Scope & boundaries

A narrow scope is the product.

We are a Cyprus operational support company. We do not hold a gaming licence, an accountancy practising certificate, an administrative services provider authorisation, or a payments authorisation — and our services are defined so that none of them applies.

That definition is not a marketing position. It is a set of specific exclusions, written into every service description on this site and repeated in our contracts. Where a client needs any of those things, we say so and refer them to a licensed firm. We would rather lose the work than take it on the wrong basis, because a provider who blurs a regulatory boundary creates the problem for the licensee — and the licensee is the one who answers for it.

Inside our scope
reconciliationvendor coordinationreporting & analysiscontract administrationprocurement coordinationprocess documentation
Outside — referred to licensed firms
ledgers & accountscompliance functionsfunds & paymentsplayer datacorporate administrationlegal advicepersonnel supply
Master scope statement

What we do not do

We do not hold, and our services do not require us to hold, a gaming licence, an accountancy practising certificate, an administrative services provider authorisation, a payment institution authorisation, or an employment agency licence. The following exclusions apply to every engagement without exception, and are repeated in our master services agreement.

Gaming

We provide no gambling services of any kind, to any person, in any jurisdiction. We do not operate, manage or control gaming activity. We do not supply gaming software, game content, random number generation or any component of a licensed gaming supply. We do not accept, place, process or settle bets. We do not market or promote gambling to the public. We perform no key function, controlled function or other licensable role under any gaming regulatory framework. We do not offer or promote gambling to persons in the Republic of Cyprus.

Accountancy and tax

We do not maintain books of account or general ledgers, post accounting entries, prepare financial statements or management accounts, prepare audit files, conduct audit, or prepare data for tax or VAT filings. We provide no accounting, audit or tax advice. We hold no ICPAC practising certificate and do not hold ourselves out as accountants.

Corporate and fiduciary services

We provide no administrative services within the meaning of the Law Regulating Companies Providing Administrative Services and Related Matters, Law 196(I)/2012 of the Republic of Cyprus. Specifically, we do not: form or incorporate companies; act as, or arrange for any person to act as, a director, company secretary or nominee shareholder; provide a registered office, business address or correspondence address; act as trustee or protector of any trust; manage or direct companies, partnerships, trusts or other entities; maintain statutory registers or minute books; or act as signatory on any account.

Funds and payments

We do not hold, receive, control or have signing authority over client monies or player funds. We do not initiate, authorise or execute payments or transfers. We provide no payment services and are not a payment institution or electronic money institution.

Compliance and regulatory

We perform no compliance function. We do not act as MLRO, compliance officer, nominated officer or data protection officer. We make no anti-money-laundering, sanctions or suitability determinations, file no reports with any authority, make no regulatory submissions, and provide no regulatory, licensing or legal advice.

Players and personal data

We have no player-facing contact. We do not access player accounts, receive player personal data, or make any decision affecting an individual player.

Personnel

We do not recruit, place, supply, second or lease personnel. Our staff remain our employees under our exclusive direction, supervision and control at all times. We are not an employment agency or a temporary work agency, and we deliver defined outputs rather than hours of personnel time.

Where a client requires any excluded service, we say so and refer them to an appropriately licensed provider.
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