Operating under Curaçao egaming IP Licensing

Curaçao egaming IP Guidance Information Operating under Curaçao egaming IP Licensing 01 August 2014 info@gmcgaminglicenses.com 1

Curaçao egaming License and IP Compliance Services About Curaçao egaming Curaçao egaming is one of the oldest and most reputable providers of regulated egaming license and IP compliance services. Since the early 90 s Curaçao egaming has proudly served some of the most highly regarded egaming operators and providers of services. egaming IP licensing simplified - One license type Curaçao provides one egaming license type. Operating under Curaçao egaming IP Licensing covers games of skill; randomness, chance and wagering related services that use telecommunications (phone, Internet, IP Networks, Applications, Services, Mobile, Servers, etc). In this section we list some of the more popular egaming services that can be authorized to operate under the Curaçao egaming license and IP compliance services. Although not intended to be a complete list, this list should serve only as a general guidance. Specific questions about other possibilities and variations should be discussed in detail over a phone consultation or emailed to info@gmcgaminglicenses.com Sports books Betting exchanges Online casino games (roulette, blackjack, slots - as examples) Live dealing Peer to peer games (poker, backgammon, Mah-jong, etc.) Mobile phone games, betting Fantasy football (or similar) Financial trading Pari-mutuel and pool betting Network gaming Lotteries Trivia Bingo Common platforms Affiliate s, Skins, Marketing services No restrictions Important to note is that Curaçao egaming has no restrictions on the territories for which services are offered other then to the residents of Curacao. It is the responsibility of the IP operator to be familiar with the local laws and requirements for the territories for which services are offered. Global compliance services Curaçao egaming provides unmatched global compliance-ready solutions to qualified IP operators and providers of services. Our unique flexible global IP compliance services assure a future-proof solution to meet compliance requirements and ever-changing global business needs. Our mandatory Compliance services, global private compliance network and data centers are strategically located around the world providing a full range of flexible turnkey compliance-ready solutions. Curaçao egaming provides a complete suite of services tailored specifically to meet business, legal, geographic and jurisdictional requirements and challenges. Our in-house advisors and professionals provide a wealth of knowledge, experience and credentialed expertise in the full gamut of the egaming and ecommerce sectors. Our established 3 rd party supporting relationships circle the globe. Our global private IP compliance services enable us to bring any service into our compliance services. 1 2

Leverage existing services Our global IP compliance services may be combined and/or layered over any existing services providing the ability to leverage existing and 3rd party services. Services to operate in cooperation with our egaming compliance services may include specific IP traffic, data, application services or 3rd party contributing remote services as outlined further in this guide. Curaçao egaming provides solutions to worldwide IP compliance issues and challenges We understand the challenges faced by IP operators and providers of services to meet multijurisdictional compliance, services issues, and geographic regulatory challenges. Operators focused on global delivery of their services or operating under multiple jurisdictional licenses often encounter multi-jurisdictional compliance issues, geographic regulatory challenges or simply need to better geographically manage their own or their clients applications, traffic, data and services. Because of the unique and proprietary flexibility of our worldwide IP compliance services we are able to adapt our services to support operators to easily meet various additional business, legal, technical, geographic and multijurisdictional challenges without any changes to existing infrastructure. Managed and unmanaged services Curaçao egaming provides a complete spectrum of managed and unmanaged IT Infrastructure, IP compliance and privacy services to meet any challenges worldwide as outlined further in this guide. Curaçao Licensing and IP compliance services programs Curaçao egaming offers specialized programs for software and service providers, operators and legal and corporate providers of services. Our client base is largely comprised of operators, software and service providers from around the world who we have established turnkey relationships with, many since the early 90's. For over 18 years we have designed numerous special packages to accommodate the specific needs of these providers of services and in particular those with a large multi-user service or network that accommodates numerous brands, skins, partners and clients with high demand for global services and specialized technical requirements. Indeed, some of the very first and largest operators and providers of services in egaming have been beneficiaries of our unique programs. Our specially designed programs and global private IP compliance services combined with our worldwide locations provide a 'turnkey' offering with the purpose of assisting our clients in being an attractive source to do business with, allowing the client to concentrate on managing and building their business effectively. We work with approved applicants to create a custom framework for a 'turnkey' proposal fitting specific business and services needs. 1. Qualifying for IP Approval Curaçao egaming provides qualified IP applicants approval to operate egaming services in accordance with the Curaçao Offshore Games of Chance Act as an approved IP (Information Provider) of egaming services. First Step towards Curaçao egaming IP approval An IP applicant s first step towards receiving approval to operate egaming services under Curaçao egaming licensing is to provide a detailed response to the items under section 7 of this Curaçao egaming licensing services guide. Upon receipt and review of this information our compliance officers will then begin the process to determine and advise on the necessary corporate, personal and services compliance requirements for the specific services intended to be operated. 2. Corporate Legal Presence in the Country of Curaçao Corporate decisions are often decided based upon tax, personal and jurisdictional considerations. Regardless of the choices an applicant may make, submission of all necessary corporate and personal compliance documents as noted in the Curaçao egaming IP application is required. 3 2

