Version 1.1. Last Updated: 13/05/21
AML/CFT POLICY LEGAL BACKGROUND
This Anti-Money Laundering and Countering the Funding of Terrorism (AML/CFT) Policy takes into consideration the recommendation developed by the GAFIC (Caribbean financial action task force).
All gaming operators have a responsibility to keep financial crime out of gambling.
The Curacao gaming board has a duty as a supervisory authority under the Regulations to ensure that adequate controls are in place to prevent gaming companies from being used for money laundering or terrorist financing.
The AML/CTF Policy is developed on the risk-based approach.
The main objective of the AML/CFT Policy is the adaptation of measures and policies, controls and procedures in order to mitigate the money laundering and funding of terrorism risk the company is exposed to.
The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.
To these ends:
- A risk-based approach will be adopted to the monitoring of the activities of the customers to allow the time and resources to be invested as applied where they are most required.
- CDD measures will apply to all customers, which includes collecting a series of personal details on the registration stage and verification of the data in the period of 72 hours.
- CDD measures will apply to the customers opening accounts for their own use as well as to the beneficial owners of the account.
- EDD measures will apply to all customers who have reached the 2000 Euro deposit threshold, which includes building a risk profile of the customer, online and media search, collection and verification of source of funds and source of wealth information, when needed.
- Ongoing monitoring of business relationship with the customers to be performed.
- Any suspicious activity will be reported to the GAFIC by submitting an STR and all AML activities will be recorded.
- The Money Laundering Reporting Officer is a main contact point in the company for GAFIC and act as the main channel through which any communications with GAFIC are to be conducted.
- A Compliance Officer responsible for overseeing the daily implementation of AML/CTF measures, policies, controls and procedures.
- All employees of the company are to be aware of AML/CTF risks, the company is exposed to, and of AML/CFT policies and procedures, AML/CTF obligations of the company and individual responsibilities.
- Regular training is provided to all relevant employees.