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Curaçao Gaming Control Board (operationally Curaçao Gaming Authority) — Curaçao online-gambling standards explorer (Landsverordening op de Kansspelen — LOK — entered into force 24 December 2024 · NOOGH 1993 transition · NORUT, NOIS and MLTFPO AML stack · FIU Curaçao goAML)
All 54 Curaçaoan standards, organised by theme
A searchable, filterable index of Curaçao's post-LOK online-gambling rulebook, drawn from the Landsverordening op de Kansspelen (LOK, adopted 17 December 2024 and entered into force 24 December 2024), the legacy Nationale Verordening Offshore Hazardspelen 1993 (NOOGH) in run-off, the National Ordinance Identification when Rendering Services (NOIS), the National Ordinance Reporting Unusual Transactions (NORUT), the Money Laundering and Terrorist Financing Prevention Ordinance (MLTFPO), the FIU Curaçao (MOT) reporting framework on goAML, and the published policies and fee schedules of the Curaçao Gaming Control Board operating as the Curaçao Gaming Authority. Standards are grouped by theme, tagged editorially and deep-linkable.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
Curaçao is an autonomous country within the Kingdom of the Netherlands under the Statuut voor het Koninkrijk der Nederlanden. The Kingdom retains responsibility for foreign relations and certain AML / CFT obligations through the FATF; Curaçao legislates its own gambling regime through Landsverordeningen adopted by the Staten van Curaçao.
5 standards5 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Treating Curaçao licences as Kingdom-wide or EU passportable when they are country-specific
Missing FATF / CFATF obligations that bind Curaçao through the Kingdom
Ignoring the constitutional split between Kingdom and country competences
Constitutional anchoring within the Kingdom 3
Statuut art. 3
Kingdom competences vs country autonomy
Player Rights
Article 3 of the Statuut voor het Koninkrijk der Nederlanden reserves to the Kingdom foreign relations, defence, nationality and certain rule-of-law matters. All other matters, including gambling regulation, are autonomous country competences. Curaçao therefore legislates its own kansspelen regime through the Staten van Curaçao and is not bound by Dutch Kansspelautoriteit licensing.
Requirements
Treat Curaçao gambling licences as country-specific, not Kingdom-wide
Do not assume passporting into the European Netherlands or other Kingdom countries
Document the Statuut basis when defending the GCB/CGA perimeter
Recognise that Kingdom-level treaty obligations (FATF, sanctions) still bind Curaçao
The Statuut is the constitutional foundation that lets Curaçao operate an autonomous gambling regime distinct from the Dutch KSA.
Staatsregeling Curaçao art. 2
Country-level legislative competence
Player Rights
The Staatsregeling van Curaçao vests legislative power for autonomous matters in the Staten van Curaçao acting jointly with the Government. The LOK was adopted under this competence on 17 December 2024 by a 13 to 6 vote of the Staten and entered into force on 24 December 2024 upon publication.
Requirements
Anchor every LOK obligation to the Staten's legislative competence under the Staatsregeling
Treat Landsverordeningen as primary law within Curaçao's autonomous sphere
Recognise the Government's role in implementing Landsbesluiten under the LOK
Maintain a register of LOK amendments adopted post-entry-into-force
Country-level autonomy is exercised through Landsverordeningen, the equivalent of national statutes within the autonomous sphere.
Kingdom FATF anchoring
FATF and CFATF obligations binding through the Kingdom
Player Rights
Curaçao is a member of the Caribbean Financial Action Task Force (CFATF) and is bound, through the Kingdom of the Netherlands' FATF membership, to implement the FATF Recommendations. This anchors the NORUT and MLTFPO obligations applied to gambling licensees.
Requirements
Apply FATF Recommendation 22 (DNFBPs including casinos) to all LOK B2C licensees
Treat CFATF mutual-evaluation findings as binding policy guidance for AML / CFT
Maintain alignment between the LOK AML annex and FATF Risk-Based Approach guidance
Track CFATF follow-up reports for Curaçao on cfatf-gafic.org
Although Curaçao is not directly a FATF member, the Kingdom's membership extends FATF obligations to all four Kingdom countries.
