#CasinoSecrets

Investigating the Offshore Online Gambling Industry

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Legacy Eight Curacao N.V.

Gaming OperatorRegistered March 15, 2024
1
Applications
26
Domains
13
Related Entities
0
Locations

OGL/2024/956/0417

Granted
Submitted: June 19, 2025End Date: August 7, 2025

Customer

Contact
George Van Zinnincq Bergmann
Email
legacyeight@igamingcompliance.com
Company
Legacy Eight Curacao N.V.

Review Timeline

Verification
JMJosenne Mambre (GCB User 2)
Ended Apr 5, 2024
Verification
DFDesiree Francisco (CGA User 6)
Due Diligence
PWPhilippe Warzee (PW)
Background Check
PWPhilippe Warzee (PW)
Due Diligence
PWPhilippe Warzee (PW)
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)
Suitability
AFAsha Fitzgerald (ASHF)
Approval
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
CPCedric Pietersz (Managing Director GCB)
Conditionally Issued
DEDennis Engelhardt (CGA User DE)
Conditionally Issued
JWJulienne Wilsoe (JW)

Compliance Checklists

Application Verification ReviewCritical3 items
Question 17 Online Gaming License Application FormQuestionCriticalDue Oct 25, 2024

More than one option is selected.

Kindly adjust the answer and/or fill answer 17.1 if it's applicable.

Kings Entertainment Group Inc. - Share registerShare LedgerCriticalDue Oct 25, 2024

Shareholder Register of Kings Entertainment Group Inc. is missing.

Kindly submit Shareholder Register of Kings Entertainment Group Inc.

NA anymore
[Kevin Mallia - 16-07-2026 09:31]
Kings Entertainment Group Inc.- Directors ListDirector's ListCriticalDue Oct 25, 2024

The list is missing

Kindly submit the directors list

Application Due Diligence ReviewCritical11 items
QPA/2024/03223 - Paul Mailing - ApplicationMiscellaneousCriticalDue Apr 17, 2025

Documentation has not been uploaded. Please ensure that all documents are uploaded and verified.

The application is not valid. Please ensure that all documents are uploaded and certified.

QPA/2024/03223 - Paul Mailing - PHDFMiscellaneousCriticalDue Jun 5, 2025

Please upload the New PHDF form.

Please upload the New PHDF form.

QPA/2024/03223 - Paul Mailing - Proof of addressProof of AddressCriticalDue Jun 5, 2025

Kindly provide a utility bill that is no older than six months as of today.

<p class="MsoNoSpacing">Kindly provide a utility bill that is no older than six months as of today.<o:p></o:p></p>

QPA/2024/03223 - Paul Mailing - Reference LetterMiscellaneousCriticalDue Jun 5, 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 class="MsoNormal">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.<o:p></o:p></p>

QPA/2024/03223 - Paul Mailing - SOWSource of WealthCriticalDue Jun 5, 2025

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

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

NA anymore
[Kevin Mallia - 16-07-2026 09:38]
Share Ledger CertificationShare LedgerCriticalDue Jun 14, 2025

Share ledger is uncertified. Resubmit duly certified

<p>Share ledger is uncertified. Resubmit duly certified</p><p>Confirm whether Kings Entertainment Group Inc is the current shareholder or whether, as per media sources, this has sold the shares in the applicant company.</p>

UBO documents submittedQuestionCriticalDue Jun 9, 2025

1. Steven Budin was removed as UBO. He still appears as director on the holding company and as CEO from the company's website. Please confirm or otherwise. If affirmative, please include Steven Budin as a qualifying person, indicating his position accordingly 2. Paul Mailings was indicated as a UBO. He does not appear in the business plan, corporate structure or any other corporate document. Please provide clarification as to his role and provide certified corporate documentation evidencing his involvement

1. Steven Budin was removed as UBO. He still appears as director on the holding company. Please confirm or otherwise. If affirmative, please include Steven Budin as a qualifying person, indicating his position accordingly 2. Paul Mailings was indicated as a UBO. He does not appear in the business plan, corporate structure or any other corporate document. Please provide clarification as to his role and provide certified corporate documentation evidencing his involvement

NA anymore
[Kevin Mallia - 16-07-2026 09:39]
Corporate StructureMiscellaneousCriticalDue Jun 9, 2025

Steven Budin was removed as UBO. The holding company is a listed company. Please provide an updated corporate structure indicating roles accordingly

Steven Budin was removed as UBO. The holding company is a listed company. Please provide an updated corporate structure indicating roles accordingly, signed by the director of the company and duly dated

Financial StatementsFinancial AuditCriticalDue Jun 9, 2025

Resubmit FS 2023 duly signed and approved by the director. Submit also financials in whatever form for year ending 2024

Resubmit FS 2023 duly signed and approved by the director. Submit also financials in whatever form for year ending 2024

Compliance officerMiscellaneousCriticalDue Jun 9, 2025

The Compliance officer is required to submit their PHDF and relevant enclosures.

The Compliance officer is required to submit their PHDF and relevant enclosures.

