Tivit Bet Casino: 26.10.2023 заблокировали аккаунт и не вывели средства на 2.500.000 RUB

лицензия написала для казино:
Dear Executive,

In order for Curaçao eGaming («CEG») to process this complaint further, can you please provide CEG with information, documentation or evidence that supports your case, as listed below:

Player account information showing; deposits history and withdrawals history.
In the response provided by the Operator, we are unable to see supporting evidence regarding your statement(s). Please submit the appropriate evidence accordingly.
In order to process this complaint in a timely manner, please ensure to respond within seven calendar days and to attach all relevant evidence to your response.

Please note that, since the complaint has now been formalized, CEG will only accept this communication thread in the matter. Other communications will be ignored and shall not be part of the ADR-case file. CEG has included both parties in this email, and it is mandatory to keep all recipients included in all correspondence at all times, unless any of the above contains confidential and/or sensitive details such as method of investigation, third-party data or similar details, which can pose a security risk. In those circumstances, please send the said information to us directly without copying the other party.

Best regards,

Curaçao eGaming | ADR Department

представитель казино ответил лицензии следующее:
Dear CEG,

We are not sure that the last letter was delivered to you, so I am
duplicating our answer.
The WunGroup company is the operator of two gaming domains Chill.bet and
Tivit.bet. After blocking the domains chill and Tivit, in order to avoid
any restrictions on the company by the government authorities of the
Russian Federation, the company decided to completely stop any
activities in the Russian Federation, including the operation of the
Tivit domain.

In accordance with clause 2.1. T&C Player can play on Site if he is from
a country where online gambling is allowed. By accepting this Agreement,
the Player confirms and guarantees that online gambling is allowed in
the country in which he will use Our services. For non-observance and
violation of this requirement, the User bears responsibility
independently and in full.

In accordance with Article 5 of the Federal Law of December 29, 2006 N
244-FZ «On state regulation of activities for the organization and
conduct of gambling and on amendments to certain legislative acts of the
Russian Federation» 3. Activities for the organization and conduct of
gambling on the territory of the Russian Federation using information
and telecommunication networks, including the Internet, as well as
communication means is prohibited, with the exception of cases of
acceptance of interactive bets and payment of winnings on them by
organizers of gambling in bookmakers or sweepstakes in accordance with
Article 14.2 of this Federal Law. For the purposes of this part, the
place of activity for organizing and conducting gambling using
information and telecommunication networks, including the Internet, as
well as communications means, is the territory of the Russian Federation
if at least one of the following conditions is met:

1) the place of residence of the gambling participant is located on the
territory of the Russian Federation;

2) the location of the bank in which the account is opened, used by the
gambling participant to pay for bets, interactive bets and make other
payments in favor of the gambling organizer, or the electronic money
operator through which the gambling participant pays for bets,
interactive bets and other payments in favor of the gambling organizer,
located on the territory of the Russian Federation;

3) the network address of the gambling participant, used when paying for
bets, interactive bets and making other payments in favor of the
gambling organizer, is registered in the Russian Federation;

4) the international country code of the subscriber number used by the
gambling participant to pay for bets, interactive bets and make other
payments in favor of the gambling organizer is assigned to the Russian
Federation.

The company does not meet the requirements set out in Art. 14.2, and
therefore does not have the right to operate on the territory of the
Russian Federation, and therefore the company has ceased all activities
in the territory of this country. Based on the above, the Player also
violated the provisions of clause 2.1. T&C.
Please find the requested files in the attachments.

вот такой ответ пришел

Dear Executive and Player,

Curaçao eGaming («CEG») has reviewed all documentation that has been filed by the Player and the Operator (the: “Parties”) in the matter of this complaint. CEG acknowledges that both parties have been granted ample time to communicate their statements and provide evidence, supporting their statements.

In this case, CEG rules that the dispute between parties shall be resolved as follows:

Regarding the current situation between the Russian Federation and Ukraine, additional sanctions have been and are still being imposed on the Russian Federation and Belarus by the EU consisting of listings, financial sanctions, and prohibitions. Reference is made to the EU sanctions map: sanctionsmap( . )eu, the consolidated list of financial sanctions and consolidated list of persons, groups and entities subject to EU financial sanctions:webgate( . )ec.europa.eu/europeaid/fsd/fsf

Curaçao is legally bound to implement the sanctions from the European Union and the Security Council of the United Nations and therefore freeze all assets, including players’ balances from persons that reside within the sanctioned jurisdiction. In this case, CEG rules that these balances need to be retained until such jurisdiction becomes unsanctioned, at which point in time the player may reclaim the balances. CEG furthermore reconfirms that the sanctioned player is not allowed to place any deposits, nor is the Operator allowed to accept any deposits from any sanctioned persons. If this would show up in future intermediary complaint handling procedures, this shall result in an incident audit being triggered against the Operator and may result in consequences for the license. Furthermore, made deposits should still be held and frozen until further notice, and the player shall not be allowed to reclaim the deposit until circumstances change. The player is therefore also advised not to attempt making any deposits against sanction policies.
Failure of parties to abide by this ruling may result in disciplinary action by CEG against any of the parties.

Both parties may file an appeal against this ruling within seven days with CEG’s ADR Appeals Commission. Appeals that have not been timely received or do not include proper identification, new evidence and/or motivation of the appeal shall be ignored.

Best regards,

Curaçao eGaming | ADR Department