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As a leading gambling hub where an enormous amount of gaming licenses have historically been issued by privately held master licensees with minimal regulatory oversight, Curacao has received long-standing criticism from the international community.
The absence of effective control over operators, combined with limited accountability mechanisms and frequent abuse of sublicensing conditions, made the Curacao sublicensing scheme a reference point for what the industry now seeks to avoid. These issues were among the first to undermine the reputation of this Caribbean country in the eyes of well-developed countries and international markets.
However, those systematic weaknesses – combined with both domestic and international problems, as increasing external pressure and the looming threat of potential trade and financial restrictions – pushed Curaçao to make steps on the side of historical gambling regulatory reforms and framework changes.
This article explores the drivers, mechanics, and implications of regulatory transformation in the Curacao gambling framework.
What Is the LOK and The Rationale Behind Its Introduction
National Ordinance on Games of Chance (in Dutch: Landsverordening op de Kansspelen or “LOK”) is a piece of Curacao legislation that marks a pivotal reform in the regulation of the region’s online gaming sector.
The enactment of LOK on December 24, 2024, introduced stricter requirements both for operators with existing master license holders and new operators. Curacao license reform was triggered by a complex set of factors that had accumulated as a drawback of the previous iGaming framework, compounded by global developments. Key drivers have included:
- Agreement with the Netherlands. During the COVID-19 pandemic, Curacao entered into an agreement with the Kingdom of the Netherlands, granting it pandemic relief packages in exchange for making a series of structural reforms – one being the overhaul and review of its gambling sector. This reform was actively pushed and promoted by the Netherlands in post-pandemic times.
- Risk of increased oversight. Largely, due to concerns about the exploitation of the gambling sector for criminal activity, there was a growing threat that Curacao could be placed on the FATF list of jurisdictions under increased monitoring. The government commenced to make reforms in order to avoid potential reputational damage and economic consequences resulting from such potential designation.
- Curacao’s budget shortfall. Under the previous master license regime, Curacao experienced significant budget deficits, as most licensing fees were concentrated on the four master license holders, with limited revenue flow to the government.
- Poor oversight and control for the sublicensee. The master license holders had the authority to set licensing conditions and exercise full control over the sub-licensees, resulting in inadequate supervision, regulatory fragmentation, and a lack of transparency in the sector.
1. Unified application requirements
Until the implementation of LOK, the Curacao gambling sector was regulated by the National Ordinance Offshore Games of Hazard (NOOGH) since 1991. Under NOOGH, the Curacao government issued four master licenses and authorized them to issue sublicenses to other operators.
Master license holders were given the power to set their own requirements for sublicensing, leading to a fragmented and largely self-regulated environment. As a general rule, they required sublicensees to maintain distinct policies, set up their specific regulations, AML norms, and KYC procedures. Certain master license holders asked sublicensees to also carry out additional paperwork and conduct virtual interviews with applicants, while another granted a license with no additional requirements other than a general set of documents.
In contrast, the LOK introduces a centralized licensing regime. One significant part of the reform is the establishment of the Curaçao Gaming Authority (CGA) – a newly formed main regulatory body responsible for issuing iGaming licenses and overseeing the gambling sector.
The LOK settles a unified and standardized licensing process, under which operators are required to submit their license applications through an online portal. Under this legislation, there is no longer the option to choose between more lenient master license holders, as all applications are reviewed directly by the CGA.
The CGA conducts a more throughout and rigorous assessment of all applications, focusing on compliance with all license conditions. Those include:
- Local Incorporation. Incorporating a legal entity in Curaçao, with management led by at least one Curaçao resident (service provider).
- Transparency in Ownership. Full disclosure of the identities and roles of all ultimate beneficial owners (UBOs) as well as other key stakeholders.
- Financial Compliance. Meeting financial obligations, including timely tax payments, and adhering to Curaçao’s financial regulations.
- Legal and Regulatory Compliance. Ensuring full compliance with legal frameworks including the National Ordinance on the Reporting of Unusual Transactions, the Sanctions Ordinance, and the National Ordinance on Games of Chance.
- Responsible Gambling Measures. Implementing responsible gambling policies to safeguard minors and vulnerable individuals, including self-exclusion tools and access to support resources.
- Employee Training Requirements. Providing ongoing staff training in responsible gambling, anti-money laundering (AML), dispute resolution, and others.
- Regulatory Reporting Obligations. Submitting all required compliance reports to the CGA as needed to verify adherence to regulatory standards.
- Local Presence Requirements. Within four years of license issuance, employing at least one additional local staff member, and by the fifth year, at least three local employees (excluding the resident director). Additionally, licensed operators are required to establish a substantial economic presence in Curaçao, including, but not limited to, conducting business operations from a dedicated, immovable commercial property located in Curaçao.
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Applicants/operators may face a license revocation or application rejection should some of the aforementioned compliance requirements not be met (i.e., deficiencies are not remedied).
2. License validity term
Both B2B and B2C licenses are now issued for a fixed term of one year, with the option for renewal upon payment of annual fees. On the opposite side, under the NOOGH licensing framework, sublicenses were valid for as long as the master license they were issued.