3. Qualifying for Curaçao s Ezone 2% Net Profits Tax Curaçao became a country on October 10, 2010 with the dismantling of the Netherlands Antilles. Curaçao still remains part of the Dutch Kingdom. An applicant may prefer to establish a Curaçao company. One of the more popular reasons to do so is to apply for an Ezone permit to take advantage of our special tax regime where the Curaçao Company is obligated to pay 2% of its Net company profits. The special tax exemption is valid until 2026. An Ezone company must at all times remain in egaming and ecommerce services compliance to maintain this favourable tax treatment. Only a Curaçao Company can hold an Ezone permit. There is no VAT in Curaçao. Application for an Ezone permit is accomplished through our authorized egaming corporate services provider. Authorized egaming corporate services provider Should an applicant be interested in forming a specialized Curaçao Ezone company for egaming purposes we will be pleased to provide an introduction to our local authorized egaming corporate management services provider who will provide the necessary support and information for company formation services for Curaçao and other worldwide jurisdictions. NOTE: Forming a Curaçao Ezone company requires that Curaçao egaming compliance will first need to approve the UBO s (ultimate beneficial owners), the person(s) to be named in the egaming license application as the Curacao company to be formed will operate under articles of incorporation specific for egaming. Once approved applicant will then proceed to setup the Curaçao Company with the authorized corporate services provider. For your reference our authorized corporate services providers locations: Beijing, Belgium, Curaçao, Cyprus, Geneva, Germany, Guangzhou, Hong Kong, Ireland, Jersey, Luxembourg, Malta, Mauritius, Netherlands, New Zealand, Shanghai, Shenzhen, Singapore, Spain, Taiwan, United Arab Emirates, United Kingdom, United States, Zurich, Zug. The authorized corporate services provider can also provide services in non-listed countries via partners. Completing the IP application Applicants may initially return the Curaçao egaming application along with all required documents as noted in the application in electronic format to info@gmcgaminglicenses.com allowing compliance officers to begin to process the application documents immediately while the original items are sent via courier. We suggest using FedEx or DHL when sending any original documents. How long does it take to process an application? The entire IP application process can usually be completed within 5 business days, depending on an applicant s turnaround time to provide our compliance officers with the necessary corporate, personal and services compliance requirements as noted in this guide and the Curaçao egaming licensing IP application. 4. Specialized Curaçao egaming Licensing & Compliance Services We recognize that many egaming operators may have licenses and companies established in other jurisdictions and those ancillary applications, technical services and remote functions might be operating from various geographic locations. An operator may wish to operate under the Curaçao egaming license in order to benefit from the many specialized compliance services Curaçao egaming offers. In that respect we offer specialized services to operators in order to coordinate compliance requirements in a multi-jurisdictional environment. Such services may include but not be limited to application services, domains, IP traffic, the transport and delivery of specific contributing logic or event functions, SSL, DNS, player history data, settlement and back office services as further outlined within this document. 4 3

