Belize
Table of Statutes
This
is a non-exhaustive list of the main Belizean
statutes affecting offshore and non-resident
business. The statutes are listed in alphabetical
order - click on the statute for a fuller
description of the statute or the legal
regime it forms part of.
Belizean Nationality
Act 1981
Commercial Free Zone (CFZ) Act 1994
Computer Wagering
Licensing Act 1995
Exchange Control
Regulations 1980
Export Processing Zone (EPZ)
Act 1990
Fiscal Incentive Act No
6 Of 1990
IBC Act,
1990
Income Tax Amendment
Act 1998
International Insurance Act, 1999
Limited Liability
Partnerships Act, 1999
Limited Life Companies
Act, 1999
Money Laundering
(Prevention) Act, 1996
Mutual Funds Act, 1999
Offshore Banking (Amendments)
Act, 2002
Protected Cell Companies
Act, 1999
Registration
Of Merchants Ships Act 1989
Retired Persons
Incentive Act 1999
Trade Unions and Employers Organizations
Act of 2000
Financial Intelligence
Unit Act 2002
Trust Act 1992
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Belize
Banking Law
Offshore
banking in Belize began when the outdated
1977 Banking Act, which did not adequately
provide for a sound regulatory and supervisory
authority, was repealed and replaced by
the enactment of the Banks and Financial
Institutions Act, 1995, and the introduction
of the Offshore Banking Act, 1996, and the
Money Laundering (Prevention) Act, 1996,
which incorporated the best features of
offshore banking legislation in Panama,
Cayman and the British Virgin Islands.
The
Offshore Banking Act was amended in 2002
to change the name of the Offshore Banking
Act and offshore banks to International
Banking Act (IBA) and international banks,
respectively. The amendments also strengthen
the supervisory and investigative powers
of the CBB to meet international standards,
to provide better transparency and exchange
of information with respect to international
banking and to empower the CBB to grant
licenses for international banking.
A
Belize International Bank can carry on the
following activities within Belize:
- establish,
maintain, and operate a business office
in Belize;
-
transact offshore banking business through
its business office in Belize without
restrictions;
-
transact offshore banking business with
a local entity in Belize licenced under
the Banks and Financial Institutions Act,
1995.
The
major local banks offer a full range of
international banking services including
foreign currency savings and checking accounts
earning tax-free interest and operated for
the purpose of exchange control on a non-resident
basis. Such accounts are offered to IBCs,
individuals and trustees. Credit card services
are also available.
Belize
International Banks are not subject to exchange
control regulations.
The
Central Bank of Belize, the financial sector's
regulatory and supervisory body, says that
although many applications for international
banking licences have been received since
the introduction of the new legislation,
only five had successfully met its requirements
by mid-2003.
Two
categories of Belize International Banks
are currently available, "A" Class
- Unrestricted and "B" Class -
Restricted. A "B" Class bank is
restricted to carrying on such business
as is specified in its license.
The
holder of an "A" Class internationak
banking licence needs to establish, maintain,
and operate a business office (physical
presence) in Belize. This type of Belize
International Bank is permitted to transact
international banking business through its
business office in Belize without restrictions
on that business.
Authorised
and paid up capital of not less than US
$500,000 must be maintained if the licence
is for a local company, or US $25,000,000
in the case of a foreign bank.
"B"
Class - Restricted
The
holder of a "B" Class international
banking licence also needs to establish,
maintain, and operate a business office
(physical presence) in Belize, but they
are limited to transacting only such international
banking business as is specified in its
licence. A "B" Class Belize International
Bank is prohibited from soliciting or accepting
monetary deposits or any other valuable
property from the general public, as well
as from issuing cheque books or providing
any current deposits or chequing account
facilities to depositors.
Authorised
and paid up capital of not less than US$1,000,000
must be maintained if the licence is for
a local company, or US $15,000,000 in the
case of a foreign bank.
Belize's
International Banking legislation stipulates
that an entity is eligible to apply for
an international banking licence if:
- it
is incorporated or registered under the
Companies Act or the International Business
Companies Act as a company limited by
shares, or if it is a foreign bank;
-
its shares are in registered form and
not in bearer form;
its memorandum and articles of association
are acceptable to the Central Bank; and
-
its authorized and paid up capital are
in compliance with statutory requirements
(see above).