Geographic perimeter set by the Kingdom 2
LOK geographic perimeter
Exclusion of Curaçao residents and the European Netherlands
Player Rights
The LOK perimeter is built on the principle that Curaçao-licensed B2C operators must not offer games to persons resident in Curaçao itself or to persons resident in the European Netherlands (where the Kansspelautoriteit holds exclusive jurisdiction under the Wet op de kansspelen). The CGA enforces this perimeter through geo-blocking and KYC residency checks.
Requirements
Implement IP geo-blocking for Curaçao and the European Netherlands at the platform layer
Reject registrations where KYC residency evidence places the player in an excluded jurisdiction
Document the geo-blocking policy in the licence file and provide it on CGA request
Apply enhanced controls for VPN detection to prevent perimeter circumvention
The exclusion of Curaçao residents protects local consumers; the European Netherlands exclusion respects KSA exclusivity under the Wet op de kansspelen.
KSA cross-border coordination
Dutch KSA exclusivity over the European Netherlands
Affiliate Rules
The Kansspelautoriteit (KSA) holds exclusive licensing jurisdiction over remote gambling offered to consumers in the European Netherlands under the Wet op de kansspelen as amended by the Wet kansspelen op afstand (Wet Koa). Curaçao-licensed operators that target Dutch residents face KSA enforcement under article 33h Wok with administrative fines up to EUR 900,000 or 10 percent of group turnover.
Requirements
Treat any Dutch-facing marketing or payment integration as a KSA enforcement trigger
Map prioritisation criteria published by the KSA against the operator's footprint
Coordinate with the CGA before responding to a KSA information request
Avoid .nl domains, Dutch-language sites or iDEAL integrations without a KSA licence
The KSA's prioritisation framework focuses on Dutch-language sites, .nl domains, Dutch payment methods and advertising targeted to Dutch residents.
2
Theme 2
LOK statutory framework & NOOGH transition
The Landsverordening op de Kansspelen (LOK) of 24 December 2024 replaces the Nationale Verordening Offshore Hazardspelen 1993 (NOOGH). The four master licensees and their sublicensees operate in a managed sunset that ended 15 October 2025; new licences are issued directly by the Curaçao Gaming Control Board operating as the Curaçao Gaming Authority.
5 standards5 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Continuing to rely on a NOOGH sublicence after 15 October 2025
Confusing master-licensee orange-seal status with a direct CGA licence
Failing to migrate to the LOK regime within the transitional window
LOK adoption and entry into force 2
LOK adoption 17 December 2024
Staten van Curaçao adoption of the LOK
Player Rights
On 17 December 2024 the Staten van Curaçao adopted the Landsverordening op de Kansspelen (LOK) by a 13 to 6 vote, replacing the Nationale Verordening Offshore Hazardspelen (NOOGH) of 1993 as the principal statutory framework for online gambling. The LOK entered into force on 24 December 2024 upon publication in the Publicatieblad.
Requirements
Treat 24 December 2024 as the LOK entry-into-force reference date for every transitional calculation
Use the LOK as the primary legal authority for any new licence application from that date forward
Track Landsbesluiten and implementing regulations adopted after entry into force
Cite Publicatieblad references when relying on the LOK in contracts or compliance manuals
The 13-6 Staten vote and the 24 December 2024 entry into force are the two foundational dates for the post-LOK regime.
LOK scope — kansspelen op afstand
Statutory definition of remote games of chance
Game Design
The LOK regulates kansspelen op afstand — games of chance offered remotely (typically through electronic communications) where the outcome depends wholly or predominantly on chance and a stake is wagered with the prospect of a prize. The definition tracks the Dutch Wet Koa concept and brings online casino, slots, poker, bingo and sports betting within scope.
Requirements
Treat every wager-prize product offered remotely as a kansspel op afstand within scope
Apply LOK obligations whether the operator is B2C or providing platform services as B2B
Recognise that skill-dominant games (e.g. genuine fantasy sports outside chance dominance) may fall outside scope
Document scope analysis for any borderline product before launch
Predominance of chance is the dispositive test; mixed skill-chance products require a documented scope opinion.
