Background: Gambling Sector Reform

Purpose of this session

This session focuses on the relationship between the future regulated gambling sector and Sint Maarten's financial system.

The draft Kansspelenverordening strengthens licensing, integrity, financial transparency, reporting and information exchange. It does not, however, require banks to provide services to gambling operators.

The purpose of the session is to understand whether the proposed regulatory framework can support a more transparent and bankable sector, and to identify practical AML/KYC, payment, cash management and reporting issues that should be considered during implementation.

Building on the 2025 stakeholder engagement

Banking access was a recurring issue during the 2025 stakeholder engagement. Stakeholders described a highly cash based sector, difficulties accessing banking services, AML/KYC concerns, alternative payment methods and the need for stronger financial transparency.

The current consultation does not treat banking access as solved. It provides an opportunity to test how the proposed licensing and regulatory framework interacts with the requirements and risk assessments of financial institutions.

What we would like to discuss

• • banking access for properly licensed gambling operators
• • AML/KYC expectations and the information financial institutions need from operators and the regulator
• • cash intensive operations and opportunities for safer payment channels
• • ownership, beneficial ownership and integrity information
• • financial reporting and regulatory data that may strengthen transparency
• • interaction between banks, CBCS, FIU/MOT and the Gambling Authority
• • payment service providers and digital payment channels
• • practical transition from the current environment to a more regulated sector

Relevant parts of the draft Kansspelenverordening

Articles 2 to 6 and 9 on licensing and integrity, Article 2, fourth paragraph, on use of a Sint Maarten bank account, Articles 10 to 12 on regulatory charges and data, Article 50 on the role of the Gambling Authority, and Article 73 on information exchange in the consultation version of the draft Kansspelenverordening dated 23 October 2026.

What we will explain and share

• • the proposed licensing and fit and proper framework
• • the proposed role of the Gambling Authority in supervision and information exchange
• • the financial transparency and reporting direction of the reform
• • the limits of what the Kansspelenverordening itself can do in relation to commercial banking decisions

Key questions for consultation

1. 1. What information and regulatory assurances do financial institutions need in order to assess licensed gambling operators under their normal risk based AML/KYC frameworks?
2. 2. Can the proposed licensing, ownership transparency and reporting framework materially improve confidence in the regulated gambling sector?
3. 3. What practical steps could reduce dependence on cash while maintaining appropriate AML/CFT safeguards and commercial risk controls?
4. 4. What cooperation and information exchange arrangements between financial institutions, CBCS, FIU/MOT and the Gambling Authority would be useful and legally appropriate?
5. 5. Is the requirement in Article 2(4) for licensed gambling activities to be conducted through an account with a bank established in Sint Maarten workable in practice, and what implementation issues should be considered?

Who we would like to have at the table

We particularly welcome participants with direct responsibility or expertise in:

• • banking compliance and AML/KYC
• • risk management and onboarding of higher risk business sectors
• • payments and cash management
• • financial crime prevention
• • central bank supervision and policy
• • licensed payment services
• • corporate banking and operational banking

Expected outcome

Identify what the regulatory reform can realistically do to strengthen financial transparency and bankability, what remains a commercial or prudential matter and what cooperation or implementation measures may be useful.

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: Tuesday, 10 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.