As a remote gaming entity authorized under the Remote Gaming Regulations are classified as carrying out “relevant financial business” under the Prevention of Money Laundering and Funding of Terrorism Regulations.
Consequently, it is designated as a subject-person and is obligated to comply with the pertinent legislation and guidance pertaining to anti-money laundering (AML) and counter-financing of terrorism (CFT). This includes supervision by the competent authority, the Financial Intelligence Analysis Unit.
2. Scope
The Anti-Money Laundering Process outlined herein aims to mitigate the potential misuse of Mirage Corporation’s services for criminal purposes or regulatory violations. This process provides guidance on AML and CFT prevention within the legal framework of Curaçao and internationally accepted regulations.
3. Law, Regulations, and Rules
This framework aligns with the Code of Criminal Law (Penal Code) of Curaçao, delineating procedures for prosecuting money laundering offenses, asset confiscation upon conviction, freezing assets during investigations, and issuing investigation and/or attachment orders.
The policies in this Manual adhere to the National Ordinance on Prevention of Money Laundering (NOPML), the National Ordinance on Reporting Unusual Transactions (NORUT), and the National Ordinance on Identification Service Providers (NOIS).
Additionally, the Central Bank of Curaçao and Sint Maarten’s Provisions and Guidelines, based on FATF recommendations, are integral to our AML/CFT measures.
4. Policy
Responsibility:
- The Director holds ultimate responsibility for Mirage Corporation’s AML policies.
AML Policies and Procedures:
- Detailed in this Manual, our policies and procedures align with AML and CFT regulatory requirements and undergo regular reviews.
AML Risk:
- Mirage Corporation’s AML risk model encompasses cultural commitment, identity verification, ongoing customer due diligence, staff training, and clear organizational structures.
AML Risk Factors:
- Categorized into Customer risk, Product risk, Interface risk, and Geographical risk.
5. Risk Assessment, Management, and Risk-Based Approach
Risk Assessment:
- Procedures enable identifying and assessing ML/FT risks, determining enhanced due diligence necessity, establishing timelines for customer due diligence, and evaluating customer risk.
Risk-Based Approach:
- Mirage Corporation adopts a risk-based approach, conducting risk assessments at onboarding and periodic intervals. Ongoing due diligence ensures up-to-date information, and a continuous risk assessment informs business development.
Financial Crime Risk Assessment:
- Undertaken during new services, customer groups, or market entries, guiding the development of systems and controls.
Risk Mitigation:
- Minimizing opportunities for financial crime through due diligence, risk assessment, and ongoing development of controls.
Monitoring Controls:
- Constant monitoring of controls to adapt to changing circumstances and promptly modify controls in response to identified risks.
As part of our commitment to compliance, Mirage Corporation actively reviews legislative developments, implements periodic internal controls, and regularly reassesses financial crime risks. This ensures a dynamic and responsive AML framework, contributing to a secure and compliant gaming environment.