NOOGH 1993 transition and master-licensee sunset 3
NOOGH 1993 statutory base
Pre-LOK offshore hazardspelen regime
Player Rights
The Nationale Verordening Offshore Hazardspelen (NOOGH) of 1993 established the four master-licensee model under which Cyberluck Curaçao (Curaçao eGaming, JAZ-1668), Antillephone (JAZ-8048), Curaçao Interactive Licensing (JAZ-5536) and Gaming Curaçao (JAZ-365) were authorised to grant sublicences. NOOGH continues to govern legacy sublicensees during the transitional run-off.
Requirements
Identify whether the licensee operates under NOOGH (legacy) or LOK (post-2024) authority
Maintain the JAZ master-licence reference for any pre-LOK sublicensee
Document the migration path from NOOGH to LOK before the orange-seal sunset
Recognise that NOOGH ceases to grant new authorisations after the LOK transitional window
Master licensees are identified by their JAZ numbers: 1668 (Cyberluck / Curaçao eGaming), 8048 (Antillephone), 5536 (Curaçao Interactive Licensing) and 365 (Gaming Curaçao).
Orange-seal sunset 15 October 2025
End of sublicensee operations under master licences
Affiliate Rules
The transitional regime that allowed NOOGH sublicensees to continue operating under master-licence orange-seal certification ended on 15 October 2025. From that date no sublicensee may operate without either a direct CGA licence under the LOK or an in-flight LOK application with an extension granted by the CGA.
Requirements
Verify direct CGA licence status for every operator after 15 October 2025
Treat any post-sunset orange-seal claim as a compliance red flag
Document the LOK application stage if relying on a transitional extension
Update operator-due-diligence files to reference the LOK licence rather than master-licence sublicensee status
Master licensees themselves are wound down to administrative shells; the supervisory weight shifts entirely to the CGA under the LOK.
CGA ministry transfer 19 August 2025
Curaçao Gaming Authority moved from Finance to Justice
Player Rights
On 19 August 2025 oversight of the Curaçao Gaming Authority transferred from the Ministry of Finance to the Ministry of Justice. The transfer aligns gambling supervision with the AML / CFT and law-enforcement portfolio and consolidates the supervisory mandate under a single ministerial line.
Requirements
Address ministerial correspondence on gambling matters to the Ministry of Justice after 19 August 2025
Update compliance manuals to reference Justice rather than Finance as the responsible ministry
Recognise the policy intent of aligning gambling supervision with AML / CFT enforcement
Monitor Justice-issued Landsbesluiten implementing the LOK going forward
The Justice ministry alignment reflects the FATF-driven framing of gambling as a higher-risk DNFBP sector.
3
Theme 3
Licensing under the LOK — B2C, B2B, application architecture
The LOK creates two licence categories: a B2C operator licence (offering games to players) and a B2B supplier licence (providing platforms, games or critical services to B2C licensees). Applications run through a two-phase portal process on portal.gamingcontrolcuracao.org with statutory fee structures fixed by the November 2025 CGA policy.
6 standards6 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Submitting a B2C application with B2B-only documentation or vice versa
Missing the 14-day invoice or 71-day revocation cycle on annual fees
Underestimating the Phase 1 + Phase 2 timeline and provisional-licence window
Licence categories 2
LOK B2C licence
Operator licence to offer games to players
Player Rights
The LOK B2C licence authorises the holder to offer kansspelen op afstand directly to players. It carries an annual fee of EUR 47,450, split between EUR 24,490 paid to the National Treasury and EUR 22,960 paid to the CGA as supervisory contribution. The licence covers casino, slots, poker, bingo and sports-betting verticals subject to the operator's approved scope.
Requirements
Apply for a B2C licence before offering any game to a player
Budget EUR 47,450 per year as the consolidated B2C annual fee
Allocate EUR 24,490 to the National Treasury and EUR 22,960 to the CGA supervisory line
Maintain approved-product scope and notify the CGA before adding verticals
The fee split (Treasury vs CGA) is fixed by the November 2025 CGA policy; both lines must be paid for the licence to remain in good standing.
