Money Laundering Reporting Officer

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CHAPTER C

iGAMING DATABASE

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ANTI-MONEY LAUNDERING

MONEY LAUNDERING REPORTING OFFICER

Related Elements

An officer responsible for ensuring that, when appropriate, the information or other matter leading to knowledge or suspicion, or reasonable grounds for knowledge or suspicion of money laundering is properly disclosed to the relevant authority.

Ip-Operators are required to appoint a Money Laundering Reporting Officer (the: “MLRO”).  This task is allocated to the Non-Executive Director, who has to be aware of any suspicious activity that might be linked to money laundering or terrorist financing, and if necessary to report it. The MLRO needs to be a Curaçao resident.

 

Although the Non-Executive shall hold the official title as MLRO, the Executive Director shall as non-resident be responsible for preparing Quarterly reports for the MLRO to review and approve. This shall be a combined report in which also technical as well as responsible gaming information shall be prepared and subsequently reviewed by MLRO. A standard reporting form is available for download in the iGaming Database.

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Frequently Asked Questions

Can a Curaçao iGaming license be held by a company that is non-resident, for example a Belize resident?

No. The legislation is clear. The IP-Operator needs to be a Curaçao resident. Deviation from this cardinal rule could lead to criminal prosecution.

Does the IP-Operator require a Money-Laundering Reporting Officer?

Yes. A resident MLRO is required to report to the appropriate authorities

Why is the Executive Director required to prepare the Report?

The Executive Director is selected from within the circle of key individuals. He or she is in the center of the team that handles the data necessary for the Reporting on a daily basis, as the Non-Executive Director is not and as a result the latter is partially dependent from the information provided by the (non-resident) team. Pretending otherwise would not be in line with substance requirements. Although the Non-Executive Director and Executive Director are jointly responsible for adequate reporting, it shall be the Non-Executive Director that shall approve or deny the Report.

When should the Quarterly Report be prepared by the Executive and subsequently filed by the Non-Executive?

The Report needs to be fully prepared, two weeks prior to the end of the Quarter. It needs to be filed, at the latest two week past the end of the Quarter.

The Company has not yet appointed a Non-Executive and/or Executive, what should I do?

Contact your corporate service professional as soon as possible to arrange this. I change of the articles of incorporation may be required, which may take some time.

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Money Launder Reporting Officer (MLRO) factsheet

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