What are Key Functions and why do they matter?
Some regulators do not just require that an operator has the right procedures in place — they require that named, qualified individuals are personally accountable for those procedures. These roles are called Key Functions. The individuals who fill them are vetted by the regulator, approved before they start, and held directly responsible for the licensed entity's compliance.
Under the MGA framework in Malta, Key Functions include the Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, Chief Technology Officer, and Compliance Officer. Each role requires individual regulatory approval and carries ongoing personal accountability. Under the Curaçao LOK, the equivalent requirement is the Key Person — at least one of whom must be physically based in Curaçao, scaling to three local Key Persons by the operator's fifth year of operation.
For operators who do not have qualified in-house candidates ready, or who need to establish a local presence quickly, Key Function Services provide an experienced, regulator-approved individual on a managed basis. This is not a workaround — it is the standard approach used by operators entering a new jurisdiction for the first time, or scaling their operations without hiring a full in-house team immediately.
We provide Key Function Services for MGA-licensed operators in Malta and Key Person appointments for CGA-licensed operators in Curaçao.
