AML/CFT Supervision
Keeping the gambling sector from becoming a route for illicit money.
Gambling, and cash-intensive activities such as casinos in particular, are widely recognised — including in independent international assessments of Sint Maarten — as a sector with elevated exposure to money laundering and terrorist financing (AML/CFT) risk. AML/CFT supervision is the Gambling Authority's role in making sure licence holders understand that risk and take it seriously: applying proper controls, monitoring for warning signs, and working with the wider system of authorities responsible for financial integrity.
The approach described below reflects principles that are broadly consistent with how gambling regulators across the Caribbean region and Europe approach AML/CFT supervision, and with international standards in this area. It is intended to explain why this activity exists and what it broadly involves — not to set out the detailed procedures or reporting formats of the future framework, which will be published once the new Kansspelverordening has entered into force.
At a Glance
AML/CFT Oversight
Checking controls exist and are followed
Risk Monitoring
Attention where the risk is highest
Information Exchange
Working with the FIU and other authorities
Oversight of AML/CFT Compliance
Gambling operators, and casinos in particular, handle significant cash volumes, which makes the sector a recognised target for attempts to launder illicit proceeds or move funds linked to criminal activity. Independent international assessments of Sint Maarten have specifically identified gambling as a higher-risk sector in this respect, and pointed to gaps in how thoroughly it has historically been supervised. Overseeing AML/CFT compliance means checking that licence holders have the policies, procedures and controls required by law in place — and that these are genuinely applied, not just documented.
- ● Applies recognised international AML/CFT standards to the gambling sector
- ● Checks that required policies and procedures exist, and are actually followed
- ● Responds to a risk that independent assessments have already identified, not a hypothetical one
Risk Monitoring and Control Frameworks
Not every gambling activity carries the same level of money laundering risk, so supervision is generally organised around a risk-based approach: closer attention where the risk is highest, proportionate monitoring elsewhere. In practice, this involves reviewing how operators identify and verify their customers, monitor transactions for unusual patterns, and manage relationships that carry elevated risk — including politically exposed persons and other higher-risk profiles.
- ● Concentrates supervisory attention where money laundering risk is highest
- ● Reviews customer due diligence, transaction monitoring and internal controls
- ● Applies enhanced scrutiny to higher-risk relationships and transactions
Information Exchange with FIU and Authorities
Effective AML/CFT supervision does not happen in isolation. Gambling regulators generally coordinate with a country's financial intelligence unit and other relevant domestic authorities, sharing and receiving information so that a concern identified in one part of the system can properly inform action elsewhere. This kind of coordination is a standard, well-established feature of AML/CFT frameworks internationally, rather than something unique to any one sector or jurisdiction.
- ● Coordination with financial intelligence and law enforcement bodies is a standard feature of AML/CFT frameworks
- ● Supports the reporting of unusual or suspicious activity into the wider system
- ● Reflects standard international practice for gambling regulators
Why AML/CFT Supervision Matters
A Sector Under International Scrutiny
Independent international evaluations of Sint Maarten's AML/CFT framework have specifically named gambling among the sectors most exposed to money laundering risk, and have called for effective, independent supervision as a priority — not a hypothetical improvement, but a documented recommendation.
Consequences Reach Beyond the Sector
Weaknesses in AML/CFT supervision in any one sector can affect a country's international standing as a whole — including its banking relationships and access to the global financial system. Effective supervision of gambling protects far more than the gambling sector itself.
Closing a Documented Gap
A dedicated, independent regulator with real supervisory powers is the direct response to previously fragmented and under-resourced oversight of the sector — turning a documented weakness into an area of genuine strength.
Further Reading
AML/CFT supervision of the gambling sector is a documented area of international assessment for Sint Maarten. The reports below are publicly available and can be read in full:
- Mutual Evaluation Report — Sint Maarten (CFATF, 2025)
- Twelfth Follow-Up Report of Sint Maarten Compliance (CFATF)
- 3rd Mutual Evaluation Report on AML/CFT (CFATF)
- National Risk Assessment — Money Laundering & Terrorist Financing (FIU Sint Maarten)
Additional background reports are also available on the Historical Overview & Publications page.
Please note: the new Kansspelverordening (National Gambling Ordinance) has not yet entered into force. This page describes the general purpose and underlying principles of AML/CFT supervision as a regulatory activity — not the finalized reporting formats, thresholds or procedures of the future framework. Detailed, procedural information will be published on this website once the legal framework has been adopted.