Curacao's license reform: what awaits gambling operators

Until 2025, the gambling licensing rules in Curaçao were widely regarded as among the most lenient and straightforward in the world. The jurisdiction's existing system offered two license types: a master license and a sub-license. The requirements for obtaining a master's license were relatively high. Thus, only four large gambling market players (the “big four”) obtained them: Cyberluck Curaçao N.V., Antillephone N.V., Gaming Services Provider N.V., and Curaçao Interactive Licensing N.V.

These master license holders had the right to issue an unlimited number of sub-licences. While the “big four” were rigidly controlled by the national regulator of Curaçao (known as GCB, or Curaçao Gaming Control Board, since 1999), numerous sub-licensed businesses were operating in the most favorable, almost greenhouse-like conditions. On paper, there were some compliance rules, but they were purely nominal.

The additional advantage of Curaçao is a favorable legal environment, offshore status, relatively low costs, a strong global reputation, and high confidentiality. All these facts made the jurisdiction one of the leading gambling centers.

However, in late 2024, Curaçao introduced new regulatory standards, replacing the National Ordinance on Offshore Games of Hazard (NOOGH), which had been in effect since 1993. The document called LOK (Landsverordening op de kansspelen) created a new legal space in which there was no room for the previous liberal rules. It became evident that the gambling business on Curaçao would no longer be able to function as it had.

But does that mean the jurisdiction is no longer worth it for companies seeking gambling licenses? To determine the best course of action, we consulted our experts to analyze the current situation and prepare an objective article accordingly. But there is one thing we can state for sure: the rumours that the new LOK law has put an end to the gambling business in Curaçao are greatly exaggerated.

Reasons for Licensing Rules Changes

The primary official argument for introducing the LOK is to transform Curaçao into a jurisdiction that adheres to law and is transparent in meeting KYC/AML standards. Such a step was supposed to make business safer for players, attract additional investment into the budget, and ensure the national regulator's control.

There are no apparent contradictions in this version. The business gradually gets used to the fact that it's better to start forgetting about the days of offshore independence. The financial flows must be transparent, the taxes must be paid in full, and the players must feel secure under the law. It's hard to argue this, but in most cases, the valid reasons for system changes are hidden beneath layers of official statements, press releases, and official speeches. The LOK implementation is not an exception.

The independent experts believe that Curaçao's new rules for the issuance of gambling licenses are not just about business but also a global redistribution of spheres of influence. To be more precise, those are the actions of the European gambling lobby.

The thing is that strengthening business controls and implementing KYC/AML regulations created significant problems for the gambling operators on the European market. As a result, gambling companies have moved to jurisdictions with more lenient licensing rules. It caused a decline in budget revenues even in leading European gambling centres, such as Malta, Gibraltar, and the Isle of Man.

The national regulators in these countries had to follow the pan-European directives, since they had little room for manoeuvre. But of course, they couldn't silently observe the capital outflow. The solution to this difficult situation was the "forced" introduction of transparency standards into the legislation of competing jurisdictions, including Curaçao.

Key Accusations:

• Almost non-existent control during sub-licence issuance;
• Minimum (rather declarative) monitoring of businesses working under sub-licences;
• Limited transparency of reporting mechanisms;
• Tax and financial abuses;
• Too lenient regulating rules.

All these factors contributed to Curaçao's popularity as a global center for issuing gambling licenses. And the same factors, at the instigation of the gambling lobby, have caused discontent among international regulators.

Chronology of Events

The severe pressure on Curaçao is no new phenomenon. The first complaints from international regulators emerged in the early 2010s. The main shortcomings were typical for an offshore jurisdiction: partial AML compliance, formal oversight of sublicense companies, and unclear, diffuse powers of national regulators. But then, in the FATF and MONEYVAL reports, Curaçao was cautiously labeled as a jurisdiction with insufficient transparency of financial flows.

In 2017-2019, pressure on the offshore zone intensified. "Expert" reports began to appear in Europe directly linking Curaçao to illegal gambling in the EU. There was no actual evidence.

