Curaçao is a leading Caribbean gambling hub and a top global issuer of gaming licences. Until 2023, the compliance requirements for companies in this sector were relatively lenient. This made it possible to open a legal online casino quickly and easily. A Curaçao licence became a de facto standard for launching a high-risk gambling business. Opening a corporate account could be tricky, but the island’s reputation and adherence to AML/CTF rules often resolved those issues.
The old system for issuing gambling licences in Curaçao
The key document governing the issuance of special permits for gaming businesses is the National Ordinance Offshore Games of Hazard (NOOGH). It was adopted in 1993. The first licences were issued in 1996. In 1999, the island’s government created a special regulatory body called the Curaçao Gaming Control Board (GCB). It not only supervised the issuance of Curaçao gambling licences but also oversaw the entire gambling industry, including the first online casinos.
Key features of the old system:
- Two types of permits: master licences valid for five years (renewable) and sub-licences tied to the master licence period.
- Legal entities holding a master licence could grant sub-licences to other companies.
In the simplest case, launching a gambling business under a Curaçao licence involved forming a new company in Curaçao and obtaining a sub-licence from one of the four main holders. You also had to meet a set of organisational and technical requirements, which were usually straightforward.
This Curaçao licence structure was effective, flexible, and popular among businesses, and it was relatively easy to administer. It is why a small island jurisdiction became a leading gambling hub. However, modern trends in deoffshorisation and transparency have turned many of those advantages into disadvantages.
Reasons for Changes in the Online Casino Licensing Policy
The old licensing system was very convenient for businesses and comfortable for the authorities. The state effectively controlled the gambling sector, set the rules for its operation, and issued Curaçao master-level gambling licences. Relations between master licence holders and sub-licensee companies remained “behind the scenes.”
Here are the main reasons for changes in Curaçao’s gambling legislation:
- Stronger global trends towards deoffshorisation and transparency.
- Weak state oversight of companies operating under subordinate gambling licences.
- Desire to strengthen Curaçao’s reputation as a legal gambling hotspot.
- Stricter enforcement of AML/CTF standards.
- Curaçao’s budget shortfall (revenues from sub-licences went to the issuing companies).
- Accusations of passive involvement in money laundering.
Another indirect reason for tougher licensing rules is the example of Cyprus. In autumn 2020, Cyprus cancelled its “Golden Passports” programme. This happened after Al Jazeera journalists published an investigation revealing various violations and abuses. At that time, Cyprus was accused of issuing passports to suspicious or criminal individuals.
The investment citizenship programme was then frozen. The situation with Curaçao gambling licences is similar. When choosing between stricter control of the gambling sector or conflict with international regulators (FATF, OECD), the island’s authorities understandably chose stricter regulation.
Timeline of Changes to Legislative Regulation
Analysis of the dates shows swift reforms affecting the gambling sector. In just 18 months (starting July 2024), the authorities produced new regulations that would previously have taken much longer. This indicates Curaçao’s genuine interest in these measures. Another view suggests external pressure prompted rapid amendments to LOK.
Key dates in the evolving Curaçao gambling licence framework:
- 17 July 2023 – The Ministry of Finance formally announced a new licensing regime.
- 15 November 2023 – Online casino operators and other gambling firms began applying for licences under the updated rules.
- January 2024 – Start of the gradual transition to the new licensing standards.
- April 2024 – Preliminary version of the LOK (National Ordinance for Games of Chance) replaced the older NOOGH.
- 30 April 2024 – Final date for sub-licence applications.
- 15 July 2024 – National GCB portal (Curaçao Gaming Control Board) resumed full operations.
- 17 December 2024 – Curaçao’s parliament approved the new legal framework LOK (13 voted “for,” 6 voted “against”).
Deadlines for the Final Expiration of Master Gambling Licences:
| Date of Expiration | Curaçao Gambling Licence Owner |
|---|---|
| 18 August 2024 | Gaming Services Provider |
| 1 October 2024 | Cyberluck Curaçao |
| 28 November 2024 | Antillephone |
| 31 January 2025 | C.I.L Curaçao Interactive Licensing |
The expiry date of a master licence affects the licence holder’s legal right to operate in the gambling sector. It also directly impacts the companies that received permission from any of these four key entities in Curaçao’s gambling market.
New Curaçao Gambling Licences
The changes introduced by the LOK law have already impacted the global gambling market. The new measures affect online casinos and related fields, including betting. Typical examples include sports wagering, networked games, and other forms of bets. However, there should be no major structural shifts. The example of investment citizenship programmes is an indirect, yet telling, confirmation.
When it emerged that “Golden Passports” and “Golden Visas” could be obtained by people with questionable backgrounds, the eligibility rules changed. The option of real estate investments was removed from most programmes, checks on potential applicants intensified, and the financial thresholds rose. However, fast routes to residence or citizenship remained.
The most significant change in the Curaçao licence conditions for gambling concerns the types of authorisations. The old system, based on two possible ways to enter the market, was cancelled. It was replaced by two new types of licences, B2B and B2C. Their target audiences do not overlap. This approach allows the regulator to oversee all gambling companies effectively.
B2B (Business-to-Business) licence is aimed at organisations serving gambling market operators, such as:
- software providers,
- integrated solutions developers,
- payment service providers.
The B2B licence can be considered technical, as companies operating under a Curaçao B2B licence do not deal directly with the player (end user). This separation clarifies responsibilities and avoids imposing universal laws and regulations.
