Compliance Updates
GCB Requirements for Compliance Officer Based on NOIS/NORUT
Introduction
The GCB provides these guidelines for the role of a Compliance Officer which is a statutory requirement for Curacao companies under the National Ordinance on the Identification of Clients when Rendering Services (NOIS) and the National Ordinance on the Reporting of Unusual Transactions (NORUT) as part of the fight against money laundering and terrorism financing.
Fit and Proper Requirements
The GCB aims to license operators that maintain integrity in their operations, which includes an effective compliance function. The individual acting as a Compliance Officer must demonstrate professional experience, competence and integrity. This entails specific requirements for those authorized by the GCB to serve as a Compliance Officer for a gaming operator.
Suitability
As part of the fit and proper process of the Compliance Officer, the operator must submit a comprehensive Personal History Disclosure Form to the GCB, along with all necessary supporting documents, including a CV, to enable the GCB to conduct thorough due diligence. The due diligence process may include, but not limited to, an assessment of the Compliance Officer’s:
- Personal and Professional History: Assessment of the individual’s background and experience, including any past legal or regulatory issues, to ensure no history of criminal activity, regulatory violations, or other conduct that would raise concerns about their suitability for the role.
- Reputation: Verification of the individual’s reputation through reference checks and, where applicable, consultation with relevant regulatory or industry bodies.
Competence
The operator must provide a detailed CV of the Compliance Officer, detailing their experience and education levels.
To qualify for the role, the Compliance Officer should meet one of the following criteria:
- Education and Experience: At least two years of experience in Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) compliance in a reporting role, along with a bachelor’s degree or a relevant AML certification. Recognized certifications in Curaçao include the CAMS certification from the Association of Certified Anti-Money Laundering Specialists (ACAMS) and the AMLFC certification from the AML Foundation & Compliance Institute. Other comparable certifications may be accepted, subject to approval by the GCB.
OR
- Experience Only: At least four years of experience in AML/CFT compliance in a reporting role.
Additionally, individuals with at least two years of experience in a Money Laundering Reporting Officer (MLRO) role, or equivalent, in other jurisdictions are qualified to serve as a Compliance Officer according to NOIS/NORUT.
The Compliance Officer must demonstrate a commitment to continuing professional development by investing at least 10 hours annually in AML-related training. This may include industry-specific training and workshops offered by the GCB.
The Compliance Officer should have knowledge of Curaçao laws, including NOIS and NORUT, as well as AML regulations issued by the GCB. Familiarity with screening against EU and OFAC sanctions lists is also required.
- Scope of Responsibilities
The operator must formally designate a senior officer at the management level as responsible for detecting and deterring money laundering and terrorist financing. This AML/CFT Compliance Officer should have timely access to customer identification data, Customer Due Diligence (CDD) information, transaction records, and other relevant data, and must be able to act independently.
The Compliance Officer is responsible for:
- Designing and implementing the AML program.
- Ensuring compliance with Curaçao laws and regulations regarding money laundering and terrorist financing.
- Reviewing adherence to the casino’s policies and procedures.
- Organizing staff training sessions on compliance-related issues.
- Analyzing transactions and identifying those subject to reporting under the Ministerial Decree on Indicators for Unusual Transactions.
- Reviewing internally reported unusual transactions for completeness and accuracy.
- Maintaining records of both internally and externally reported unusual transactions.
- Design an internal procedure about when reporting of unusual transactions will lead to blocking/ freezing of user accounts
- Conducting further investigations into unusual transactions if necessary.
- Preparing external reports on unusual transactions.
- Making necessary changes to the AML program.
- Staying informed about local and international developments related to money laundering and terrorist financing and suggesting improvements to management.
- Preparing periodic reports on the casino’s efforts against money laundering, terrorism financing, and proliferation financing.
Conflict of Interest
The role of Compliance Officer must not be combined with any other function that could lead to a conflict of interest or compromise the independence of the compliance function. The Compliance Officer role cannot be combined with the functions of UBO, CEO, CFO, COO, Casino Manager, Slot Manager and other operational functions. Additionally, it should be separate from the internal audit function.
Exercising of Functions in Other Jurisdictions
An individual appointed as a Compliance Officer for a Curaçao entity may also serve as an MLRO in a foreign jurisdiction, provided they have sufficient time and resources to fulfill all roles effectively.
Outsourcing
The GCB permits the outsourcing of the compliance function to a reputable third party. The CV of the responsible manager must be submitted, detailing their experience and education levels. The operator should be able to provide the outsourcing contract upon request for evaluation by the GCB.
Any one person cannot represent more than 10 operators in the role of compliance function. This limit also includes similar roles in foreign jurisdictions. In specific cases, the GCB may contest this maximum given the size of the serviced operators.
Please note that the licensed operator remains responsible for ensuring the proper execution of the compliance function.
Transitional Arrangements
The GCB expects that both current and newly appointed Compliance Officers in the gaming sector will adhere to these guidelines.