Upon
application, eligible companies must furnish
the following documentation, along with
a non-refundable fee of US $500:
- name
and address of directors and principal
shareholders;
-
the ultimate beneficial ownership of the
company or proposed company where shareholders
of record are, or are to be, corporations,
trusts or other legal entities or organizations,
or where the shareholders of record are
acting as nominees for or under the direction
of any other person;
-
the shareholding structure, management,
and financial standing of the company;
-
detailed business and financial plans;
-
particulars of referees, guarantors and
other third parties;
-
details of any subsidiary or affiliated
company;
-
details of any overseas office which the
company has or proposes to open;
-
names and addresses of the external auditors
including the experience of the auditors
in auditing banks;
-
if a foreign bank, a written statement
confirming that there is no objection
to the application from banking supervisory
authorities in its country of incorporation
and in the country where its principal
office is located;
-
signed application by the directors of
the eligible company; and
-
any other information that the Central
Bank may require.
The
Central Bank of Belize submits its recommendation
to the Minister of Finance within sixty
days of receiving a completed application.
After which, a decision is rendered within
four weeks by the Minister.
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Belize
Fiscal Incentives Act
The
Fiscal Incentives Act 1990 (FIA) superseded
and incorporated previous investment incentive
legislation.
A
company that meets the necessary criteria
set by the Ministry of Economic Development
is granted an "Approved Enterprise
Order" (locally referred to as a "Development
Concession") and is considered an "Approved
Enterprise" under the FIA.
Normally
tax holidays are given for a period of five
years commencing from the date of production,
but upon application the tax holiday period
may be renewed for a further term not exceeding
ten years. As an additional incentive, however,
companies that will engage in Agriculture,
Agro-industry, Food-processing, Mariculture
or Manufacturing and whose operations are
highly labour intensive and whose productions
are strictly for export, can be granted
tax holidays for up to twenty five years.
During
the tax holiday period, an approved enterprise
is partially exempt from the payment of
income tax on all profits and gains accruing
to the approved enterprise and arising from
the production of the approved product or
service under the Income and Business Tax
Act, at the specified annual percentage
rates.
In
addition, any dividends or other profits
arising out of such an enterprise during
the tax holiday period and paid to shareholders
during such period shall not be taken into
account when the chargeable income of the
shareholders is being ascertained. This
benefit, however, shall not apply:
- where
the total amount of the dividends or profits
paid to the shareholder exceeds an amount
which is equivalent to the total amount
invested by the shareholder in the said
enterprise during its tax holiday period;
and
-
where the shareholder is likely to become
liable by the laws of his country of residence
to pay additional tax owing to the fact
that the dividend he received hereunder
was not subject to income tax in Belize.
A
duty exemption period is normally not more
than fifteen years duration commencing from
the date of the approved enterprise order,
but in the case of an export enterprise
this period may be extended for an additional
ten years. And, for those companies engaged
in Agriculture, Agro-industry, Food- processing,
Mariculture or Manufacturing whose operations
are highly labour intensive and whose productions
are strictly for export, the duty exemption
period can be up to twenty five years.
Upon
production to the Comptroller of a certificate
issued by the Permanent Secretary in the
Ministry of Economic Development (such a
certificate specifies under what terms and
conditions certain articles or materials
may be imported, e.g,. being that they are
necessary for the establishment or expansion
and conduct of the approved enterprise)
an approved enterprise may import the following
items into Belize, free of customs duty
and stamp duty during the duty exemption
period:
- all
building materials, plant, machinery,
equipment, tools including specialist
hand tools (but not including other hand
tools), utility and transport vehicles,
fixtures and fittings, office equipment
and appliances, spare parts on plant and
plant related machinery and agricultural
machinery;
-
any raw materials or other items imported
for use in the approved enterprise.
However,
in the case of an export enterprise exporting
to non-CARICOM countries, no duty exemption
will be granted for any raw materials or
articles which are available in Belize or
in any Member State provided that they are
of comparable quality and price.
All
the rights, privileges, benefits, immunities,
duties and obligations conferred or imposed
by or under the FIA on an approved enterprise
can be transferred to another company where:
- the
approved enterprise merges with or is
taken over by another company, or forms
part of another company's reconstruction,
and/or
-
in the opinion of the Minister of Economic
Development it is equitable or in the
public interest to do so.
