On December 24, 2024, online gaming regulation in Curaçao underwent a significant transformation due to the implementation of the National Ordinance on Games of Chance (LOK). This new regulatory framework replaced the former National Ordinance on Offshore Games of Hazard (NOOGH) and introduced essential changes for both B2C and B2B operators.
In this blog, we will provide a detailed summary of the new rules, requirements, and fees involved in the National Law on Games of Chance of Curaçao.
1. Objectives of the National Law on Games of Chance of Curaçao
The new legislation was created with the purpose of modernizing the country’s gambling sector. To achieve this, it establishes clear guidelines for the organization and operation of these activities, ensuring a regulated and secure environment. Its main objectives include:
- Defining precise rules for the offering and management of games of chance.
- Strengthening regulatory supervision to ensure compliance with the norms.
- Implementing measures to mitigate the risks of gambling addiction, protecting consumers.
- Gradually applying legislation, starting with the regulation of remote gambling.
- Creating an independent regulatory entity that will oversee and control the sector.
2. Transition from NOOGH to LOK
With the LOK coming into effect on December 24, 2024, the transition process includes:
- Processing of previous applications under the NOOGH rules.
- New applications subject to LOK requirements.
- Conversion of old licenses: NOOGH licenses will be automatically converted into provisional LOK licenses.
3. Licensing Structure and Validation Process
During the second validation phase, the Curaçao Gaming Authority (CGA) may grant a provisional gaming license for a period of up to 6 months, extendable for another 6 months (except in cases prohibited by Article 2.2 of the LOK).
Criteria for Gaming License Denial – Article 2.2
The CGA may refuse to grant a license if it identifies factors that compromise the integrity and security of the sector. The main reasons for denial include:
- Lack of Verification: Identities of Ultimate Beneficial Owners, holders of Qualified Interest, and decision-makers have not been properly verified.
- Criminal Record: Involvement of the Ultimate Beneficial Owner with more than 25% participation, or the holder of a Qualified Interest with more than 25% participation, in financial crimes in the last 8 years (theft, fraud, money laundering, terrorist financing, etc.).
- Source of Funds: Resources to finance the operation are unidentified or linked to illegal activities.
- Debts: Any license fees due in relation to the application have not been fully paid.
- Suspended Previous Licenses: Connection with operations that had their license revoked.
- Financial Capacity: Lack of liquid assets to pay prizes to players.
- Responsible Gaming Policy: Absence of measures for player protection.
- Dispute Resolution: Lack of a system approved by the CGA.
- Vulnerable Key Persons: Involvement of individuals classified as vulnerable.
- Registration in goAML: Non-compliance with anti-money laundering requirements.
Suspension and Revocation of the Gaming License
The CGA has the authority to suspend or revoke a license in cases of:
- Serious violation of licensing conditions;
- Failure to pay mandatory fees;
- Non-compliance with responsible gaming standards;
- Involvement in fraudulent or illegal activities;
- Mismanagement or misuse of player funds.
Besides the mentioned criteria, the CGA may consider other factors affecting the sector’s integrity and, if necessary, determine the suspension or revocation of the license.
4. Requirements and Process for Obtaining a Gaming License
Operators must meet the following criteria:
- Obtain a public limited company or a limited liability company, registered in Curaçao and managed by a natural person residing in Curaçao or by a legal entity incorporated and registered in Curaçao.
- Completion of revised forms and payment of the application fee.
- Detailed analysis of the business and financial structure.
- Demonstration of compliance with player protection and digital security guidelines.
If you do not yet have a registered company in Curaçao, we can assist you with company incorporation and the appointment of a resident Managing Director. Learn more about our incorporation service here.
5. Fee Structure and Costs
Application Fees
- EUR 4,592 for B2C and B2B operators.
- EUR 150 per UBO (Ultimate Beneficial Owner) or Qualified Interest holder.
- EUR 2,551 per UBO listed in the application.
Annual Fees
B2C Operators:
- EUR 24,490 (License Fee – National Treasury)
- EUR 22,960 (Supervision Fee – CGA)
- Total: EUR 47,450 per year
B2B Operators:
- EUR 24,490 (License Fee – National Treasury)
Administrative Fees
- Additional domain (B2C): EUR 250 per domain
- Certificate Application: EUR 383
- Change or addition of UBO: EUR 128 per person
6. Licensee Registration and Financial Reporting Obligations – Article 5.11
Licensees must comply with strict registration and financial reporting requirements, ensuring full transparency and compliance with CGA guidelines. This includes:
- Maintaining detailed financial records.
- Regularly submitting accounting and operational reports.
- Undergoing periodic audits to ensure compliance with LOK rules.
- Implementing anti-money laundering and terrorist financing measures.
7. Licensee Obligations – Article 5.12
Licensed operators are responsible for:
- Ensuring player safety and implementing responsible gaming policies.
- Complying with all tax and regulatory obligations imposed by the CGA.
- Providing adequate player support and effective complaint mechanisms.
- Maintaining high standards of integrity and transparency in all operations.
Conclusion
The new gaming regulation in Curaçao establishes a stricter and more transparent environment for iGaming operators. The transition to LOK brings stricter rules, with clear compliance, financial reporting, and business structure requirements. To ensure compliance and avoid penalties, it is essential that operators prepare in advance and adjust their internal processes.
If you would like more information or to start your license application under LOK, contact Egaming Services for personalized guidance.
