Background: Gambling Sector Reform

Purpose of this session

This session focuses on the integrity, AML/CFT and enforcement framework proposed under the new Kansspelenverordening.

A central element of the reform is ensuring that gambling activities in Sint Maarten are conducted by reliable and suitable operators, and that the future Gambling Authority can cooperate effectively with the authorities responsible for financial intelligence, AML/CFT supervision, criminal enforcement and other relevant regulatory functions.

The purpose is to assess whether the proposed framework provides sufficient legal clarity, whether responsibilities between the different authorities are appropriately defined and whether the proposed arrangements can work effectively in practice.

Building on the 2025 stakeholder engagement

This consultation builds on stakeholder engagement undertaken in February 2025. Earlier discussions identified the need for greater clarity regarding AML/CFT responsibilities, financial and integrity oversight, information exchange between public authorities, enforcement against illegal gambling and the control of gambling related equipment and financial flows.

These matters have since been further developed in the draft Kansspelenverordening. This session returns to those issues on the basis of the actual proposed legislative framework.

What we would like to discuss

• • reliability, suitability and integrity requirements for applicants and license holders
• • the relationship between AML/CFT compliance and gambling licensing
• • access to information for background and integrity assessments
• • information exchange between the Gambling Authority and other competent authorities
• • supervision and enforcement of licensed gambling activities
• • cooperation in relation to suspected illegal gambling and other criminal activity
• • the relationship between administrative and criminal enforcement
• • practical arrangements for inter agency cooperation

Relevant parts of the draft Kansspelenverordening

Articles 2, 3 to 6, 9, 50 and 68 to 76 of the consultation version of the draft Kansspelenverordening dated 23 October 2026.

What we will explain and share

• • the role of the Gambling Authority and its cooperation responsibilities
• • the proposed reliability and suitability framework
• • the link between AML/CFT compliance and gambling licensing
• • the proposed supervision, information exchange and enforcement framework
• • how the current draft has developed since the 2025 stakeholder engagement
• • the proposed framework does not transfer the statutory AML/CFT supervisory role of MOT/FIU to the Gambling Authority — the Gambling Authority would have a separate licensing, integrity, supervision and enforcement role, supported by lawful information exchange and cooperation with MOT/FIU and other competent authorities

Key questions for consultation

1. 1. Does the proposed framework provide a sufficiently strong and workable basis for assessing the reliability, suitability and integrity of gambling operators, their management and beneficial owners?
2. 2. Are the respective roles and responsibilities of the Gambling Authority, FIU/MOT, law enforcement authorities and other relevant public bodies sufficiently clear?
3. 3. Does the proposed framework provide an adequate basis for timely and effective information exchange and cooperation between the authorities involved, while providing appropriate safeguards?
4. 4. Are the proposed supervisory and enforcement arrangements workable in practice, including the interaction between administrative enforcement and criminal investigation or prosecution?

Who we would like to have at the table

We particularly welcome participants with direct responsibility or expertise in:

• • AML/CFT supervision and financial intelligence
• • integrity and background assessment
• • criminal investigation and prosecution
• • operational policing and enforcement against illegal gambling
• • customs enforcement and relevant cross border movements
• • regulatory inspection and administrative enforcement
• • licensing and business permitting
• • legal and policy aspects of inter agency cooperation and information exchange

Expected outcome

Identify legal or practical gaps in the proposed integrity and enforcement framework, clarify the respective responsibilities of the authorities involved and identify issues that may require legislative, regulatory or implementation follow up.

How the input will be used

Feedback from the session will be assessed together with written responses received through the wider public consultation. Depending on the nature of the input, it may inform further refinement of the draft Kansspelenverordening, the accompanying Explanatory Memorandum, future secondary regulation, implementation arrangements or cooperation protocols. Participation does not imply that all views or recommendations will necessarily be incorporated into the final legislation.

Practical information

Date: Friday, 6 November 2026.

The session is part of the targeted stakeholder consultation. Organizations will be invited directly. Other interested stakeholders may participate in the wider public consultation and may register their interest in the stakeholder process through the consultation website.

Participation in a targeted session is not required in order to submit comments through the public consultation.