#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Crayon B.V.

Gaming OperatorRegistered March 8, 2024
1
Applications
2
Domains
12
Related Entities
0
Locations

OGL/2024/830/0751

Granted
Submitted: October 1, 2024End Date: April 16, 2025

Customer

Contact
Kevin Goncalves Segredo
Email
crayon_curacao@fastmail.com
Company
Crayon B.V.

Review Timeline

Verification
DFDesiree Francisco (CGA User 6)
Verification
RTRowenne Tweed (GCB User 4)
Background Check
PWPhilippe Warzee (PW)
Background Check
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
DIDarvey Isidora (CGA User DI)

Compliance Checklists

Application Verification ReviewCritical7 items
Source of FundsSource of FundsMinorDue Aug 5, 2024

The enclosed document, Proof of funding is missing details.

Kindly resubmit.

Sok E KhyQuestionCriticalDue Aug 5, 2024

PAGE 5: QUESTION 25 Please be advised that appointing the UBO as the Compliance Officer presents a conflict of interest and is therefore not permissible.

Kindly ensure that these roles are assigned to separate individuals.

Sok E KhyBirth CertificateMinorDue Aug 5, 2024

The enclosed document, Certified True Copy of Birth Certificate is missing.

Kindly submit.

Sok E KhyPassportCriticalDue Aug 5, 2024

The enclosed Passport document is missing.

Kindly submit a true copy of the Passport.

Sok E KhyPassportCriticalDue Aug 5, 2024

The enclosed Passport document is missing.

Kindly submit a true copy of the Passport.

Sok E KhyPassportCriticalDue Aug 5, 2024

The enclosed Passport document is missing.

Kindly submit a true copy of the Passport.

Sok E Khy - Criminal Record (submitted—pending review)Criminal RecordMinorDue Oct 29, 2024

The enclosed criminal record of Sok E Khy is expired. Kindly resubmit a valid certificate no older than six months.

The enclosed criminal record of  Sok E Khy is expired. Kindly resubmit a valid certificate no older than six months.

The updated criminal record has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 16:27]
Application Due Diligence ReviewCritical24 items
QPA/2024/01037 - Vivian Pieters - PHDFMiscellaneousCriticalDue Nov 11, 2024

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

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

QPA/2024/01039 - Claire Godschalk Olmtak - PHDFMiscellaneousCriticalDue Nov 11, 2024

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

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

QPA/2024/01036 - Sok E Khy - PHDFMiscellaneousCriticalDue Nov 11, 2024

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

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

Sok E Khy - QPA/2024/01036 - SOW (submitted—pending review)Source of WealthCriticalDue Feb 18, 2025

Please submit a SOW along with certified supporting evidence in order to support the business.

Please submit a SOW along with certified supporting evidence in order to support the business.

The updated SOW has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 19:15]
Sok E Khy - QPA/2024/01036 - Criminal Record (duplicate ticket)Criminal RecordCriticalDue Feb 18, 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.

Sok E Khy - QPA/2024/01036 - Proof of Address (reviewed and approved)Proof of AddressCriticalDue Feb 18, 2025

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.

The proof of address has already been reviewed and approved.
[Darvey Isidora - 23-02-2026 19:22]
Compliance officerMiscellaneousCriticalDue Feb 27, 2025

No CO appointed. Appoint a CO fluent in AML and submit their PHDF , together with relevant enclosures. Include also a CV and Letter of Engagement. No SOW required.

No CO appointed. Appoint a CO fluent in AML and submit their PHDF , together with relevant enclosures. Include also a CV and Letter of Engagement. No SOW required.

Share Ledger CertificationShare LedgerMediumDue Feb 27, 2025

Share ledger uncertified. Resubmit duly certified.

Share ledger uncertified. Resubmit duly certified.

Director's RegisterDirector's ListCriticalDue Feb 27, 2025

Vivian Pieters and Claire G Olmak have indicated their role as 'non executive directors' Clarify in which entity they hold this role. Note that, at least one local director is required to be an executive director. Update the roles accordingly and/or appoint an executive individual director.

Vivian Pieters and Claire G Olmak have indicated their role as 'non executive directors' Clarify in which entity they hold this role. Note that, at least one local director is required to be an executive director. Update the roles accordingly and/or appoint an executive individual local director.

Source of funds of businessSource of FundsCriticalDue Feb 27, 2025

SOF is invalid. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

SOF is incomplete. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

AML Policy (duplicate ticket)MiscellaneousCriticalDue Feb 27, 2025

The AML policy must adhere to Curacao AML laws. Kindly amend.

The AML policy must adhere to Curacao AML laws. Kindly amend.

Platform OwnershipOperationsCriticalDue Mar 9, 2026

The applicant answered question 17 of the OGLAF as follows: "The platform is licensed as an end user from Malta so it does not require a Maltese license." Please clarify this statement.

The applicant answered question 17 of the OGLAF as follows: "The platform is licensed as an end user from Malta so it does not require a Maltese license." Please clarify this statement.<br><br><b><u>Update: 2/23/2026</u></b><br>Dear Applicant, <br>The requested information remains outstanding. Kindly provide clarification at your earliest convenience. Thank you for your cooperation.