In
addition, an approved enterprise can also
benefit from Belize's access to a number
of preferential markets. These include the
USA under the Caribbean Basin Initiative,
Canada under CARIBCAN, the Caribbean under
CARICOM and Europe under LOME IV.
Establishing
an Approved Enterprise
The
Government considers several factors before
granting development concessions to companies.
These include: the company's local value
addition, its profitability on investment,
the potential for foreign exchange earnings
or foreign exchange savings, the creation
of employment, the transfer of new technology,
the location of industry, the destination
of the final products - export/domestic
market, and the level of investment.
The
following is required in order to obtain
the status of an approved enterprise:
- Establishment
of a Chapter 206 Corporation;
-
Formal letter of application addressed
to the Permanent Secretary in the Ministry
of Economic Development;
-
Three copies of the project proposal,
providing as much information about the
project as possible;
-
The prescribed non-refundable fee, which
varies depending on the size of investment
as follows:
-
US $250,000 - $500,000, fee US $5,000;
-
US $500,000 - $750,000, fee US $6,000;
-
Over US $750,000, fee US $7,000.00
A
"Belizean Company" with an investment
of less than US $250,000 may apply without
the payment of any fee. A "Belizean
Company" is one which Belizean nationals
own 51% or more of the share capital. A
number of other supporting documents are
also needed.
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Belize
Free Zone Acts
The
Commercial Free Zone Act 1994 established
a Commercial Free Zone at Corozal to attract
foreign investment. The Zone provides facilities
for various activities including manufacturing,
processing, packaging, warehousing and distribution
of goods and services.
Merchandize
warehoused in the CFZ may be wholesaled
or retailed for:
- sales
to diplomats of other countries who under
customary and conventional international
law are exempt from payment of duties;
-
sales to ships that dock at ports in Belize
and are destined for other foreign ports;
-
sales for direct export whether by sea,
air or land, provided that such merchandise
arrive at the port of exit under customs
control;
-
entry into national customs territory,
provided the goods are sold wholesale,
and the import license if so required,
is secured and the customs duties paid;
-
entry into national customs territory,
provided that the goods are sold retail
in operations which have licenses to sell
duty-free to residents and non-residents
who are leaving the country and have submitted
proof of departure. Such duty-free retailed
goods shall be delivered to the buyers
at a port of exit or embarkation.
Merchandise
may be sold inside a CPZ from one business
to another, provided that a proper record
is kept of such transactions.
There are no restrictions on foreign exchange
including the sale of foreign currency or
the transfer of foreign exchange into, out
of or within a CFZ by CFZ businesses. There
are no Government charges and taxes on the
use of foreign currency within a CFZ.
CFZ businesses are allowed to open an account
in any currency with a duly registered bank
of their choice which is located in the
CFZ.
Duty
exemptions and tax holidays are available
to the investors in the Zone as follows:
- All
merchandise, articles, or goods entering
a CFZ for commercial purposes are to be
exempt from import duties, stamp duties
and revenue replacement duties;
-
All fuel and goods including buildings
materials, furniture, equipment, supplies
and parts required for the proper functioning
of a CFZ business is likewise are to be
exempt from all duties and taxes;
-
No quotas upon any article, item, or goods
apply to imports or exports of a CFZ business;
-
Imports or exports of a CFZ business do
not require an import or export license.
-
Imports and exports of a CFZ to or from
whatever destination (other than the territory
of Belize) shall be exempt from all custom
duties, consumption taxes, excise taxes,
and export duties.
See
Offshore Legal
and Tax Regime for details of low rates
of income tax paid by CFZ businesses.
The Export Processing
Zone Act 1990
Belize's
legislation defines an EPZ as being "a
geographic area in Belize designated outside
national customs territory and duly restricted
by controlled access, wherein the benefits
created shall apply to a complex of industries."
The legislation also makes allowances for
single businesses and their facilities,
referring to these as "Special Export
Processing Zones".
An
EPZ business is only allowed to sell, lease
or transfer any article, item, goods or
services in an EPZ or outside Belize to
other EPZ businesses, to foreign businesses,
or to foreign individuals. However, waivers
to this regulation may be provided upon
application to the EPZ Committee (EPZC)
and the Ministry of Trade and Industry.
The EPZC comprises representatives from
various Government Ministries, The Chamber
of Commerce, the small business sector,
EPZ developers, EPZ businesses, and the
industrial sector.