No one presented it that way, but public opinion was swayed in the right direction. At the same time, the Dutch regulator, the KSA (Kansspelautoriteit), took a stand against Curaçao, which was an unpleasant surprise given the close political and economic ties between the two countries.

This intense pressure became especially pronounced during the COVID pandemic in 2020-2021. Curaçao then requested financial support from the Dutch government. The condition for this assistance was reforming gambling licensing rules and creating an independent regulatory body to replace the GCB. It was then that Curaçao began developing the LOK law.

Companies that received sublicenses faced significant difficulties in doing business in 2022-2024. Curaçao also encountered problems: in 2022, the offshore zone was added to the EU's grey list, citing insufficient oversight. This led to banks unilaterally severing ties with the gambling industry en masse.

In this situation, the Curacao government had few options. The first was to abandon its focus on gambling and focus on providing services to international businesses. However, gambling revenues generated significant budget revenues, and there was no way to offset them.

The second option was to completely transition to offshore jurisdictions. However, the global prospects for classic tax-free territories, in light of deoffshorization trends, are no longer as clear as they were 10 years ago. Financial transparency is gradually becoming a requirement for virtually all jurisdictions, with the exception of rogue states (North Korea and Iran). This approach is fundamentally incompatible with plans to develop offshore services.

As a result, the Curacao government chose the third option: large-scale changes to the rules for issuing gambling licenses. The new LOK law was approved at the very end of 2024. Almost immediately afterward, the GCB ceased operations, and its functions and powers were transferred to a new structure—the CGA (Curaçao Gaming Authority). These steps are expected to address concerns raised by international regulators and restore business confidence in the Curacao gambling license.

LOK against NOOGH

A direct comparison of the two legislative acts provides formal grounds to state that gambling regulations in Curaçao have become stricter, which has allegedly made the gambling business less profitable. But it is entirely incorrect because a general, holistic picture of innovations falls out of sight with this approach. A comprehensive and unbiased analysis shows that the new LOK law simplifies business and makes it more predictable, transparent, and secure. Thus, talk of Curaçao's decline as a global hub for issuing gambling licenses is greatly exaggerated.

LOK and NOOGH comparison:

•  Licence types. LOK introduced two types of permits: for B2C (Business-to-Consumer) and for B2B (Business-to-Business). The old system, based on a master license and a sub-license, no longer works. Both types of permits — B2B and B2C — are issued by the national regulator, which also oversees compliance with all applicable rules and regulations.
•  New regulatory body. The GCB, which has faced allegations of money laundering, creating an opaque business environment, and inadequate oversight over the past few years, is shutting down. The new body, called CGA, will control the issuance of Curaçao's gambling licenses in its entirety. It's expected to abandon the formal approach completely.
•  Compliance rules change for the gambling market operators. Corporate and financial norms existed earlier as well, but adherence controls were mainly nonexistent. LOK not only tightens the rules governing the gambling business but also introduces mandatory monitoring for all market operators.
• Financial requirements. The gambling license fee in Curaçao and the annual prolongation expenses have increased. But the situation is no better in other countries. It is also vital to consider that the corporate tax rate for companies working in the digital format is only 2%, and there is no separate Gross Gaming Revenue (GGR). It's worth noting that there is no VAT on gambling in Curaçao, which offsets the insignificant increase in the financial threshold.

Key corporate requirements

Following the introduction of the LOK, some businessmen and investors interested in obtaining a Curacao gambling license adopted a wait-and-see approach, hoping for a quick resolution. However, many operators did not delay and submitted applications to the CGA. It turns out that obtaining a license in 2025 is entirely possible; the regulator's approach is friendly and businesslike, and there are no particular difficulties or insurmountable obstacles.

Basic compliance rules:

• Ultimate Beneficial Owners (UBOs) and key persons. When issuing a license, all ultimate beneficiaries and persons with influence over the legal entity's business must be identified.
• A legal entity. Due diligence is mandatory, and managers must have experience and relevant qualifications. The Curacao regulator will also request documentary evidence that the project's source of funding is transparent and legitimate.
• Effective economic presence. Substance has long been a mandatory requirement for legal entity registration for resident companies seeking tax benefits. Therefore, a gambling operator in Curacao must open a separate physical office in the jurisdiction and hire local employees. Exceptions are only provided for smaller companies if they meet the qualifying conditions regarding maximum annual revenue.
• Full KYC/AML compliance. A dedicated company employee must oversee compliance. This individual is also responsible for implementing responsible gaming requirements and implementing complaint and dispute resolution procedures.

