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Compliance Updates

GCB Requirements for Compliance Officer Based on NOIS/NORUT

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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.

 

  1. 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.

BMM

BMM TESTLABS PROMOTES SACHA MCLAUGHLIN TO VICE PRESIDENT OF GLOBAL QUALITY ASSURANCE

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BMM Testlabs, the world’s original gaming test lab renowned for exceptional product compliance and certification services, today announced the promotion of Sacha McLaughlin to Vice President of Global Quality Assurance.

BMM’s President of Land-Based Gaming & Inspections, Kirk White, said, “Sacha has consistently demonstrated exceptional leadership, operational excellence, and a customer-first attitude. Her experience and passion will be critical as we continue to grow our QA services to meet the always-evolving needs of the global gaming industry.”

With over 18 years of experience in software implementation and seven years in the gaming industry, McLaughlin brings extensive knowledge of both agile and waterfall development methodologies, test planning, project management, and cross-regional team leadership. She is recognized for her ability to build and scale QA organizations that deliver quality, speed, and value to customers.

McLaughlin joined BMM in 2018 and has held roles of increasing responsibility within the Company, most recently serving as Senior Director of Quality Assurance. Throughout her tenure, she has been instrumental in expanding BMM’s QA capabilities and helping customers launch products into the global gaming market more quickly, with a focus on regulatory compliance, functionality, fairness, and security.

The post BMM TESTLABS PROMOTES SACHA MCLAUGHLIN TO VICE PRESIDENT OF GLOBAL QUALITY ASSURANCE appeared first on Gaming and Gambling Industry in the Americas.

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Central Europe

Change of Chairmanship in the GGL Board of Directors as of 1 July 2025

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On the occasion of the four-year anniversary of the Joint Gambling Authority of the Federal States (GGL) on 1 July 2025, Sandro Kirchner, State Secretary in the Bavarian State Ministry of the Interior, for Sport and Integration, has taken over the chairmanship of the GGL Administrative Board, succeeding Reiner Moser, Head of Office in the Ministry of the Interior, for Digitalisation and Municipalities for Baden-Württemberg.

During Reiner Moser’s term as Chairman of the Board of Directors, the GGL further established itself as a reliable institution for the supervision and monitoring of the online gambling market.

“The online gambling market has developed rapidly in recent years. The GGL has met the resulting challenges with great commitment and can already demonstrate remarkable results both in combating illegal gambling and in regulating and supervising the legal market. The exchange between the states and the GGL is always trusting and results-oriented. I would like to sincerely thank the Board of Directors and all GGL employees for this constructive cooperation over the past year,” said Head of Department Moser.

State Secretary Kirchner takes over the chairmanship at a time when the GGL is pursuing ambitious goals, including stronger international networking, particularly to further curb the illegal gambling market.

“The consistent prosecution of illegal offerings and player protection are my highest priorities. The work of the GGL must continue to be significantly geared towards ensuring that the business model of illegal gambling is not profitable in Germany,” said Sandro Kirchner.

With regard to his role as Chairman of the Board of Directors, he added: “I look forward to continuing the successful work of everyone involved over the past four years. We will certainly continue to face many challenges. However, I believe the GGL is well positioned to achieve this.”

The Board of Directors is the supervisory and steering body of the GGL. It consists of the heads of departments or state secretaries of the ministries responsible for gaming supervision in the 16 member states. The chair of the Board of Directors rotates annually on July 1st in alphabetical order of the member states.

The post Change of Chairmanship in the GGL Board of Directors as of 1 July 2025 appeared first on European Gaming Industry News.

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Australia

L&GNSW Launches Compliance Campaign

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The Liquor & Gaming NSW (L&GNSW) has launched a compliance campaign focusing on external gambling signage and internal gambling related signage that is visible from the outside of the premises.

Inspectors will be engaging licensees and attending venues to assess compliance.

L&GNSW will be taking escalated enforcement action against any venue found not to be complying with the requirements.

From 1 December 2023, L&GNSW adopted a zero-tolerance enforcement approach regarding external gambling-related signage. This followed a compliance campaign which involved the removal of all external gambling related signage such as “VIP Lounge,” signage that includes dragon imagery or similar, and the removal of adopted imagery including images associated with gaming machines.

External gambling related signage at hotels and registered clubs are subjected to the requirements of sections 43 and 44 of the Gaming Machines Act 2001 NSW (the Act).

These requirements are in place to continue supporting gambling harm minimisation by reducing the visibility and promotion of gambling, particularly to vulnerable individuals and the broader community.

Venues that are not yet compliant should consult the 2023 Compliance Campaign: External gaming signage for hotels & clubs position paper or contact the Hospitality Concierge for additional information on the requirements.

L&GNSW recommends venues conduct self-audits to ensure their obligations and requirements in relation to the Act are met. A Gaming Harm Minimisation Fact sheet is also available.

Breaches of section 43(1) and 44(1) of the Act can result in on the spot fines of $1100 per offence or a maximum fine of $11,000 per offence if prosecuted.

The post L&GNSW Launches Compliance Campaign appeared first on European Gaming Industry News.

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