Player VerificationQuestionCriticalDue Jun 12, 2025

Please advise how players are verified in line with Curacao AML obligations together with age verification.

Please advise how players are verified in line with Curacao AML obligations together with age verification.

Personal Background ChecksCritical14 items
Application DateQuestionMinorDue Jul 17, 2026

Check and list the Application Date.

Position/RoleQuestionCriticalDue Jul 17, 2026

List Position:

Native NameQuestionCriticalDue Jul 17, 2026

Please list the native name.

PHDFQuestionCriticalDue Jul 17, 2026

Approved or not. If no list, why?

PassportPassportCriticalDue Jul 17, 2026

Approved, or if not, list why.

Birth CertificateBirth CertificateCriticalDue Jul 17, 2026

Approved, or if not, list why.

Criminal RecordQuestionCriticalDue Jul 17, 2026

Approved, or if not, list why.

Not valid - we need an official criminal record from Mexico and canada
[Support Admin - 10-07-2026 12:44]
Proof of AddressQuestionCriticalDue Jul 17, 2026

Approved, or if not, list why.

Not a valid utility bill
[Support Admin - 10-07-2026 12:43]
Reference LetterQuestionCriticalDue Jul 17, 2026

Approved, or if not, list why.

SOW - Source of WealthSource of WealthCriticalDue Jul 17, 2026

Approved, or if not, list why.

Not certified
[Support Admin - 10-07-2026 12:43]
Letter of EngagementQuestionMediumDue Jul 17, 2026

Approved or if not, list why.

CVCuriculum VitaeHighDue Jul 17, 2026

Approved or if not, list why.

PEP or family of PEPQuestionCriticalDue Jul 17, 2026

If yes, list the place and role.

Open Source MediaQuestionMinorDue Jul 17, 2026

Add the URL and give a small summary.

<p>https://www.linkedin.com/in/michael-mcloughlin-786bba94/</p>

https://www.linkedin.com/in/michael-mcloughlin-786bba94/
[Support Admin - 10-07-2026 12:46]
Personal History Disclosure FormCritical33 items
CGA Personal History Disclosure FormIncomplete FormCriticalDue Jul 24, 2026

Check document.Inspect all pages to ensure that there are no blank pages The applications must be filled in digitally. No forms shall be accepted where the customer has completed any section of the form handwritten. Check the forms and make sure there are no ink marks or handwritten notes.

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

Page 1: Application NumberIncomplete FormCriticalDue Jul 24, 2026

Check document. Make sure that this is filled and the same as that shown on the portal

The personal application number is missing or has an incorrect application number. Kindly resubmit the forms with the correct application number.

Page 1: Application DateQuestionCriticalDue Jul 24, 2026

Check document. The application date must be filled and within six month`s of today`s date.

The application date is missing or has an incorrect application date. Kindly resubmit the forms with the correct application date.

Page 1: Personal Information Section - Question 1: First NameQuestionCriticalDue Jul 24, 2026

Check if information matches the passport.

The applicant`s first name is incorrect or does not match.Kindly resubmit the form with the correct first name.

Page 1: Personal Information Section - Question 2: Last NameQuestionCriticalDue Jul 24, 2026

Check if information matches the passport.

The applicant`s last name is incorrect or does not match.Kindly resubmit the form with the correct lasr=t name.

Page 1: Personal Information Section - Question 6: DOBQuestionCriticalDue Jul 24, 2026

Check if information matches the passport.

The Date of birth (DOB) of the applicant is missing or incorrect. Kindly resubmit the forms with the correct DoB.

Page 1: Personal Information Section - Question 7 and 8: Former namesQuestionCriticalDue Jul 24, 2026

Check if applicant has submitted certified proof of previous names.

Kindly provide certified proof of name change documents.

Page 1:Personal Information Section - Question 11QuestionCriticalDue Jul 24, 2026

Must not be blank.

The response to Question 11 is missing. Kindly complete Question 11 and resubmit the form.

Page 1: Personal Information Section - Question 12QuestionCriticalDue Jul 24, 2026

Must not be blank. personal email address

The response to Question 12 is missing. Kindly complete Question 12 and resubmit the form.

Page 2: Contact Details Section - Question 13QuestionCriticalDue Jul 24, 2026

Must not be blank. Email address

The response to Question 13 is missing. Kindly complete Question 13 and resubmit the form.

Page 2: Contact Details Section - Question 14QuestionCriticalDue Jul 24, 2026

Must not be blank. Mobile number

The response to Question 14 is missing. Kindly complete Question 14 and resubmit the form.

Page 2: Citizenship Section - Question 15QuestionCriticalDue Jul 24, 2026

Check if matches the passport. Place of Birth must not be blank.

The response to Question 15 is missing. Kindly complete Question 15 and resubmit the form.

Page 2: Citizenship Section - Question 16QuestionCriticalDue Jul 24, 2026

Must not be blank and check if matches the passport. Passport number must not be blank.

The response to Question 16 is missing. Kindly complete Question 16 and resubmit the form.

Page 2: Citizenship Section - Question 17QuestionCriticalDue Jul 24, 2026

Check if matches the passport. Country of Issue must not be blank.

