From November 12 to 14, 2019, the Curaçao Gaming Control Board (GCB) organized an AML/CFT in Gaming Workshop. This event, held at the Central Bank of Curaçao and Sint Maarten, was officially opened by the Minister of Finance, His Excellency Mr. Kenneth Gijsbertha. Mr. Gijbertha pointed out that the workshop was an important step in the awareness of all the stakeholders that can contribute to getting the Curaçao gaming industry AML/CFT-compliant prior to the 4th Mutual Evaluation by the Caribbean Financial Action Task Force (CFATF) in the year 2022. Considering the available timeline, compliance must be pursued with the utmost sense of urgency.
The workshop started with a full day general session. An introductory presentation was given by GCB’s Director General, Mr. Gino Campbell, who discussed the way forward for the GCB to execute their responsibility as the AML/CFT supervisory authority for the Curaçao gaming industry. The presentation of Mrs. Anne-Marie Kemna, Director of the FIU Curaçao, distributed the message that “turning a blind eye” on AML/CFT-compliance in our new reality is unacceptable. Mrs. Kemna also addressed the unusual transactions reporting (UTR) behavior and the quality of UTRs submitted by gaming licensees. Mr. Daniel Kalkhoven of Caribbean Identity informed the participants of the challenges in spotting false identification and other documents in the customer due diligence process and offered a technological solution to make the process more efficient and effective. Mr. Cedric Pietersz of the Central Bank of Curaçao and Sint Maarten presented the topic, De-risking, the good, the bad and the ugly.
Mr. Alan Pedley of Governance Associates subsequently took over the reigns of the workshop and supplied insights into the money laundering vulnerabilities in the gaming sector and the risk-based approach of gaming supervision. He also laid the groundwork for the next two days by introducing several money laundering typologies for land based casinos, lotteries and online gaming.
The general session was followed by three half day sessions, one half day each for land based casinos, lotteries and online gaming, where different stakeholders in a multi-disciplinary setting could practice in analyzing and scrutinizing different sector-specific scenarios for money laundering and terrorism financing risks and the mitigation of those risks.
The workshop brought together the different stakeholders that play a role in proper AML/CFT risk mitigation. The stakeholders included operators, regulators, FIU, trust company service providers, law enforcement, financial institutions etc. The objective of the workshop was to improve understanding of actual AML/CFT typologies for land based casinos, lotteries and online gaming, to create awareness and understanding of the role that each stakeholder plays in realizing compliance and to foster relationships between stakeholders.
On November 30, 2018, the Gaming Control Board (GCB) organized the Responsible Gaming conference on Curaçao titled, Responsible Gaming: A Team Effort!. The tile reflects the reality that successful countering of gambling addiction and promotion of responsible gaming requires the effort of multiple stakeholders.
In addition to the fantastic preparatory work by GCB’s Mrs. Ayeska Coster, the success of this event can be attributed to the enthusiastic participation of the local gaming industry, members of Parliament, government representatives and the terrific presentations by Fundashon pa Maneho di Adikshon (FMA) and Mr. Keith Whyte, Executive Director of the National Council of Problem Gambling (NCPG).
At the end of the day, there was consensus that the gambling addiction reports for Curaçao are in desperate need of updating. Furthermore, the gambling addiction problem in Curaçao is not to be underestimated and needs to be on the radar of lawmakers as well as the executive branch of government. Funds need to be made available to finance professional avenues of treatment and guidance.
The popular Curaçao playwrite, actor and director, Percy “Boskwiri” Benita and the Curaçao Gaming Control Board (GCB) closed ranks to create awareness for the gambling addiction challenges that Curaçao faces. The GCB sponsored 3 performances for middle and high school students of Boskwiri’s play B’a Hink’é, Sak’é Awó, a tragicomedy that depicts the ripple effect of the harm gambling addiction causes to a family and a community. After each performance, a short info session was provided by the GCB and the Fundashon pa Maneho di Adikshon (FMA) on the available avenues for assistance when confronted with gambling addiction.
In 2017 the Gaming Control Board (GCB) hosted a three day event, the 2nd Dutch Caribbean Gaming Regulation Forum (DCGRF), organized by The International Governance and Risk Institute (GovRisk) from London, the United Kingdom.
GovRisk has provided high quality consultancy and training programmes to public and private sector institutions from more than 30 countries. They offer a wide variety of programmes covering specific topics within the broader fields of financial crime, corruption, risk management and governance.
The 2nd DCGRF, visited by 100+ participants from the gaming and financial services sectors in the different countries in the Dutch Caribbean, was officially opened by the Minister of Finance, His Excellency Mr. Kenneth Gijsbertha.
