Summary of Resolution 217-2025 for the Prevention of Money Laundering and Terrorism Financing through a Risk-Based Approach for Obligated Entities under the Oversight of the Directorate of Casinos and Gambling

On the fourth (4th) of November two thousand twenty-five (2025), the Directorate of Casinos and Games of Chance of the Ministry of Finance and Economy issued Resolution 217-2025, which regulates the Prevention of Money Laundering and Terrorist Financing with a risk-based approach for the obligated parties under its supervision. This resolution repeals Rule 204-17 of 2017 and introduces important changes that strengthen the Anti-Money Laundering and Terrorist Financing prevention regime for the gaming sector, granting obligated parties a period of six (6) months from the publication of the resolution to adapt their Compliance Manuals. Among the most important changes, we highlight:

Scope of application. Rule 217-2025 expands the scope of application, expressly establishing its application to:
Casinos of Games of Chance and Slot Machine Gaming Rooms, with their respective responsible administration.
Online or internet games of chance.
Virtual games of chance.
Electronic lottery concessionaires.
Lottery betting shops.
Sports betting shops.
Charitable and non-charitable raffles.
Traditional and electronic bingo halls.
Betting companies and horse-racing agencies.
National Lottery.
All entities that engage in games of chance in any modality.

2. General obligations of operators. It provides that operators licensed to offer games of chance must comply with the following general obligations:

Design and implement a Compliance Program for the Prevention of Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction (AML/CFT/CPWMD) with a risk-based approach (RBA).
Design policies and procedures to assess their risks of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction and mitigate them.
Register with the FIU for the purpose of submitting the corresponding reports.
Register the Compliance Officer and their alternate with the Directorate of Casinos and Games of Chance.
Promote an organizational culture of good practices, ethics and compliance with Law 155-17.
Maintain a record of prize winners.
Respond to express requests from the DCJA and the FIU.

Additionally, it establishes the obligation for all operators to periodically conduct and document a comprehensive assessment of the risks of Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction, at intervals no longer than eighteen (18) months or sooner if significant changes occur in their operations. A period of ninety (90) calendar days from the entry into force of the regulation is granted for operators to conduct the first comprehensive risk assessment.

For small-scale operators, the resolution establishes obligations such as a simplified risk assessment methodology accompanied by a notarized sworn statement signed by the owner or legal representative of the business, which must be submitted within a maximum period of ninety (90) days from the entry into force of the resolution and must be updated annually.

3. Regarding the AML/CFT/WMD Compliance Program.

It establishes mandatory adherence to the AML/CFT/WMD Compliance Program for all individuals and legal entities associated with the Operator, including all employees, officers, members of the Board of Directors, shareholders, partners and license or authorization holders.
If the license holder hires a responsible administrator, both parties must sign an agreement defining the terms and conditions to ensure effective coordination in the implementation and supervision of the AML/CFT/WMD Compliance Program, which must include each party’s responsibilities regarding the identification and assessment of inherent risks to casino operations, the administrator’s obligation to design, implement and maintain policies, procedures and internal controls to mitigate such risks, oversight by the license holder of contractual obligations related to AML/CFT/WMD prevention, cooperation with authorities in investigations of possible AML/CFT/WMD cases, and mechanisms for effective communication and coordination between the license holder and the responsible administration.
It strengthens the policy for knowing shareholders, board members, employees and officers, establishing the obligation to approve policies that allow not only identifying shareholders, board members and employees, but also conflicts of interest and the likelihood of their involvement in a possible AML/CFT/WMD operation.
It establishes the number of annual trainings required for the Compliance Officer, Board members, employees and their specialization based on their relationship with clients.
It sets requirements for the Operator’s AML/CFT/WMD trainer.

• Compliance Structure.

The regulation establishes the obligation to create a compliance structure within the Obligated Party, which may include the Compliance Area, the Compliance Committee and the Compliance Officer, where applicable.

Compliance Officer and their alternate:
Regarding the Compliance Officer, the suitability requirements for their selection and training are strengthened. It establishes the mandatory designation of an alternate Compliance Officer, who must meet the same requirements as the Compliance Officer.

They must reside in the Dominican Republic during the exercise of their duties and may not simultaneously perform their functions in different companies, regardless of whether they engage in the same commercial activity, except for operators belonging to the same economic group.

Both the Compliance Officer and their alternate must possess academic, technical and practical experience in the prevention of Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction. For electronic lotteries, casinos, slot machine rooms, online gaming and sports betting shops, a minimum experience of two (2) years is required.

The regulation also establishes disqualifying criteria for appointment as Compliance Officer or alternate, including economic violations, money laundering, organized crime, removal from public office due to disciplinary misconduct, disqualification from public service, or prior declaration of unsuitability by the Directorate of Casinos and Games of Chance. To prove the latter, the candidate must submit a sworn statement certifying they have not been removed from public office for disciplinary reasons nor convicted with temporary or permanent disqualification from public service.

