Licensees
Junket representatives

This section provides detailed information for junket representatives wishing to apply for a licence. It covers Licence applicants, who should apply for a licence, what we expect from licence applicants, how applications are assessed, how to apply, and our expectations of licensees.

Licence applicants

To be eligible to apply for a junket representative licence you must have an employment or consultant agreement with a junket operator licensed as a junket operator with the Commission (which agreement is subject to obtaining a junket representative licence from the Commission). Applications received that do not meet these criteria will not be accepted and you could lose your application fees.

No person shall perform any of the functions of a junket representative with respect to the Republic of Cyprus Integrated Casino Resort (ICR) unless that person holds a junket representative licence issued by the Commission.

Who should apply for a licence?

You must apply for a junket representative licence if you intend to provide junket representative services for a junket operator relating to the ICR.

What the Commission expects from licence applicants

Individuals applying for a junket representative licence should:

  • be able to demonstrate that they can meet the Commission’s suitability assessment
  • ensure that the activities they plan to carry out will be conducted in a manner which minimises the risks to the licensing objectives
  • work with the Commission in an open and co-operative way, and
  • disclose to the Commission anything which the Commission would reasonably expect to know.
How the application is assessed

The Commission needs to be satisfied that licensees are suitable to hold a licence and undertake the activities for which they are licensed.

The Commission will take a number of factors into consideration whilst processing your application and determining suitability including:

  • identity – The identity of the applicant will be established and verified using appropriate official documentation. We may carry out checks with overseas regulators. The Commission also asks for a current photograph of the applicant and will check that this is consistent with any photographs on any identity documents.
  • integrity – The integrity of the applicant will be assessed using a variety of means. The Commission will consider whether the information it collects raises any concerns about integrity. This includes an assessment of an applicant’s criminal record, and any past involvement in civil or regulatory investigations or proceedings. We will also consider the manner by which the applicant has conducted themselves with specific regard to the provision of gambling in other jurisdictions. The Commission will also consider the evidence and findings of any complaints about the applicant and/or investigations by other regulators, and we will investigate any history of compliance in previous employment. Applicants who have held a licence(s) in another jurisdiction are required, as part of the documentation to be submitted with the application form, to provide a letter of conduct from the jurisdiction(s) where a licence(s) is held.
  • finances – The past and present financial circumstances of the applicant will be investigated to ensure that the licensing objectives will not be put at risk. Where an individual is also providing funding for the junket operator, the Commission will want to be assured as to the integrity and source of such funds.
  • competence – Whether the applicant has the technical capability to provide junket representative services will be taken into consideration. This includes the applicant’s track record of compliance with the legal and regulatory requirements of any jurisdiction where they may hold a junket representative licence/permit or approval. The Commission may also take up references and may review the CVs of relevant persons to assess their work experience and the training they have received which demonstrates their competence to carry out the role required of them.
  • criminality – The criminal record of the applicant and/or individual(s) relevant to the application will be considered. Any prior offences committed by the applicant and any individual(s) relevant to the application will be taken into account when assessing an application for a junket representative licence. Any previous offences do not mean that the application will automatically be refused. Each case will be considered on its individual merits, and consideration will be given to the seriousness, relevance and date of the conviction. In evaluating the seriousness and relevance of an offence, the Commission’s assessment will focus on whether the conviction has a potential bearing on suitability to hold a licence and will have regard to safeguarding the licensing objectives and the public interest.

In assessing suitability, the Commission will use both the information and supporting documentation provided by the applicant as part of the application and information available from other sources (for example, open source, government departments, overseas regulators).

The Commission will carry out the investigations and enquiries it considers necessary to enable it to consider the application properly and in particular, the Commission may:

  1. carry out an investigation of the applicant in relation to the person’s suitability to be a junket representative
  2. carry out an investigation of any individual who may be an associate or who has a business association with the applicant
  3. require the applicant or any individual, referred to in (b), to provide such information and produce such records relevant to the investigation of the application
  4. require the applicant or any person, referred to in (b) to consent to having his photograph, and with the collaboration of the police, fingerprints and palm prints taken, and
  5. send a copy of the application and any such photograph, fingerprints and palm prints taken to the police, who will investigate and report to the Commission on such matters as the Commission requests.

For every application, the Commission may:

  • grant a licence
  • grant a licence subject to conditions required by the Commission
  • refuse a licence where there are reasons to do so.
How to apply

If you wish to apply for a Junket Representative licence you must:

Licensees

Junket representatives should familiarise themselves with the Casino Operations and Control Regulations of 2016, Part VII, section 20.

Moreover, licencees shall:

  • ensure compliance with the Law and Regulations with respect to junket operator licences and junket representative licences, including but not limited to continuing suitability and performing their duties under Section 43 of the Law and Regulation 20
  • upon request from the Commission, provide information, documentation, records and assurance, which constitutes evidence:
    1. of their continuing suitability to act as junket representatives
    2. of their good reputation for honesty and integrity and that they are not disqualified from maintaining a licence for any reasons relating to suitability, esteem, character, honesty or integrity
    3. of their financial soundness and stability and that they have sufficient financial resources and have the ability to obtain further financial resources to ensure financial viability
    4. that the reputation, suitability and record of compliance of the associates of the junket representatives remains suitable, and
    5. of any other matter relating to their activities.
  • enter into and maintain an employment or consultant agreement with the junket operator named in their licence and shall notify the Commission immediately should they cease to be employed by the junket operator named in their licence
  • appear before the Commission to answer questions relating to their licence or activities, when requested to do so
  • extend credit to junket customers only to the extent that their credit procedures have been submitted to the Commission and approved by the Commission.

Furthermore, junket representatives are not permitted (unless their licence issued by the Commission specifically permits them to do so) to:

  • receive fees or other payments directly or indirectly from a junket customer
  • handle junket customers money directly or indirectly
  • operate as a host in rooms specifically designed for very important persons (VIPs) at the ICR and which involve gaming for junket customers. The permitted extent of host services shall be defined and communicated by the Commission to the junket representatives
  • operate casino games or carry out gaming activities at the ICR.
What the Commission expects from licensees:

The Commission expects licensees to conduct their activities in a way that does not put the licensing objectives at risk. It expects those holding a junket representative licence to:

  • conduct their business with integrity
  • act with due care, skill and diligence
  • maintain adequate financial resources
  • work with the Commission in an open and co-operative way
  • disclose to the Commission at any time anything which we would reasonably expect to know
  • provide to the Commission such information or records as the Commission considers necessary from time to time, and
  • ensure that the junket operator and the services provided are in compliance with the Law, the Regulations and conditions imposed by the Commission in the junket representatives licence, including but not limited to compliance with Commission Anti-Money Laundering (AML) requirements.