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.
Looking beyond Brazil, which LatAm market stands out most right now, and what makes it attractive?
Liam Hoofe, Content Strategist at GameOn
Based on our research for GO Intel, I think Chile is the market to watch out for the most. The size of the opportunity is potentially massive, with the Chilean Senate’s own figures estimating that more than 5 million Chileans are already gambling online.
The demand is definitely there, and broader discussions about a regulatory framework are underway. Our estimates in GO Intel also put channelisation rates at 80% if enforcement and regulation ran smoothly.
The proposed ‘cooling-off’ period for operators already active there is also quite a unique approach, and it will benefit those who approach the market with the right foundations in place.
Of course, as we’ve seen with Brazil, there will no doubt be a lot of public debate around the market, and the tax structure could be complex, but of the three we researched, this one still stands out the most.
Paulina Hovar, Lead Sales Manager LATAM at BGaming
Right now, Mexico and Argentina stand out the most to me.
Mexico has been showing steady growth for a while now. It’s already a fairly mature market with strong operator presence, but there’s still plenty of room to scale. At the same time, one of the main things to watch is the tax situation and how regulation may develop in the future, since that could impact profitability and market dynamics.
Argentina is interesting for a different reason. The market is regulated at the provincial level, so it’s much more decentralized. That creates opportunities because entry can be more flexible, but it also means you need to understand the local landscape and choose partners and regions carefully.
Ramiro Atucha, Board Advisor to Kiron Interactive
Mexico stands out. The size of the market alone makes it attractive, and the current regulation is already acceptable enough for public companies to feel comfortable operating there. It’s also moving toward a more formal framework, so there’s still margin to grow. Beyond Mexico, I’d point to Chile, certain provinces in Argentina, and Colombia. All three have their own dynamics, but they’re markets you can’t ignore right now.
When entering markets that are still evolving from a regulatory perspective, what’s the right balance between moving early and waiting for clarity?
Liam Hoofe, Content Strategist at GameOn
That’s the million-dollar question, and it’s one I’m not sure there is a 100% correct answer to. For me, it’s about building relationships, ensuring you have the right infrastructure in place, and understanding a market before you invest.
Operators and studios that just enter with no understanding of the culture and of the way the regulatory landscape could adapt are putting themselves at risk of failing.
Trying to remain one step ahead of regulation and working alongside the regulators to help the market mature is always going to be a much better approach than just waiting for regulation to come into place and being reactive.
Paulina Hovar, Lead Sales Manager LATAM at BGaming
It depends on how mature the market is.
If the regulatory framework is already clear and established, then the best approach is to operate fully within the licensed model from day one.
But in markets that are still in a gray or transitional stage, where operators are already active, it can make sense to take a more gradual approach. That could mean building partnerships, adapting the product to local needs, and preparing for future regulation before fully committing.
You also have to be very careful about legal and reputational risks. Every market is different, so timing and level of involvement should be assessed on a case-by-case basis.
Ramiro Atucha, Board Advisor to Kiron Interactive
As early as possible, as long as it isn’t illegal or forbidden. That’s the right moment to enter and transition through the regulatory process. Brazil is the clearest example. Sports betting was legalized in 2018, but the full regulatory framework only came in late 2023, with licensed operations starting in 2025. The operators that used those years to attract players, test the market and build name recognition without breaking the law made a real difference. By the time regulation arrived, they were already established.
As markets like Chile, Peru, and Uruguay develop, what will separate the brands that succeed from those that struggle?
Liam Hoofe, Content Strategist at GameOn
The biggest differentiator for me is localisation, and by that, I mean real localisation, not just translating a game into Spanish and calling it a day. This means actually creating products and promotions that speak to local audiences. LatAm is not just some big monolithic market with a one-size-fits-all solution – brands that succeed there are the ones that understand this. The ones who know that a player in Chile is not the same as one in Uruguay or Brazil are going to be the big winners.
