#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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The inclusion of a person, company, domain, or other entity in the CasinoSecrets database does not imply illegal or improper conduct. The data was extracted directly from relevant gambling authorities and official registers on the basis of a significant public interest and reflects information available up to August 2026.

Records may be incomplete, outdated, or contain errors from the underlying source systems. Please verify identities using company numbers, addresses, domains, licence details, or other identifying information before drawing conclusions. The database is intended to make information of significant public interest accessible for journalistic and research purposes. Individual records should be understood in the context of the underlying data and the reporting published alongside them.

Comeback N.V.

Gaming OperatorRegistered March 14, 2024
1
Applications
5
Domains
18
Related Entities
0
Locations

OGL/2024/899/0371

Granted
Submitted: August 11, 2025End Date: October 15, 2025

Customer

Contact
George van Zinnicq Bergmann
Email
comeback@igamingcompliance.com
Company
Comeback N.V.

Review Timeline

Verification
MBMonica Botero (GCB User 7)
Ended Apr 23, 2024
Verification
SMSaura Maurera (CGA user 5)
Verification
SLShamira Leolina (User_81)
Verification
JPJemy-Ree Pilgrim (GCB User 3)
Verification
KDKimberly De Freitas (KdF)
Verification
SLShamira Leolina (User_81)
Background Check
AAAnton Axiaq (AAX)
Background Check
PWPhilippe Warzee (PW)
Background Check
AAAnton Axiaq (AAX)
Due Diligence
STSarah Tua (ST)
Due Diligence
KMKevin Mallia (KM)
Suitability
HSHilary Stewart Jones (HSJ)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
GHGisah Hollander (GH)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)

Compliance Checklists

Application Verification ReviewCritical30 items
Mazi Holdings Ltd. - share holderShare LedgerCriticalDue Nov 25, 2024

The shareholder register of the company is missing. Kindly submit the shareholder register.

The shareholder register of the company is missing.  Kindly submit the shareholder register.

Fabiano Bugelli: Personal History Disclosure formMiscellaneousCriticalDue Dec 16, 2024

Missing Personal History Disclosure form . Kindly submit.

Missing Personal History Disclosure form . Kindly submit.

Mazi Holding LTD: Fabiano Bugelli: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosures of Fabiano Bugelli. Kindly submit

Missing Personal History Disclosure Enclosures of Fabiano Bugelli. Kindly submit

Level Up Entertainment Ltd: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Form of Aron Caruana. Kindly submit.

Missing Personal History Disclosure Form of Aron Caruana . Kindly submit.

Level Up Entertainment Ltd: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosure of Aron Caruana. Kindly Submit

Missing Personal History Disclosure Enclosure of Aron Caruana. Kindly Submit

The personal application number is missing Kindly fill in the personal application number and resubmit the forms.MiscellaneousCriticalDue Dec 30, 2024

The personal application number is missing Kindly fill in the personal application number and resubmit the forms.

The personal application number is missing  Kindly fill in the personal application number and resubmit the forms.

Anya Holdings: Glenn Anders Karlsen: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosures of Glenn Anders Karlsen. Kindly Submit

Missing Personal History Disclosure Enclosures of Anders Karlsen. Kindly Submit

PAGE 3: QUESTION 17QuestionCriticalDue Nov 6, 2024

Question 17.1 is missing details. Kindly specify

Question 17.1 is missing details. Kindly specify

Jovin Genovese - Personal History Disclosure FormMiscellaneousCriticalDue Dec 16, 2024

Missing Personal History Disclosure form. Kindly submit

Missing Personal History Disclosure form. Kindly submit

Mazi Holding Ltd: MiscellaneousMiscellaneousCriticalDue Oct 30, 2024

Missing Personal History Disclosure Enclosures of Jovin Genovese. Kindly submit

Missing Personal History Disclosure Enclosures of Jovin Genovese. Kindly submit

Brenton Bartolo: Personal History Disclosure FormMiscellaneousCriticalDue Dec 16, 2024

Missing Personal History Disclosure Form. Kindly submit.

Missing Personal History Disclosure Form. Kindly submit.

