KSA issues enforcement order to Tulipa over AML compliance failures

The Netherlands Gambling Authority (KSA) has issued a formal directive to Tulipa Ent Limited after uncovering several breaches of the Money Laundering and Terrorist Financing (Prevention) Act.

Tulipa, the operator behind the ComeOn and GetLucky brands in the Netherlands, was found to have significant weaknesses across key elements of its anti-money laundering (AML) system.

According to the KSA, Tulipa did not apply customer due diligence measures with the level of scrutiny required under Dutch regulations. Investigators found that player risk classifications were incomplete or incorrectly assigned, undermining the operator’s ability to accurately assess customer profiles.

The regulator also criticised shortcomings in Tulipa’s transaction-monitoring controls, including insufficient verification of the source of players’ funds – an essential safeguard in a sector vulnerable to financial crime.

In addition, the KSA reported that Tulipa failed to properly archive documentation linked to unusual transaction reports filed with the Netherlands’ Financial Intelligence Unit. The lack of adequate record-keeping hindered the regulator’s ability to determine whether the operator was consistently meeting its reporting duties.

The investigation further concluded that Tulipa’s AML training was too general and not tailored to specific roles. The KSA stressed that staff in compliance-critical positions, including the Money Laundering Reporting Officer, must receive targeted, regular training to identify suspicious behaviour and conduct thorough due diligence – core components of effective AML oversight.

The authority reiterated that licensed operators must continuously monitor customer activity and intervene when patterns appear irregular. Sudden increases in deposit levels, even from verified bank accounts, were highlighted as examples of activity that require closer review. The KSA also referenced the wider risk landscape – such as potential match-fixing indicators – to underline operators’ responsibility to detect and address suspicious conduct.

Tulipa has been instructed to remedy the identified failings within deadlines ranging from two to six months. The KSA noted that the company cooperated fully during the investigation and has already begun implementing improvements. A follow-up assessment will be conducted once the deadlines have passed to confirm that Tulipa’s procedures comply with Dutch AML standards.

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