The Curaçao National Ordinance on Games of Chance (LOK) 2024 brings major regulatory changes for gambling operators. It introduces stricter compliance requirements, a new licensing system, financial transparency, responsible gaming measures, and enhanced oversight.
We have carefully reviewed the 47-page regulatory document (download) to highlight the most important points for operators, suppliers, and investors.
1. Key Regulatory Changes Under LOK 2024
Curaçao Gaming Authority (CGA): Expanded Role & Powers
A major development in the new regulations is the establishment of the Curaçao Gaming Authority (CGA) as the sole regulatory body overseeing the gaming industry. The CGA replaces the previous decentralized system and is now tasked with:
- Granting and revoking gaming licenses.
- Regulating both online and land-based gaming operators.
- Enforcing anti-money laundering (AML) and responsible gaming practices.
- Supervising suppliers, software providers, and other key participants.
- Conducting regular audits and inspections to identify non-compliant operators.
- Maintaining a publicly accessible register of all licensed operators and service providers.
- Imposing sanctions, fines, and license suspensions for breaches of regulatory obligations.
The CGA now regulates marketing and advertising, restricting targeting of minors, misleading promotions, and excessive bonus incentives. Operators may be required to submit their marketing strategies for approval, and the CGA may set limits on ad frequency and placement (not yet determined).
These expanded powers provide the CGA with significant authority to streamline Curaçao’s gaming industry and align it with international standards.
2. Licensing Structure and Compliance Requirements
New Multi-Tiered Licensing System
Under LOK 2024, Curaçao now offers four distinct categories of licenses:
- Gaming License – Required for any entity operating games of chance, including online casinos, sports betting platforms, and poker rooms.
- Supplier License – Mandatory for service providers offering critical gaming-related infrastructure, including game developers, payment processors, and cybersecurity firms.
- Nonprofit Game License – Designed for gaming activities that channel profits toward charitable causes.
- Certificate for Service Providers – Issued to businesses that provide essential gaming-related services, such as affiliate marketing, hosting services, or compliance software, without operating games directly.
Each license category comes with its application process, compliance obligations, and annual renewal requirements.
Eligibility Criteria and Local Presence Requirements
- Mandatory incorporation in Curaçao – Gaming operators must register as legal entities in Curaçao.
- Physical presence requirement – A license holder must maintain an operational presence in the country, which includes:
- At least one Curaçao-resident key person for the first four years of licensing.
- Increasing to three key persons in the fifth year to reinforce local governance and accountability.
- Physical Office in Curaçao – License holders must own or lease an immovable property in Curaçao as a dedicated business space with the necessary facilities to conduct operations.
- Transparency obligations – Ultimate Beneficial Owners (UBOs) must be disclosed and undergo stringent background checks.
- Financial stability proof – Applicants must provide audited financial statements and demonstrate the ability to meet their financial commitments.
- AML Compliance – Operators are required to register on goAML, implement robust Know Your Customer (KYC) and Know Your Business (KYB) procedures, and report suspicious transactions.
- Third-party audits – License holders must submit to periodic financial and operational audits by CGA-approved auditors.
The process of application:
Phase 1: Initial screening of Ultimate Beneficial Owners (UBOs), financial viability, and corporate structure.
Phase 2: Full technical compliance verification, AML/KYC checks, and operational review.
Operators may receive a provisional six-month gaming license while completing Phase 2 requirements.
Operators who fail to meet these requirements risk immediate license suspension or revocation.
Exemptions & Alternative Compliance Options
- Startups & Small Operators Exemption
Startups and small operators may qualify for exemptions from the local presence requirement under certain conditions. Newly incorporated companies within one year of applying for a license can receive an exemption to facilitate early-stage growth. If no UBO has been linked to another gaming provider in the past two years, this measure ensures that established entities do not exploit the exemption.
Companies generating annual Gross Gaming Revenue (GGR) below ANG 20 million for the first three years are also eligible, allowing them to scale operations before complying with full local presence requirements. However, starting from the fourth year, these operators must fully comply and submit semi-annual financial reports to confirm continued eligibility.
- Ministerial Exemption
In cases where hiring local key personnel or securing a dedicated business space is unfeasible, the Minister of Finance may grant a temporary two-year exemption. This exemption is regulated by a national decree and may include additional compliance requirements. Operators benefiting from this exemption may need to implement alternative compliance strategies to ensure regulatory oversight remains effective.
- Alternative Compliance Measures
For operators unable to maintain a fully dedicated office, an alternative compliance measure allows license holders to share business premises with other regulated entities if they meet Curaçao Gaming Authority (CGA) operational standards. Such shared spaces must be reviewed and approved by the CGA to ensure they meet necessary operational, security, and accessibility standards.
This framework balances regulatory oversight with flexibility, ensuring that new and small operators can grow while maintaining compliance with Curaçao’s gaming laws.
3. Financial Obligations and Taxation Framework
Annual License Fees
The new framework introduces significant financial commitments for operators:
- Gaming License Fee: EUR 47,450 per year (split between CGA and the National Treasury).
- Supplier License Fee: EUR 24,490 per year.
- One-time application fee: EUR 4,592.
- Additional fees:
- EUR 150 per Ultimate Beneficial Owner (UBO) check
- EUR 2,551 per listed UBO registration
- EUR 250 per registered domain name
- EUR 13 per new game added to the platform
Gaming operators generating over €50 million in annual revenue may be subject to:
Higher licensing fees; More frequent financial audits (up to biannual reviews instead of annual); Stricter reporting obligations, including detailed breakdowns of Gross Gaming Revenue (GGR), player deposits, and transaction flows; Additional security requirements, such as higher financial reserves and stronger internal AML controls.
4. Responsible Gaming and Player Protection Measures
The new law introduces several player-centric protections, including:
- Mandatory self-exclusion options.
- Prohibition of offering credit to players.
- Stricter advertising regulations, ensuring that marketing materials do not target minors or vulnerable individuals.
- Implementation of fair gaming standards.
- Regular reporting on gambling addiction prevention programs.
5. Industry Impact and Remaining Uncertainties
While Curaçao’s new gaming regulations enhance transparency and regulatory compliance, several unanswered questions remain:
- What additional reporting and financial obligations will operators face?
- How will transition periods be handled for existing operators under the new framework?
Existing sub-license holders must transition to direct licensing within 12 months. Operators failing to transition risk immediate shutdown. Moreover, the CGA may revise fees, compliance rules, and advertising guidelines based on operator feedback and regulatory assessments.
The industry is now awaiting further guidelines from the CGA and legal clarifications on tax policies and compliance enforcement.
Conclusion: Key Takeaways for Operators
- Curaçao is transitioning to a fully regulated, globally competitive gaming jurisdiction.
- Operators must meet stricter licensing, compliance, and taxation obligations.
- Gaming businesses should budget for higher operating costs and tax liabilities.
- Until more clarity emerges, operators should take a cautious financial approach.
Stay Updated on Curaçao Gaming Regulations
The regulatory framework in Curaçao is evolving rapidly, and gaming operators must stay informed to remain compliant. We will continue to monitor CGA announcements and policy updates to provide the latest insights on Curaçao’s gaming industry.
.svg)
.svg)
.svg)