In
the EPZ, facilities are provided for activities
in manufacturing, processing, packaging,
warehousing and the distribution of goods
and services. In fact, amendments made to
the legislation in 1994, provide investors
with the added option of constructing their
own facilities and developing infrastructure
within an EPZ, including independent utility
installations. This option enables an EPZ
to enhance its economic development, since
it does not necessarily have to use the
electricity or telephone facilities provided
by the two local monopolies, The Belize
Electricity Limited and The Belize Telecommunications
Limited respectively.
Three
locations have been designated as EPZs.
The San Andres EPZ is spread across 28.5
acres of land in the northern section of
the country, only 8 miles away from the
Mexican border, and ideally located next
door to NAFTA. The other two Zones are both
located approximately 9 miles from Belize
City, the country's commercial capital.
The EPZ adjacent to the Philip Goldson International
Airport covers a tract of 4 acres, while
the Price Barracks EPZ covers 14 acres.
A
developer is responsible for the administration
of an EPZ, and needs to own or have leased
all the land within the Zone, as well as
provide infrastructure and public services
within the area.
One
of the main incentives for establishing
an EPZ business in Belize is that of receiving
a guaranteed tax holiday of 20 years. Under
the tax holiday period, an EPZ business
is exempt from income tax, withholding tax,
capital gains tax or any new corporate tax.
This incentive also comes with the following
benefits:
- the
option to extend the tax holiday period;
-
losses incurred during the tax holiday
period may be carried forward and deducted
against any future profits;
-
and any dividend paid by an EPZ business
is exempted from tax in perpetuity.
In
addition an EPZ business is also exempt
from:
-
currency export taxes or foreign exchange
taxes on all purchases or sales of foreign
currency;
-
customs duties, tariffs, consumption taxes,
excise taxes, trade turnover taxes, or
other taxes for all imports of an EPZ
business into an EPZ;
-
customs duties, value-added taxes, sales
taxes, excise taxes, trade turnover taxes,
tonnage taxes, consumption taxes or other
taxes for all exports of an EPZ business
out of an EPZ;
-
capital gains tax on the sale of stock
or other partial or complete ownership
interest in an EPZ business, and property
or land tax and property transfer tax.
The Land Tax Act does not apply to EPZ
property.
Bureaucracy
is minimised for EPZ businesses:
- no
import or export licenses are required
for any imports or exports into or out
of an EPZ;
-
no licenses are required for domestic
suppliers who sell to EPZ businesses;
-
no price controls for items sold by domestic
suppliers to EPZ businesses;
-
no regulatory restrictions on any exports
(except of course for fire-arms, military
equipment or material, and illegal drugs
under the laws of Belize).
The
Supplies (Control) Act and the Rent Restriction
Act do not apply to an EPZ business either.
In addition, an EPZ business will enjoy:
- negotiable
factory space and energy rates;
-
on-site customs facilities;
-
no costs for work permits;
-
competitive wages;
- satellite
telecommunications and fibre-optic capability.
Preference
is given to those businesses which will
be located in an area designated by the
EPZC as in most need of development, as
well as to those businesses which will generate
more jobs. Some of the most promising areas
of interests are assembly plants, seafood
processing, fruit processing, wood products,
sporting goods, edible oils and fats, pharmaceuticals,
canning and packaging materials, garments
and yacht manufacturing.
The
following procedures need to be undertaken
to establish an EPZ business in Belize:
A
completed application form along with the
documents listed below must be submitted
with a non- refundable application fee of
US $500.00. This information will be reviewed
by the EPZC within thirty working days of
receipt.
- Physical
master plan showing overall layout;
-
proposed construction schedule;
-
capital cost estimate;
-
staff and management organisation;
-
five year financial projections, including
leasing or sale arrangements plan;
-
copies of the company's Memorandum and
Articles of Association, and Certificate
of Incorporation;
-
two bank references on the firm and its
main partners;
-
one commercial reference each on the firm
and its main partners;
-
and any other information which the EPZC
may require.
The
Certificate of Compliance, issued by the
Ministry of Trade and Industry, allows a
company to conduct business within an EPZ.
