Genuine relationships add real value in a digital world. That´s why eMoore N.V. and EMS Management Services N.V. (together: “EM Group”) aim to build long-term and personal relationships with you. It´s one of the many ways of how we raise your game.
We take care of all the requirements you need to comply with, so you can focus on reaching your goals.
Our proactive services generate additional value to you and therefore, we would like to inform you about some important regulatory developments.
Through this new article, we will explain the impact of these developments, what impact it will have on your business and how we can assist you to comply in an efficient manner.
Background on the regulatory developments for Curaçao e-Gambling license holder.
The Curaçao Gaming Control Board (“GCB”) has been officially tasked with the supervision of the gaming sector operating from Curaçao. The GCB exercises this supervision on the operators through the Master License Holder (“MLH”) and the Corporate Service Provider (“CSP”).
As part for the upcoming peer review by CFTAF, which is scheduled for Q3 2021, the preparation for a National Risk Assessment (“NRA”) in Curaçao is taking place. As a result thereof, and in accordance with the guidelines of the OECD, Curaçao operators of online games of chance are required to ensure that their terms of service shall remain compliant with the Fifth Anti-Money Laundering Directive.
In anticipation of these developments and the NRA, the MLH has sent us a letter regarding certain warrants to be confirmed by EM Group in our role as director/CSP.
What is required to comply with the regulatory developments for Curaçao e-Gambling license holders?
The MLH has requested EM Group to confirm that the following warrants are in place:
A. Warrant 1 –
FIU registration and reporting
EM Group is required to register each operator with the Financial Investigation Unit and keep a copy of this registration on file. Any reportable event should be reported timely and directly. This includes events where a third-party attempts to acquire any claims while this party was not a part of the original gaming agreement.
Warrant 2 –
AML/CTF policies and T&C
EM Group is required to obtain and review the AML/CTF policy of each operator. EM Group should have proof on file that sufficient measures by the operator are taken to prevent manipulation or abuse of Know Your Customer Information in relation to accounts of players (“end users”). Furthermore, the General Terms and Conditions should reflect that rights, benefits or claims pertaining to these accounts cannot be transferred or sold by the end user.
Warrant 3 –
EM Group needs to have on file at all times, proof that the operator’s website includes a clearly visible link to policies on Responsible Gaming, including but not limited to policies of self-exclusion.
We expect that the MLH will send requests for additional confirmations in the near future, please subscribe to our newsletter so we can inform you.
Why is it important and what are the benefits of complying with the regulatory developments for Curaçao e-Gambling license holders?
Compliance with these requirements is not only important for your continued eligibility for a Curaçao gaming license, but also for the reputation of the Curaçao gaming sector in general. A robust and solid regulatory framework will strengthen the position of the Curaçao license in the online gaming sector and will also increase confidence of players in the level of professionalism.
What can we do for you?
Given the importance of these developments and to ensure that you comply with these new requirements we can further assist you as follows:
- Taking care of registration with FIU if such was not already done in December 2019;
- Drafting and providing an AML policy;
- Providing terms and conditions, specifically aimed at meeting the warrants mentioned above;
- Providing a Responsible Gaming policy, if not yet in place.
In view of these and possibly further upcoming regulatory requirements, we can also arrange for an (employed) compliance coordinator to deal with the specific AML related and regulatory compliance requirements on your behalf. This will also likely help to comply with stricter real presence requirements that were introduced in the revised tax legislation at the beginning of this year.