Corporate requirements. All company financial transactions must be transparent. Filing company reports with the CGA is mandatory. Gaming systems (hardware and software components) require certification. Reliable protection for players and their financial transactions must be ensured. The company must hire a local director.

Obtaining Curacao Gaming Licenses in 2025

What should businessmen and investors who previously planned to enter the global gambling market with a Curacao license do? Should they wait for the situation to become clearer or act now? We cannot provide clear, targeted recommendations without knowing the client's goals and objectives. If you need specific answers and a personalized action plan, contact the specialists at IT-Offshore.

However, a wait-and-see approach to Curacao gambling licenses is not the best choice. Yes, the LOK law has been passed, but it does not hinder the launch and operation of a business. While the situation remains unclear, a window of opportunity has opened. Right now, entering this promising and profitable market has temporarily become easier, faster, and cheaper. In 2-3 years, the situation will become clearer, the procedure will become more formal, competition will increase significantly, and financial requirements will increase. Therefore, we believe it's possible and necessary to act without putting off the project's launch.

How to launch a gambling project from scratch:

• Preliminary planning. Contact our specialists. Discuss the business format, the required license type (B2B or B2C), and roughly calculate the project's budget requirements.
• Company registration in Curaçao. One of two legal forms of business is suitable for you: N.V. (Naamloze Vennootschap) or B.V. (Besloten Vennootschap). We will set up a legal address for you, assist with selecting a local director and preparing the necessary documents, and then submit them to the Curaçao registrar (Curaçao Chamber of Commerce and Industry). We will also open a corporate bank account for you.
• Preparing to obtain a Curaçao gambling license. This is an important and crucial stage, where miscalculations often lead to refusal. We need to gather personal and corporate documents, select a casino platform, prepare software, hardware, and network support, select payment partners, and implement KYC/AML compliance. Once all preparatory steps are completed, we will submit documents for a Curacao gambling license.

If the CGA has no objections, a provisional permit is issued, valid for six months. This allows the regulator to ensure the transparency, viability, and legality of the business. After six months, assuming no violations, the company receives a permanent Curacao gambling license, which must be renewed annually.

Influence of LOK on the Global Gambling Business

The change in licensing rules is one manifestation of the trend toward deoffshorization, increased transparency of financial flows, and countering aggressive tax practices. LOK establishes enhanced compliance standards, which have already become the norm in the European Union. Similar changes will be introduced in other countries in a few years, so it's hard to say that Curacao is "unlucky."

The global impact of the LOK Act is increased trust in the gambling industry. This will facilitate the entry of new players into the gambling market, gradually eradicate wariness of the gambling industry, and improve the level of security for all stakeholders—not only companies, but also players themselves.

How the LOK Act will change the gambling industry:

• The emergence of a viable alternative to strict European licensing;
• Simplified access for gambling companies to financial services and facilities;
• Gradually lowering the entry barrier (administrative requirements, costs, licensing complexity, etc.);
• Decreased popularity of "gray" unregulated jurisdictions for the gambling business;
• Globalization of the gambling industry;
• The formation of a global gambling ecosystem with several hubs (one of which is Curacao), and increased competition from Malta and Gibraltar.

Conclusions

Skeptics who have given up on the gambling revolution

The prospects for Curaçao after the introduction of the LOK failed to grasp the most important aspect. The new law does not hinder the launch of gambling businesses or push them into a legal gray area. In fact, the LOK eliminates the main problem in the gambling industry—legal uncertainty—without significant harm to all stakeholders.

The situation will soon become fully clear, the national regulator will issue official comments, and enforcement practices will gradually develop. The transition period, which is expected to last several years, is not a time for forced pause, but rather new prospects and opportunities for launching a legal and secure gambling project.

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