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.
Betsson Group, a leading global online gaming operator, has strengthened its commitment to quality, sustainability and responsible business practices through the achievement of three ISO certifications and two independent assessments in Italy. These were awarded to Azzurri Ltd, the Group’s locally licensed entity, by Bureau Veritas – a leader in testing, inspection and certification – following extensive audits of the Group’s Italian operations.
With a presence in over 25 markets and a strong focus on regulatory compliance, ESG and customer experience, Betsson Group continues to embed responsible practices across all areas of its business.
The following internationally recognised standards were awarded:
• ISO 9001 – Quality Management: Recognises effective quality management systems that consistently deliver services meeting customer and regulatory requirements.
• ISO 14001 – Environmental Management: Focuses on reducing environmental impact through responsible resource use and environmental stewardship.
• ISO 26000 – Social Responsibility: Reflects a commitment to ethical behaviour, transparency and contributing to sustainable development.
• ISO 30415 – Human Capital: Diversity and Inclusion: Validates inclusive workplace practices that respect human rights and promote equal opportunities.
• ISO 50001 – Energy Management: Acknowledges systematic efforts to improve energy efficiency and reduce consumption across operations.
“These certifications reflect our Group-wide commitment to operating responsibly, ethically and sustainably. While the audit was conducted for our Italian operations, the values underpinning these standards – from quality and environmental care to diversity and social responsibility – are deeply embedded across Betsson Group,” said Corinne Valletta, General Counsel at Betsson Group.
“Thanks to Betsson’s strong culture and drive towards operational excellence, continuous improvement and commitment towards ESG, the certification process was fairly straightforward. Kudos to the whole team for their commitment and strong knowledge across all disciplines. Their proactive approach to implementing best practices across multiple disciplines is commendable and aligns with the highest international standards,” said Peter Cain, Country Manager at Bureau Veritas Malta.
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The Alcohol and Gaming Commission of Ontario (AGCO) is continuing its efforts to combat unregulated gambling and protect the public. As part of these efforts, the AGCO took steps this week to revoke the lottery seller registrations of a number of retailers in the GTA that were found to be offering unapproved electronic gambling machines under the Prime Slot brand.
The AGCO regulates all gambling in the province of Ontario to ensure gambling products and gaming sites are held to high standards of game integrity, player safety, and the protection of minors and vulnerable individuals.
Over the past decade, unregulated gaming machines have increasingly proliferated across North America. While they largely rely on chance like traditional slot machines, manufacturers have claimed they are games of skill and have installed terminals in convenience stores and other locations where gaming machines would otherwise be prohibited.
The AGCO will continue to take every action within its authority to protect the public against the risks that these unregulated machines pose – particularly in locations easily accessible to children and youth.
A registered lottery seller served with a Notice of Proposed Order to revoke their registration has the right to appeal the AGCO’s action within 15 days to the Licence Appeal Tribunal (LAT), an adjudicative tribunal that is part of Tribunals Ontario and independent of the AGCO.
“Unapproved gambling machines have no business being in convenience stores or other locations, particularly those that are available to children and youth. ” – Dr. Karin Schnarr, Chief Executive Officer and Registrar, AGCO
Background:
Under Section 10(b) of the Gaming Control Act, the Registrar shall refuse to register an applicant as a supplier or to renew the registration of an applicant as a supplier if there are reasonable grounds to believe that the applicant will not act as a supplier in accordance with law, or with integrity, honesty, or in the public interest.
Under Section 12 of the Gaming Control Act, the Registrar may propose to suspend or to revoke a registration for any reason that would disentitle the registrant to registration or renewal of registration under section 10 if the registrant were an applicant.
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Asia
Think Tank Advocata Questions Independence and Integrity of Proposed Gaming Regulator in Sri Lanka
Sri Lankan policy think tank has questioned the independence and integrity of the country’s proposed new regulatory body as the government rushes to put the agency in place ahead of next month’s launch of Melco Resorts & Entertainment’s City of Dreams Sri Lanka.
Sudaraka Ariyaratne, Research Consultant at Advocata Institute, said to media that while establishing a regulator was vital to the industry’s long-term future, the planned Gambling Regulatory Authority appears to lack the independence needed to provide proper oversight.
Ariyaratne said: “If you look at the theory of regulation, it is very clear that the regulator has to be an independent body which gives credibility. That is not the case with this Gambling Authority Bill.
“I think the government is trying to push this bill through in a rush because Melco is coming next month. We think Melco would’ve wanted a regulator in place. When it comes to these big names in the gaming industry, the integrity of the market is a big consideration, given the image of the industry, as a whole. They need to sustain a good reputation so that they can attract good customers to whom integrity is important.”
Ariyaratne, who stressed that his think tank supports the idea of a legal, regulated gambling industry, added that the Gambling Regulatory Authority in its current form risks being a proxy for the nation’s Finance Minister.
“Even if it’s not a proper regulator, as long as it gives the perception of integrity, that’s what [operators] are looking for, to engender market confidence,” he said.
“The danger with this bill is that it won’t even give a perception of integrity, if the Minister of Finance can basically do whatever he or she wants.”
Ariyaratne added that Sri Lanka would be better served to withdraw its current bill and resubmit a more comprehensive version.
The post Think Tank Advocata Questions Independence and Integrity of Proposed Gaming Regulator in Sri Lanka appeared first on European Gaming Industry News.
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