Regulation through the Ministry of Tourism and Finance

Regulation through the Ministry of Tourism and Finance (Saint Lucia)

Brief summary

Gambling supervision in St. Lucia is built around three pillars: policy and development of the tourism product (Ministry of Tourism), financial stability/taxes/AML control (Ministry of Finance, including the competence of the Treasury and financial intelligence), and a specialized regulator (gambling council/power) implementing day-to-day supervision. Such a "triangular" model allows us to simultaneously see the industry as part of the tourism ecosystem and as a source of fiscal revenues that requires strict compliance and transparency.

Roles and Responsibilities

Ministry of Tourism

Product development policy: integration of casinos and betting points into resort clusters, MICE and "evening economy."

Locations and planning: coordination of zoning of 18 + spaces in tourist areas, requirements for navigation/guest safety.

Marketing and image: advertising standards for a foreign audience (without "easy money," 18 +, RG disclaimers), correlation with the country's brand guides.

Customer experience: requirements for accessibility, language support, tourist complaints and communication with the Ombudsman/ADR.

ESG/sustainability: emphasis on noise, traffic flows, energy efficiency of sites, local suppliers.

Ministry of Finance

Fiscal framework: licenses/fees, gross gaming income taxes (GGR) and corporate taxes, financial reporting.

AML/CFT: risk assessment methodology, interaction with banks/PSP, suspicious transaction reports (STR/SAR), sanctions lists.

Payment corridors: coordination of "white" channels with banks and payment providers, approve rate/commission/withdrawal time.

Treasury control: segregation of customer funds, bonds/guarantees, refund procedures.

Data and audit: accounting standards, API reporting for aggregated statistics and selective audit of licensees.

Profile regulator (gambling board/authority)

Issue/renewal of licenses (operators, bookmakers, equipment manufacturers/distributors).

Technical control: admission of equipment, rules for the operation of halls, inspections, investigation of incidents.

Player protection: RG tools (limits, self-exclusion), 18 +, transparent T & Cs, access to independent ADR.

Quarterly reporting: turnovers, GGR, RG/AML metrics, security incidents.

How decisions are agreed: "process from application to operating activities"

1. Pre-screening (tourism)

Analysis of location, transport infrastructure, compliance with tourist zones and ESG requirements.

Position letter: admissibility of the project in the context of tourism strategy.

2. Licensing (regulator)

Due diligence of beneficiaries, review of business plan, equipment requirements and internal controls.

Public notice and objection window (if applicable).

Recommendation for issuance/refusal/conditional license.

3. Financial Reconciliation (Finance)

Bonds/guarantees, opening trust accounts of client funds, connection to permitted PSPs.

Setting up forms/channels of fiscal reporting and thresholds of AML triggers.

4. Start-up and monitoring

Site/system inspection, green light for opening.

Quarterly API reporting (turnover, GGR, conclusions, approve payment rate, RG/AML signals).

Joint inspections for complaints/incidents.

Coordination mechanisms: MoU and RACI

Memoranda of Understanding (MoU) between tourism, finance and the regulator record:

data exchange (finance ↔ regulator), procedure for joint inspections (regulator ↔ tourism), AML/payment escalation (finance ↔ regulator ↔ banks/PSP), KPI and SLA for responses to interdepartmental requests.

RACI matrix (schematic)

Responsible: regulator for licensing and inspections; finance for fiscal and AML; tourism for zoning/marketing.

Accountable: profile minister (in his block); Cabinet - on key issues.

Consulted: Police/Fire Supervision/Municipalities.

Informed: Ombudsman/ADR, industry associations, NGOs.

Responsible play and advertising policies (cross-cutting for both ministries)

18 + and verification: e-KYC on risk, youth targeting ban.

RG instruments: deposit/time/loss limits, cool-off/self-exclusion; "hard" delay to increase the limit.

Marketing: no promises of "easy money," clear bonus/vager rules, tourist coverage - only in adult media slots.

ADR: available independent dispute arbitration with transparent timing.

Data and digital surveillance: "one portal - three panels"

E-licensing portal: statuses of applications/renewals, checklists and notifications.

Tourism panel: zoning maps, calendar of events, load on areas.

Financial dashboard: aggregated fiscal data, approve rate/commissions/withdrawal dates, STR/SAR (without PII).

Regulator panel: RG/ADR/incidents, inspections, technical tolerances of equipment.

Industry Management KPIs

Block	Indicator	Purpose
Tourism	Share of facilities in approved 18 + zones; Evening Product NPS	Compliance with zoning; NPS ≥ 70
Finance	Approve payment rate; average commission; Output TAT	Approve ≥ 85%; ↓ commission; output <48 h
Regulator	% of accounts with limits; complaints/ADRs and resolution deadline; reporting portal uptime	Accounts with limits ≥ 60%; 90% ADR ≤ 30 days; uptime ≥ 99.9%
Soc. stability	Number of self-exclusions and speed of interventions	Rapid help, reduced relapse

Risks and how ministries contain them

De-risking banks/PSP: finances lead "white corridors," publish aggregated AML metrics, keep spare providers.

Reputational incidents in travel zones: tourism + regulator - quick audit, correction plan, communication with business and NGOs.

Compliance gaps: regulator - inspections and regulations; finance - accounting adjustments and, if necessary, fines.

Protection of minors: tourism - zoning and media policy; regulator - control of advertising materials and access.

Cyber threats/leaks: common WAF/DDoS/SIEM/SOC standards and annual licensee pentests.

Roadmap 12-24 months

1. Unified e-portal: license statuses, API reporting on turnover, RG/AML and payments.

2. MoU with banks/PSP: public quarterly KPIs (approve rate, commission, deadlines).

3. Zoning 18 +: updated maps of tourist clusters, navigation and requirements for facades/signs.

4. Advertising codes: general guidelines of ministries for offline/online, control of influencers.

5. Ombudsman/ADR 2. 0: standardized SLAs, online cabinet for tourists and locals.

6. Training programs: RG/AML for personnel, safety and service; joint trainings of ministries and the regulator.

7. Public dashboards: Aggregated metrics (no PII) on RG/ADR/payments to build confidence in banks and society.

Practical checklist for applicant (operator)

Confirmation of zoning from the Ministry of Tourism (location, facade, navigation, operating mode).

Regulator licensing package: beneficiaries, internal controls, equipment specifications, RG policies.

Approvals from the Ministry of Finance: bonds/guarantees, trust accounts of client funds, connection to the "white" PSP, API reporting format.

Advertising policy: 18 +, RG banners, youth targeting ban, transparent bonuses.

Preparation for inspection: KYC/AML procedures, incident log, personnel training, response plan.

The model "Tourism + Finance + Profile Regulator" allows St. Lucia to maintain a balance between the attractiveness of the resort product and strict financial discipline. Ministries set the strategy and fiscal/social standards, the regulator - daily control. By 2030, a bunch of e-licensing, "white" payment corridors, clear advertising of 18 + and mature RG/AML practices are not only about compliance, but also about the competitiveness of the island on the Caribbean map.