Where operators were stuck, and how we got them moving

Challenge

The group's application had stalled at the MGA's fit-and-proper stage because two key function holder roles were not yet credibly resourced, and the individuals proposed had unexplained gaps in their documented professional history.

Approach

We advised on interim resourcing for the key function holder roles, worked with the individuals to prepare complete personal documentation addressing the history gaps directly, and resubmitted the file with a clearer explanatory narrative for the MGA's reviewers.

Outcome

The application moved past the stalled fit-and-proper stage on resubmission.

Challenge

The operator held a sub-licence under a master licensee and needed to transition to a direct Curaçao Gaming Authority licence under the LOK reform, with an unclear internal picture of what the new documentation standard required.

Approach

We ran a gap analysis against the CGA's current requirements, restructured the UBO documentation to close transparency gaps, and rebuilt the AML/CFT policy set to reflect the operator's actual product rather than the template inherited from the former master licensee.

Outcome

The operator completed its transition within the CGA's window with no material queries on the resubmitted documentation.