SteelRose Legal has recently been involved in the process of applying for a licence in Curaçao. Under Curaçao's regulatory framework, appointing a compliance officer is a mandatory requirement. This article will exclusively address the regulatory requirements of the licence pertaining to the appointment of the Anti-Money Laundering (AML) Officer.
In December 2024 the Curacao Gaming Control Board (Regulator/ GCB) published the GCB Requirements for Compliance Officer Based on NOIS/NORUT, which outlined a detailed description of the key responsibilities of the compliance officer and guidelines for the role of a compliance officer.
The GCB will only license those operators whose compliance officers meet the requirements. The person acting as a compliance officer must demonstrate professional experience, competence, and integrity. This includes specific requirements for those authorised by the GCB to act as a compliance officer for a gaming operator.
Suitability
The operator is required to submit the compliance officer’s CV to GCB for review. The Regulator will assess the individual's background and experience, including any past legal or regulatory issues, ensuring there is no history of criminal activity, regulatory violations, or other conduct that could raise concerns about their suitability for the role. GCB will verify individual's reputation through reference checks and, where applicable, consultation with relevant regulatory or industry bodies.
Competence
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.
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.
The Compliance Officer must demonstrate a willingness to undertake continuing professional development by completing at least 10 hours of AML-related training each year. This may include industry-specific training and workshops offered by the GCB.
The role of compliance officer shall not be combined with any other function that may create a conflict of interest or compromise the independence of the Compliance function. Specifically, the role of compliance officer cannot be merged with the functions of UBO, CEO, CFO, COO, Casino Manager, Slot Manager and other operational functions. It is equally important that the compliance officer’s role remains distinct from the internal audit function.
The GCB permits the outsourcing of the compliance function to a reputable third party, including from the foreign jurisdiction, provided that the third party has sufficient time and resources to perform all functions effectively. It should be noted that B2B licensees are not required to appoint a compliance officer under the requirements set out in this guidance.
Compliance officer is responsible for the following:
At SteelRose Legal , we draw on extensive experience with regulatory frameworks, including those applicable in Curaçao, such as AML regulations issued by the GCB. Combined with our expertise in screening against EU and OFAC sanctions lists, we provide clients with practical support and informed guidance to address their compliance and operational needs.
In December 2024 the Curacao Gaming Control Board (Regulator/ GCB) published the GCB Requirements for Compliance Officer Based on NOIS/NORUT, which outlined a detailed description of the key responsibilities of the compliance officer and guidelines for the role of a compliance officer.
The GCB will only license those operators whose compliance officers meet the requirements. The person acting as a compliance officer must demonstrate professional experience, competence, and integrity. This includes specific requirements for those authorised by the GCB to act as a compliance officer for a gaming operator.
Suitability
The operator is required to submit the compliance officer’s CV to GCB for review. The Regulator will assess the individual's background and experience, including any past legal or regulatory issues, ensuring there is no history of criminal activity, regulatory violations, or other conduct that could raise concerns about their suitability for the role. GCB will verify individual's reputation through reference checks and, where applicable, consultation with relevant regulatory or industry bodies.
Competence
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.
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.
The Compliance Officer must demonstrate a willingness to undertake continuing professional development by completing at least 10 hours of AML-related training each year. This may include industry-specific training and workshops offered by the GCB.
The role of compliance officer shall not be combined with any other function that may create a conflict of interest or compromise the independence of the Compliance function. Specifically, the role of compliance officer cannot be merged with the functions of UBO, CEO, CFO, COO, Casino Manager, Slot Manager and other operational functions. It is equally important that the compliance officer’s role remains distinct from the internal audit function.
The GCB permits the outsourcing of the compliance function to a reputable third party, including from the foreign jurisdiction, provided that the third party has sufficient time and resources to perform all functions effectively. It should be noted that B2B licensees are not required to appoint a compliance officer under the requirements set out in this guidance.
Compliance officer is responsible for the following:
- Designing and implementing the AML program.
- Ensuring compliance with Curaçao laws and regulations regarding money laundering and terrorist financing.
- Reviewing adherence to the operator’s policies and procedures.
- Organising staff training sessions on compliance-related issues.
- Analysing transactions and identifying those subject to reporting.
- Reviewing internally reported unusual transactions for completeness and accuracy.
- Maintaining records of both internally and externally reported unusual transactions.
- 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.
At SteelRose Legal , we draw on extensive experience with regulatory frameworks, including those applicable in Curaçao, such as AML regulations issued by the GCB. Combined with our expertise in screening against EU and OFAC sanctions lists, we provide clients with practical support and informed guidance to address their compliance and operational needs.