Topics of the forum included:
• The Regulatory Requirements for Modern Gaming Operations
• The Role of Industry in Promoting Good Regulatory Policy
• Implementing Supervision and Enforcement Measures - Grey and Black Operations
• The Challenges and Opportunities Facing a Small-Market Gaming Jurisdiction
• Comprehensive Compliance and Due Diligence in Gaming
• Security, Vetting and Internal Investigations
• AML/CFT in Gaming - Risks, Red Flags and Best Practice
• Case Studies: Catastrophic Gaming Failures and Their Causes
• Practical Governance Considerations for Gaming Operations
• Discussion Session: Does Grey Gaming Exist in Online Operations?
• Data Breaches, Leaks and the New Frontiers of Cybersecurity
• The Effect of New Technologies on Regulatory Compliance
• The Future of Identity in Online Gaming
• Bitcoin, Cryptocurrencies, Blockchain - What Impact are they Having on Gaming?
• Responsible Gaming Approaches in Gaming Operations
• A Caribbean Lotto - the Risks and Returns for Small Islands
• Panel Session: The Future of Gaming Regulation at Home and Abroad
On August 24 and 25, 2016, gaming and lottery regulators and government lottery representatives from all over Latin America and the Caribbean gathered together in Curacao to participate in Gaming Laboratories International's (GLI) unique Latin American and Caribbean Regulators Roundtable.
GLI is the world’s leading gaming laboratory that provides services and tools for regulators, suppliers and operators.
Government lotteries and gaming and lottery regulators from more than 36 entities and two associations (ALEA and CIBELAE) from 22 countries from the Caribbean and Latin American region participated in this unique event. This year, the event saw almost 90 attendees who represented the following countries: Argentina, Aruba, Belize, Bolivia, Brazil, Chile, Colombia, Curacao, El Salvador, Guyana, Honduras, Jamaica, Mexico, Panama, Paraguay, Peru, Puerto Rico, Saint Maarten, Trinidad and Tobago, Turks and Caicos Islands, Uruguay and Virgin Islands.
The free, two-day event allowed attendees the opportunity to not only attend and participate in high-level discussions relevant to the Latin American and Caribbean region, but also to speak with like-minded professionals and ask the experts questions about the industry. Event topics included:
• Understanding Regulatory Tools – When and How to Use Them
• Governance and Acting Under Strict Rules of Law
• Certification Process – Back to the Basics
• Minimum Internal Controls in the Lottery and Gaming Industry: Why and How to Audit
• The Gaming and Lottery Industry of the Future
• iGaming and Sports Betting Regulations and Operations from a Risk Control Perspective
• Multijurisdictional Games in the Gaming and Lottery Industry
• Bringing It All Together – Open Forum
• Responsible Gambling in the Lottery and Gaming Industry
• The Current State of the Anti-Money Laundering Guidelines
• What Information Security Means to You: Is It Crucial for Your Organization?
• Online Monitoring and Control System: The Latin American and Caribbean Experience
As part of the program, Regulators Roundtable participants traveled to a local casino to watch a live on-site inspection demonstration of their monitoring and control system, courtesy of the Curaçao Gaming Control Board.
The Regulators Roundtable was concluded with a cocktail event, providing attendees with an exclusive opportunity to network with other professionals and further discuss topics presented at the educational event.
This Roundtable was successful not only in terms of content and attendance, but also in its contribution towards developing the camaraderie among attendees that will hopefully continue as one of many of the positive results of the event.
On November 23, 2015, the Gaming Control Board (GCB) organized the one day AML/CFT seminar, Money laundering risks for the casino industry. Mrs. Saskia Rietbroek, LL.M, MBA, CAMS, President of AML Services International (AMLSI) (www.nomoneylaundering.com) and founding Executive Director (September 2001 to December 2005) of the Association of Certified Anti-Money Laundering Specialists (ACAMS), was found available to conduct the training.
The objective of this successful event, that could count on 60+ participants from all Curaçao casinos, the Financial Intelligence Unit Curaçao (FIU) and the GCB, was to provide insight inthe Curaçao AML/CFT legislation and related casino regulation, the reporting portal of the FIU and the assessment of AML/CFT risks inherent to landbased casinos.
Training topics included:
• Money laundering methods and risks – Introduction
• Money laundering methods and risks in casinos
• International guidance for money laundering controls
- Financial Action Taskforce (FATF) Guidance
- American Gaming Association Best Practices document for AML Compliance
• Pillars of a sound and risk-based AML Compliance program
- Designated compliance officer
- Internal controls, policies and procedures
- AML training
- Independent review
- Detection of unusual activity, including FinCEN’s Guidance “Casino or Card Club Risk-Based Compliance Indicators”
• Case studies with lessons learned from AML enforcement actions, and group exercise.