An online casino and sports betting operator with existing Curaçao licensing, looking to legitimise its Romanian player base. We structured the Romanian SA, deposited €115K paid-up capital, and ran technical certification in parallel with compliance documentation.
The situation
A Limassol-based operator running on a Curaçao licence with a meaningful Romanian player share, exposed to ONJN ISP-level enforcement against unlicensed operators. The choice was either to exit the Romanian market or to obtain a Class 1 authorisation. Operator chose the latter.
The challenge was timing: a Class 1 dossier touches entity formation, capital deposit, technical certification at an ONJN-approved lab, AML and responsible-gambling policy drafting, and the ONJN review itself. Sequenced naively, this is twelve to fifteen months. The operator had a six-month internal deadline.
The approach
We mapped the dependencies and ran four workstreams concurrently: entity and capital, technical certification, policy framework, ONJN dialogue. The critical path was the lab certification, which we started at week one rather than waiting for entity completion.
A Romanian joint-stock company (SA) was incorporated with the full €115,000 paid-up capital deposited at a Romanian credit institution. The SA structure (rather than SRL) was chosen for capital flexibility against future investor changes. Shareholder fit-and-proper documentation prepared in parallel.
BMM Testlabs engaged at week two for RNG and platform certification. The operator's existing Curaçao certification accelerated the lab process: BMM accepted the prior test reports as supporting evidence and ran a delta certification against ONJN-specific requirements.
AML/KYC procedures, responsible-gambling policy with self-exclusion register integration, advertising compliance, complaints handling. Drafted to ONJN format, in Romanian, by us. We do not template these documents because ONJN reviewers know the templates.
Full dossier submitted at week eighteen. ONJN review took eleven weeks with two clarification rounds, both responded to within five working days. Class 1 authorisation issued at week twenty-nine. Live operations began the following week.
The outcomes
Services used