This certificate also states what lines
of businesses the EPZ enterprise may conduct
within the Zone. Application forms must
be submitted along with the documents listed
below. No application fee is required, but
an annual fee of US $0.13 per sq. ft. of
industrial roof is payable. And, for those
firms requiring over 7,500 sq. ft. of industrial
roof, the excess of 7,500 sq. ft. is assessed
at 80% of the basic fee mentioned above.
The Ministry of Trade and Industry will
review the information provided within thirty
working days of receipt.
By
signing an Operations Contract with the
Ministry of Trade and Industry, the owner(s)
of an EPZ enterprise pledges "compliance
with all applicable legal and regulatory
requirements under the laws of Belize, and
all rules and regulations of the established
EPZ."
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Belize
Shipping Law
Registration
of Merchant Ships Act, 1989 established
the International Merchant Marine Registry
of Belize (IMMARBE). IMMARBE's worldwide
network of surveyors provides shipowners
with ease of access in obtaining the technical
certification necessary for compliance with
the legislation.
The
Act stipulates that every vessel registered
in IMMARBE must have a shipping agent in
Belize. In addition, based on the type of
ship, vessels seeking registration are expected
to have the following certificates on board
at all times:
- International
Loadline Ship Safety Radiotelephony;
-
Ship Safety Equipment Ship Safety Radiotelegraphy;
-
Ship Safety Construction International
Oil Pollution Prevention;
-
International Tonnage Passenger Ship Safety;
-
Annual General Inspection Shipboard Oil
Pollution Emergency Plan.
IMMARBE
normally grants provisional registration
to vessels for a period of six months (extensible
to one year). Applicants may then apply
immediately for permanent registration (valid
for five years).
All
formal applications need to be signed by
both the shipping agent of the vessel and
the shipowner or his duly authorised representative.
For
provisional registration, the following
documents are required in addition to the
application form and fee:
- a
duly notarised power of attorney in favour
of the shipping agent of the vessel;
-
a copy of a tonnage certificate issued
by a classification society or technical
company or a copy of the last patent from
the last registry;
- request
for confirmation of availability of vessel’s
name;
- application
for Registration of Ships form duly completed
and signed by the applicant. One application
for each vessel is required. This application
includes the necessary information for
the issuance of a Provisional Ship Station
License;
- proof
of Ownership in the form of a Bill of
Sale, Auction Document or Builder’s
Certificate;
- valid
Cargo Ship Safety Radio Certificate in
compliance with GMDSS Code (where applicable);
- international
Tonnage Certificate (where applicable);
- proof
of compliance with ISM Code-Copy of Document
of Compliance and Safety Management Certificate
(where applicable);
- application
for Minimum Safe Manning Certificate;
- letter
of confirmation from an authorized radio
accounting entity undertaking the payment
of vessel’s radio accounts;
- letter
of undertaking from ship owner that the
applications for the Endorsements of Licenses
for officers will be submitted.
In order to facilitate same day registrations,
the above documents may be sent by fax.
For
permanent registration, the following documentation
(where applicable) need to be submitted:
- a
duly notarised bill of sale, or a duly
notarised builder's certificate, if the
vessel is newly built;
-
an original deletion certificate or a
certified copy of the extract of registry
from the previous flag administration;
-
a duly notarised power of attorney in
favour of the shipping agent of the vessel;
-
in the case of a vessel which is over
twenty years old, an inspection report
prepared by an authorised Government Safety
Inspection (GIS) Surveyor stating that
the vessel has passed an inspection to
determine seaworthiness;
-
an original or a certified true copy of
a tonnage certificate issued by a survey
company authorised by IMMARBE.
- copies
of all valid statutory certificates issued
by a Recognized Organization on behalf
of the Government of Belize, including
the ITC, DOC, SMC, ILLC, CSSRC, etc.,
- application
form for Maritime Ship Station License
duly completed;
- copies
of Document of Compliance and Safety Management
Certificate issued by a recognized organization
on behalf of the Government of Belize
(where applicable).
All
documents submitted must be in English or,
if they are in a foreign language, they
must be accompanied by an official translation.
IMMARBE
also accepts vessels to be registered for
a short period under special circumstances
such as one delivery voyage for scrap. Procedures
for special registration allow for documents
to be issued with a validity of three months
and automatic expiration when this period
elapses.
Dual
Registration
A
vessel's status with IMMARBE will not be
affected if a second registration in another
country is obtained in order to comply with
the terms of a charter contract. The applicant
is responsible for obtaining the necessary
approval in the country in which the second
registration is being sought.