On top of that, working closely with regulators and showing genuine concern for players’ well-being in these markets will make a huge difference. It’s not enough anymore to just display simple responsible gambling tools; players want to see it in your actions, and it’s obvious to them which brands really care and which are just ticking boxes.
And finally, local partnerships. Some of the most successful companies we work with are those that really integrate themselves and find local partners that offer genuine insight into communities, and can be leveraged to build trust. This can be achieved in a number of different ways, whether it’s through working with local content creators and influencers or getting involved with local charities and events.
Paulina Hovar, Lead Sales Manager LATAM at BGaming
As markets like Chile, Peru, and Uruguay continue to develop, the following three factors will set successful brands apart from the rest.
First, strong local partnerships. Without people on the ground and a real understanding of how each market works, it’s very difficult to build a sustainable position.
Second, product adaptation. Translation alone is never enough. Companies need proper localization that reflects user behavior, cultural differences, and local audience preferences.
And third, regulatory readiness. The companies that invest early in certification, compliance, and building the right processes will have a major advantage later on. It’s expensive and takes time, but in regulated markets, long-term preparation usually makes the difference between short-term growth and lasting success.
Ramiro Atucha, Board Advisor to Kiron Interactive
Brands that bring international experience and proven competitiveness from other markets, combined with genuine local understanding, will get the best of both worlds. The international background gives you credibility and product depth. The local presence gives you a product that’s actually adapted to how players in that country behave. Neither side works on its own. In Chile, Peru, and Uruguay, the operators who get this combination right are the ones who’ll separate from the pack.
The post LatAm: Beyond Brazil – Chile, Uruguay and Peru’s Regulatory Trajectories appeared first on Americas iGaming & Sports Betting News.
Dutch gambling trade association VNLOK is going to sue Meta and is filing a complaint with the European Commission regarding the large-scale dissemination of illegal gambling advertisements on Facebook and Instagram. According to VNLOK, the tech company’s measures are structurally inadequate, while vulnerable groups – including young people – are being reached en masse by the illegal gambling advertisements.
Meta has for quite some time refused to enter into a substantive dialogue with the Dutch trade association of legal online gambling providers. VNLOK now announces that it is taking both legal action and involving the European Commission.
Illegal Gambling Market Continues to Grow
The illegal gambling market in the Netherlands is now approximately as large as the legal market. It is estimated that over 1 billion euros is involved in illegal online gambling annually.
“This is not only an economic problem, but above all a major risk to consumer protection. Illegal providers do not adhere to rules regarding addiction prevention and actively target vulnerable groups such as minors and problem gamblers,” said VNLOK Chairman Björn Fuchs.
Facebook and Instagram Flooded with Illegal Gambling Advertisements
Facebook and Instagram play a central role in the growth of the illegal market. VNLOK has been conducting research into advertisements for illegal gambling sites for some time. This research shows that in the last quarter of 2025, an average of over 70,000 gambling advertisements targeting the Netherlands were visible on Meta platforms. More than 95% of this gambling promotion originated from illegal providers, generating tens of millions of monthly impressions among Dutch consumers. Less than 5% of these advertisements were removed by Meta. Consequently, illegal gambling providers continue to reach Dutch consumers on a large scale via Meta platforms.
VNLOK is highly critical of Meta’s approach. The tech company relies primarily on retroactive reporting via standard user tools. “That is like trying to mop up water with the tap still running,” says VNLOK. “Illegal providers keep returning with new advertisements. The Gaming Authority submits thousands of reports of illegal gambling advertisements to Meta every month. Large online platforms are legally obliged to continue investing in the detection, monitoring, and restriction of illegal gambling advertisements targeting Dutch consumers. As long as Meta fails to meet its legal obligation, the illegal market will continue to grow and vulnerable players will be exposed to significant risks. That is why we are now taking legal action as well as taking the matter to Brussels.”
According to VNLOK, the European Digital Services Act (DSA) obliges very large online platforms such as Meta to take adequate measures to limit the risks of illegal content on their platform, especially if it occurs structurally and on a large scale. Given the large number of illegal gambling advertisements, this system falls structurally short at Meta.