LOK B2B licence
Supplier licence for platforms and critical services
Player Rights
The LOK B2B licence authorises the holder to supply platform software, game content, payment-integration services or other critical services to LOK B2C licensees. The annual fee is EUR 24,490 and the licence carries fit-and-proper, technical and AML obligations adapted to the supplier role.
Requirements
Apply for a B2B licence before supplying platform, game or critical services to a Curaçao B2C licensee
Budget EUR 24,490 per year for the B2B annual fee
Maintain a register of all B2C licensees served, with the services delivered to each
Notify the CGA of material changes to the supplier's service catalogue
B2B licensing brings supplier accountability inside the LOK perimeter and mirrors the supplier-licensing trend in Malta and the Netherlands.
Application architecture 4
Two-phase application process
Phase 1 corporate file and Phase 2 operational file
Player Rights
The CGA application process is structured in two sequential phases. Phase 1 examines the corporate structure, beneficial ownership, fit-and-proper of key personnel and integrity of funds, with an indicative duration of approximately eight weeks. Phase 2 examines the operational, technical, RG and AML files and again runs for approximately eight weeks. A provisional licence of up to six months may bridge to full grant.
Requirements
Prepare a Phase 1 file covering corporate structure, UBOs, key personnel and source of funds
Prepare a Phase 2 file covering operations, technical certification, RG programme and AML policy
Budget approximately eight weeks per phase as indicative CGA review time
Plan for a provisional licence window of up to six months between provisional grant and full licence
The two-phase structure lets applicants stand up technical infrastructure between Phase 1 corporate approval and Phase 2 operational scrutiny.
Application fee EUR 4,592
One-off application fee under the November 2025 policy
Player Rights
The CGA charges a one-off application fee of EUR 4,592 per LOK licence application. The fee is invoiced on submission of the Phase 1 dossier and is non-refundable irrespective of the outcome of the review.
Requirements
Pay EUR 4,592 on submission of the Phase 1 application dossier
Treat the application fee as non-refundable in financial planning
Settle the application invoice within the CGA standard payment window
Allocate separate budget lines for application fee and first-year annual fee
The application fee is distinct from and additional to the annual licence fee.
14-day invoice / 71-day revocation cycle
Statutory billing and revocation cycle for annual fees
Player Rights
The November 2025 CGA fee policy fixes a 14-day payment window from invoice issuance. Non-payment triggers a sequence of reminders culminating in licence revocation after a maximum of 71 days from original invoice date. The cycle applies to both B2C and B2B annual fees.
Requirements
Settle CGA invoices within 14 days of issuance
Treat day 71 from invoice issuance as the absolute revocation trigger
Maintain a billing-cycle calendar covering each licence held
Reconcile CGA payments to the licence-management portal monthly
The 71-day cycle is the operative deadline; missing it converts a payment delay into a licence loss.
Provisional licence up to six months
Bridging provisional grant between Phase 2 and full licence
Player Rights
Where the CGA is substantially satisfied at the conclusion of Phase 2 but residual conditions remain (typically technical certification, final UBO clearance or banking arrangements), it may grant a provisional licence of up to six months. The provisional licence carries the same operational obligations as a full licence and is converted to full status on satisfaction of conditions.
Requirements
Treat a provisional licence as fully operative for compliance purposes
Track the residual conditions attached to the provisional grant and close them within six months
Provide monthly progress reports to the CGA against provisional conditions
Plan banking and certification work to close before provisional expiry
Provisional status is a bridge, not a discount; six months is the maximum, not an entitlement.
4
Theme 4
Fit-and-proper, ownership & local substance
The LOK requires full disclosure of ultimate beneficial owners, key personnel and group structure, with a fit-and-proper assessment by the CGA. Licensees must demonstrate local substance in Curaçao through a registered office and qualified personnel resident on the island.
4 standards4 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Hidden beneficial ownership disclosed only at group level
Key personnel failing the fit-and-proper test post-licence
Operating without genuine local substance on Curaçao
Beneficial ownership and group structure 2
Full UBO disclosure
Disclosure of ultimate beneficial owners up the chain
Player Rights
Applicants must disclose every ultimate beneficial owner holding 10 percent or more of the applicant entity or exercising effective control, mapped through the full corporate chain. The CGA verifies UBO identity against NOIS-standard documentation and runs adverse-media and sanctions screening.