A
formal application to IMMARBE is required,
and it is to be submitted along with the
following documentation:
- full
details of the contract, including the
name and address of the charterer, and
the date of expiration of said contract;
-
a notarised letter of consent from the
mortgagee is also needed, if the vessel
has a mortgage recorded on it.
Vessels
may initially be granted dual registration
for two years, during which they must continue
to make all relevant annual payments and
other dues to IMMARBE. A vessel's title,
mortgage or other documents also need to
be registered exclusively at IMMARBE's Head
Office during this time period.
Registration
of Foreign vessels
IMMARBE
permits the registration of foreign vessels
which are under the terms of a charter contract,
as long as such dual registration is allowed
by the vessel's mother country. The following
documentation need to be submitted along
with the completed application form and
the prescribed fees:
- notarised
copy of the charter contract;
-
certificate of freedom from registered
encumbrances or a registered lienholder's
letter of consent.
After
all the formalities have been met, IMMARBE
will then issue a special navigation and
radio licence to the vessel for an initial
period of two years. Title, deed, mortgage
or other documents relating to such vessel
need to be registered only at the vessel's
mother registry during this time period.
Registration
of Particulars
Both
preliminary and permanent registrations
are available for titles, mortgages, assignments
and other documents relating to vessels
governed by the Belize Registration of Merchant
Ships Act, 1989. A preliminary registration
(valid for six months) has "the same
legal effect as a permanent registration,
provided that permanent registration is
effected within the six months period of
validity".
The
documents that need to be submitted must
be in duplicate and duly authenticated by
a notary public or a Deputy Registrar of
IMMARBE in the place where such documents
were issued. If a document is not written
in the English language, it must be translated
to English by a competent and qualified
translator in order for it to be registered.
See
Offshore
Legal and Tax Regime for details
of fees and taxes payable in respect of
ship registration.
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Belize
Internet Gambling Law
Belize
is one of the few countries that has enacted
legislation allowing for the establishment
of online wagering. Its Computer Wagering
Licensing Act, 1995, which came into force
on May 28, 1996, provides for the proper
conduct and regulation of gambling via the
Internet.
Besides
legalising wagering on the Internet, the
Act also provides for the licensing of computer
services operators who provide Internet
users with the facility to wager against
each other on sporting events or other games
of chance.
'Computer
Internet' is defined in the Act as being
any publicly accessible data transmission
network, or any privately-owned data transmission
network which is authorised to transmit
such data. And, computer wagering service
is defined as being a computer service which
allows computer users to wager on sporting
events or other games of chance against
each other through the Computer Internet.
The
Belize Computer Wagering Licensing Board
vets all applications for licences to provide
computer wagering services and, with the
prior approval of the Minister of Home Affairs
(Minister), can grant exclusive licences.
They are also responsible for the control
and regulation of all persons who provide
computer wagering services.
The
Board is comprised of the Accountant General,
the Auditor General, the Permanent Secretary
of the Ministry of Home Affairs, and three
other persons appointed by the Minister,
one of whom is appointed on the recommendation
of the Leader of the Opposition.
Application
for a licence to provide computer wagering
services should be accompanied by the prescribed
licence fee of US$15,000 for a non-exclusive
licence. If an application is refused, the
licence fee is refundable subject to an
administrative charge.
If
a licensee breaches any provision of the
Act, or any regulations made thereunder,
or any of the conditions attached to the
licence, the Board may at any time revoke
the licence without compensation and without
prejudice to any other penalties imposed
by or under the Act. Revocations may be
appealed to the Minister whose decision
is final. Regardless of the time of issue,
an annual licence expires on March 31st
next following.
The
following documentation need to be submitted
upon application for a licence to provide
computer wagering services:
- Application
letter - including corporate name, website
address and a brief description of the
activities of the business;
-
Description of project - including methodology,
operational procedures, etc.;
-
Business background of the Company as
related to Wagering on the Internet;
-
Memorandum and Articles of Association;
-
Certificate of Incorporation or registration
in Belize;
-
Names and personal employment record of
the beneficial owner(s), officers and
principal employees;
- Character
references of the beneficial owner(s),
officers, and principal employees;
-
Police/criminal history record of the
beneficial owner(s), officers and principal
employees;
-
Names of all holding, intermediary and
subsidiary