In this section, the rules and regulations regarding requirements for AML Reporting are discussed.

AML-Reporting Requirements further explained

Operators are required to report every Quarter to CEG on matters of AML. For this purpose, the Operator shall appoint a Money Laundering Reporting Officer, (hereinafter: the “MLRO”) who as the Non-Executive Director shall be responsible for the filing of a Quarterly preformatted Report, pertaining a risk analysis on Money Laundering (hereinafter: the “MLR” or the “AML-Report”) with CEG.

The Executive Director shall prepare the AML Report, the Non-Executive has to approve and file it with CEG

The Executive Director shall be responsible for the drafting of the MLR and shall timely present a properly filled out MLR to the MLRO for approval and filing with CEG.

Both the Executive Director as well as the Non-Executive Director are required to sign the MLR prior to its filing. The MLRO shall also be responsible for ensuring that, when appropriate, the information of any other matter leading to knowledge or suspicion, or reasonable grounds for knowledge or suspicion of Money Laundering is properly disclosed to CEG.

Minimum Reporting Requirements

The AML-Report shall at minimum include the following information:

(i) a general description of the policies on AML that have been implemented, including any updates or material changes;

(ii) any suspicions or Money Laundering;

(iii) any Incidents.

Immediate reporting required whenever Incidents transpire

Whenever Incidents transpire, the MLRO shall directly report such events to CEG and not wait for quarterly reporting to be due.

Duties of the MLRO

The MLRO is required to reside, as a resident, within Curaçao. The MLRO is allowed to combine other duties, if this may be deemed appropriate. CEG may order an Audit of the Administration of the Operator, costs to be borne by the Operator if it has a reasonable suspicion of Money Laundering or risks of Money Laundering.

Dormancy status does not negate reporting requirements

The Operator that has been granted Dormancy Status shall not be exempt from any of its obligations deriving from this section and shall therefore remain fully responsible for the Operation during the time of dormancy