

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
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Compliance Updates
TGP Europe Leaves GB Market Following UKGC Investigation

TGP Europe, which ran a number of websites, has surrendered its licence after being told by the UK Gambling Commission (UKGC) that it needed to pay a £3.3 million penalty and make significant improvements if it wanted to continue trading in Great Britain.
The fine was for failing to carry out sufficient checks on business partners and breaching anti-money laundering rules.
TGP’s white label business model involved running a gambling business using the branding of other businesses.
A Commission investigation revealed failures to:
• carry out effective due diligence on each entity involved in the ownership of the third party
• carry out due diligence on the source of funds for business arrangements
• sufficiently consider money laundering risks
• sufficiently consider any activity by a third-party that is illegal, in either GB or the territory in which it is conducted.
Anti-Money Laundering (AML) breaches included failing to effectively implement enhanced due diligence measures outlined in its own AML policy by not effectively scrutinising information received from a third party.
This is the second time TGP Europe has breached regulations. In 2023 the operator was fined £316,250 for failures including not adequately considering and mitigating money laundering risks posed by business-to-business relationships, and having ineffective policies and procedures in relation to due diligence undertaken prior to white label agreements.
John Pierce, Commission Head of Enforcement, said: “This case involves a gambling company that was unwilling or unable to meet the regulatory standards we expect from our licensees. It is right that they have now exited the British market.
“Following TGP’s exit, several online gambling operators can no longer lawfully offer gambling facilities to consumers located in Great Britain. These sites, previously operating under TGP’s licence, may not provide adequate protection against criminal activity or gambling-related harm and should not be available to GB consumers with immediate effect.”
He continued: “We have already been in contact with several football clubs today to highlight the impact of the withdrawal from the market by TGP and make clear that we will be carrying out checks-without further notice-to ensure these sites remain blocked. We will also conduct ongoing spot checks as necessary to ensure they are not accessible to consumers in Great Britain by any means. Should any of these sites be available to GB consumers, we will take appropriate action.
“It is essential that football clubs play their part in protecting fans and GB consumers who may be exposed to advertising of these sites through their sponsorship arrangements from harm or exploitation. All licensed operators with similar arrangements to TGP should take notice of the action taken in this case.
“We would like to warn consumers that sites operated by TGP are now unlicensed and may not provide protections against criminality or gambling related harm.”
The post TGP Europe Leaves GB Market Following UKGC Investigation appeared first on European Gaming Industry News.
Australia
ACMA Imposes Fine of $500,800 on PointsBet

The Australian Communications and Media Authority (ACMA) has imposed a fine of $500,800 on PointsBet Australia Pty Ltd for breaching the e-marketing and gambling self-exclusion laws.
Investigations by the Australian Communications and Media Authority (ACMA) found that the company sent more than 800 messages that breached Australia’s spam laws.
PointsBet also contravened laws relating to BetStop – the National Self-Exclusion Register (NSER), by delaying closing accounts of customers who had registered and sending marketing messages to self-excluded persons.
Between September and November 2023, PointsBet sent 705 emails containing a direct link to its betting products without including an unsubscribe function.
The emails were mischaracterised by PointsBet as “non-commercial” despite promoting their services, making them subject to the spam rules.
PointsBet also sent seven marketing emails without recipient consent and 90 commercial texts that did not have sender contact information.
The NSER investigation found PointsBet sent 508 marketing messages to self-excluded individuals in August and September 2023. Under the NSER laws, people registered with the NSER must not be sent marketing materials from a licensed wagering service.
ACMA Chair Nerida O’Loughlin said there are no excuses for gambling companies that fail to understand their legal obligations given the risks to people experiencing gambling harms.
“It is deeply concerning that these failures have impacted PointsBet’s customers, some of whom had taken proactive steps to exclude themselves from online wagering,“ Ms O’Loughlin said.
“People signing up to the NSER are taking positive steps to remove online gambling from their lives. Their decision must not be compromised by companies like PointsBet.
“Wagering providers must also appropriately identify where messages promote or advertise their services and ensure that those messages comply with the rules, including the obligation to promote the NSER.”
The ACMA found that no excluded customers were able to place bets with PointsBet during the period investigated. The ACMA has accepted comprehensive court-enforceable undertakings from PointsBet committing it to reviews into its compliance with spam and NSER laws, actioning any recommended improvements and providing regular training for all relevant staff.
“This action should serve as a warning to all wagering providers that they must meet their legal obligations or face the consequences. We will closely monitor PointsBet’s compliance with its undertakings and with the spam and NSER laws,” Ms O’Loughlin said.
The imposition of a financial penalty was not available to the ACMA for the NSER breaches due to the complex and novel matters investigated. However, a failure to comply with an enforceable undertaking can lead to court-ordered financial penalties.
Compliance with interactive gambling safeguards and misleading spam messages are both current compliance priorities for the ACMA. This is the first enforceable action announced under the NSER rules, and businesses have paid more than $14 million in spam penalties over the last 18 months.
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Compliance Updates
IGT-led Consortium Will be Proposed to be Awarded the Italy Lotto License Through November 2034

International Game Technology PLC announced that the Judging Commission completed its analysis of the technical and economic offers in the bid for the Italy Lotto License and will propose LottoItalia, a consortium comprises Allwyn, Arianna 2001 and Novomatic Italia and led by IGT, to the Agenzia delle Dogane e dei Monopoli (ADM), which is expected to make the award notice within the next 35 days.
“The Italian Lotto concession is one of the world’s most important lottery contracts. IGT and its predecessor companies have successfully managed the license for 30+ years through constant innovation and the introduction of cutting-edge technology. The award is very gratifying, and we are honored and excited to continue working with the ADM for nine more years,” said Marco Sala, IGT Executive Chair of the Board.
“The €2,230 million investments in upfront fees reflect the significant value of the new license and IGT is confident that the investment will enhance our revenue and profit potential. The exciting innovation pipeline with fresh launches planned for commencement of the new license will drive Lotto wager growth. In addition, we plan to significantly grow our iLottery sales and leverage that momentum to expand into the Italian B2C iCasino, sports betting, and other digital gaming business,” said Vince Sadusky, CEO of IGT.
The consortium’s comprises a €2230 million upfront license fee payable in three installments between the time of award and April 2026. IGT currently expects the first two installments of €500 million and €300 million to be made in 2025, with the balance made in 2026.
The nine-year license term secures the business until November 2034. The concession rate collected from total wagers is 6% and an additional 8% gross fee is collected through the digital channel as a distributor fee.
IGT maintains operational control of the business. Allwyn Entertainment is committed to the consortium and contributes a pro-rata share of license fees and capital expenditure.
The post IGT-led Consortium Will be Proposed to be Awarded the Italy Lotto License Through November 2034 appeared first on European Gaming Industry News.
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