Last Updated / Effective Date: August 1, 2026
1. Introduction & Regulatory Commitment
As a developer of digital gaming software, NovaPlay is committed to upholding financial integrity and mitigating systemic risks. Our corporate operations are governed by the regulatory framework of the Curaçao Gaming Authority (CGA) under the National Ordinance on Games of Chance (LOK). We adhere to the statutory frameworks of Curaçao’s National Ordinance on Identification when Rendering Services (NOIS/LID) and the National Ordinance on the Reporting of Unusual Transactions (NORUT/ LMOT), alongside international baselines established by the Financial Action Task Force (FATF).
Because our business model operates strictly within a business-to-business (B2B) infrastructure, we do not directly serve retail end-users, settle individual player wagers, or manage consumer wallets. Accordingly, our Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) program focuses heavily on securing our corporate supply chain through Know Your Business (KYB) validation, downstream contract enforcement, continuous multi-tier risk assessments, and rigid technical transaction monitoring controls.
2. Know Your Business (KYB) & Partner Screening
We enforce an onboarding policy where no Application Programming Interface (API) integrations are activated, and no software distribution rights are granted, prior to the successful completion of our corporate vetting process. We require all prospective business partners—including distributors, resellers, and aggregators—to submit verified corporate documentation. This includes:
Valid certificates of incorporation and articles of association.
Proof of corporate operational substance and active regulatory licensing.
Full disclosure of the corporate ownership structure, identifying all Ultimate Beneficial Owners (UBOs) holding a stake of 10% or greater (an enhanced risk threshold exceeding the statutory 25% minimum under Curaçao law).
All corporate entities, directors, and identified UBOs are continuously screened against global sanctions lists, anti-terrorism watchlists, and Politically Exposed Persons (PEP) registries. We maintain a zero-tolerance policy for any entity listed on international sanctions lists or operating without valid regulatory standing.
3. The Downstream Chain of Trust
Because our direct relationship is with corporate Resellers who distribute our games to downstream online Operators, we utilize an enforceable "Chain of Trust" framework. We contractually mandate that all Resellers perform equivalent, comprehensive KYB and licensing checks on every operator they onboard.
Resellers must contractually guarantee that downstream B2C Operators maintain and enforce end-user compliance controls aligned with LOK standards, executed in two distinct phases:
- Account Onboarding: Operators must collect mandatory minimum profile data at account creation, including the player's full legal name, date of birth, permanent residential address, nationality, and explicit, auditable acceptance of AML/KYC terms.
- Statutory Threshold Verification: Operators must execute full, independent Customer Due Diligence (CDD) and verify the player's identity using valid government-issued documentation at or before the statutory Curaçao transaction threshold of 4,000 Antillean Guilders (ANG), or its currency equivalent, in cumulative deposit or withdrawal activity.
Resellers shall guarantee that downstream B2C Operators maintain and enforce the relevant AML and CFT training for their personnel.
We retain an absolute contractual right to audit our Resellers' compliance records and demand documentation for any downstream operator delivering our gaming content to verify systemic integrity.
4. B2B Transaction Monitoring & Security
While we do not handle player funds, our server infrastructure actively monitors game-level transaction flows using API-level tracking. Our automated systems monitor technical parameters—including unexpected spikes in betting volume, payout ratios, and unusual sub-partner activity—to detect and prevent complex financial crimes, including cross-operator chip-dumping and game manipulation.
All corporate financial settlements are restricted entirely to secure, closed-loop transactions executed through verified institutional bank accounts that match the legal name of our contracted Reseller. We strictly prohibit and reject any third-party payments or financial transfers originating from unverified intermediaries.
5. Reporting, Compliance, & Substance Restrictions
In compliance with the NORUT ordinance, any identified operational irregularities or structural compliance failures within our distribution network are immediately evaluated by our dedicated Compliance Officer. Qualified unusual activities are reported directly to the Financial Intelligence Unit (FIU) Curaçao via the official goAML platform. In strict adherence to international laws against "tipping off," we do not disclose to any partner if their activity is under formal regulatory review.
Furthermore, we utilise API-level geo-fencing to block game requests originating from LOK-restricted or high-risk jurisdictions. To satisfy local data integrity and regulatory access mandates, all corporate compliance data, partnership logs, and API transaction logs are securely archived for a minimum of five (5) years and hosted via a certified server architecture situated within a registered data center facility in Curaçao, remaining audit-ready for the Curaçao Gaming Authority at all times.