IP application infrastructure and services In order to insure compliance with our policies and procedures we encourage operators to discuss the technical aspects of their egaming system with one of our technical compliance officers. Please contact a compliance officer at info@gmcgaminglicenses.com to determine the necessary compliance requirements for the services intended to be offered. Examples of application and infrastructure services The following are some examples of egaming Services that can be considered for operation under the Curaçao egaming license: Common Platform Service Provider Integrator/Services Provider/Operator BackOffice, Registration Management and Services Brokerage, Agent Services Marketing Services (Affiliates, White Labels) Relay or IN-Path event or logic services Backup services or Disaster Recovery Shadow License (for political or business reasons) Providing only the results of event *(see below) Registering Players and maintaining financial records **(see below) Offering the Service ***(see below) *Provision of IT which just presents the results of play It is possible that an approved random number generator could be in another jurisdiction and its output could be generated there with results forwarded to the IP compliance services network where the result would be relayed, processed or prepared. ** Registering players Operator authenticates, collects and stores personal details (such as name, age, address, username, password, player request or player history etc. Operator monitors the status of players funds. *** Offering the service The service is considered to be offered when the player and the operator enter into an arrangement or relationship without which the player cannot participate in the game. A company that offers registration or downloads of software to the player that allows them to connect to a service, network or site or server to engage in the service is not offering the service. The service is offered by the site (network, server, IP address, etc.) to which the player connects with in order to play or engage in the service. A website which allows the player to begin gambling is offering the service. A web page may source it s games from a variety of providers. A website that is referring the player does not offer the service. The service is offered by the website that the player is referred to. The final Terms and Conditions are determined by our compliance team on a case-by-case basis after the specific services are coordinated. You are encouraged to provide details to info@gmcgaminglicenses.com 5 4

5. Provisioning of services under Curaçao egaming IP compliance services Curaçao egaming licensing is valid and authorized only for the specific registered and approved applications, services, domains and URL s operating under Curaçao egaming IP compliance services. No egaming services may be offered without the operator receiving prior written approval from Curaçao egaming licensing and compliance. For each intended service to be operated, compliance services must be maintained at all times. An operator may add, remove or make changes to their registered and approved suppliers, services, domains and URL s by providing Curaçao egaming with the necessary required technical and operational compliance information for review and approval as outlined in this Licensing Services Guide. Core services With respect to technical and operational compliance services, the main areas for licensing compliance services are the following: Compliance for specific data, application services, IP traffic, contributing remote services, events and logic. Compliance for example, may be achieved via our Global IP compliance services suite consisting of global remote IP compliance services, dedicated servers, co-location, VPS, cloud servers, data storage services and hosting. A detailed compliance requirements analysis is required to determine the necessary compliance service requirements. Curaçao egaming provides a full range of compliance services Curaçao egaming offers a full range of custom solutions including dedicated servers, VPS servers, private cloud servers, global IP compliance services, cloud data storage, hosting, single unit rack space or high capacity private racks and aggressive rates from our worldwide private network locations. Our compliance services and data centers are strategically located worldwide providing licensees with turnkey compliance-ready solutions, optimal performance and geographic control for maximized delivery of worldwide services. Our core compliance services data center and centralized hub of our global operations and IP compliance services is located and operated from within the Curaçao Government Ezone. This is the centralized location where all the major International Sub- Marine Fiber-Optic Cable Systems terminate to Curaçao. 6. Analysis of technical checks on games offered Whether a service is offered to a player directly or via a third party, the operational and technical description of the service must be submitted for review by our compliance department. New services can be added to an approved IP operator s portfolio but require a description of the service before we can accept it and register it as approved. At all times Curaçao egaming must have on file an up to date services registration document which details the registered and approved suppliers, services, domains and URL s operated by the approved IP operator. Curaçao egaming IP compliance engineers conduct compliance audits on a regular basis. In order to avoid possible penalties and suspension of services for non-registered services or services operating out of compliance, the IP operator should ensure all services; domains and URL s operating under the Curaçao egaming license are up to date and approved. 6 5