If existing Compliance Officers of licensed operators do not meet one or more requirements at the time of introduction, some adjustment time will be allowed. The GCB expects the operator to comply with item 3 for its compliance officer right away. For items 5 and 6 the operator will have up to six months to comply with these requirements. Regarding item 4, competence, if the compliance officer is not compliant regarding experience and education levels, the licensed operator is awarded a maximum of 1 year to bring the knowledge of the compliance officer up to par. In this case, the licensed operator should disclose a training plan for the Compliance Officer, which will be monitored by the GCB.
Operators that have applied for a GCB license but have not been granted a license as yet at introduction date, should make sure that the proposed compliance officer complies with these guidelines since the mentioned transitional arrangements will not apply.
Exemptions
B2B licensees are not required to appoint a compliance officer as per the requirements issued in this guidance document.
Implementation Date
The implementation date is set for January 1, 2025
The post GCB Requirements for Compliance Officer Based on NOIS/NORUT appeared first on European Gaming Industry News.
Compliance Updates
Labour MP Raises Questions Over Impact of UK Gambling Tax Hike on Gibraltar Economy
The House of Commons was reminded last week that the decisions it took could have “a huge impact” on Gibraltar, as a Labour MP warned that a planned increase to UK gaming taxes could “leave a huge hole” in the Rock’s economy.
Gareth Snell used a Commons debate on the Finance Bill to warn that changes to the UK’s remote gaming and remote betting duty could have a significant impact on Gibraltar’s public finances, and that higher costs in the regulated sector risked driving more gamblers into the black market.
Mr Snell tabled an amendment to the Bill requiring the UK Government to conduct an impact assessment on Gibraltar, whose economy he said was heavily reliant on the gaming and gambling sector.
Citing his discussions with Nigel Feetham, Gibraltar’s Minister for Trade, Industry and Justice, Mr Snell said the gaming accounts for 30% of Gibraltar’s GDP, employs 3500 people and generates one third of Gibraltar’s tax receipts.
He said companies with a footprint in Gibraltar pay Gibraltar corporation tax as well as levies in the UK and argued that changes to the UK duty structure could have an immediate effect on Gibraltar’s revenues because of the way the tax is applied.
“The minister will be acutely aware that the gaming and gambling sector in Gibraltar is a huge part of their economy,” he said, addressing Labour MP Dan Tomlinson, the Exchequer Secretary at the Treasury.
“So…anything that we do in this place that has an impact on the sector in Gibraltar will leave a huge hole in the Gibraltar economy which will have to be filled.”
Mr Snell also linked the issue to Gibraltar’s wider importance to the UK, saying tax decisions taken in Westminster could affect its ability to fund public services.
He said Gibraltar needed stability and called on the minister to set out what contact the Treasury had had with Gibraltar on the issue.
“Gibraltar is of strategic importance to us,” he said.
“It is part of the family of nations that make up who we are.”
“And decisions that we take in this Finance Bill are having a huge impact on their economy and on their ability to fund their public services and fund their defence.”
Alongside his comments on Gibraltar, Mr Snell devoted substantial attention to what he said were the risks of pushing consumers towards unregulated operators.
He tabled a separate amendment calling for an independent assessment of the impact of the duty changes on the black market, arguing that any effective response to gambling harm depended on keeping consumers inside the regulated sector.
He said the black market offered none of the protections available through licensed operators and warned that those using unregulated sites would be more exposed to harm.
“The more people we push into the black market, where there is no support, there is no gam care, there is no lockout system,” Mr Snell said.
“It means people are more at risk of harmful activity and being preyed upon by predatory organisations.”
“And companies that are outside of the UK do not pay taxes here and are simply not worried about the participants.”
He cited an independent study by Ernst and Young for the Betting and Gaming Council, which he said estimated that £6 billion worth of stakes could be diverted to the black market as a result of the changes.
He told the Commons this would amount to a 140% increase in stakes moving into unregulated channels.
“Now, the independent study done by Ernst and Young for the Betting and Gaming Council did come up that there is a potential for £6 billion worth of stakes to be diverted to black market as a result of this change,” Mr Snell said.
“That’s six billion pounds of stakes that were going to be made somewhere but will go into the black market.”
Mr Snell also said illicit operators were easily accessible and that money staked through those sites could be linked to criminal activity overseas.
“Every single one of us is no more than two clicks away from an unregulated gaming or gambling site, where, again, that money often goes into questionable activities overseas,” he said.
“Some of it is funding organised crime.”
Mr Snell said the Treasury had earmarked £26 million for the UK Gambling Commission as part of broader regulatory changes, but argued that the UK Government had not yet assessed whether that would be sufficient to address the scale of any shift to the black market.
He also said the Treasury had not given him an answer on when a post-implementation review might take place.
“To be honest, we just simply don’t know how big the impact is going to be,” he said.
“The assessment simply hasn’t been done by government to determine whether that £26 million is enough.”
In the debate, Mr Snell said his concern was not to revisit the principle of the tax changes themselves, but to secure an assessment of their unintended consequences for both Gibraltar and the black market.