Level Up Entertainment LTD: Jovin Genovese: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosure of Jovin Genovese. Kindly Submit

Missing Personal History Disclosure Enclosure of Jovin Genovese. Kindly Submit

Level Up Entertainment: Brenton Bartolo: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosure of Brenton Bartolo. Kindly Submit

Missing Personal History Disclosure Enclosure of Brenton Bartolo. Kindly Submit

Anya Holdings: Hans Martin Nakkim: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosures of Hans Martin Nakkim. Kindly Submit

Missing Personal History Disclosure Enclosures of Hans Martin Nakkim . Kindly Submit

Anya Holdings: Lars Carl Fabian Qvist: MiscellaneousMiscellaneousCriticalDue Nov 22, 2024

Missing Personal History Disclosure Enclosures of Lars Carl Fabian Qvist. Kindly Submit

Missing Personal History Disclosure Enclosures of Lars Carl Fabian Qvist. Kindly Submit

Anya Holdings: Lars Carl Fabian Qvist: Personal History Disclosure Form: Personal Application NumberMiscellaneousCriticalDue Jan 9, 2025

The personal application number is missing. Kindly fill in personal application number and resubmit.

The personal application number is missing. Kindly fill in personal application number and resubmit.

Level up Entertainment Ltd: Aron Caruana: Personal History Disclosure Form: Personal Application NumberMiscellaneousCriticalDue Dec 16, 2024

The personal application number is missing. Kindly fill in the personal application number and resubmit.

The personal application number is missing. Kindly fill in the personal application number and resubmit.

Level up Entertainment LTD: Aron Caruana - EnclosuresMiscellaneousCriticalDue Dec 30, 2024

Missing Enclosures. Kindly submit birth certificate, criminal record, bank reference letter. The enclosed proof of address document is expired. Kindly resubmit a recent proof of address document no older than 6 months

<div>Missing Enclosures. Kindly submit birth certificate, criminal record, bank reference letter. </div><div><br></div><div>The enclosed proof of address document is expired. Kindly resubmit a  recent proof of address document no older than 6 months.</div>

Fabiano Bugelli - EnclosuresMiscellaneousCriticalDue Nov 25, 2024

Missing Enclosures of Fabiano Bugelli. Kindly submit.

Missing Enclosures of Fabiano Bugelli. Kindly submit.

Anya Holdings: Glenn Anders Karlsen - Birth certificateMiscellaneousCriticalDue Dec 30, 2024

Birth Certificate is missing. Kindly submit.

<div>Birth Certificate is missing. Kindly submit.</div><div><br></div><div><br></div>

Brenton Bartolo - EnclosuresMiscellaneousCriticalDue Nov 25, 2024

Missing Enclosures of Brenton Bartolo . Kindly submit.

Missing Enclosures of Brenton Bartolo . Kindly submit.

Anya Holdings: Lars Carl Fabian Qvist - EnclosuresMiscellaneousCriticalDue Jan 9, 2025

Missing Enclosures. Kindly submit birth certificate, criminal record, bank reference letter. The enclosed proof of address document is expired. Kindly resubmit a recent proof of address document no older than 6 months

<div>Missing Enclosures. Kindly submit birth certificate, criminal record, bank reference letter. </div><div><br></div><div>The enclosed proof of address document is expired. Kindly resubmit a  recent proof of address document no older than 6 months</div>

Nextrise Holding Ltd. - Share LedgerMiscellaneousCriticalDue Nov 8, 2024

The Share Ledger of Nextrise Holding Ltd. is missing. Kindly upload.

The Share Ledger of Nextrise Holding Ltd. is missing. Kindly upload.

Level up Entertainment ltd: Brenton Bartolo: Personal History Disclosure Enclosure: Source WealthSource of FundsCriticalDue Dec 30, 2024

The Declaration and evidence of Source of Funds/Source of Wealth of Shareholders/UBO was not provided. Kindly resubmit.

The Declaration and evidence of Source of Funds/Source of Wealth of Shareholders/UBO was not provided. Kindly resubmit.

Anya Holdings: Glenn Anders Karlsen: PAGE 1: APPLICATION NUMBERQuestionMinorDue Jan 20, 2025

The personal application number is missing Kindly fill in the personal application number and resubmit the forms.

The personal application number is missing Kindly fill in the personal application number and resubmit the forms.

Glenn Anders Karlsen (Anya Holdings) - Criminal RecordCriminal RecordMinorDue Aug 11, 2025

The original criminal record of Glenn Anders Karlsen is missing. Kindly provide both the original document and the translated version, ensuring that both are sign and certified.

