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.
AUSTRAC has announced that it will expand its intelligence partnership, Fintel Alliance.
Fintel Alliance is a world leading public-private partnership where members and law enforcement work together and share data in real time to target serious crime.
AUSTRAC CEO Brendan Thomas said the Intelligence Division’s Fintel Alliance has been so productive that the agency will now make its collaborative data analytics hub a central function going forward.
“Together, we are able to do much more than any of us could do alone. Fintel Alliance members are working in partnership to fight financial crime – pooling data, sharing insights, and targeting major threats to strengthen financial systems and law enforcement action,” Mr Thomas said.
“This has generated real intelligence across a range of serious crimes including money laundering, child sexual exploitation, domestic violence, tax evasion, fraud and illegal phoenixing.
“For example, late last year we worked with our partners using the collaborative data analytics hub. We obtained all cash deposit transaction data under $10,000 from the four largest banks and jointly looked for criminal patterns. We had more than 50 million data points.
“Using the combined datasets, new software, and with our analysts and bank analysts working together in the same room, we were able to see things that were not visible before. In just a few days we identified major criminal networks now subject to law enforcement action. This shows the power of intelligence partnerships and collective effort.”
Fintel Alliance, first established in 2017, connects experts from major banks, remittance service providers and gambling operators, with law enforcement and security agencies in Australia and overseas.
AUSTRAC is building out the collaborative data analytics hub, a platform for data sharing which has helped identify criminal patterns and trends across the financial sector
This expansion also includes increasing its capacity with additional staff so that Fintel Alliance can contribute to more intelligence innovations and lay the groundwork for partnerships with tranche 2 entities. As part of the expansion, a seconded senior manager from ANZ Bank will help co-lead and build new pairings with industry and government members.
Last year Fintel Alliance produced a threat alert on money muling behaviour and identified an increase in micro-laundering, a process where funds are co-mingled with legitimate and illicit sources and moved at volume through low-value digital transfers.
Fintel Alliance also recently launched a campaign on “scambling”, a practice where unlicensed online gambling platforms advertise on social media and trick people to visit a scam website to participate in gambling.
Regional and remote Aboriginal communities are being targeted in this scam and Fintel Alliance is working with police, banks and other industry partners to raise awareness of “scambling”, to minimise harm to vulnerable Australians.
Fintel Alliance member and NAB Chief Financial Crime Risk Officer, Paul Jevtovic, said practical warnings for customers targeted by criminals is just one of many constructive outcomes achieved through Fintel collaboration.
“The nature of scambling – frequent small transactions – means it isn’t traditionally captured by mandatory reporting,” Mr Jevtovic said.
“However, combining data from multiple sources about cash transactions less than $10,000 allowed Fintel Alliance to more rapidly understand the nature and extent of criminality resulting in timely dissemination amongst members.
“I’ve seen this partnership and capability evolve since 2017 and its expansion is a modern approach not only to intelligence gathering, but more responsive regulation.”
Fintel Alliance Executive Board co-chair and ANZ Group Head of Financial Crime Risk, Cassandra Hewett, said ANZ is proud to have been actively involved in Fintel Alliance since its inception.
“The breadth of industry involvement reflects the value the financial industry sees from the public-private partnership,” Ms Hewett said.
“All members of Fintel Alliance continue to prioritise fighting financial crime and have strengthened our contribution to the collective effort – to prevent our businesses being infiltrated by organised crime, to protect our customers from being exploited, and to drive crime out of our communities.
“Criminals are adept at finding the weak points. By working together to develop and use new tools, technologies and fresh approaches to combat crime we can strengthen the ecosystem we all operate in.
“The collaborative data analytics hub allows Fintel Alliance members to connect our data in ways that weren’t previously possible, providing real time responses to criminal behaviour on already more than one occasion. We are excited to continue to develop these tools and drive real time responses, together.”
Fintel Alliance Executive Board co-chair and AUSTRAC Deputy CEO Intelligence John Moss, said Fintel Alliance expansion is key to AUSTRAC’s ability to disrupt criminal activity above and beyond the existing intelligence efforts and regulatory reach.
“Building even stronger partnerships is going to extend our ability to weed out criminal abuse of the financial system and hit organised crime where it hurts,” Dr Moss said.