The response to Question 17 is missing. Kindly complete Question 17 and resubmit the form.

Page 2: Citizenship Section - Question 18QuestionCriticalDue Jul 24, 2026

Check if matches the passport. Date of Issue must not be blank.

The response to Question 18 is missing. Kindly complete Question 18 and resubmit the form.

Page 2: Citizenship Section - Question 19QuestionCriticalDue Jul 24, 2026

Check if matches the passport. Date of Expiry must not be blank.

The response to Question 19 is missing. Kindly complete Question 19 and resubmit the form.

Page 2: Citizenship Section - Question 20QuestionCriticalDue Jul 24, 2026

Check if matches the passport. Nationality/ Citizenship

The response to Question 20 is missing. Kindly complete Question 20 and resubmit the form.

Page 5: Key Person Involvement Section - Question 27QuestionCriticalDue Jul 24, 2026

Must be filled. If the Local Executive Director(official representative) is selected the name of the local service provider must be filled in. If other Key Function Holder is selected, then the function must be filled.

The name of the local service provider or the function of the person in the company is missing. Kindly fill in and resubmit the form.

Page 5: Key Person Involvement Section - Question 28QuestionCriticalDue Jul 24, 2026

If question 28 is filled then question 28.1. must be filled.

The response to question 28.1 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 30QuestionCriticalDue Jul 24, 2026

Must be filled.

The response to question 30 is missing. Kindly fill in and resubmit.

Page 5: Key Person Involvement Section - Question 31QuestionCriticalDue Jul 24, 2026

Must be filled.

The response to question 31 is missing. Kindly fill in and resubmit.

Page 7: Present Employment Section - Question 34 and 39QuestionCriticalDue Jul 24, 2026

They must provide evidence of present employment.

The proof for question 34 and 39 is missing. Kindly upload in the section of extra documentation.

Page 8: Source of Wealth Section - Question 41 - 42QuestionCriticalDue Jul 24, 2026

Must be filled.

The response for question 41 and or 42 is missing. Kindly fill in and resubmit.

Page 8: Source of Wealth Section - Question 43QuestionCriticalDue Jul 24, 2026

Must be filled. At least one must be selected, if 43.11 is selected then other Income must be filled.

The response to question 43 is missing. (if applies 43.11 must be filled) Kindly fill in and resubmit the form.

Page 8: Question 44QuestionCriticalDue Jul 24, 2026

If yes is selected, 44.1. must be filled.

The response to 44.1. is missing. Kindly fill in and resubmit the form.

Page 9: Declaration and Data PrivacyMiscellaneousCriticalDue Jul 24, 2026

The document must contain the name and surname and digital signature of the person that filled the form on Page 9.

The DECLARATION AND DATA PRIVACY is missing the name and/or is not digitally signed. Kindly fill in the name and/or surname /sign and resubmit the form.

PassportPassportCriticalDue Jul 24, 2026

Check date and make sure the passport is not expired.Make sure that persons photo is clear and recognizable.

The enclosed passport document is expired or unclear. Kindly resubmit a valid passport with a clear picture and certified.

Birth CertificateProof of AddressCriticalDue Jul 24, 2026

Check the document and make sure it is in English Language or orginal document with translation. Both have to be certified. (In some cases we accept the Marriage Certificate)

The enclosed document, Certified True Copy of Birth Certificate is missing or not certified or in english language. Kindly resubmit.

Bank Statement /Reference LetterReference LetterCriticalDue Jul 24, 2026

Make sure that it is in the applicant name verifying their personal account.Check date and make sure the certificate is not expired (not older than 6 months).

The enclosed reference document is expired or not valid. Kindly resubmit a valid reference letter or bank statement.

Letter of appointment/ Engagement agreement as Key Person.Reference LetterCriticalDue Jul 24, 2026

Check document. (mandatory for compliance officers)

The letter of appointment/ engagement agreement is missing/incomplete. Kindly resubmit/ submit.

Personal Gaming Authorisations from Other JurisdictionsReference LetterMediumDue Jul 24, 2026

Certified true copies of any Gaming License issued in favor of the applicant in a personal capacity from any jurisdiction ( eg. UK Personal Management License)

The Certified true copies of Gaming License issued in favor of personal capacity is missing/incomplete. Kindly submit.

Curriculum Vitae (CV)Curiculum VitaeCriticalDue Jul 24, 2026

Check document. (mandatory for compliance officers)

Source of Wealth for the UBO OnlySource of WealthCriticalDue Jul 24, 2026

The Source of Wealth must demonstrate the UBO`s financial standing and confirm their ability to operate and support the company.

The Source of Wealth documentation for the Shareholders/UBO was not provided/or is invalid.Kindly resubmit the required documents, including certified bank statements clearly displaying amounts and dividends, tax returns evidencing earnings, or any other certified documentation demonstrating the source of wealth of the UBO,and ensure that all certifications are made as true copies by authorized persons such as legal or accountancy professionals, regulated financial institutions, or other duly empowered authorities within the relevant jurisdiction.