Every applicant for an Eritrea Gaming license is subject to regulatory due diligence as part of the application process.
The purpose of due diligence is to assess the identity, integrity, financial standing, competence and regulatory suitability of the applicant, its owners, controllers, directors and other persons connected with the proposed licensed business.
Due diligence is mandatory. No license will be issued unless the Authority is satisfied that the applicant meets the applicable licensing requirements and that unresolved concerns do not present an unacceptable regulatory risk.
The scope and depth of the assessment will be proportionate to the license category, ownership structure, proposed activities, target markets and overall risk profile of the applicant.
Applicants must provide complete and accurate information concerning the legal entity applying for the license and all entities within its relevant ownership and control structure.
The Authority will review the corporate structure to identify:
Supporting documentation may include:
Complex ownership structures must be clearly explained. The Authority may require additional information where an arrangement appears unnecessarily opaque or prevents the identification of the persons who ultimately own or control the applicant.
Applicants must disclose every natural person who directly or indirectly owns, controls or materially benefits from the applicant or licensed operation.
The Authority may require beneficial ownership declarations, identity documents and supporting evidence demonstrating how ownership or control is exercised.
The use of nominees, trusts, holding companies or layered corporate structures does not remove the obligation to identify the ultimate beneficial owners.
Any failure to disclose a beneficial owner or controlling person may result in:
Individuals performing key roles are subject to fitness and propriety assessment.
Depending on the structure of the business, key persons may include:
The assessment may consider:
The Authority may interview a key person or request further documentation where necessary.
An applicant or key person must demonstrate that they are suitable to participate in a regulated internet gaming business.
The Authority may consider whether the person:
The assessment is continuing. A person considered suitable at the application stage must remain suitable throughout the license term.
Applicants must demonstrate that they possess sufficient financial resources to establish, operate and maintain the proposed licensed business.
The Authority may review:
The Authority may assess whether the applicant can meet player liabilities, regulatory fees, supplier obligations and normal operational expenses without creating an unacceptable risk to players or the licensing framework.
Applicants, shareholders and beneficial owners may be required to demonstrate the legitimate origin of the funds used to establish, acquire or operate the licensed business.
Evidence may include:
The Authority may also request source of wealth information where necessary to understand how a beneficial owner accumulated their overall assets.
Unverified, unexplained or suspicious funding may result in the application being refused.
Applicants, beneficial owners, directors and key persons may be screened against:
The identification of a potential match does not automatically determine the application. The Authority may request clarification and supporting evidence before reaching a decision.
A license will not be issued where an unresolved sanctions, financial crime, integrity or national security concern presents an unacceptable risk.
Applicants must disclose existing and previous licenses, registrations and regulatory approvals held by the applicant, its related entities and relevant key persons.
The Authority may request information regarding:
The duty to provide accurate information continues after an application has been submitted.
Applicants must notify the Authority promptly if:
Information must not be withheld because the applicant considers it immaterial. Where uncertain, the applicant should disclose the matter and allow the Authority to determine its relevance.
The Authority may request additional documents, explanations, interviews, certifications or independent reports at any stage of the assessment.
Submission of an application does not create an entitlement to a license. Incomplete, misleading, inconsistent or unsatisfactory information may delay the assessment or result in refusal.
