Licensedmarkets (fintech and cryptoservices, online gambling, and similar sectors) have long ceased to be a «grey zone» for regulators and international standards. Today, they operate within an environment defined by strict rules, regular inspections, and a strong emphasis on transparent corporate governance.

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And while a licence grants a company the right to operate, it is the key roles and specialists within the organisation that act as the mechanism keeping thebusiness on track.

Below is acloser look at the professionals who, in practice, safeguard the stability,legality, and reputation of licensed businesses (using examples from MSB inCanada, CASP in the EU/Cyprus, and iGaming in Ontario and Curaçao), and whythese roles are never merely «formal».

Compliance Officer

- or the person who says «no» so often that they are heard even without speaking.

Role: ensures the company’s ongoing compliance with regulatory requirements and applicablelegislation across all jurisdictions in which it operates.

Mission: to design, implement, and maintain a robust corporate compliance framework that addresses regulatory, operational, and reputational risks.

Key responsibilities:

• implementing and maintaining internal policies and procedures in line with regulatory standards (including MiCA and CySEC guidelines for CASPs, PCMLTFA / FINTRAC requirements for MSBs in Canada, the Registrar’s Standards for Internet Gaming (AGCO), and GCB (Curaçao) requirements for the gaming sector);

• continuously monitoring legislative and regulatory developments and adapting the company’sinternal processes accordingly;

• preparing, submitting, and overseeing regulatory reporting, as well as participating ininspections, reviews, and audits;

• developing internal control programmes, managing compliance risks, and working with seniormanagement on corrective actions;

• organising mandatory staff training on regulatory compliance, ethics, and internalprocedures.

In the event of any regulatory breaches, the compliance function is the first to be assessedby the regulator.

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AML/CTF Officer (MLRO)

- or the person whose warnings andrecommendations are not open to debate if you want your business to still beoperating tomorrow.

Role: ensures the company’s compliance with anti-money laundering and counter-terroristfinancing (AML/CTF) requirements and acts as the designated officer responsible for financial monitoring.

Mission: to design, implement, and continuously oversee an effective AML/CTF system that minimises the risk of the company being used for illicit financial activities.

Key responsibilities:

•  developing and maintaining KYC/CDD procedures (customer identification and verification), assessing clients’ source of funds (SOF) and source of wealth (SOW) in accordance with a risk-based approach;

• continuous transaction monitoring, identifying unusual and suspicious activity, and performing analytical assessments of such transactions;

• preparing and submitting mandatory suspicious transaction/activity reports (STR/SAR) to the relevant authorities: FINTRAC in Canada, the Financial Intelligence Unit (FIU) in the EU, and the competent regulators in gaming jurisdictions;

• organising and conducting internal AML reviews and audits of financial monitoring systems, as well as regular staff training;

• contributing to the development of risk profiles for clients, products, and transactions,and implementing remedial actions where deficiencies are identified.

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Inadequate monitoring by the AML/CTF Officer (MLRO) or the failure to detect suspicious activity may result in regulatory sanctions, account freezes, financial losses,and serious reputational damage to the company.

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Risk Officer

-or that very “corporate worrier” who is always thinking 20–30 stepsahead. Not because they are pessimistic, but because someone in the companymust anticipate scenarios others have not yet even considered.

Role: is responsible for the systematic identification, assessment, and control of risksthat may affect the company’s financial stability, regulatory compliance, andreputation.

Mission: to ensure proactive risk management by implementing a structured risk management system in line with internationally recognised frameworks, including ISO 31000 ( Risk Management) and COSO Enterprise Risk Management, enabling the organisation to identify critical threats before they materialise into real problems.

From a legal perspective, the position of Risk Officer is not always formally mandatory forall licensed companies. In practice, however, in complex and highly regulated business models (such as payment services, crypto platforms, and large iGaming operators) regulators expect a structured risk management framework to be in place, very often supported by a dedicated function or responsible officer.

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Board of Directors / Top Management

‍- or the“corporate parliament”

Role: provides strategic leadership, establishes the corporate governance framework, and bears ultimate responsibility for the effectiveness of the company’s key control functions.

In many licensed structures (particularly in smaller or privately held companies) the functions of a Board of Directors may be performed by a single director. However, even in such a model, the principle remains unchanged: this individual carries full managerial and regulatory responsibility for the company’soperations.

In addition to the roles outlined above, licensed companies typically also have an Internal Auditor (independent review of controls), a Data Protection Officer (DPO)(personal data protection and GDPR compliance), a Responsible Gambling Officer (responsible gaming and user protection), Legal Counsel (licensing, contracts, and regulatory interpretation), and a CFO (financial reporting, capital requirements, and relationships with banks).

In licensed businesses, key roles are neither a formality nor regulatory window dressing -they are a practical instrument of governance and business protection, and the foundation of trust between a company, its clients, financial partners, and thestate. Appointing professionals to key roles and senior management creates a governance model in which a business not only obtains a licence, but also develops without breaches, regulatory sanctions, or strategic disruptions.

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