According to VNLOK, the situation has escalated further because Meta refuses to enter into a substantive dialogue with the trade association.
It is not the first time Meta has had to answer to a Dutch court. In 2025 and 2026, Meta was already ordered by the District Court and the Amsterdam Court of Appeal to remedy a structural violation of the DSA. “Dutch judges have frequently taken a critical stance towards Meta,” states VNLOK, “So it is possible. And without this constituting a disproportionate burden.”
Summons and complaint in Brussels
Because negotiations are yielding no results, VNLOK is now taking two drastic steps:
• VNLOK requests a declaration from the judge that Meta has violated the DSA and is directly liable for the illegal content; an order compelling Meta to comply with the DSA, for example by using better systems to prevent and detect problems; and a penalty payment for each day that Meta fails to comply with this order.
• VNLOK has notified the European Commission and requests an investigation, enforcement, and possible sanctions due to the violation of the DSA.
Political Pressure is Mounting
The move comes just before a debate in the House of Representatives on online gambling and consumer protection. Attention to illegal gambling advertisements on major platforms is also growing in Brussels. MEPs had previously warned that Meta plays a key role in the dissemination of these advertisements.
While VNLOK currently focuses on Meta, it points out that Google, banks, and game providers must also do more to stop the activities of illegal gambling companies, including advertising.
The post Dutch Gambling Trade Association Sues Meta Over Illegal Gambling Ads appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
Finland’s National Institute for Health and Welfare (THL) has launched a new set of gambling risk limits built around a single rule: no more than 2% of monthly net income, 4 gambling days per month and 2 recurring game types. Bonusetu.com examines the new framework and why its real-world success depends on the bank ID identification already standard in the country’s registration-free casinos.
The “2-4-2” Rule and the Player’s Credit Line
THL packaged the new limits as a player’s credit line (pelaajan luottorivi), a memorable “2-4-2” mnemonic released alongside a self-assessment gambling test (rahapelitesti) that lets a player gauge their own relationship with gambling. The thresholds are deliberately simple: keep monthly spend under 2% of net income, gamble on no more than 4 days a month, and stick to no more than 2 recurring game types. The guidance lands against a backdrop where 70% of Finns reported gambling in the past 12 months.
The numbers are not arbitrary. The framework adapts Canada’s Lower-Risk Gambling Guidelines, reworked for Finnish conditions between 2022 and 2024. Where Canada anchors its limit to 1% of gross household income, THL chose 2% of net personal income to better match how Finnish households actually think about money.
According to the THL’s assessment, the introduction of the licensing system will shift the focus of the gambling system from preventing and reducing harms to emphasising gambling revenue; for this reason, they felt it was best to launch the 2-4-2 rule right now.
“A risk limit only works if the casino knows exactly who is sitting behind the screen. THL hands players the 2-4-2 rule, but the rule has no teeth unless the operator can verify identity, age, and play history in real time. Bank ID does that at the door. Registration-free does not mean anonymous, it means the player is identified before the first euro is staked, not after,” said Tommi Korhonen, acting CEO of Bonusetu.com.
Why a Limit Needs to Know the Player
A spending cap is only as strong as a casino’s ability to recognise who is actually playing. That recognition runs on strong identification (vahva tunnistautuminen) through bank credentials, the technology that lets a player log in with Nordea, OP or S-Pankki details instead of filling out a signup form. The “no registration” label describes the missing form, not a missing identity check.
Verified age: Bank ID confirms a player is over 18 before the first spin, closing a gap that form-based signups leave open to minors.
Recognised identity: One verified identity per player turns play-history limits like 2-4-2 into something a system can enforce, not just a slogan a player is asked to remember.
Founded in 2016 and headquartered in Helsinki, Bonusetu.com is a leading Finnish comparison platform for online casinos.
The post Finland Sets Casino Gambling Risk Limits at 2% of Income, 4 Days, 2 Game Types appeared first on EE Gaming | Global iGaming & Tech Intelligence Hub.
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