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.
The Michigan Gaming Control Board (MGCB) has issued a cease-and-desist order to BetUS, an offshore gambling operator, for illegally offering internet gaming and sports betting to Michigan residents without proper licensure.
Investigations by the MGCB revealed that BetUS was accepting wagers from Michigan residents on various gambling activities, including sports and casino-style games, without the necessary state authorization. This operation violates Michigan’s Lawful Internet Gaming Act, the Gaming Control and Revenue Act, and the Michigan Penal Code.
“Unlicensed operators like BetUS undermine the integrity of Michigan’s regulated gaming market and expose consumers to potential risks. The MGCB is committed to protecting Michigan residents by ensuring that all gambling activities are conducted legally and responsibly,” said Henry Williams, Executive Director of MGCB.
The cease-and-desist order mandates that BetUS immediately halt all operations involving Michigan residents. The company has 14 days to comply or face further legal action in coordination with the Michigan Department of Attorney General.
The post MGCB Issues Cease-and-Desist Order to BetUS appeared first on Gaming and Gambling Industry in the Americas.
Your recent AML Outlook report highlights over €36 million in fines issued across Europe in just one year. What recurring weaknesses or compliance gaps are regulators most commonly identifying in payments and e-money firms?
John Gidla (JG): Regulators continue to flag underinvestment in anti-financial crime controls as a key concern for payments and e-money firms. Common themes include weak governance, limited oversight, and fragmented controls, all of which increase vulnerability to financial crime. There’s a growing expectation that firms scale their compliance frameworks in line with their risk exposure and growth trajectory
The report mentions that AML compliance can be costly—yet the reputational and financial risks of non-compliance are even greater. What are the most cost-effective measures firms can implement today to strengthen their AML frameworks without overwhelming their budgets?
JG: While not all firms can afford advanced compliance tools, strong governance remains one of the most cost-effective ways to reduce risk. Practical steps such as training staff on emerging threats, embedding a culture of accountability, and regularly updating frameworks as the business grows can go a long way in strengthening AML resilience without major spend.
With the creation of the EU’s new AMLA authority, do you expect a more consistent and centralized enforcement approach across Europe? How might this change how firms prepare for inspections and adapt their compliance strategies?
JG: AMLA has the potential to bring greater consistency to AML enforcement across the EU, addressing long-standing issues caused by fragmented supervision and uneven implementation by national authorities. Its impact will depend on how much direct oversight it gains, how assertively it acts on cross-border risks, and whether it can close the regulatory gaps that have permitted high-profile scandals. Firms should expect more rigorous and standardised inspections and will need to ensure their compliance programmes are not only locally robust, but scalable across jurisdictions.
Vixio emphasizes the importance of a proactive rather than reactive compliance culture. In your view, what does a ‘proactive’ AML strategy look like in 2025, and what technologies or best practices are leading firms adopting to stay ahead?
JG: A truly proactive AML strategy in 2025 extends beyond technology to encompass a strong compliance culture at every level of the organisation. Leading firms understand that combating financial crime isn’t just the responsibility of the compliance team — it’s integrated into day-to-day operations, with senior leadership driving risk awareness across departments. In terms of technology, firms are increasingly adopting AI, machine learning, and automated monitoring systems to detect suspicious activity early and reduce human error. However, culture plays a critical role; firms that foster a compliance-first mindset and invest in ongoing staff training are better positioned to adapt to emerging threats and ensure that their compliance frameworks evolve in step with business growth and digital transformation. A proactive approach also means constantly reassessing risk and using data to predict and prevent issues, rather than just reacting to them. With regulations in constant flux, and regulators ramping up enforcement, proactive compliance looks like implementing strategies to anticipate regulations, not just react to them. In Vixio’s PC Outlook Report, we found that a clear majority of firms surveyed are using some form of outsourcing for their compliance functionality, turning to firms like Vixio to get ahead of regulatory change.
Thanks to John Gidla, Head of Payments Compliance at Vixio, for his insightful responses.
The post Exclusive Commentary from Vixio On Their AML Outlook Findings appeared first on European Gaming Industry News.
Peru’s Ministry of Foreign Trade and Tourism (Mincetur) reported that, a little more than a year after having implemented the law that regulates the online sector, it has been able to reduce by 40% the offer of illegal games in digital platforms and applications.
In a public statement, the Executive portfolio in charge of regulating gambling also highlighted that, thanks to the inspection work, 15% of the illegal websites “have left the Peruvian market” and that “payment methods providers and financial entities have been contacted to block services to unauthorized operators”.
Based on this, Mincetur highlighted that “Peru has managed to position itself as a regional referent in the integral regulation of gambling” and that, through the normative framework, it was possible to “protect the consumer, guarantee transparency in the operations and promote the formal and sustainable economic development”.
The Ministry highlighted that with the implementation of Law No 31557, which regulates sports betting and online games, “the country became the third country in Latin America to establish clear regulations for this activity”.
“Since its entry into force in February 2024, 60 technological platforms have been authorized and 280 linked service providers have been registered, as well as the accreditation of nine international certification laboratories,” Mincetur said.
In this regard, the Ministry stated that “this regulation has made it possible to formalize the digital sector, promoting an environment of trust for both operators and users.” At the same time, it has allowed “new investment opportunities, boosting the digitalization of entertainment and strengthening the country’s tax collection”.
The post Peru Reports 40% Drop in Illegal Online Gambling appeared first on Gaming and Gambling Industry in the Americas.
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