Why Curacao is reforming its licensing system

Introduction: what happened and why

Until 2023-2024 Curaçao lived under the outdated master-license → sub-license scheme, where the supervision of sub-licensees was indirect and lay with the holders of master licenses. This created risks for AML/CFT and reputation, which led the EU, the Netherlands and FATF to point out supervisory deficiencies and possible vulnerabilities for money laundering. In response, the country adopted LOK - National Ordinance on Games of Chance, which introduced direct state licensing and strengthened compliance.

Key drivers of reform

1. International pressure and compliance with standards. The island needed to address gaps in the old model, where sub-licensees fell out of the regulator's direct oversight.

2. Bank and payment access. Derisking by banks/PSP pushed to raise AML/KYC standards so that companies from Curaçao calmly go onboarding.

3. Player protection and market resilience. We need rules on segregation of client funds, technical audits and direct "fit & proper" for owners/key persons.

4. Economic strategy. The renewal of the regime increases the legitimacy of the jurisdiction and expands the pool of "white" markets available to operators.

What exactly has changed (LOK - "new architecture")

Cancel master/sublicense. Instead of an indirect model - direct licenses: B2C (operators) and B2B (suppliers), with a single registry and public supervision.

New regulatory loop. Oversight functions are formalized through the Gaming Control Board with the transition to the Curaçao Gaming Authority (CGA) by LOK; a full-fledged licensing, monitoring and sanctions toolkit appears.

Fit & proper и «key persons». Direct checks of beneficiaries, managers and responsible for AML/machinery/payments.

AML/KYC by international standards. Mandatory compliance programs, reporting, risk assessment, transaction monitoring.

Technical requirements and protection of players. Segregation of customer funds, game logs and auditing, responsible play policy, clear T&C and payment/complaint procedures.

Transition: Timing and status quo (2024-2025)

Deadlines for registering old sub-licenses in the GCB portal fell on March-April 2024 to switch to the new system.

Parliament approved LOK in December 2024; reform officially launches a "new era" of regulation.

LOK entered into force: from December 2024, provisions on direct licensing, enhanced compliance and transitional statuses are in effect.

The renewal of individual "temporary" licenses in 2025 confirmed the flexible transition for companies that managed to apply for LOK.

What it means for business

• You will have to relicense under LOK, put the ownership structure in order, appoint and approve "key persons."
• Strengthen AML/KYC, complaint regulations and RG, put things in order in payment chains and hosting/logs.
• Prepare for thematic audits, including an audit of financial segregation.

• Pros: transparent roadmap, understandable checklists, growing acceptability among banks/partners.
• Cons: more capital costs for compliance and terms of preparation (fit & proper, politics, technical audit).

How the "risk economy" is changing

Access to payment infrastructure: strong AML/KYC and direct supervision reduce PSP/bank failure - it is easier to scale white-label/B2B.

Reputation Award: LOK brands are easier to list partners and content marketplaces.

Reduced regulatory volatility: clear penalty/suspension procedures and public rules of the game replace "gray" sub-license practices.

LOK Preparation Checklist (short)

1. Ownership structure and documents for fit & proper (UBO, directors, AML officer).

2. AML program: CDD/EDD, sanctions lists, triggers, STR/SAR reporting.

3. Technical base: logs, RNG/content audit, incident policy, segregation of client funds.

4. RG and T&C: limits, self-exclusion, transparent rules for bonuses and payments.

5. Payments and providers: white PSP roadmap, on/off-ramp, bank letters.

Curaçao reformed licensing because the old format could not withstand the requirements of FATF/EC, banks and players. LOK closes these gaps: direct B2C/B2B licenses, hard AML/KYC, fit & proper, customer funds protection and a new institutional oversight framework. For the industry, this means more predictability and access to payment infrastructure - with a higher bar for compliance and responsibility.