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How Curacao new AML requirements differ from other flexible license jurisdictions

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By: Dmitry Hotsyn, Senior Consultant and Head of CIS Desk at 4H Agency

Discussing Anti-Money Laundering (AML) rules in a way that keeps everyone awake is a real challenge. The iGaming industry often overlooks anything filled with jargon like KYC, AML, CDD, and SoWs—terms that just breed myths and misconceptions about jurisdictions supposedly having lax AML standards and low compliance burdens. For a while, Curacao was viewed as one of these almost mythical places.

Not anymore.

A significant shake-up has occurred with Curacao’s latest overhaul of its AML regulations, set to take effect on September 1, 2024. This update has triggered quite a bit of debate among gambling operators who view these new rules as unwelcoming, especially since Curacao is known for its sluggish pace in updating its gambling regulations.

But may it really be as bad as Curaçao’s deadline management?

Curacao’s AML Regulatory Changes: An Overview

Curacao is continuously revamping its regulatory frameworks, taking a page from Malta’s book — Maltifying the industry may work best to describe this process. The new AML rules, while perceived as burdensome, are in fact a balanced update alligning the Curacao practices with generally acceptable standards. Key aspects of the new regulations include:

  • Clear Customer Due Diligence (CDD) thresholds: Operators must conduct CDD at the earliest practical time, but no later than when a player engages in a transaction amounting to approximately EUR 2200;
  • Sanction and Politically Exposed Persons (PEP) Screening: Mandatory for at least EU, US and UN sanctions lists;
  • High-Risk Indicators: A detailed list of indicators for high-risk cases has been provided, noting that the use of cryptocurrencies increases risk, though it is not outright prohibited;
  • AML Officer Role: Each operator shall have a dedicated AML officer, equipped with sufficient resources and headcount to manage risks effectively;
  • Policies and Guides: Ah year, more internal docs, rules and practice guides are expected from the operators holding licences in Curacao.

Despite the extensive nature of Curacao’s new rules, in essence, they closely resemble those enforced in Malta and other EU countries, as well as competing jurisdictions offering flexible licenses. The upcoming webinar hosted by 4H Agency and Hipther Agency will delve into these comparisons, focusing on jurisdictions like Anjouan, Kanawake, and Tobique, alongside Curacao.

Key Insights on AML Across Jurisdictions

  • Detailed AML Frameworks: Curacao and Tobique lead with the most comprehensive AML regulations. Kanawake’s requirements are also robust albeit not as detailes as Curacao rules;
  • CDD Thresholds: Similar financial thresholds exist across these jurisdictions (approximately EUR 2000), with varied stipulations on the timing of CDD post-player registration (again, Curacao is not the leader here);
  • Outsourcing AML Functions: All jurisdictions permit outsourcing some AML activities to third-party providers, providing flexibility in compliance strategies;
  • Stringency of Regulations: Tobique’s regulations are notably stringent, casually requiring additional checks like adverse media searches to identify higher risk profiles;
  • Anjouan the Outlier: Anjouan stands out for its outdated AML framework, lacking specific provisions for the gambling sector. For now, this could attract operators seeking more AML-friendly environments. However, Anjouan will inevitably follow the Curacao’s reformatory steps if the country intends to make iGaming an important factor of the now-struggling economy.

The evolution of AML regulations in Curacao represents a predictable shift towards more robust regulatory environment, aligning more closely with global standards. While initially perceived as onerous, these changes are in line not only with international practices, but with the rules already in force in a competing jurisdaction.

Our upcoming webinar will further explore these developments, providing attendees with comprehensive insights into flexible licensing options in 2024.

The post How Curacao new AML requirements differ from other flexible license jurisdictions appeared first on European Gaming Industry News.

Arizona

Arizona regulator orders five operators to stop alleged illegal gambling activity

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Cease-and-desist letters cite alleged felonies and underage access tied to BetOpenly, Bookmaker, Club WPT Online Poker, Kutt Inc., and Raffle Creator.

The Arizona Department of Gaming said it has issued cease-and-desist orders to five online platforms—BetOpenly, Bookmaker, Club WPT Online Poker, Kutt Inc., and Raffle Creator—after investigations that the Department says involved alleged illegal gambling activity and underage access in Arizona.

In its announcement, the Department said each enforcement action alleges conduct giving rise to three felonies under Arizona law: promotion of gambling, illegal control of an enterprise, and money laundering. The agency cited Arizona’s prohibition on gambling unless specifically authorized (Ariz. Rev. Stat. Tit. 13, Ch. 33) and said the legal gambling age in the state is 21.

