June 16, 2025
Getting your Compliance Officer appointment right is not just about ticking a regulatory box
Getting your Compliance Officer appointment right is not just about ticking a regulatory box for the Curaçao Gaming Authority (CGA)—it directly impacts your operational efficiency and long-term success in Curaçao's iGaming market.
Legal foundation that drives results
Under Curaçao's National Ordinance Identification when Rendering Services (NOIS) and National Ordinance Reporting of Unusual Transaction (NORUT) laws, your Compliance Officer serves as your primary defense against Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Proliferation Financing (PF) violations. This role delivers measurable protection for your business operations while ensuring regulatory adherence.
The CGA’s official Requirements for Compliance Officer Based on NOIS/NORUT guidelines provide the complete framework for these standards and serve as your essential compliance reference.
Independence requirements that protect your investment
Your Compliance Officer must operate independently from operational roles. This means they cannot hold positions as CEO, CFO, COO, UBO, Casino Manager, or engage in internal audit functions. This independence structure prevents conflicts of interest that could expose your business to regulatory scrutiny.
The individual must maintain impeccable integrity with no criminal or regulatory infractions. They need comprehensive knowledge of Curaçao laws (NOIS, NORUT), EU/OFAC sanctions, and CGA regulations, plus 10 hours of annual AML training.
Two clear qualification paths
Option A: Bachelor's degree with 2 years of AML/CFT experience and AML certification (CAMS or AMLFC)
Option B: 4 years of AML/CFT experience, or 2 years as Money Laundering Reporting Officer (MLRO)
Critical deadlines for your business
The CGA's AML and KYC policy review begins July 1, 2025, with inspections starting September 1. These dates directly impact your operational readiness.
If your current Compliance Officer does not meet requirements, you have until June 30, 2025, to make necessary adjustments. The CGA requires immediate compliance for your appointed Compliance Officer's suitability—no exceptions.
You have until June 30, 2025, to ensure your Compliance Officer reaches expected competence and responsibility levels. If your Compliance Officer lacks necessary experience or education, you have one year to enhance their knowledge to meet standards, but you must submit a detailed training plan that the CGA will monitor.
Missing these deadlines puts your license at risk and disrupts your business operations.
We previously covered the CGA's AML policy deadline for all license holders - these new Compliance Officer requirements build on those foundational compliance obligations.
We have the expertise to ensure that your Compliance Officer is up to speed on all relevant CGA topics. Contact us today!
Core responsibilities that deliver value
Your Compliance Officer will design and implement your AML/CFT program, ensuring compliance with laws and internal policies. They conduct transaction monitoring, identify unusual transactions, and report suspicious activities to the Financial Intelligence Unit (FIU).
Additional responsibilities include maintaining comprehensive records, organizing staff training, staying current on AML/CFT developments, and preparing periodic reports with improvement recommendations.
Access and authority for maximum effectiveness
We ensure your Compliance Officer has timely access to customer identification, due diligence records, transaction details, and internal reports. They report directly to senior management and handle external reporting through the goAML portal.
Flexible solutions for your business needs
Compliance functions can be outsourced to qualified third parties while you retain ultimate responsibility. One individual can oversee up to 10 operators and work across multiple jurisdictions when workload management allows.
Streamlined screening process
The fit and proper process requires submitting a comprehensive Personal History Disclosure Form to the CGA, including CV and supporting documents. The CGA evaluates personal and professional history plus reputation through reference checks and regulatory consultations.
Your next step
We help you identify and appoint the right Compliance Officer for your specific needs. Our expertise in Curaçao's regulatory landscape ensures your appointment meets all requirements while supporting your business objectives.
Contact us to discuss how we can streamline your Compliance Officer appointment process with a truly unique solution.
Written by Arran McCarthy
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