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Pretense Flip N.V.

Gaming OperatorRegistered March 11, 2024
1
Applications
3
Domains
10
Related Entities
0
Locations

OGL/2024/865/0413

Granted
Submitted: August 12, 2024End Date: December 18, 2024

Customer

Contact
Glenn Cretien Rellum
Email
pretenseflip@igamingcompliance.com
Company
Pretense Flip N.V.

Review Timeline

Verification
JMJosenne Mambre (GCB User 2)
Ended Apr 22, 2024
Verification
DFDesiree Francisco (CGA User 6)
Background Check
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
PWPhilippe Warzee (PW)
Due Diligence
STSarah Tua (ST)
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
GCGerald Chocolaad (CGA User 25)

Compliance Checklists

Application Due Diligence ReviewCritical0 items
Application Due Diligence ReviewCritical12 items
QPA/2024/00685 - Thomas Greenwood-Pollard - PassportPassportCriticalDue Nov 15, 2025

Please upload a better scan of the passport.

Please upload a better scan of the passport.

11/11/2025: Applicant's reply: this has been resubmitted. 11/11/2022: Passport has been resubmitted and approved in the portal.
QPA/2024/00685 - Thomas Greenwood-Pollard - Proof of AddressProof of AddressCriticalDue Nov 15, 2025

Please submit a utility bill that reflects your residential address.

Please submit a utility bill that reflects your residential address.

11/11/2025: Applicant's reply: Document uploaded
QPA/2024/00685 - Thomas Greenwood-Pollard - Reference LetterMiscellaneousCriticalDue Nov 15, 2025

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.

<p>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.</p><p><br></p><p>Please upload a bank statement in English that has been certified as true.</p>

11/11/2025: Applicant's reply: Banks in Portugal and Australia do not issue Bank Reference letters. Please indicate how to proceed with this item for Mr. Greenwood-Pollard. 11/24/2025: New item created.
QPA/2024/00685 - Thomas Greenwood-Pollard - SOWSource of WealthCriticalDue Nov 28, 2025

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>11/11/2025: Please be advised that the submitted SOW is not valid. Kindly submit an updated SOW, signed by the UBO, along with certified supporting evidence to demonstrate how the business is supported.</p><p>The ultimate submission date is November 15, 2025.</p><p><br></p><p>The SOW uploaded is a corporate SOW. We need a personal SOW.</p><p>11/24/2025: Dear applicant, we have taken note that you have not acted upon our previous request. Please be advised that the submitted SOW is not valid, as the uploaded SOW is a corporate SOW. Kindly submit a <span data-start="269" data-end="285" style="">personal SOW</span>, signed by the UBO, along with certified supporting evidence demonstrating how the business is supported.</p> The latest submission date is <span data-start="424" data-end="445" style="">November 28, 2025</span>, before end of day.

11/11/2025: Please be advised that the submitted SOW is not valid. Kindly submit an updated SOW, signed by the UBO, along with certified supporting evidence to demonstrate how the business is supported. The ultimate submission date is November 15, 2025.
Compliance OfficerMiscellaneousCriticalDue Nov 28, 2025

No compliance officer has been appointed. Appoint a CO, fluent in AML and submit their PHDF as a key person (No SOW required)

<p>No compliance officer has been appointed. Appoint a CO, fluent in AML and submit their PHDF as a key person (No SOW required)</p><p>11/11/2025: This serves as a final reminder to appoint a Compliance Officer with a minimum of three years of relevant AML experience. Please submit the completed PHDF as a key person, digitally signed using DocuSign or Adobe. All corresponding PHDF enclosures must be provided, including the engagement letter and curriculum vitae. No SOW is required for this appointment.</p> <p data-start="379" data-end="429">The ultimate submission date is November 15, 2025.</p><p data-start="379" data-end="429">11/24/2025: Dear applicant, we have taken note that you did not act upon our previous request. This serves as a final reminder to appoint a Compliance Officer with a minimum of three years of relevant AML experience. Please submit the completed PHDF as a key person, digitally signed using DocuSign or Adobe, along with all corresponding PHDF enclosures, including the engagement letter and curriculum vitae. No SOW is required for this appointment. The ultimate submission date remains November 28, 2025.</p>

Closed due to rejection
[Gerald Chocolaad - 05-05-2026 01:47]
Financial StatementsFinancial AuditCriticalDue Nov 15, 2025

Submit the FS of the applicant company for years ending 2022 and 2023.

