address or bank statement.

The proof of address is not correct. Kindly resubmit a proof of address or bank statement.

Application Due Diligence ReviewCritical8 items
Director's RegisterDirector's ListCriticalDue Sep 28, 2024

1. The director's register submitted is uncertified. 2. The business plan indicated the UBO as the managing director. This is unverified from the director's register. Submit a certified copy of the official extract of the Curacao commercial register clearly identifying the directors of the company

1. The director's register submitted is uncertified. 2. The business plan indicated the UBO as the managing director. This is unverified from the director's register. Submit a certified copy of the official extract of the Curacao commercial register clearly identifying the directors of the company

Business PlanBusiness PlanCriticalDue Sep 28, 2024

1. Annex A, the financial forecasts is missing. Submit detailed 3 year financial projections indicating the initial investment, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider. 2. A compliance officer (CO) is not identified in the management structure. Identify a CO, fluent in AML, and submit their PHDF

1. Annex A, the financial forecasts is missing. Submit detailed 3 year financial projections indicating the initial investment, the projected marketing expenses and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider. 2. A compliance officer (CO) is not identified in the management structure. Identify a CO, fluent in AML, and submit their PHDF

Share Ledger CertificationShare LedgerLowDue Sep 28, 2024

The share ledger is uncertified. Resubmit duly certified.

The share ledger is uncertified. Resubmit duly certified.

Source of funds of businessSource of FundsCriticalDue Sep 28, 2024

Submit documentation as to how the business is funded and by whom, including documents evidencing funding/loans by shareholders or third parties.

Submit documentation as to how the business is funded and by whom, including documents evidencing funding/loans by shareholders or third parties.

QPA/2024/00644 - Dariko Danelia - PHDFMiscellaneousCriticalDue Mar 30, 2026

The PHDF must be filled out, signed and verified digitally. Please resubmit.

<p>The PHDF must be filled out, signed and verified digitally. Please resubmit.</p><p>Please tick the correct roles and include the personal application number.</p>

QPA/2024/00644 - Dariko Danelia - Proof of addressProof of AddressCriticalDue Nov 11, 2024

The proof of address must be no more than 6 months old. Please upload an updated one.

The proof of address must be no more than 6 months old. Please upload an updated one.

QPA/2024/00644 - Dariko Danelia - Reference LetterMiscellaneousCriticalDue Nov 11, 2024

The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

The reference letter is not valid. Please submit a reference letter from a financial institution dated within the last six months confirming that the person is a valid customer.

QPA/2024/00644 - Dariko Danelia - SOWSource of WealthCriticalDue Mar 30, 2026

Please certify the SOW

<p>Please certify the SOW</p><p>Update 3/12/2026</p><p>Dear Applicant, </p><p>Kind reminder to certify SOW</p><p>Still not certified </p>

Responsible GamingCritical21 items
ID verification procedurePolicy DocumentCriticalDue May 28, 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 May 28, 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 May 28, 2026

Record-keeping

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

Contacting the operatorPolicy DocumentCriticalDue May 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 2026

Establish player profiles to assess risk levels

The RG policy must establish player profiles to assess risk levels

Monitoring and interventionPolicy DocumentCriticalDue May 28, 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 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 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 May 28, 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 28, 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 May 28, 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 28, 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