Highly experienced team with a great understanding of your needs
We have a great understanding of licensing and regulatory compliance across multiple jurisdictions, along with a strong foundation in client due diligence, anti-money laundering, risk and data protection.
If an operator registers players in the Isle of Man then the operation requires an OGRA licence.
Where an operator collects and stores personal details (such as name, age, address, username, password – in effect any information which could be used to identify a living person) for the purposes of gambling it requires a licence. Our advisers can help draft and implement processes for you to collect customer information for purposes of registering them in a compliant manner.
Customer Due Diligence
In addition, we will work with you to ensure that results of your Know Your Customer/Customer Due Diligence checks performed by you as the operator are available to the Commission upon request. The Inspectorate will also review the screening policy for appropriate staff designed to check their integrity before exposure to player funds or information. Appropriate staff are defined as those who can directly participate in the running or support of the operation or in its management and direction.
Anti-Money Laundering/Countering Financing of Terrorism
We will ensure that any new business to the sector has Anti-Money Laundering/Countering Financing of Terrorism procedures in place including provision within the staff handbook to ensure that appropriate staff are advised of their obligations. We need to evidence that the 2013 AML Code (Money Laundering and Terrorist Financing (Online Gambling) Code 2013) has been obtained and understood, and ensure that a suitable Money Laundering Reporting Officer (MLRO) has been appointed. The Commission, through its Inspectorate, will evaluate this individual’s background, qualifications and previous experience to ensure they are competent in the role. It is important that appointed MLROs have independent and unimpeded access to the board or ownership of a company: and we will formally demonstrate this for the company records.
It is important to recognise that where you intend to devolve elements of your operation to third parties the Commission may feel that there is a player protection implication, then it is expected that the prospective licensee should negotiate a right of inspection on the Commission’s behalf. Such an inspection if notified would only apply to the third party’s Isle of Man facing business and we would work with you to handle the administration.
Even where the right of inspection is not required, such as when a new operator joins a license-holder using an OGRA network services licence to offer play on its equipment, the Commission will still expect its licensees to only enter into business arrangements with companies that can demonstrate they operate to international (and therefore Isle of Man) standards of Anti-Money Laundering/Countering Financing of Terrorism. Likewise, any business undertaken by a third party on behalf of an Isle of Man license-holder must also be performed to international (and therefore Isle of Man) Anti-Money Laundering/Countering Financing of Terrorism standards.