The Netherlands Gambling Authority (Ksa) has issued a formal instruction to Tulipa Ent Limited, operator of the ComeOn and GetLucky brands, for violations of the Money Laundering and Terrorism Financing (Prevention) Act (Wwft).
Key Findings
The directive highlights several deficiencies in Tulipa’s compliance framework:
- Customer Due Diligence: Risk classifications were applied incorrectly, and monitoring of transactions and the origin of player funds was insufficient.
- FIU Reporting: Tulipa failed to properly document unusual transaction reports submitted to the Financial Intelligence Unit Netherlands (FIU), preventing regulators from fully assessing compliance. The Ksa reminded Tulipa that reporting parties must receive a PDF confirmation within 24 hours of filing, in line with Wwft requirements.
- Training Gaps: Wwft training was not adequately tailored to different job levels, particularly compliance staff and the Money Laundering Reporting Officer (MLRO). Proper training is essential to ensure employees can identify unusual transactions and conduct thorough due diligence.
Monitoring Unusual Behavior
The Ksa emphasized its role in safeguarding the financial system by enforcing Wwft compliance across gambling providers. Operators are required to monitor customer behavior and intervene when unusual activity occurs—for example, sudden large deposits or suspected match-fixing.
The regulator reiterated that even deposits from a player’s own bank account can pose risks if they are unusually high, as outlined in its Wwft Guidelines.
Next Steps
Tulipa has been instructed to remedy the identified violations within two to six months. During the investigation, the company cooperated and proactively developed a remediation plan, with some issues already addressed.
The Ksa will conduct a follow-up inspection after the deadlines to verify compliance.