Requirements
Map the corporate chain from the applicant entity to every UBO
Disclose all holders of 10 percent or more and all controllers of equivalent influence
Provide NOIS-compliant identification for each UBO
Update the UBO register on any material change and notify the CGA
Group-level disclosure that stops at an intermediate holdco is treated as a material omission and grounds for refusal.
Fit-and-proper test
Integrity, competence and financial soundness of key personnel
Player Rights
Key personnel including directors, senior managers, the compliance officer, the AML officer and the responsible-gambling officer must satisfy a fit-and-proper test covering integrity (no relevant convictions or regulatory sanctions), competence (sector experience) and financial soundness. The CGA may require additional information and reserves the right to refuse on integrity grounds alone.
Requirements
Submit fit-and-proper questionnaires for every key person before licence grant
Provide certified criminal-record checks from every country of residence in the last ten years
Demonstrate sector experience for compliance, AML and RG officer roles
Notify the CGA of any post-licence change affecting fit-and-proper status
Fit-and-proper is a continuing obligation; any post-licence integrity event must be self-reported.
Local substance 2
Local substance test
Registered office and qualified personnel on Curaçao
Player Rights
The LOK requires every B2C licensee to maintain a registered office on Curaçao and to employ qualified personnel resident on the island, including at least one director, the compliance officer and the AML officer. The substance test prevents brass-plate operations and anchors the supervisory relationship with the CGA.
Requirements
Maintain a registered office on Curaçao with a physical address
Employ at least one director resident on Curaçao
Locate the compliance officer and the AML officer on Curaçao
Document the substance footprint annually for the CGA supervisory file
Brass-plate models that satisfied NOOGH practice are no longer sufficient under the LOK substance test.
Key personnel approval
CGA approval of compliance, AML and RG officers
Player Rights
Appointment of the compliance officer, the AML officer (MOT-meldfunctionaris) and the responsible-gambling officer requires CGA approval. Replacements must be notified in advance and approved before the new appointee takes responsibility for the regulated function.
Requirements
Submit CGA approval requests for compliance, AML and RG officer appointments
Avoid simultaneous vacancies in compliance and AML roles
Notify the CGA in advance of any replacement and obtain approval before handover
Maintain delegation arrangements that satisfy local-substance and fit-and-proper criteria
Approval of the AML officer also triggers registration with FIU Curaçao for goAML access.
5
Theme 5
Player accounts, KYC & identity (NOIS)
The National Ordinance Identification when Rendering Services (NOIS) sets the identification baseline for service providers in Curaçao. Combined with the LOK player-account rules, licensees must verify identity before account funding, prevent duplicate accounts and apply enhanced due diligence above the CDD threshold of NAf 4,000.
5 standards5 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Funding an account before NOIS identification is complete
Allowing duplicate accounts in the name of the same natural person
Missing CDD aggregation for linked transactions above NAf 4,000
NOIS identification baseline 2
NOIS art. 2
Identification of clients when rendering services
Player Rights
The Landsverordening Identificatie bij Dienstverlening (NOIS) requires service providers, including LOK B2C licensees, to identify clients before rendering a service. Identification is satisfied by inspection of a valid identity document and recording of the identifying particulars; identification must precede account funding.
Requirements
Identify the player before any account is funded
Inspect a valid identity document and record the particulars
Retain the identification record for at least five years after the relationship ends
Treat identification as the gating control for all subsequent gameplay
NOIS identification is the gating control; CDD and EDD layer on top of the identification baseline.
CDD threshold NAf 4,000
Customer due diligence threshold with linked-transactions aggregation
Player Rights
The Curaçaoan CDD threshold for gambling-related transactions is NAf 4,000. Linked transactions that together exceed the threshold must be aggregated and trigger full CDD. Transactions below the threshold still attract baseline NOIS identification but reduced documentation may be permitted under a risk-based approach.
Requirements
Trigger full CDD on any single or linked transaction at or above NAf 4,000
Implement linked-transactions aggregation logic in payments monitoring
Maintain documentation evidencing the aggregation rule
Apply enhanced due diligence above the threshold where risk indicators are present
Linked-transactions aggregation closes the structuring loophole; design the rule to look back at least 24 hours.
