Anti-Money Laundering


A term mainly used in the financial and legal industries to describe the legal controls that require financial institutions and other regulated entities to prevent, detect, and report money laundering activities.

General Description of Requirements for IP-Operators

Curaçao eGaming requires IP-Operators to apply enhanced customer due diligence measures to manage and mitigate risks of money laundering and the financing of terrorism. Each IP-Operator therefore has to determine within its operation the type of enhanced due diligence measures to be taken.

A need for Harmonisation on regulator level

Those different approaches between IP-Operators may create weak spots on the management of business relationships involving high-risk operations such as gaming. It is therefore important to improve the effectiveness of the said measures by providing for a harmonised treatment of those IP-Operators at the level of the regulator ("CEG"). That harmonised approach should primarily focus on enhanced End User as well as Critical Supplier due diligence measures, where such measures are not already required under national law. In accordance with international obligations, IP-Operators are required to apply additional mitigating measures complementary to the enhanced due diligence measures, in accordance with a risk based approach and taking into account the specific circumstances of business relationships or transactions.

Requirements for CSP’s

In addition, Corporate Service Providers ("CSP's") providing management for these IP-Operators should require obliged entities to apply additional mitigating measures by taking into account calls for countermeasures and recommendations, such as those expressed by the FATF, and responsibilities resulting from international agreements.