The LOK has passed in Curacao: What Does It Mean For Operators
The Curacao parliament approved significant reforms to online gambling. A majority vote of 13 to 6 brought clarity to the Curacao license obtaining process. It represents the biggest shake-up of the iGaming industry, changing not only the island’s online gambling regulations but also the rules of the game and the hierarchy of jurisdictions. How will this impact existing operators and new market participants? Let’s take a closer look.
Major Changes Under The LOK Law
Big changes have been underway since 2022, when the first rumors emerged that Curacao would redesign its framework. The adopted law will lead to three significant changes:
Transition from Master License to Direct Licensing
The LOK replaced the well-known master license holders that worked for two decades with a direct-obtaining model.
This means that only the GCB, as the central regulatory body, has the authority to issue licenses, replacing the previously fragmented system of master license holders. So, operators must apply directly to the GCB to obtain the Curacao gaming license. Being the only regulatory body, the GCB is also responsible for regulating operators and enforcing compliance.
B2B and B2C licenses
The upcoming law caused confusion in understanding the new types of licenses. In reality, B2B (Business-to-Business) and B2C (Business-to-Consumer) have always been available to get from Curacao, and they still cover all major online gambling activities. The difference is the costs for the licenses.
From now on, the B2C license application fee will be €4 500 (or ANG 9 000), as well as one-off due diligence fees that range from €140 (ANG250) to €270 (ANG500) per person. The exact amount of due diligence fee depends on the person’s role. The annual fee will be more than €25 000 (ANG48 000), while the monthly fee will be at €2 000 (ANG4 000). Future B2C license holders must pay €270 (ANG500) per domain. The rate applied is 1.00 EUR = 2.00 ANG.
The same applies to the new B2B licenses under the LOK framework. The primary differences are that B2B licenses will not incur a monthly fee, and this license type does not include domains.
Please note that above are the costs and the final price will also include company formation fee, local managing director fee, agent’s fee and other. Moreover, Curacao introduced different seals (orange and green ones) where orange seal would cost extra 14,000 EUR. On average the final price would be 90,000 - 100,000 EUR.
Strict compliance requirements
Compliance is stricter than ever before, more similar to Malta (the most difficult international license to get). Moreover, Curacao consulted Maltese lawyers to help them to develop LOK regulations, borrowing best practices from Malta’s highly regarded gaming framework.
The key Curacao’s compliance requirements include:
- Enhanced Anti-Money Laundering (AML) Compliance. Obtaining a license process is now impossible without implementing robust AML measures. All about prevention of money laundering, and other illicit activities. That means that operators must monitor transactions, identify suspicious activities, and report them to the above-mentioned GCB. As for implementing AML policies, they must comply with international standards, particularly those set by the Financial Action Task Force (FATF) and the Caribbean FATF (CFATF).
Moreover, the appointment of compliance officer meeting specific "fit and proper" criteria becomes a mandatory for each Curacao entity.
- Due Diligence (CDD) and Enhanced Due Diligence (EDD). The LOK legislation requires comprehensive due diligence checks from both corporate entities and individuals associated with the business. That is why the jurisdiction will impose one-off due diligence fees on individuals. In this case, Curacao is trying to avoid fraud or unqualified operators.
- Know Your Customer (KYC). Operators must verify the identities of their players, collect identification documents, and verify financial sources. It’s no longer possible to turn a blind eye to high-risk customers, who used to engage in unusual transactions. Operators must enhance due diligence of those.
- Responsible gaming. The same applies to promote responsible gambling. Operators must set deposit limits, implement self-exclusion programs, and offer resources for those at risk of gambling addiction to show Curacao that they protect players.
To ensure ongoing compliance with AML, KYC, and responsible gaming policies, the regulator plans to undergo regular audits. The GCB or independent third parties will be responsible for the audits.
Impact of The LOK on Gambling Operators
Higher costs for operators than ever before: The updated framework introduces higher costs for operators: application fee, annual and monthly fees, as well as domain fees per each domain, and due diligence fee for all individuals associated with the business.
Potential delays: The GCB will go through challenging times of increased workload. It’s impossible to issue licenses to all applicants at the same time, some will meet a delay. For example, the regulatory body has processed 200 applications from 741 transitioning from Masters since April and 300 more new ones. With a promise to process 600 total by January, but it sounds surreal given the current pace.
It means to be delayed with every old and new applications..
Unpredictable compliance with the law: No one can say how the GCB intends to manage the licensing process and ensure compliance with the stricter requirements.
It means more surprises are coming..
Enhanced reputation and trust from players and financial institutions: With help of the LOK legislation, Curacao enhanced its reputation, taking the first place in the iGaming industry together with Anjouan license, leaving other licenses in second place. That is why the jurisdiction is attracted to some providers like Evolution Gaming, EGT, and Play'n GO.
Potential impact on other jurisdictions: Curacao is going to replace Malta adopting its due diligence process but complete the full process faster. Other licenses, such as Anjouan, can become more attractive to operators, due to it taking the place of the former Curaсao.
Preparing to the Future: Action Steps for Operators
The near future promises to be turbulent for operators seeking to obtain a Curaçao gaming license. Stricter requirements and higher fees make a Curacao license more unattainable for startups. Considering more affordable alternatives, such as Anjouan or Tobique, can be a great solution. We can assist you with finding the right license for your project.
As for the businesses with experience in gambling industry, it needs to carefully choose a local director in Curacao to avoid hidden fees, slow responses, rejections of document signing, and refusals to issue a power of attorney. Such issues can ruin a business or cause significant harm.
Does the task seem impossible? We agree — it’s a very challenging process, which is why MGL is always ready to help. This is a time of growing opportunities, and choosing the right agent to obtain your license can make you a winner.
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