Compliance Updates
How Curacao new AML requirements differ from other flexible license jurisdictions
By: Dmitry Hotsyn, Senior Consultant and Head of CIS Desk at 4H Agency
Discussing Anti-Money Laundering (AML) rules in a way that keeps everyone awake is a real challenge. The iGaming industry often overlooks anything filled with jargon like KYC, AML, CDD, and SoWs—terms that just breed myths and misconceptions about jurisdictions supposedly having lax AML standards and low compliance burdens. For a while, Curacao was viewed as one of these almost mythical places.
Not anymore.
A significant shake-up has occurred with Curacao’s latest overhaul of its AML regulations, set to take effect on September 1, 2024. This update has triggered quite a bit of debate among gambling operators who view these new rules as unwelcoming, especially since Curacao is known for its sluggish pace in updating its gambling regulations.
But may it really be as bad as Curaçao’s deadline management?
Curacao’s AML Regulatory Changes: An Overview
Curacao is continuously revamping its regulatory frameworks, taking a page from Malta’s book — Maltifying the industry may work best to describe this process. The new AML rules, while perceived as burdensome, are in fact a balanced update alligning the Curacao practices with generally acceptable standards. Key aspects of the new regulations include:
- Clear Customer Due Diligence (CDD) thresholds: Operators must conduct CDD at the earliest practical time, but no later than when a player engages in a transaction amounting to approximately EUR 2200;
- Sanction and Politically Exposed Persons (PEP) Screening: Mandatory for at least EU, US and UN sanctions lists;
- High-Risk Indicators: A detailed list of indicators for high-risk cases has been provided, noting that the use of cryptocurrencies increases risk, though it is not outright prohibited;
- AML Officer Role: Each operator shall have a dedicated AML officer, equipped with sufficient resources and headcount to manage risks effectively;
- Policies and Guides: Ah year, more internal docs, rules and practice guides are expected from the operators holding licences in Curacao.
Despite the extensive nature of Curacao’s new rules, in essence, they closely resemble those enforced in Malta and other EU countries, as well as competing jurisdictions offering flexible licenses. The upcoming webinar hosted by 4H Agency and Hipther Agency will delve into these comparisons, focusing on jurisdictions like Anjouan, Kanawake, and Tobique, alongside Curacao.
Key Insights on AML Across Jurisdictions
- Detailed AML Frameworks: Curacao and Tobique lead with the most comprehensive AML regulations. Kanawake’s requirements are also robust albeit not as detailes as Curacao rules;
- CDD Thresholds: Similar financial thresholds exist across these jurisdictions (approximately EUR 2000), with varied stipulations on the timing of CDD post-player registration (again, Curacao is not the leader here);
- Outsourcing AML Functions: All jurisdictions permit outsourcing some AML activities to third-party providers, providing flexibility in compliance strategies;
- Stringency of Regulations: Tobique’s regulations are notably stringent, casually requiring additional checks like adverse media searches to identify higher risk profiles;
- Anjouan the Outlier: Anjouan stands out for its outdated AML framework, lacking specific provisions for the gambling sector. For now, this could attract operators seeking more AML-friendly environments. However, Anjouan will inevitably follow the Curacao’s reformatory steps if the country intends to make iGaming an important factor of the now-struggling economy.
The evolution of AML regulations in Curacao represents a predictable shift towards more robust regulatory environment, aligning more closely with global standards. While initially perceived as onerous, these changes are in line not only with international practices, but with the rules already in force in a competing jurisdaction.
Our upcoming webinar will further explore these developments, providing attendees with comprehensive insights into flexible licensing options in 2024.
Compliance Updates
Danish Gambling Authority Opens Applications for Land-based Bingo Licences
The Danish Gambling Authority has officially opened applications for land-based bingo licences under the country’s new regulatory framework.
The licences will be valid from 1 January 2025 for applicants who meet the required conditions and submit complete applications by 10 December 2024.
This development provides opportunities for operators to offer land-based bingo within a regulated environment.