7. Please provide a detailed response to the following items A potential applicants possibility to obtain Curaçao egaming IP approval can only be determined by providing Curaçao egaming with the necessary information to begin to determine the required egaming licensing and IP compliance services requirements for the services intended to be offered. A detailed response to the following items below is required to begin to determine licensing and compliance requirements. A) BUSINESS OVERVIEW - CURRENT AND PLANNED egaming OPERATIONS Please provide a detailed overview of existing or planned egaming business activities. B) Please advise if it is intended that an existing company will be used or a new company will be required to be formed? C) Please provide the details of any existing egaming license or authority presently held or presently operating or marketing under. This includes operation of play for free or real money services, white-labels, skins or affiliate operations. egaming SYSTEM / SOFTWARE / SERVICE SUPPLIER DETAILS D) Please provide a detailed overview with description of the software, supplier or service intended to be offered. E) Is the software or service developed in-house, purchased or licensed or are you a marketing partner or a software or service provider? F) Please provide a detailed description of the applications and services for the egaming system architecture or service that you or the operator will have full control over, manage or have access to. Also please indicate which services will be supplied to you or managed by the supplier or a 3rd party as they apply to the various services intended to be offered. *Please Note: Supporting diagrams are appreciated. WHITE-LABELS & SOFTWARE LICENSING OPTIONS G) Please specify if it is intended that the service will be offered to other operators in the form of a white-label, skins or affiliate or by means of software licensing agreement or similar. This is applicable for planned or existing operations, play for free or real money services. *Please Note: Curaçao egaming offers special programs for software and service providers, or operators who need to provide qualified licensing services to their clients or to operators for their own or 3rd party registered services. Please inquire for detailed information on these specialized programs. PLEASE LIST THE GEOGRAPHIC AREAS INTENDED TO OFFER SERVICES TO H) i.e. North/South/Latin America, Europe, Asia/PAC SERVICES, SUPPLIERS, DOMAIN NAMES TO BE OPERATED I) Please provide a list of existing or intended domains to be licensed as per examples below. SERVICE(s) SUPPLIER(s) DOMAIN(s) e.g. sports, poker, bingo, casino e.g. xyz software supplier, in-house e.g. yourdomain.com e.g. sports, poker, bingo, casino e.g. xyz software supplier, in-house e.g. yourdomain.com PROPOSED GO LIVE DATE J) What is the target date to go live online? ADDITIONAL NOTES K) Please provide any additional information. 7 6

Our review process Our Compliance will begin by first reviewing the requirements for each potential licensee s intended services to be offered in detail to fully understand all components which make up or contribute to the service along with a complete understanding of the licensing and compliance services requirements. The monthly ongoing operating fees for operating under Curaçao egaming IP licensing and compliance services are determined by an applicants egaming licensing, application and services compliance requirements. Curaçao egaming compliance offices will first require a response to the items under section 7 of this Curaçao egaming licensing services guide to begin to determine those requirements. Curaçao egaming will provide applicant with a general estimate for these services upon receipt and review of the necessary required services and compliance information. Further consultation, assistance and approvals will be provided upon applicant fully engaging in the Pre-approval egaming application process. Should you initially desire we would be pleased to discuss over a call your specific licensing and compliance requirements in detail regarding the services intended to be offered. Thank you for your interest in our jurisdiction! Curaçao egaming egaming IP License and Compliance Services 7 8