The UBO and other Key Individuals


In this section, the rules and regulations regarding rules and regulations pertaining Ultimate Beneficial Owners (“UBO’s”) and other Key Individuals.

All key individuals need to be known to and identified by the Operator

Prior to any B2C Services provided, the Operator is obliged to identify as well as register every natural individual whose knowledge and experience are essential to an adequate performance of the Operator (“Key Individual”), including UBO’s, with CEG. It is required to keep this information updated, as per relevant Curaçao and international legislation.

The Operator needs to actively establish that the registered UBO of the Operator, a Key Individual, is holding the Ownership for himself and not, as a Fiduciary, on behalf of other individuals or entities.

The Operator is required to actively establish that no Key Individuals are misrepresenting their position relating to the Operator, such as however not limited to UBO’s who act as advisors to the Operator, without disclosing that they are UBO, or individuals without any involvement in the Operator or substance, who misrepresent themselves as a Key Individual.

Key individuals are required to use their name when communicating with third parties

Key Individuals representing the Operator are at all times obliged to disclose their name in communication between Parties. Sole reference by Key Individuals to a general department is prohibited.

Key individuals need to be registered with CEG

The Operator is obliged to register a minimum of two Key Individuals with CEG and has the obligation to register proof of sufficient and relevant education, as well as proof of good conduct of its Key Individuals and furthermore is obliged to keep this information at all times up to date.

Fit and Proper

All Key Individuals are required to at all times be familiar with all rules and regulations that touch on B2C Services rendered by the Operator and to stay informed on any changes and developments. The Operator vouches for the performances of Key Individuals as if these performances have been its own. CEG may, without any liability, opt to Report Key Individuals that are in breach of rules and regulations as described in this section, to the appropriate authorities of the country of which they are resident.