Meanwhile, the B2C (Business-to-Consumer) licence has a broader scope and is issued to companies that interact directly with customers and drive the main financial flows in the industry:
• online casinos;
• organisations running esports tournaments;
• lottery operators offering cash or tangible prizes;
• betting companies accepting wagers.
Changes in Curaçao’s Gambling Regulation
The new LOK law reshapes the balance of power in Curaçao’s gambling sector. Adopted at the end of 2024, it is too soon to assess its practical impact. No enforcement practice exists yet, and official regulator comments are not published. However, key updates for online casinos under the new licensing regime are already known.
Main changes introduced by LOK:
- A new national regulator, the Curaçao Gaming Authority (CGA), will oversee the gambling sector.
- Applications for Curaçao gambling licences can be submitted online through a specialised portal.
- Both B2B and B2C licences now last for one year, with an option to renew.
- A Curaçao gambling licence forbids offering clients products or services unrelated to licensed gambling activities.
- Obligatory economic presence (substance) in Curaçao is now required.
- The GCB’s supervisory roles have transferred to the CGA.
- The government has unlimited access to data on all entities holding a Curaçao gambling licence.
- Stricter reviews for companies applying to launch online casinos have been announced.
- The company requesting a gambling licence must be registered in Curaçao.
- All sub-licences are revoked, with the last master licence expiring on 31 January 2025.
Commissions and Fees
An unavoidable result of LOK is revised Curaçao gambling licence fees. Complete details are not yet available, but many expect a price review. The main reason for uncertainty is the direct comparison of older minimal costs under NOOGH and new fees under LOK.
Minimum expenses for licensing a Curaçao gambling project (B2C licence type):
| Criterion | Regulatory Standards (NOOGH vs New LOK Law) |
|---|---|
| Application Submission | 0 / €4,600 + €125–€250 for each company representative check |
| Licence Renewal in Curaçao | €18,500 / €24,600 |
| GPT Tax | 0% / 0% |
| Monthly Fee | €3,600 / €2,050 |
| Domains | Up to 40 ( €250 each ) / €250 each |
The minimum licensing costs after LOK’s adoption have decreased from €61,700 to €49,200, excluding domain fees. This appears illogical, given the stated objectives of transitioning to LOK. If Curaçao intends to optimise its budget revenue, a €12,500 reduced fee is hard to justify. Therefore, businesses should wait until the situation becomes clearer.
Control of Gambling Companies
Previously, many supervisory functions were performed by the master licence holders. Curaçao’s government only monitored four major entities. This approach created legal conditions for financial violations and abuses, prompting criticism from international regulators.
After LOK’s adoption, the situation changed. The document sets basic rules for all market participants holding a Curaçao gambling licence. The aim is to maintain order in the online casino sector and address AML/CTF compliance concerns.
Staff Requirements for Gambling Companies
Executives in key roles must be Curaçao citizens or residents. Under NOOGH, only one manager had to meet this criterion (CEO, CFO, COO, or CTO). Under LOK, the rule applies to three out of these four positions.
The minimum staff requirement also changed. Previously, any authorised employee could manage AML checks. Now you must hire a specific AML/CTF officer responsible for compliance.
Other Important LOK Provisions
- All shareholders and key personnel of gambling companies face stricter Due Diligence.
- The regulator places extra focus on beneficial owners and individuals with significant control (owning at least 10% of shares).
Changes in Regulation Principles
The Curaçao Gaming Authority (CGA) prioritises effective anti-money laundering and player protection. Curaçao’s gambling control must meet international standards. One key tool is the goAML financial platform (a UN product), which was not used before.
Additional control and state regulation measures include:
- mandatory certification of all gambling products;
- expanded protection for vulnerable players;
- transparent dispute resolution measures;
- complete ban on delegating Curaçao gambling licences;
- mandatory independent audits.
In the post-LOK era, the following business data will be public:
- detailed licence information (including issuance and expiry dates);
- a list of games, showing approximate win probabilities and payout details;
- key company data (including a list of responsible individuals with their contact info);
- information on dispute resolution methods;
- a detailed online casino operating policy;
- measures used for protecting players with gambling addiction.
During the transitional period, gambling companies may obtain a standard B2C licence in two forms:
| Licence Type | Issuance Conditions |
|---|---|
| Green | The licensing procedure under the new rules has been completed successfully |
| Orange | The gambling licence application has been submitted, but approval is not yet granted |
Key changes to organisational structure and staffing:
- Formal identification of key individuals and legal definition of their responsibilities.
- Residency requirements for online casino staff urge businesses to invest in training local employees.
- To secure a gambling licence, a company must officially hire several Curaçao residents or citizens (employment contracts, social contributions, minimum wage, etc.).
Applying for a Curaçao gambling licence
The transitional rules remain in place for now. The situation should stabilise within a few months once the regulator processes existing applications. The main reason for possible delays is the high demand created by the switch to LOK. We recommend waiting until the situation becomes clearer.
Securing approval for an online casino is complex. Forming an operator company in Curaçao is relatively quick, and problems are rare. Opening a corporate account can be difficult, because gambling is classified as high-risk. In some cases, an offshore bank account is possible, but it is not suitable for everyone. A British payment system is a good alternative.
The requirements for obtaining a Curaçao gambling licence have changed. However, the transition to the new legal framework (LOK replaces NOOGH) is not yet complete, so administrative challenges and delays are likely. You can submit an application now, but it is better to wait for official comments from the Curaçao Gaming Control Board (GCB). Only then should you plan your next steps.