Hit'n'Spin is the first Sherlock case where the strongest finding is not a hidden company. It is document drift.
Story 1 — General Terms
The current English Terms say:
TwiceDice B.V. → owner/operator
OGL/2024/818/0448 → Curaçao licence
ICS MANPOWER SOLUTIONS Ltd. → payment agent
This version is supported by the live CGA domain certificate.
Story 2 — Privacy Policy
The live Privacy Policy, version 2.0 published 12 February 2025, still says:
ICS MANPOWER SOLUTIONS Ltd. → operator
TwiceDice B.V. → licensing parent
8048/JAZ2021-047 → gambling licence
That was published before the new OGL licence was granted, so it may accurately describe an older structure. The problem is that it remains live while the legal structure elsewhere has moved on.
Sherlock label: STALE LEGAL DISCLOSURE
Story 3 — Curaçao regulator records
The live domain certificate says:
Twicedice B.V.
The regulator's public licensed-operator register says:
TwiceDice N.V.
Both use company number 154842 and licence OGL/2024/818/0448.
That strongly suggests we are looking at the same regulated entity record, but we have not obtained the corporate extract needed to explain why the legal form differs.
Sherlock label: REGULATOR-NAME MISMATCH / OPEN LEAD
Story 4 — Polish Hit'n'Spin
The current Polish homepage on hitnspin.com repeatedly says Hit'n'Spin operates under a Tobique licence.
That conflicts with the English Terms and the live CGA certificate. The English Terms say the English version prevails when versions conflict.
We found no primary Tobique evidence for Hit'n'Spin during this investigation.
Sherlock label: LOCALISATION LICENCE MISMATCH
Sherlock conclusion
The current Curaçao licence is still the strongest evidence because it can be independently verified against the exact domain.
But a player should not have to reconcile four different legal narratives across one casino's live documentation.