Additionally, the Directorate of Casinos must validate candidates proposed by Obligated Parties for Compliance Officer or alternate positions through the submission of the Criminal Record Certificate, sworn statement of non-dismissal and other documents. However, the resolution does not specify the timeframe in which the Directorate must respond to validation requests, which should occur prior to hiring due to the obligations and penalties arising once the employment relationship begins.

Compliance Area.
It establishes the obligation to create a Compliance Area or Department for operators with more than fifty (50) employees and annual gross sales exceeding SIXTY-ONE MILLION FIVE HUNDRED FIFTY-THREE THOUSAND ONE HUNDRED EIGHTY-SEVEN PESOS (RD$61,553,187.00). This Compliance Area will be responsible for ensuring compliance with the responsibilities assigned to the Compliance Officer, serving as strategic and operational support for the proper implementation of the Program.

Operators below these thresholds may allow the Compliance Officer to assume the functions without creating a Compliance Department unless the Directorate of Casinos identifies significant risks or inconsistencies through audits or inspections.

To remain under this regime, Operators must submit within the first one hundred twenty (120) days of each year a notarized sworn statement accompanied by:

Financial Statements for the previous fiscal year, certified by a Certified Public Accountant (CPA).
Official DGII form supporting the reported sales.
Certificate issued by the Social Security Treasury (TSS) or the Ministry of Labor verifying the average number of employees in the previous fiscal year.

Compliance Committee.
Casinos, Slot Machine Rooms, Online Games of Chance, and operators required to form a Compliance Area based on employee count and gross sales must form a Compliance Committee. In other cases, the functions may be assumed by Senior Management in collaboration with the Compliance Officer.

The Compliance Committee must consist of an odd number of members, at least three (3), with voice and vote:

One member of the Board of Directors or Senior Management.
A senior executive of the Operator.
A senior executive of the operations area or similar.

This committee must meet at least quarterly.

4. Code of Ethics.

Guidelines are established to strengthen the Code of Ethics and a culture of compliance, such as the management and protection of confidential information of both the operator and the client, identification and management of conflicts of interest, and the commitment to implementing a responsible gaming program.

A specific section dedicated to player protection is established to ensure the proper creation and distribution of gaming products, guarantee privacy and fair treatment of players, protect minors and individuals with mental health issues, among others.

5. Internal Audit.

Operators with more than fifty (50) employees or annual gross sales exceeding RD$61,553,187.00 must conduct a comprehensive internal audit. If the Obligated Party does not have an Internal Audit Department, the highest governing body of the company must designate the person(s) responsible for conducting internal audits. Such individuals must have held their academic degree for at least five (5) years and possess an accredited certification or a minimum of two (2) years of experience in auditing or internal controls related to AML/CFT/WMD.

The designation of the external auditor must be notified to the Directorate of Casinos within fifteen (15) business days after the appointment.

Operators not meeting the thresholds are exempt from conducting internal audits. However, they must conduct a simplified annual review of the effectiveness of the Compliance Program.

6. External Audit.

It establishes the obligation for all operators to conduct an independent external compliance audit at least every two (2) years, unless specifically required otherwise by the Directorate of Casinos and Games of Chance. For small-scale operators, the external audit report may consist of a compliance opinion issued by a Certified Public Accountant (CPA) or a professional qualified in Money Laundering Prevention.

Operators of Single-Draw Raffles are exempt when the activity is limited to that draw and not combined with permanent gaming modalities.

Criteria are established for the hiring of external auditors, and a period of twelve (12) months from the entry into force of Rule 217-25 is granted for operators to submit the first external audit report.

7. Customer Identification.

A threshold of US$1,000.00 is established for customer identification when:

Players request chip exchanges, virtual credits, winnings or any other monetary value equal to or greater than the threshold.
Online game players acquire credits for participation or withdraw funds from gaming accounts, whether in credits or any other authorized payment method for an amount equal to or greater than the threshold.
Winners of prizes from any type of game or draw offered by operators receive an amount equal to or greater than the threshold.

Customer identification, beneficial ownership verification and understanding of the nature of the commercial activity may be delegated to another operator only when part of the same economic group. However, responsibility remains with the party delegating the task.

Commercial relationships are prohibited when the operator cannot perform customer identification, verification or due diligence.

Regarding Online Games of Chance, operators must establish additional due diligence measures such as:

Customer verification through authentication technologies.
Detailed monitoring of betting patterns and unusual transactions.
Ongoing monitoring of gaming activities to detect behaviors indicating AML/CFT/WMD risk.
Ensuring their platforms are not used for concealing or transferring illicit funds by implementing robust early warning systems and reporting to the competent authorities.

Risk-based due diligence must be applied not only to clients and employees but also to junkets, agencies or authorized electronic lottery sales points and the National Lottery, in the following cases:

When establishing or attempting to establish commercial or professional relationships;
When there are suspicions of money laundering, terrorist financing or proliferation of weapons of mass destruction;
If there are doubts regarding the authenticity of customer or beneficial owner data;
When transactions reaching or exceeding three thousand US dollars (US$3,000.00) or equivalent in national or foreign currency occur within a twenty-four (24)-hour period.