The original criminal record of Glenn Anders Karlsen  is missing. Kindly provide both the original document and the translated version, ensuring that both are sign and certified.

Passports - Non Executive DirectorsPassportCriticalDue Feb 19, 2025

Please provide a certified copy of the passport's first page and bio. Please note that the full page needs to be uploaded.

Please provide a certified copy of the passport's first page and bio for all the Non Executive Directors . Please note that the full page needs to be uploaded.

Financial AuditFinancial AuditCriticalDue Aug 11, 2025

The enclosed document, audited accounts ( latest audited or financial accounts, are financial records that have been reviewed and verified by an independent, qualified professional a certified public accountant (CPA) or auditor) are missing. Kindly upload document. Update: The required document — the latest audited financial accounts — is missing. These are financial records that have been checked and confirmed by an independent professional, like a certified public accountant (CPA) or auditor.

<p>The enclosed document, audited accounts ( latest audited or financial accounts, are financial records that have been reviewed and verified by an independent, qualified professional a certified public accountant (CPA) or auditor) are missing. Kindly upload document.</p><p>Update: The required document — the latest audited financial accounts — is missing. These are financial records that have been checked and confirmed by an independent professional, like a certified public accountant (CPA) or auditor.</p>

Hans Martin Hakkim (Anya Holdings) - Proof of AddressProof of AddressCriticalDue Aug 11, 2025

Proof of address: The enclosed proof of address is not in English. Kindly resubmit a proof of address or bank statement in English or an English translation not older than 6 months and must be certified

Proof of address: The enclosed proof of address is not in English. Kindly resubmit a proof of address or bank statement in English or an English translation not older than 6 months and must be certified

Viktor Tamm - Personal History Disclosure form (Correct form)MiscellaneousCriticalDue Apr 30, 2025

The Personal History Disclosure form is not the official form supplied by GCB. Kindly download the new appropriate form, refill and resubmit.

The Personal History Disclosure form is not the official form supplied by GCB. Kindly download the new appropriate form, refill and resubmit.

Application Due Diligence ReviewCritical29 items
QPA/2024/03243 - Viktor Tamm - CVCuriculum VitaeCriticalDue Sep 18, 2025

Please upload the CV.

Please upload the CV.

QPA/2024/03243 - Viktor Tamm - Proof of addressProof of AddressCriticalDue Sep 4, 2025

Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.

<p class="MsoNoSpacing"><b> </b></p> <p class="MsoNoSpacing">Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.<o:p></o:p></p>

QPA/2024/03204 - Jovin Genovese - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/03204 - Jovin Genovese - PassportPassportCriticalDue Sep 4, 2025

Please upload a higher-quality scan of the entire two pages of the passport.

Please upload a higher-quality scan of the entire two pages of the passport.

QPA/2024/03204 - Jovin Genovese - Proof of AddressProof of AddressCriticalDue Sep 4, 2025

Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.

<p class="MsoNoSpacing">Kindly note that the proof of address is not valid. We would require an actual utility bill that clearly displays the address.<o:p></o:p></p>

QPA/2024/03170 - Aaron Caruana - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/03170 - Aaron Caruana - PassportPassportCriticalDue Sep 4, 2025

Please upload a higher-quality scan of the entire two pages of the passport.

Please upload a higher-quality scan of the entire two pages of the passport.

QPA/2024/03145 - Brenton Bartolo - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/03145 - Brenton Bartolo - PassportPassportCriticalDue Sep 4, 2025

Please upload a higher-quality scan of the entire two pages of the passport.

Please upload a higher-quality scan of the entire two pages of the passport.

QPA/2024/03120 - Fabiano Bugelli - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/03120 - Fabiano Bugelli - PassportPassportCriticalDue Sep 4, 2025

Please upload a higher-quality scan of the entire two pages of the passport.

Please upload a higher-quality scan of the entire two pages of the passport.

QPA/2024/03119 - Glenn Karlsen - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/03119 - Glenn Karlsen - PassportPassportCriticalDue Sep 4, 2025

Please upload a higher-quality scan of the entire two pages of the passport.

Please upload a higher-quality scan of the entire two pages of the passport.

QPA/2024/02118 - George Van Zinnicq Bergmann - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2024/00792 - Mehmet Cicek - SOWSource of WealthCriticalDue Sep 18, 2025

Please submit an additional SOW and a certified true copy.