“Arizona is taking decisive action against illegal gambling operators that put Arizonans at risk,” said Jackie Johnson, Department Director. “Our top priority is protecting Arizonans and I’m grateful for the efforts of our intelligence unit led by Chief Law Enforcement Officer Doug Jensen to do just that. Through these cease-and-desist orders we are putting operators on notice: their conduct runs contrary to Arizona law and they must stop promoting illegal gambling.”

The Department’s letters describe different alleged violations by operator. For BetOpenly, the Department said peer-to-peer gambling rules prohibit third-party benefit, and alleged the platform benefited via a commission structure while enabling event wagering and daily fantasy sports contests without the required state licenses, including availability to underage Arizonans. For Bookmaker, the Department said its investigation found wagering on horse racing, casino games, and sports betting without an event wagering license or an advanced deposit wagering provider license, adding that online casino games are not legal in Arizona.

For Club WPT Online Poker, the Department alleged the platform enabled individuals under 21 in Arizona to enter pay-to-play online poker tournaments for prizes while using deceptive “no purchase necessary” language; the Department said online poker is illegal in Arizona. For Kutt Inc., the Department said Arizona “social” gambling prohibits third-party benefit and directed the operator to stop allowing Arizona users to deposit money and wager on sports, politics, pop culture, and casino-style games. For Raffle Creator, the Department said the operator did not meet requirements that allow Arizona nonprofits to conduct lawful raffles and alleged it allowed people under 21 to purchase tickets for prize chances.

The Department said the notified entities are directed to immediately stop all gambling operations and activities in Arizona “whether through mobile applications, online, or otherwise,” and to cease any future illegal gambling in the state. It added that future actions may include criminal charges or civil action against entities, principals, and employees, and that operators “may be subject to a potential award of restitution” and forfeiture of monies acquired due to the alleged conduct.

The post Arizona regulator orders five operators to stop alleged illegal gambling activity appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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Compliance Updates

Arizona Department of Gaming Issues Cease-and-Desist Orders to Multiple Operators Linked to Underage Gambling and Illegal Activity

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Investigations into five online platforms lead to cease-and-desist orders alleging Arizona felonies: Promotion of Gambling; Illegal Control of an Enterprise; and Money Laundering

The Arizona Department of Gaming (Department) announced today that it has issued cease-and-desist orders to the following entities: BetOpenly, Bookmaker, Club WPT Online Poker, Kutt Inc., and Raffle Creator. Each enforcement action alleges conduct giving rise to the following felonies: promotion of gambling, illegal control of an enterprise, and money laundering. The cease-and-desist orders underscore the Department’s commitment to guard the integrity and safety of Arizona’s regulated gaming market while promoting consumer protection.

“Arizona is taking decisive action against illegal gambling operators that put Arizonans at risk,” said Jackie Johnson, Department Director. “Our top priority is protecting Arizonans and I’m grateful for the efforts of our intelligence unit led by Chief Law Enforcement Officer Doug Jensen to do just that. Through these cease-and-desist orders we are putting operators on notice: their conduct runs contrary to Arizona law and they must stop promoting illegal gambling.”

The cease-and-desist orders outlined below follow Department public safety initiatives aligned with Arizona law, which prohibits gambling unless it is specifically authorized (Ariz. Rev. Stat. Tit. 13, Ch. 33) and where the legal age to participate in gambling is 21 years old.

Regarding BetOpenly, peer-to-peer gambling in Arizona prohibits any third-party from benefiting, and that the peer-to-peer sports betting and casino games on the BetOpenly platform benefited the operator via a commission structure. Further, the Department alleges that BetOpenly enabled event wagering and daily fantasy sports contests without the requisite state licenses, facilitated availability to underage Arizonans, and allegedly engaged in illegal felony conduct: promotion of gambling; illegal control of an enterprise; and money laundering.

View cease-and-desist letter here: gaming.az.gov/sites/default/files/BetOpenly_Signed%20Cease%20and%20Desist_Redacted.pdf

Regarding Bookmaker, the Department found through its investigation that the platform facilitates wagering on horse racing, casino games, and sports betting, without holding an event wagering license or an advanced deposit wagering provider license. Online casino games are not legal in Arizona. The Department alleges that Bookmaker engaged in illegal felony conduct: promotion of gambling; illegal control of an enterprise; and money laundering.

View cease-and-desist letter here: gaming.az.gov/sites/default/files/Bookmaker_Signed%20Cease%20and%20Desist_Redacted.pdf

Regarding Club WPT Online Poker, the Department alleges that the platform enabled Arizona individuals under the age of 21 to engage in pay-to-play online poker tournaments for prizes while using deceptive “no purchase necessary” language. Online poker is illegal in Arizona. The Department alleges that Club WPT Online Poker engaged in illegal felony conduct: promotion of gambling; illegal control of an enterprise; and money laundering.