Account integrity 3
Single-account rule
Prohibition of duplicate accounts per natural person
RG CriticalPlayer Rights
Each natural person may hold only one player account with a given B2C licensee. Licensees must implement duplicate-detection controls combining name, date of birth, address and identity-document particulars and must close any duplicate detected post-registration, returning balances to the verified primary account.
Requirements
Implement duplicate-detection at registration combining identity attributes
Run periodic duplicate sweeps across the live player base
Close duplicates and consolidate balances to the verified primary account
Document duplicate-closure decisions for the supervisory file
Duplicate accounts are a structuring vector and undermine self-exclusion; both motivate the rule.
Identity verification before withdrawal
KYC completion as a precondition to withdrawal
RG CriticalPlayer Rights
Licensees must complete identity verification before processing the first withdrawal. Source-of-funds evidence is required where deposits or withdrawals exceed the EDD trigger, and where adverse-media or sanctions screening returns a hit.
Requirements
Block first withdrawal until KYC verification is complete
Capture source-of-funds evidence above the EDD trigger
Re-run sanctions and adverse-media screening at material life-events in the relationship
Document the KYC completion timestamp against every withdrawal
Withdrawal-gating is the operational lever that makes KYC enforceable; deposit-gating alone is insufficient.
Minimum age 18
Prohibition on player accounts for minors
RG CriticalPlayer Rights
No B2C licensee may register or service a player under the age of 18. Age must be verified as part of NOIS identification, and any minor account identified post-registration must be closed with stake refunds and winnings forfeited.
Requirements
Verify age at registration as part of NOIS identification
Reject any registration without confirmed adult status
Close any minor account detected post-registration and refund stakes
Forfeit winnings on closed minor accounts to the responsible-gambling fund
Age verification is the most basic player-protection control; failure here voids the entire RG framework.
6
Theme 6
Responsible gambling & player protection
The LOK requires every B2C licensee to operate a responsible-gambling programme including self-exclusion, deposit and loss limits, reality checks, a designated RG officer and exclusion of prohibited bettors. The CGA monitors compliance through periodic audits and the licence-management portal.
7 standards7 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
No functional self-exclusion at account level
Deposit limits that are advisory rather than enforced
No designated responsible-gambling officer named in the compliance file
Limits and reality checks 3
Deposit limits — mandatory
Player-set deposit limits with enforced ceilings
RG Critical
Every B2C licensee must offer daily, weekly and monthly deposit limits at registration and must enforce them at the payments layer. Reductions take immediate effect; increases take effect after a cooling-off period of at least 24 hours.
Requirements
Present daily, weekly and monthly deposit-limit options at registration
Apply reductions immediately at the payments layer
Apply a cooling-off period of at least 24 hours before any increase takes effect
Audit deposit-limit enforcement at least quarterly
Asymmetric handling of decreases (immediate) and increases (delayed) is the standard player-protection pattern.
Loss limits and session limits
Net-loss and session-time controls
RG Critical
Licensees must offer net-loss limits and session-time limits in addition to deposit limits. Session-time alerts must surface in the gameplay UI and must allow the player to terminate the session or escalate to self-exclusion.
Requirements
Offer net-loss limits alongside deposit limits
Offer session-time limits and surface alerts in the gameplay UI
Allow session termination and self-exclusion escalation from the alert
Log limit selections and changes for the audit file
Net-loss limits are a sharper RG instrument than deposit limits because they survive winning streaks.
Reality checks
Periodic in-session reality-check prompts
RG Critical
Licensees must display a reality-check prompt at intervals not exceeding 60 minutes of active play. The prompt must surface elapsed time and net result and must allow the player to continue, pause or self-exclude.
Requirements
Surface a reality-check prompt at least every 60 minutes of active play
Display elapsed time and net result in the prompt
Provide continue, pause and self-exclude options inside the prompt
Log reality-check displays and player responses
60 minutes is the international floor; tighter intervals strengthen the RG posture.
