WhiteBox B.V.
OGL/2024/822/0338
GrantedCustomer
- Contact
- Christine Nicholls
- blackbox@xcm.cw
- Company
- WhiteBox B.V.
Review Timeline
SMSaura Maurera (CGA user 5)
SMSaura Maurera (CGA user 5)
PWPhilippe Warzee (PW)
AAAnton Axiaq (AAX)
AAAnton Axiaq (AAX)
STSarah Tua (ST)
LCLuca Camilleri (LC)
HSHilary Stewart Jones (HSJ)
CHCeline Houareau (CLHR)
CPCedric Pietersz (Managing Director GCB)
CPCedric Pietersz (Managing Director GCB)
SPSulmahine Penza-Kwidama (CGA USER 59)
GCGerald Chocolaad (CGA User 25)
Compliance Checklists
Application Verification ReviewCritical3 items
The name off the contact person is not correct. Kindly fill in the correct name of the portal user administrator and resubmit.
The name off the contact person is not correct. Kindly fill in the correct name of the portal user administrator and resubmit.
The passport number is not correct. Kindly fill in the passport number of the contact person and resubmit the form.
The passport number is not correct. Kindly fill in the passport number of the contact person and resubmit the form.
The mobile number is missing. Kindly fill in mobile number and resubmit the form.
The mobile number is missing. Kindly fill in mobile number and resubmit the form.
Application Due Diligence ReviewCritical8 items
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>SOW needs to be certified and show enough funds to run the business. Please update.</p>
Corporate structure is unsigned. Update company name and resubmit signed by director
Corporate structure is unsigned. Update company name and resubmit signed by director
Resubmit the business plan including a management structure, details on the business risk rationale, allocated responsibilities, controls, provision of information about payment gateways, contractual and financial model with key suppliers. Review business plan guidelines for assistance if necessary.
Resubmit the business plan including a management structure.
Submit FS for year ending 2023 , as well as management accounts for year 2024 which must not be older than 6 months.
Submit FS for year ending 2023 , as well as management accounts for year 2024 which must not be older than 6 months.
No CO appointed. Appoint a CO fluent in AML and submit their PHDF together with enclosures, including a letter of engagement and CV. No SOW required.
No CO appointed. Appoint a CO fluent in AML and submit their PHDF together with enclosures, including a letter of engagement and CV. No SOW required.
Question 4 (Corporate tax ID) is missing. Complete and resubmit, including with updated name
Complete and resubmit with updated company name.
Submit enhanced documentation as to how the operations of the company are being funded and by whom, including evidence of funding by the shareholder
Submit enhanced documentation as to how the operations of the company are being funded and by whom, including evidence of funding by the shareholder
It was noted that one of the registered domains blackwinmagic.com, although geo-blocking specific jurisdictions such as the Netherlands, the domain still allows the player to register by choosing the Netherlands as their country of residence when logging in from other jurisdictions. The applicant must ensure that players residing in Curacao, the Netherlands, US, sanctioned and FATF blacklisted countries are not allowed to register an account.
It was noted that one of the registered domains blackwinmagic.com, although geo-blocking specific jurisdictions such as the Netherlands, the domain still allows the player to register by choosing the Netherlands as their country of residence when logging in from other jurisdictions. The applicant must ensure that players residing in Curacao, the Netherlands, US, sanctioned and FATF blacklisted countries are not allowed to register an account.
Responsible GamingCritical21 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.
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.
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