Alex Ballinger, another Labour MP, took a different stance on the issues raised by Mr Snell, saying any impact on Gibraltar should be weighed against how operators fared in other jurisdictions with higher taxes than the UK.
“I think if the tax changes are going to be as economically damaging as claimed for Gibraltar, we do need to consider how it works in other jurisdictions, because there are often the same gambling organisations operating in other countries with much higher tax rates than the UK and they manage to survive profitably in those sectors,” he said.
“So I think we should take that into consideration when we’re looking at the impact on Gibraltar as well.”
As for concerns about pushing people to black market sites, he said the threat was “overblown” and other sectors such as the tobacco industry had employed a similar narrative in the past that later proved unfounded.
“And again, when we introduced the [gaming sector] point of consumption tax in 2014, again, there was no surge in unregulated or the black market gambling at that point either,” he added.
A study by the UK Gambling Commission in 2021 found only “a very small proportion” of UK gamblers ever used unlicensed sites, “and these were mostly by accident”.
Mr Ballinger welcomed investment to tackle harmful gambling.
“But I think we should not buy into the narrative that risks from the black market should stop us making changes that keep people safe from the most harmful forms of gambling,” he said.
Responding, Mr Tomlinson said he had met twice with Mr Feetham to discuss the impact of the changes on Gibraltar’s economy.
“I do understand there are significant impacts on the economy in Gibraltar and that is something that I hope to keep engaging on and discussing,” he said.
Mr Tomlinson was pressed by Mr Snell who asked whether he would give an assurance that there would be “no future surprises and no significant tax changes” that could impact Gibraltar negatively.
Mr Tomlinson declined “to write future budgets”, adding: “We have made a significant change when it comes to gambling taxation and rather than make further changes the Government will of course monitor to see the impact of that change.”
The Bill passed its third reading and the amendment on Gibraltar was not adopted.
The post Labour MP Raises Questions Over Impact of UK Gambling Tax Hike on Gibraltar Economy appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.
Compliance Updates
Malta Gaming Authority Publishes its Supervisory Engagement Efforts for 2026
The Malta Gaming Authority has published its Supervisory Engagement Efforts for 2026, outlining the areas that will shape its regulatory oversight of the online gaming sector in the year ahead.
Building on the supervisory framework refined in 2025, the Authority will continue to apply a risk‑based, evidence‑led and outcomes‑focused approach. This enables the Authority to identify and assess regulatory risks more effectively, direct supervisory resources where they are most needed, and maintain a proactive and responsive regulatory environment.
For 2026, supervisory efforts are structured around three core regulatory themes: compliance, player protection and sports betting integrity. Within these pillars, the Authority has identified a number of targeted focus areas that reflect its ongoing risk assessment, supervisory observations and engagement with Authorised Persons.
Key supervisory priorities for 2026 include:
• a thematic review of internal control frameworks around the use of cash and cash equivalents within the online gaming industry;
• a thematic review of internal control frameworks around the use of crypto assets;
• focused integrity reviews relating to athletes betting on their own sport and integrity risks linked to esports markets; and
• enhanced oversight of player protection measures, including the quality and consistency of operator monthly ADR reporting.
Through these focused supervisory engagements, the Authority aims to strengthen regulatory standards, safeguard player interests and reinforce the long‑term resilience and integrity of the online gaming sector.
The post Malta Gaming Authority Publishes its Supervisory Engagement Efforts for 2026 appeared first on Eastern European Gaming | Global iGaming & Tech Intelligence Hub.
American online gambling
New Analysis Shows Majority of Online Gambling Operators Targeting U.S. Players are Unlicensed
According to Blask’s latest analysis of the U.S. iGaming landscape, 290 out of 362 operators active in the American online gambling ecosystem (approximately 80%) are offshore platforms operating outside domestic regulatory frameworks. The data highlights a structural reality of the U.S. market: while regulation has expanded significantly over the past decade, offshore operators still dominate the competitive landscape in terms of brand presence.
This dominance is not limited to the number of operators. It also translates into a substantial share of total market value. Blask estimates that the total U.S. online gambling market reached approximately $79.8B in Competitive Earning Baseline (CEB) in 2025. Of that total, only around $25.2B was captured by licensed domestic operators, while the majority flowed to offshore platforms.
In other words, roughly three quarters of the U.S. market value remains outside the regulated ecosystem, despite more than a decade of state-by-state legalization.
The persistence of offshore dominance is closely tied to the fragmented structure of U.S. gambling regulation. Several of the country’s largest markets still operate without any online gambling legalization, while many regulated states allow sports betting but not online casinos — creating structural gaps that offshore platforms continue to fill.
States that offer full online gambling regulation, including both sports betting and casino, show significantly lower offshore penetration. Markets such as New Jersey and Michigan capture roughly three quarters of their online gambling value domestically, demonstrating that comprehensive regulation can meaningfully increase channelization. However, no U.S. jurisdiction has fully eliminated offshore activity.
The post New Analysis Shows Majority of Online Gambling Operators Targeting U.S. Players are Unlicensed appeared first on Americas iGaming & Sports Betting News.
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