Self-exclusion and prohibited bettors 4
Self-exclusion
Mandatory self-exclusion mechanism
RG Critical
Every B2C licensee must operate a self-exclusion mechanism allowing a player to exclude themselves for a minimum of six months. Self-exclusion takes immediate effect, applies across all products operated by the licensee and survives account closure attempts.
Requirements
Operate a self-exclusion mechanism with a minimum six-month duration
Apply self-exclusion across all products operated by the licensee
Prevent re-registration with altered identifying particulars during the exclusion period
Survive account-closure attempts that aim to circumvent the exclusion
Self-exclusion is the cornerstone RG control; circumvention via duplicate accounts must be actively prevented.
Prohibited bettors
Categories of persons barred from gambling
RG Critical
The LOK prohibits gambling by minors, by self-excluded persons and by employees and key personnel of the licensee itself. Licensees must implement controls to detect and block prohibited bettors.
Requirements
Block all gambling by persons under 18
Block self-excluded persons across all licensee products
Block employees and key personnel of the licensee from playing on its platforms
Run periodic sweeps to detect prohibited-bettor account activity
Employee exclusion prevents conflict-of-interest abuse and is a CGA supervisory expectation.
Responsible-gambling officer
Designated RG officer with CGA approval
RG Critical
Every B2C licensee must appoint a responsible-gambling officer approved by the CGA. The officer leads the RG programme, supervises problem-gambling-indicator monitoring and is the operational counterpart to the CGA on RG matters.
Requirements
Appoint a responsible-gambling officer with CGA approval
Resource the officer to lead programme design and incident response
Maintain RG officer training records and annual continuing education
Surface the officer's contact details inside the player UI
The RG officer role is the LOK's analogue to the KSA's preventiebeleid lead and the MGA's player-protection officer.
Problem-gambling indicators
Monitoring of behavioural risk markers
RG Critical
Licensees must monitor behavioural risk markers including sharp deposit-frequency increases, time-of-day patterns associated with problem gambling, chasing-loss patterns and rapid limit-increase requests. Detection must trigger intervention ranging from soft messaging to mandatory limit imposition and referral to support services.
Requirements
Monitor behavioural risk markers continuously
Define intervention tiers from soft messaging to mandatory limits
Refer at-risk players to support services on Curaçao or in their country of residence
Document interventions and outcomes for the supervisory file
Behavioural-marker monitoring is the diligent-design lever that lifts RG above tick-box compliance.
7
Theme 7
Technical standards, RNG & certification labs
The LOK mandates that every game offered by a B2C licensee uses certified random-number generation and runs on a certified platform. Certification must be performed by an accredited testing laboratory and change-controlled through the CGA portal.
4 standards4 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Operating games with uncertified RNG
Material platform changes without re-certification or CGA notification
Using a testing lab that is not accredited for Curaçaoan certification
Certification regime 4
RNG certification
Certified random number generator for every game of chance
Game Design
Every game of chance offered under a LOK B2C licence must use a random number generator certified by an accredited testing laboratory. Certification covers statistical randomness, unpredictability and resistance to manipulation; the certificate must be filed in the CGA portal.
Requirements
Use only RNGs certified by an accredited testing laboratory
File the RNG certificate in the CGA licence-management portal
Recertify on any material change to the RNG implementation
Maintain a register of RNG certificates per game
RNG integrity is the technical foundation of fair play; the certificate is non-negotiable.
Platform certification
Certification of the underlying gambling platform
Game Design
The B2C platform — covering player-account management, wallet, RG controls and game-server integration — must be certified by an accredited testing laboratory. Certification scope must explicitly cover RG controls, KYC integration and reporting outputs.
Requirements
Certify the gambling platform by an accredited testing laboratory
Include RG controls, KYC integration and reporting in the certification scope
File the platform certificate in the CGA portal
Maintain a change-control log against the certified baseline
Platform certification distinguishes white-label resellers from genuine licensees; both must satisfy the standard.
Accredited testing labs
ISO/IEC 17025 accreditation requirement
Game Design
Testing laboratories used for LOK certification must hold ISO/IEC 17025 accreditation and must be recognised by the CGA. The recognised list typically includes GLI, eCOGRA, BMM Testlabs, iTechLabs and SIQ; new entrants may apply for recognition.