To assist prospective applicants, the Danish Gambling Authority has created a dedicated “Land-Based Bingo” webpage. Here, operators can access application materials, guidelines and instructions to ensure submissions are completed accurately.
Operators seeking a licence valid from 1 January 2025 must submit their applications by the 10 December deadline. Applications that meet all requirements will be processed in time for the start date.
In cases where additional information or conditions are needed, the authority may issue licences with specific stipulations, granting operators additional time to address outstanding issues.
To support industry stakeholders, the Danish Gambling Authority will host an information meeting about the new land-based bingo rules on 5 December 2024. The session will take place at Englandsgade 25, Odense, and interested parties are encouraged to register by 29 November 2024.
Compliance Updates
CT Interactive announces certification of new games for the Italian market
CT Interactive is thrilled to announce that new titles have officially received certification for the Italian market, ready to bring a fresh wave of entertainment to players across the country. This certification ensures that the games adhere to Italy’s stringent regulatory standards for fairness, security, and quality, reinforcing CT Interactive’s dedication to providing top-tier gaming experiences.
The newly certified games include: 5x Cherry Party, Christmas Storm, Jester Jack, Lucky Kiwi, Mega Gnome, Piggy Crash, Star Girl, The Big Chilli, The New Queen of Fruits, Treasure Chase.
These exciting games offer a diverse range of themes, from the festive charm of Christmas Storm to the whimsical adventures of Piggy Crash and Mega Gnome. Whether players are in the mood for the nostalgic appeal of a classic fruit slot like The New Queen of Fruits, or looking for thrilling treasure hunts in Treasure Chase, there’s something for every type of player.
Each game has been developed with a focus on delivering engaging features, rewarding bonuses, and immersive gameplay. With unique mechanics and visually striking graphics, these releases are designed to captivate Italian players and keep them returning for more.
CT Interactive remains committed to enhancing the Italian gaming landscape by consistently providing fresh, exciting content and introducing new ways to play.
Compliance Updates
MGA Marks Safer Gambling Week by Hosting Focus Group on Addressing Problem Gambling
As part of Safer Gambling Week, the Malta Gaming Authority (MGA) has launched the first in a series of focus groups aimed at addressing problem gambling and its effects on Maltese communities.
Bringing together key stakeholders such as Caritas Malta, Aġenzija Sedqa, the OASI Foundation and the Responsible Gaming Foundation, the session explored a self-assessment tool that the Authority is currently developing, grounded in recent research and industry trends.
The self-assessment tool, which will be available both in English and in Maltese, will guide individuals through a set of questions to help them identify whether gambling is causing harm in their lives. Based on the user’s responses, the tool will provide personalised recommendations and direct them to appropriate support services.
With invaluable input from organisations experienced in supporting individuals affected by problem gambling, the tool will undergo further refinement to maximise its effectiveness and relevance.
Clinical Chair at Aġenzija Sedqa, Anna Maria Vella, hailed the focus group as a “welcome initiative” which brought together a multidisciplinary team of experts.
“Working together and not in silos is always beneficial. We learn from each other to be more effective.”
Louis Bellizzi, Secretary of Caritas’ Foundation for Victims of Usury, said: “The MGA is in a unique position to coordinate the national effort to help alleviate the scourge of gambling addictions.”
In recent years, the Authority has taken significant steps to promote safer gambling practices, ranging from regular supervisory reviews on responsible gambling to enforcing stricter regulations.
The MGA closely monitors operators’ implementation of behavioural monitoring systems, self-exclusion systems and responsible marketing practices.
With a focus on high-risk areas, the Authority is refining its supervisory approach to be more dynamic and data-driven, ensuring responsible gambling practices are maintained and continuously improved to protect players effectively.
The MGA’s efforts align closely with the European Gaming and Betting Association (EGBA)’s initiative to establish a unified European standard for identifying markers of harm. The MGA is actively engaged in this initiative, working closely with fellow regulators and industry experts to create a comprehensive standard aimed at early identification of behaviours indicative of problem gambling.
The Authority’s proactive involvement in such initiatives underscores its dedication to fostering a responsible and transparent gaming sector, both locally and across Europe.
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