View cease-and-desist letter here: gaming.az.gov/sites/default/files/ClubWPT%20Online%20Poker_Signed%20Cease%20and%20Desist_Redacted.pdf

Regarding Kutt Inc., the Department warned the operator that legal “social” gambling in Arizona prohibits any third-party benefit, as seen in Kutt Inc.’s operations. The Department directed the platform to stop allowing users located in Arizona to deposit money into accounts and wager on sports, politics, pop culture, and play casino-style games. The Department alleges Kutt Inc. engaged in illegal felony conduct: promotion of gambling; illegal control of an enterprise; and money laundering.

View cease-and-desist letter here: gaming.az.gov/sites/default/files/Kutt%20Signed%20C%26D_Redacted.pdf

Regarding Raffle Creator, the Department identified that the operator, which did not meet the requirements that allow Arizona nonprofits to conduct lawful raffles, allowed people under the age of 21 to purchase tickets for the chance to win prizes. The Department alleges that the operator engaged in illegal felony conduct: promotion of gambling; illegal control of an enterprise; and money laundering.

View cease-and-desist letter here: gaming.az.gov/sites/default/files/Raffle%20Creator_Signed%20Cease%20and%20Desist_Redacted.pdf

With the cease-and-desist orders, notified entities are directed to immediately stop all gambling operations and activities in Arizona, whether through mobile applications, online, or otherwise, and are further directed to desist from any future illegal gambling operations in the state. Future actions may include the filing of criminal charges or a civil action against entities, principals, and employees, and the operators may be subject to a potential award of restitution to those who lost money as well as an action for forfeiture of all monies acquired due to the illegal conduct.

Arizona residents are encouraged to Check Your Bet: verify that any gambling, event wagering, or fantasy sports platform appears on the Department’s list of approved operators before participating. Regulated gaming operators are subject to Arizona statutes and rules, including applicable taxes or financial contributions that benefit the state. Regulated gaming provides important consumer protections, ensuring fair play and fair winnings, data security, accountability, and a safer overall experience.

Consumers may contact the Department about potential illegal gambling activities by emailing [email protected] or by calling 602-255-3886; consumers may remain anonymous when submitting information and tips.

The post Arizona Department of Gaming Issues Cease-and-Desist Orders to Multiple Operators Linked to Underage Gambling and Illegal Activity appeared first on Americas iGaming & Sports Betting News.

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KONAMI GROUP’s Konami Gaming Inc. First to Submit Manufacturer License Application in Japan’s Emerging IR Market

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KONAMI GROUP CORPORATION’s long-established gaming & systems group company Konami Gaming Inc. announced it has become the first manufacturer to submit license applications with the Japan Casino Regulatory Commission (JCRC), government regulatory agency set forth by The Cabinet of Japan. Additionally, Konami is the first manufacturer to file across all applicable license categories. These filings represent milestone events for the nation’s regulatory framework, as Japan’s emerging integrated resort (IR) market progresses in responsible development. As a leading manufacturer of casino games and technology in 400+ regulated markets worldwide, Konami is taking proactive measures in support of the Japan IR market, highly relevant to the organisation’s rich heritage as a Japanese company.

“Konami’s early filing demonstrates our commitment and readiness to engage constructively with Japan’s regulatory framework from the outset. We have approached this process with a focus on transparency, preparation, and alignment with the stringent standards established by the JCRC,” said Lori Olk, senior vice president & chief compliance officer at Konami Gaming Inc.

Construction is currently underway for the first integrated resort in Japan—an expansive development planned for 2030 opening by one of the world’s largest casino and entertainment operators. Against this backdrop, Konami’s early submission positions the company to participate during the formative stages of this emerging regulated market. Committed to the long-term health of Japan’s IR market, Konami has invested significant resources in localisation, documentation and operational planning to ensure alignment with the nation’s legal, regulatory and cultural expectations. The supplier has leveraged its longstanding compliance infrastructure, governance processes and global licensing experience to fulfill detailed requirements of the Japanese regulatory framework.

“This milestone in Konami’s application process with the JCRC represents a significant, coordinated effort across multiple business units and jurisdictions, supported by decades of experience operating in highly regulated gaming markets worldwide. As Japan continues to expand its IR framework, Konami remains focused on supporting regulatory objectives and partnering with stakeholders to deliver compliant, high-quality gaming solutions tailored to the needs of the Japanese market,” said Tom Jingoli, president & chief operating officer at Konami Gaming.

The post KONAMI GROUP’s Konami Gaming Inc. First to Submit Manufacturer License Application in Japan’s Emerging IR Market appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.

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