“As AUSTRAC prepares to welcome tranche 2 industries to our regulated population, the expansion will no doubt continue to play an even bigger part in disrupting criminal activity.”
The post AUSTRAC Announces Expansion of Fintel Alliance appeared first on European Gaming Industry News.
Compliance Updates
Minimum Deposit Casinos Warns of Sweeping Changes as States Crack Down on Online Sweepstakes Casinos
Minimum Deposit Casinos (MDC), a leading global online casino review hub and division of the OneTwenty Group, has released new insights into the tightening regulatory landscape for sweepstakes-based gaming in the US. Recent moves by lawmakers in New York, Louisiana, and Montana suggest a coordinated push to eliminate or restrict these alternative online gambling models.
In New York, Senate Bill 5935, introduced by Sen. Joseph Addabbo, has advanced through the legislative process and targets the operation and supply of sweepstakes-style platforms. The bill specifically addresses platforms that use two forms of digital currency — one of which can be redeemed for real-world prizes — a setup now under scrutiny by state regulators.
Meanwhile, Louisiana has taken a similarly hard stance with Senate Bill 181, led by Sen. Adam Bass. The bill aims to ban all forms of sweepstakes games that mimic casino or sports betting experiences, including both the promotion and operation of such services. It passed the state Senate unanimously and is currently being reviewed by the House.
Montana could become the first U.S. state to enact a full prohibition if Senate Bill 555 is signed into law. The bill, which has passed both chambers, seeks to clearly define and outlaw the operation of unlicensed sweepstakes gambling websites.
“States are clearly starting to zero in on grey-area gambling models. These bills show how quickly the legal landscape can shift, and it’s crucial that players and operators stay ahead of the curve,” said a senior analyst at MDC.
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Carey Theil
Greyhound Advocates Applaud Oregon Governor Tina Kotek for Signing Historic Internet Betting Ban on Greyhound Races
The largest greyhound protection group in the world thanked Oregon Governor Tina Kotek for signing a bill to outlaw the processing of internet bets on dog races, calling the new law a landmark victory for greyhound advocates.
“This is the biggest victory for American greyhound advocates since Florida outlawed dog racing in 2018. The walls are closing in on the final remnants of this cruel industry,” said GREY2K USA Executive Director Carey Theil.
Internet wagers on dog races can only be legally processed in two states, Oregon and North Dakota. More than $155 million was gambled on dog racing in 2024 through these Advance Deposit Wagering platforms, with Oregon processing 57% of all internet greyhound bets nationwide. House Bill 3020 phases out the processing of greyhound bets by July 1, 2027. It also ends remote gambling on dog races in Oregon, known as simulcasting.
Greyhound racing is a dying industry, and only continues to exist at two tracks in West Virginia. Florida voters outlawed the activity in 2018 by a vote of 69% to 31%, closing twelve operational racetracks. A bill to prohibit gambling on dog racing nationwide was introduced in the 118th Congress. The bipartisan Greyhound Protection Act earned the support of 80 cosponsors and more than 250 humane groups, anti-gambling organizations, and local animal shelters.
Since 2022, greyhound simulcasting has been outlawed in the seven states of Arizona, Arkansas, Colorado, Kansas, Massachusetts, New Hampshire, and Oregon. When all of these laws take effect, gambling on greyhound racing will only be legal in fourteen states.
All mainstream animal protection groups oppose dog racing due to animal welfare concerns. At the final two tracks in West Virginia, state records indicate that 487 greyhounds were injured in 2024 including 162 dogs that suffered broken bones and thirteen greyhounds that died. Thousands of dogs also endure lives of confinement at West Virginia tracks, kept in cages barely large enough for them to stand up or turn around for long hours each day.
Formed in February of 2001, GREY2K USA is the largest greyhound protection organization in the US with more than 300,000 supporters. As a non-profit 501(c)4 organization, the group works to pass stronger greyhound protection laws and end the cruelty of dog racing on both national and international levels. GREY2K USA also promotes the rescue and adoption of greyhounds across the globe.
The post Greyhound Advocates Applaud Oregon Governor Tina Kotek for Signing Historic Internet Betting Ban on Greyhound Races appeared first on Gaming and Gambling Industry in the Americas.
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