Please submit an additional SOW and a certified true copy.

QPA/2024/00793 - Jan Svensen - SOWSource of WealthCriticalDue Sep 18, 2025

Please submit an additional SOW and a certified true copy.

Please submit an additional SOW and a certified true copy.

QPA/2025/03250 - Hans Martin Nakkim - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2025/03250 - Hans Martin Nakkim - PassportPassportCriticalDue Sep 4, 2025

Please provide a better scan of the passport first and bio page.

Please provide a better scan of the passport first and bio page.

QPA/2025/03251 - Lars Carl Fabian Qvist - PHDFMiscellaneousCriticalDue Sep 4, 2025

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

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

QPA/2025/03251 - Lars Carl Fabian Qvist - PassportPassportCriticalDue Sep 4, 2025

Please provide a better scan of the passport first and bio page.

Please provide a better scan of the passport first and bio page.

QPA/2025/03251 - Lars Carl Fabian Qvist - Proof of addressProof of AddressCriticalDue Sep 4, 2025

Kindly provide a certified translation for the utility bill.

Kindly provide a certified translation for the utility bill.

Corporate Group StructureMiscellaneousCriticalDue Sep 5, 2025

Resubmit a corporate group structure combining all the group (including subsidiaries) in one corporate structure. The % of the Holding Level Up Entertainment Ltd is not verified. Please update. Include also the corporate entity Nextrise Group Ltd which holds over 10% in Level Up. Updated corporate structure is to be signed by the director

Resubmit a corporate group structure combining all the group (including subsidiaries) in one corporate structure. The % of the Holding Level Up Entertainment Ltd is not verified. Please update. Include also the corporate entity Nextrise Group Ltd which holds over 10% in Level Up. Updated corporate structure is to be signed by the director

Corporate Group StructureMiscellaneousCriticalDue Sep 5, 2025

Resubmit a corporate group structure combining all the group (including subsidiaries) in one corporate structure. The % of the Holding Level Up Entertainment Ltd is not verified. Please update. Include also the corporate entity Nextrise Group Ltd which holds over 10% in Level Up. Updated corporate structure is to be signed by the director

Resubmit a corporate group structure combining all the group (including subsidiaries) in one corporate structure. The % of the Holding Level Up Entertainment Ltd is not verified. Please update. Include also the corporate entity Nextrise Group Ltd which holds over 10% in Level Up. Updated corporate structure is to be signed by the director

Anya Holdings OU - Statutory DocumentsShare LedgerCriticalDue Sep 5, 2025

Resubmit the share ledger, AIs and director's register duly certified

Resubmit the Articles of Incorporation duly certified

Yannick AS - Statutory DocumentsArticles of IncorporationCriticalDue Sep 5, 2025

Submit a certified copy (English version) of the Articles of Incorporation. Resubmit the director's register duly certified.

Submit a certified copy (English version) of the Articles of Incorporation. Resubmit the director's register duly certified.

Nextrise Group Ltd - Statutory DocumentsArticles of IncorporationCriticalDue Sep 5, 2025

Submit a certified copy of the AIs, share ledger and director's register.

Submit a certified copy of the AIs, share ledger and director's register.

Source of funds of businessSource of FundsCriticalDue Sep 18, 2025

Submit certified documentation showing how the company is funded and by whom, including documents which show funding by the shareholder/s or third parties. In the event that the applicant company is funded by a corporate entity, submit the most recent FS of such funding corporate entity. Submit also recent and certified documents, if any, which show funds owned by the company through cashflow or other means.

Submit certified documentation showing how the company is funded and by whom, including documents which show funding by the shareholder/s or third parties. In the event that the applicant company is funded by a corporate entity, submit the most recent FS of such funding corporate entity. Submit also recent and certified documents, if any, which show funds owned by the company through cashflow or other means.

SubsidiariesShare LedgerCriticalDue Sep 5, 2025

Submit a certified copy of the share ledger of each subsidiary

Submit a certified copy of the share ledger of each subsidiary company

Share Ledger CertificationShare LedgerCriticalDue Sep 5, 2025

The share ledger of the applicant company is uncertified. Resubmit duly certified.

The share ledger of the applicant company is uncertified. Resubmit duly certified.