Vivian Pieters - QPA/2024/01037 - PHDF (submitted—pending review)MiscellaneousCriticalDue Nov 11, 2024

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

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

You can start closing these, not me.
[Anton Axiaq - 25-02-2026 12:33]
The updated PHDF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 18:58]
Claire Godschalk Olmtak - QPA/2024/01039 - PHDF (submitted—pending review)MiscellaneousCriticalDue Nov 11, 2024

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

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

You can start closing these, not me.
[Anton Axiaq - 25-02-2026 12:32]
The updated PHDF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 19:06]
Customer Reply—Resubmitted
[Darvey Isidora - 23-02-2026 19:05]
Sok E Khy - QPA/2024/01036 - PHDF (reviewed and approved)MiscellaneousCriticalDue Nov 11, 2024

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

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

The updated PHDF has already been reviewed and approved.
[Darvey Isidora - 23-02-2026 19:11]
The updated PHDF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 19:10]
Customer Reply—Resubmitted
[Darvey Isidora - 23-02-2026 19:09]
Yanica Grech - QPA/2025/03769 - Compliance Officer (reviewed and approved)MiscellaneousCriticalDue Feb 27, 2025

No CO appointed. Appoint a CO fluent in AML and submit their PHDF , together with relevant enclosures. Include also a CV and Letter of Engagement. No SOW required.

No CO appointed. Appoint a CO fluent in AML and submit their PHDF , together with relevant enclosures. Include also a CV and Letter of Engagement. No SOW required.

The outstanding letter of appointment/engagement, duly signed by both the Compliance Officer and the Managing Director, along with the Compliance Officer’s curriculum vitae has been reviewed and approved.
[Darvey Isidora - 23-02-2026 19:40]
Statutory Documents - Share Ledger CertificationShare LedgerCriticalDue Mar 9, 2026

Share ledger uncertified. Resubmit duly certified.

Share ledger uncertified. Resubmit duly certified.<br><br><b><u>Update: 2/23/2026</u></b><br>Dear Applicant, <br>The certifier must not have any conflict of interest with the Applicant and must not be involved in the application (e.g., the Managing Director or Compliance Officer may not certify documents).<div>Documents requiring certification must be certified as true copies by an independent and authorized certifier, such as an embassy official, notary public, or a legal or accountancy professional. Kindly resubmit the outstanding document, duly certified, at your earliest convenience. Thank you for your cooperation.</div>

Customer Reply—Certified copy has been uploaded.
[Darvey Isidora - 23-02-2026 20:02]
Source of Funds of BusinessSource of FundsCriticalDue Feb 27, 2025

SOF is invalid. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

SOF is invalid. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

Source of Funds of Business (reviewed and approved)Source of FundsCriticalDue Feb 27, 2025

SOF is invalid. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

SOF is invalid. Upload enhanced documentation as to how the business is/will be funded and by whom, including documents which show funding by the shareholder or third parties. Documents submitted must be duly certified.

Checklist requirements satisfied. Checklist closed.
[Luca Camilleri - 03-03-2026 13:16]
The update SOF has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 20:57]
Customer Reply—Shareholder loan agreement uploaded to SOF.
[Darvey Isidora - 23-02-2026 20:54]
Business Plan (submitted—pending review)Business PlanCriticalDue Feb 27, 2025

Provide information about payment gateways

Provide information about payment gateways

The Applicant has provided a response to our inquiry. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 21:03]
Customer Reply—the payment provider: https://seapay88.com/
[Darvey Isidora - 23-02-2026 21:01]
Financial Projections (submitted—pending review)Business PlanCriticalDue Feb 27, 2025

The balance sheet provided is not presented in an appropriate format and appears incomplete. Furthermore, the profit and loss statement appears to have an error in the income figure for year 3. Please amend and re-submit.

The balance sheet provided is not presented in an appropriate format and appears incomplete. Furthermore, the profit and loss statement appears to have an error in the income figure for year 3. Please amend and re-submit.

accepted
[Kevin Mallia - 03-03-2026 15:49]
The updated Business Plan has been submitted. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 21:09]
Customer Reply—updated business plan has been uploaded to the portal
[Darvey Isidora - 23-02-2026 21:07]
GCB Dynamic Seal (submitted—pending review)MiscellaneousCriticalDue Feb 27, 2025

The GCB dynamic seal is not visible in the registered domain's footer. Please follow the instructions available on the following page for the proper display of the dynamic seal: https://portal.gamingcontrolcuracao.org/

The GCB dynamic seal is not visible in the registered domain's footer. Please follow the instructions available on the following page for the proper display of the dynamic seal: https://portal.gamingcontrolcuracao.org/

complete
[Kevin Mallia - 03-03-2026 15:51]
The Applicant has provided a response to our inquiry. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 21:13]
Customer Reply—The domain (baazi888.now) is added dynamic seal and footer is updated.
[Darvey Isidora - 23-02-2026 21:13]
Player Registration (submitted—pending review)Player RegistrationCriticalDue Feb 27, 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.

confirmed to be tested again in AML audit
[Kevin Mallia - 03-03-2026 15:46]
The Applicant has provided a response to our inquiry. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 21:18]
Customer Reply—yes the DOB and KYC with ID is all implement as suggested
[Darvey Isidora - 23-02-2026 21:17]
Cash Transactions (submitted—pending review)Player FundsCriticalDue Feb 27, 2025

Please submit all documented policies and procedures in place for the handling of cash transactions.

Please submit all documented policies and procedures in place for the handling of cash transactions.

to be checked during AML audit
[Kevin Mallia - 03-03-2026 15:51]
The Applicant has provided a response to our inquiry. The ticket has been assigned to the subject matter expert for review and approval. Upon completion, kindly reassign it for any further action required or proceed with closure, as appropriate.
[Darvey Isidora - 23-02-2026 21:49]
Customer Reply—there is no cash transactions. involved.
[Darvey Isidora - 23-02-2026 21:48]