8. Prohibition of Cryptocurrency Use.

Operators are prohibited from accepting cryptocurrency, crypto-assets, NFTs (non-fungible tokens), or electronic wallets (e-wallets) not recognized by Dominican monetary and financial authorities for the payment of bets, draw tickets and prizes, or when such instruments present a money laundering risk, as determined by the Directorate of Casinos and Games of Chance of the Ministry of Finance and Economy. Payment into foreign bank accounts is exceptionally permitted for prize payments to international casino clients who demonstrate they are not residents of the Dominican Republic.

9. Prohibition of Commercial Relationship.

In addition to cases where due diligence cannot be performed, operators are prohibited from initiating or continuing commercial relationships when they provide direct financing for players or bettors to continue participating in games of chance. This prohibition extends to related or associated companies, as well as any person providing services to them. Exceptions include:

Free promotional bonuses up to US$25.00 once per day per player.
Bonuses linked to the initial deposit of up to 25% of the deposited amount, not exceeding US$250.00 or equivalent.
Promotional chips that cannot be exchanged for cash.
Promotional credits that cannot be withdrawn as cash under any circumstances.

10. Registry of Prize Winners (RPW).

Operators must create a registry of payments and prizes awarded by Casinos, Online Games of Chance, Electronic Lottery Concessionaires, the National Lottery, Lottery Betting Shops, Sports Betting Shops, raffles, Bingo halls and any gaming modality. The registry must contain the following information and be available to the Directorate of Casinos and Games of Chance at all times:

a. Customer identification information.

b. Detailed description of the prize.

c. Total value or amount of the prize, if applicable.

d. Type of currency used for payment.

e. Exact date of delivery or payment.

11. Submission of Statistical Information. Operators must submit statistical information quarterly to the Directorate of Casinos and Games of Chance within the first ten (10) business days after each quarter, including:

Operating volume including gross income segmented by month and type of customer;
List of players whose transactions, winnings or not, amounted to US$1,000.00 or equivalent, including customer identification data, risk classification and transaction date;
List of prize winners receiving US$1,000.00 or equivalent, including customer identification, transaction date, amount wagered and won, and customer risk classification.
Information regarding linked employees and terminated employees.
Information on products and services offered, including quantity and type.
Number of Suspicious Transaction Reports (STR) and Cash Transaction Reports (CTR) submitted to the FIU, by month, by establishment, by point of sale, without detailing client information or reasons.

Online game operators must submit statistical reports semiannually within the first ten (10) business days after each semester, including, in addition to the above, gaming sessions, accumulated transactions and net winnings.

Operators within an economic group must submit individualized information for each establishment.

12. Registration of Economic Groups.
    Operators that qualify as an economic group must register before the DCJA, providing information regarding the group’s structure and composition, as well as the identification of parties directly or indirectly linked through ownership, management, control, equity participation, or family ties. Once recognized as an economic group, they must implement an AML/CFT Compliance Program with a Risk-Based Approach adjusted to the size and risk level of the group as a whole.

Pursuant to Resolution 217-2025, an economic group is defined as a set of natural or legal persons linked directly or indirectly through ownership, equity participation, management, administration, kinship, or control, whose economic and financial activities are guided by common interests and carried out in a coordinated manner to achieve shared objectives.

The registration must be completed within no more than thirty (30) calendar days following the issuance of Resolution 217-2025.

The regulation does not require that the economic group be previously classified as such by the Dominican Tax Authority (DGII). However, it grants the Directorate of Casinos and Games of Chance the authority to classify or reclassify an operator as an economic group ex officio.

13. Supervisory Unit.
    The Anti-Money Laundering Prevention Department of the Directorate of Casinos and Games of Chance is designated as the unit responsible for supervising compliance with Resolution 217-25.

14. Payment of Prizes.
    Payments made by the operator through checks or other negotiable instruments, related to the payment of prizes, must be issued in the name of the winning customer. The issuance of bearer checks, checks payable to third parties, and the splitting of payments is strictly prohibited.

Important deadlines to consider:

• Six (6) months from the publication of the Resolution to update Compliance Manuals in accordance with Regulation 217-25.

• Thirty (30) calendar days from the issuance of the Resolution to request registration as an economic group.

• Ninety (90) calendar days from the effective date of the Regulation to conduct the first comprehensive risk assessment.

• Twelve (12) months from the effective date of Regulation 217-25 to submit the first external audit report.

• During the first one hundred and twenty (120) days of each year, a notarized Sworn Statement must be submitted, accompanied by:

  • Financial statements certified by a CPA,

  • The form filed with the DGII supporting annual sales,

  • TSS certification.
    This applies to companies with fewer than 50 employees and annual gross sales below RD$61,553,187.00 seeking exemption from establishing a dedicated compliance department.

• Submission of statistical information to the Directorate of Casinos and Games of Chance within the first ten (10) business days following the end of each quarter.