<p>Submit the FS of the applicant company for years ending 2022 and 2023.</p><p><br></p>

11/11/2025: Kindly note that the financial statement for 2022 has been added however kindly note that 2023 is still in process 11/11/2025: FS 2023 & draft 2024 has been uploaded under the tab Extra Documentation for review. The ultimate submission date is November 15, 2025.
Articles of IncorporationArticles of IncorporationCriticalDue Nov 15, 2025

1. Submit a certified copy of the full AIs of Pretense Flip N.V 2. Submit a certified copy of the AIs (English version) of SGC Spintech Ltd

1. Submit a certified copy of the full AIs of Pretense Flip N.V 2. Submit a certified copy of the AIs (English version) of SGC Spintech Ltd

11/11/2025: Applicant's reply: attached and certified
Share Ledger CertificationShare LedgerLowDue Nov 15, 2025

Resubmit the share ledger of Pretense Flip duly certified.

Resubmit the share ledger of Pretense Flip duly certified.

11/11/2025: Applicant's reply: attached and certified.
Business PlanBusiness PlanCriticalDue Nov 15, 2025

Provide the following information: 1. Provide a full management structure, indicating the key responsibilities and controls 2. Submit a detailed 3 year financial forecast, indicating the expected initial investment, the projected marketing expenses, any salaries, and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider 3. The policies attached cannot be open. Resubmit as annexes to the business plan

Provide the following information: 1. Provide a full management structure, indicating the key responsibilities and controls 2. Submit a detailed 3 year financial forecast, indicating the expected initial investment, the projected marketing expenses, any salaries, and commissions paid to any platform/content provider and any loans paid or benefits provided by such third-party provider 3. The policies attached cannot be open. Resubmit as annexes to the business plan

11/11/2025: Applicant's reply: The documents have been uploaded. RCL: Documents requested have been submitted and this CL may be closed. Follow up action based on the docs submitted: (View the 2nd doc under business plan, updated further in 2nd doc in Ancillary docs for an understanding of the requests below) i) CO Neil Caruana to submit PHDF + Enclosures + CV and letter of appointment ii) Magdalena Frankowska : To clarify whether she holds role of CEO or CFO, and update portal role if necessary The following are to submit PHDF and enclosures (No SOW docs required) iii) CFO Peter Brincat IV) COO James Grant v) CTO Paul Mercieca vi) CCO James Palmier vii)CMO Harrison Bobridge viii) CPO Francesca Gauci ix) Chief Persons Officer Janice Mamo - likely non critical (to verify with Legal if required) x) CS/DO Remy Hordan 11/15/2025: New LC created.
Source of Funds of BusinessSource of FundsCriticalDue Nov 28, 2025

1. Kindly provide certified copies of any loan agreements between the applicant company and the shareholder/any third party, including Antopolemis Ventures Ltd, if applicable 2. The FS 2023 of Antopolemis Ventures Ltd are not signed by the director of the company. Resubmit duly signed. 3. Submit certified copies of documents evidencing funds owned by the applicant company, through cash flow or other means (Ex wallets)

<p>1. Kindly provide certified copies of any loan agreements between the applicant company and the shareholder/any third party, including Antopolemis Ventures Ltd, if applicable 2. The FS 2023 of Antopolemis Ventures Ltd are not signed by the director of the company. Resubmit duly signed. 3. Submit certified copies of documents evidencing funds owned by the applicant company, through cash flow or other means (Ex wallets)</p><p>11/25/2025: Dear applicant, we have taken note that you have not acted upon our previous request. Kindly provide certified copies of any loan agreements between the applicant company and the shareholder or any third party, including Antopolemis Ventures Ltd, if applicable. Additionally, please resubmit the 2023 financial statements of Antopolemis Ventures Ltd duly signed by the director. Lastly, kindly submit certified copies of documents evidencing funds owned by the applicant company, whether through cash flow or other means (e.g., wallets).</p> <p data-start="601" data-end="680">Please be reminded that <span data-start="625" data-end="646" style="">November 28, 2025</span>, is the ultimate submission date.</p>

11/11/2025: Applicant's reply: Loan Agreement Antopolemis attached and certified. 11/11/2025: Documents are uploaded by the applicant under the tab Extra Documentation.
QPA/2024/00685 - Thomas Greenwood-Pollard - Bank StatementMiscellaneousCriticalDue Nov 28, 2025

Please upload a bank statement in English that has been certified as true.

<p>11/15.2025: Please upload a bank statement in English that has been certified as true.</p><p>11/25/2025: Dear applicant, we have taken note that you have not acted upon our previous request. Please upload a bank statement in English that has been duly certified as a true copy. Kindly submit the document in the designated section. The ultimate submission date is November 28, 2025.</p>

Closed due to rejection
[Gerald Chocolaad - 05-05-2026 01:48]
QPA/2024/00685 - Thomas Greenwood-Pollard - Reference LetterMiscellaneousCriticalDue Nov 28, 2025

In the absence of a bank reference letter, please provide a certified copy of the bank statement for Mr. Greenwood-Pollard.

11/25/2025: Dear applicant, in the absence of a bank reference letter, please provide a certified copy of the bank statement for Mr. Greenwood-Pollard.

Closed due to rejection
[Gerald Chocolaad - 05-05-2026 01:49]