What’s important, as part of the transition to the LOK framework, the Curacao government has officially set an expiration date for all existing master licensors and their sublicensees. The last valid sublicenses expired in January 2025, thereby phasing out the previous regime.
What It Means for Existing Operators
Granular enactment and implementation of LOK provided existing operators the opportunity to either change the license jurisdiction or comply with the LOK provisions and derived regulations.
From January 2025, the holders of licenses issued under the NOOGH were required to apply for a LOK license as new applicants should they do not qualify for LOK transactional license before
In exchange for compliance with new Curacao gambling regulations, the operators benefit from the following:
- Enhanced credibility. Updated legislation, as well as a new regulator with continuously trained personnel and ongoing cooperation with the Netherlands gambling authority (Kansspelautoriteit) on LOK interpretation and enforcement, significantly boosts the reputation of the Curacao gaming license in the eyes of financial institutions, players, and suppliers. In exchange for license credibility, however, the operators will bear more operational and licensing costs.
- Compliance with international standards. As CGA tightens the application process, each operator wishing to work under the LOK license in Curacao is expected to become compliant with all applicable requirements. This means operators must implement a robust compliance program and demonstrate it during the license application reviews to be awarded the license alongside international recognition.
- More operator-friendly license issuer. Although under the new Curacao license requirements, the licensing process has become more prolonged, the CGA assists a lot with licensing proceedings and efficiently communicates all license deficiencies, providing instructions on how to remedy them.
The LOK Effect on New Applicants
One of the biggest challenges for new applicants is the substantial increase in licensing and compliance costs compared to the previous sublicensing model.
The minimum license fee under the LOK is set at EUR 47,450, which is considerably higher than former sublicense fees typically ranged from EUR 10,000 to EUR 20,000, depending on the master license holder.
In addition to the higher fee, the ongoing compliance costs under the LOK framework have increased. Licensees must now establish a robust, genuine, and active compliance program, rather than relying on a formal or nominal compliance program that was often tolerated under the old regime. Non-compliance under the new system carries serious regulatory consequences, including potential license suspension, revocation, or financial penalties imposed by the CGA.
New applicants should be ready to align their operations with new regulations as well as potentially qualify for certain compliance exemptions. For instance, startups and small operators can qualify for exemptions from the local presence requirement under specific conditions:
- To be incorporated within one year of applying for a license.
- Any Ultimate Beneficial Owners (UBOs) have not been linked to another gaming provider in the past two years.
- Annual Gross Gaming Revenue (GGR) below ANG 20 million (€10 million) for the first three years can delay full compliance.
- Starting from the fourth year, these businesses must fully comply with all local presence requirements.
- Operators must submit financial reports every 6 months to confirm eligibility.
- Operators could qualify for a temporary two-year exemption granted by the Minister of Finance. The conditions for such exemption shall be established by the Minister of Finance.
Global Perception: Will Curaçao Gain More Respect?
Such a regulatory shift to stricter license requirements will positively reflect on the general and international perception of Curacao. It is expected to substantially improve the international perception of Curaçao’s gambling sector, which has historically been criticized for regulatory laxity and associated risks.
Before LOK, Curacao’s gambling industry was widely perceived as vulnerable to serious compliance and reputational risks, including:
- Exploitation by criminal networks for the purposes of money laundering and terrorism financing, often through the use of online casinos licensed under the previous, loosely regulated regime. The weak due diligence and background checks allowed the use of companies with a sublicense for fraudulent activities.
- Regulatory inefficiency, particularly with respect to handling player complaints. Many such disputes had to be escalated to the Curaçao courts, where rulings were generally in favor of players and frequently resulted in the bankruptcy of non-compliant operators.
As the LOK introduces a unified, transparent, and enforceable licensing structure, it significantly enhances the supervisory possibilities of the CGA. Such reform is largely impacting the unity and impartiality of the whole licensing framework, which will be positively reflected in the FATF position on Curacao. Besides, it may lead to worldwide recognition of Curacao operators that will be dragged along by the new integration of Curacao with new payment processors and leading iGaming vendors.
What Operators Should Do Next
If you have any thoughts on applying for a Curaçao license or wish to continue operating under the LOK licensing framework, Inteliumlaw is here to provide you with tailored legal and regulatory guidance, whether you already hold a transitional license or are looking to establish a new gaming business.
Our dedicated team of skilled gambling legal professionals offers end-to-end support through the process of receiving a Curacao gambling license. Our support process includes:
- Preliminary Assessment & Documentation. We assist in preparing the full set of corporate, financial, and technical documentation required for your license application, tailored to your business model.
- Application Submission & Key Personnel Vetting. We will manage the submission of your license application or reapplication (in case you have already established as an operator in the region), guiding you through the verification process for all key persons involved in the business.
- Regulatory Audit Support. In tight collaboration with your project during the CGA audit, Inteliumlaw ensures prompt resolution of any deficiencies or compliance gaps identified during the review.
- License Issuance. Upon successful completion of the process, your business will be issued a full gaming license under the new LOK framework.
Contact Inteliumlaw today to book your initial consultation and begin the journey toward full regulatory compliance and long-term success in Curaçao’s evolving iGaming landscape.
