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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.

Compliance Updates

Finland’s Gambling Reform Is Official – What Happens Next?

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The wait is over: The Finnish Parliament has officially approved the new gambling legislation. In a decisive plenary session, MPs voted 158 in favor to 9 opposed, with 32 abstaining. The text remained unchanged from the version presented in previous weeks, solidifying the framework for Finland’s transition from a monopoly to a licensed market.

With the political uncertainty resolved, the focus now shifts to implementation. For operators, this means the race to compliance—and market entry—has effectively begun.

The Confirmed Timeline

With the legislation passed, the roadmap to the market opening is now set. Operators must use the coming months to prepare for a rigorous licensing process.

  • Early 2026: The application window is expected to open. The regulator will begin accepting and reviewing license applications.

  • 2026 (Throughout): The “preparatory year.” This period is dedicated to vetting applicants, ensuring technical compliance, and establishing the new supervisory authority.

  • January 1, 2027: The regulated Finnish market officially opens. Licensed operators can go live with betting and online casino services.

Entering the Finnish Market with Nordic Legal

Navigating a new jurisdiction is complex, but it doesn’t have to be inefficient. With extensive experience advising on gaming licences across the Nordic markets, Nordic Legal brings a proven, practical approach to the Finnish process.

Efficiency Through Synergy If you already work with us in Denmark or Sweden, we ensure your Finnish licence application isn’t a “start from scratch” project. We build directly on our existing knowledge of your organisation and systems.

Your usual Nordic Legal contact will coordinate directly with our Helsinki team at no extra cost. This integrated approach saves you time and avoids the frustration of duplicating work you’ve already done for other Nordic licenses.

Our Approach We focus on smart compliance:

  • Reusing documentation where regulations overlap.

  • Anticipating regulatory questions before they are asked.

  • Aligning requirements for technical standards and responsible gambling.

  • Engaging constructively with the Finnish authority to ensure a smooth process.

The Finnish Licence Application Package

To support your entry, we offer a comprehensive package designed to handle the heavy lifting:

  • Translation of all required documents.

  • Guidance and completion of complex application forms.

  • Full project management from start to submission.

  • Direct communication with the Finnish regulator on your behalf.

Next Steps

The window for preparation is narrowing. Contact your usual Nordic Legal advisor today to discuss the new legislation or our Licence Application Package. Alternatively, reach out to us directly to secure your place in Finland’s upcoming regulated market.

The post Finland’s Gambling Reform Is Official – What Happens Next? appeared first on Gaming and Gambling Industry Newsroom.

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Compliance Updates

Updated FATF Lists of High-risk Jurisdictions

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The Danish Gambling Authority has called attention to FATF’s (Financial Action Task Force) updated lists of high-risk jurisdictions: the Grey List (jurisdictions under increased monitoring) and Black List (call for actions). Among other things, gambling operators must include FATF’s lists of high-risk jurisdictions when risk assessing players.

Jurisdictions listed on the Grey List:

Algeria, Angola, Bolivia, Bulgaria, Cameroon, the Ivory Coast, DR Congo, Haiti, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, the Virgin Islands and Yemen.

Jurisdictions listed on the Black List:

Democratic People’s Republic of Korea, Iran and Myanmar

Gambling operators are required to conduct enhanced customer due diligence (EDD) pursuant to section 17(1) of the Danish AML Act, if a player is assessed to impose a higher risk of the gambling operator being misused for money laundering or terrorist financing.

Gambling operators shall conduct this risk assessment based on Annex 3 to the AML Act (high-risk factors) which includes the FATF high-risk country lists (the so called black list and grey list)

It is not required that gambling operators perform EDD if a country is listed on the FATF’s list. EDD are only a requirement for players from jurisdictions listed in the EU Regulation of High Risk Third Country list pursuant to. 17(2) of the AML Act.

The post Updated FATF Lists of High-risk Jurisdictions appeared first on European Gaming Industry News.

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Spillemyndigheden: New licence type coming soon: Bingo via walkie-talkie and local radio

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Soon it may be possible to play bingo via walkie-talkie and on local radios. A bill is currently being considered by the Danish Parliament to introduce a new type of licence for bingo via walkie-talkie and local radio. The Danish Gambling Authority expects the rules to come into force as early as 1 January 2026.

If the bill is passed, providers of walkie-talkie bingo and local radio will be able to apply for a licence from 1 January 2026. The Danish Gambling Authority will update this news article when the rules are finally adopted.

How to apply for a licence

If you want to offer bingo via walkie-talkie or radio, you need a licence from the Danish Gambling Authority. You can expect to apply as early as 1 January 2026.

When applying for a licence, you must use the form “Apply for a walkie-talkie or radio bingo licence” (no. 1-02). The form will be available on the page “revenue-restricted licenses”.

The application form will also be published in a digital version, but it will not be available on virk.dk until January.

The Danish Gambling Authority strives to process all applications as quickly as possible.

As an applicant, you will be assigned a contact person who can guide you through the legislation during the application process. The contact person will generally remain the same throughout the period of validity of your licence.

Report on the first year of offering games

Licences for radio and walkie-talkie bingo are regulated by the Gambling Act and the Executive Order on Online Casino. The legislation sets out a number of requirements for licensed gambling operators. Among other things, the licence holder must complete a report on the first year of offering gambling.

The report is prepared one year after the licence has been put into use and must be sent to the Danish Gambling Authority no later than 14 months after the date when the licence has been put into use.

The licence holder can fill out the report themselves.

The report must account for how the licence holder has provided gambling in accordance with the conditions of the licence and legislation during the past year.

The report template will be available on the Danish Gambling Authority’s website as form no. 1-04.

The post Spillemyndigheden: New licence type coming soon: Bingo via walkie-talkie and local radio appeared first on European Gaming Industry News.

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