Requirements
Use only ISO/IEC 17025 accredited testing laboratories
Verify CGA recognition of the chosen laboratory before commissioning work
Maintain the accreditation evidence in the supervisory file
Monitor accreditation renewals to avoid certification gaps
ISO/IEC 17025 is the international floor; CGA recognition is the local overlay.
Change control
Pre-notification of material technical changes
Game Design
Material changes to the certified platform, certified games or RNG implementation must be notified to the CGA in advance. Material changes typically require re-certification before deployment to production.
Requirements
Define a change-control policy distinguishing material from minor changes
Notify the CGA before deploying any material change to production
Obtain re-certification where the change affects scope of an existing certificate
Maintain a change-control register linked to the supervisory file
Quiet drift away from the certified baseline is the most common technical-compliance failure mode.
8
Theme 8
AML / CFT — NORUT, MLTFPO, MOT / FIU
The Curaçaoan AML stack combines the National Ordinance Reporting Unusual Transactions (NORUT) with the Money Laundering and Terrorist Financing Prevention Ordinance (MLTFPO). Gambling licensees report unusual transactions above NAf 5,000 to FIU Curaçao (Meldpunt Ongebruikelijke Transacties, MOT) through the goAML platform.
7 standards7 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Failing to report an unusual transaction within the NORUT timeframe
No designated AML compliance officer registered with FIU Curaçao
goAML credentials not maintained or transactions filed late
NORUT reporting framework 3
NORUT art. 11
Obligation to report unusual transactions
Player Rights
The National Ordinance Reporting Unusual Transactions (NORUT) obliges service providers, including gambling licensees, to report unusual transactions to the Meldpunt Ongebruikelijke Transacties (MOT, operating as FIU Curaçao). Reports must be filed without delay through the goAML platform.
Requirements
Report every unusual transaction to FIU Curaçao without delay
File reports through the goAML platform using approved credentials
Apply both objective and subjective indicators from the FIU Curaçao indicator list
Retain a copy of every report for at least five years
NORUT uses an unusual-transactions standard (broader than suspicious transactions) consistent with the Dutch Wwft model.
Gambling reporting threshold NAf 5,000
Objective indicator for gambling-sector transactions
Player Rights
FIU Curaçao maintains a sector-specific indicator list. For gambling, the principal objective indicator triggers a NORUT report on any cash-equivalent transaction at or above NAf 5,000, with linked-transactions aggregation. Subjective indicators (suspicion of money laundering or terrorism financing) trigger irrespective of value.
Requirements
Configure transaction monitoring to flag at or above NAf 5,000
Aggregate linked transactions for threshold purposes
Apply subjective indicators irrespective of value
Document the rationale for each filed or non-filed report against the indicator list
The NAf 5,000 gambling threshold is the operative trigger; combine it with subjective monitoring for full coverage.
goAML platform
Mandatory electronic reporting channel
Player Rights
All NORUT reports must be filed through the goAML platform operated by FIU Curaçao. Licensees must register an institutional account, maintain authorised users (typically the AML officer and a deputy) and renew credentials annually.
Requirements
Register an institutional account on goAML
Maintain authorised users with current credentials
Renew goAML access annually and on personnel change
Use goAML's STR template fields and avoid free-text-only filings
goAML is UNODC-standard software used by FIUs worldwide; familiarity transfers across jurisdictions.
MLTFPO and compliance governance 4
MLTFPO CDD obligations
Customer due diligence under the MLTFPO
Player Rights
The Money Laundering and Terrorist Financing Prevention Ordinance (MLTFPO) imposes customer due diligence on service providers including gambling licensees. CDD covers identification, verification, beneficial-ownership identification for legal persons, purpose-of-relationship understanding and ongoing monitoring.
Requirements
Identify and verify the customer at relationship initiation
Identify the UBO where the customer is a legal person
Document the purpose and intended nature of the relationship
Conduct ongoing monitoring including transaction-pattern review
The MLTFPO mirrors the FATF Recommendation 10 standard CDD pillars.
AML compliance officer
Designated MOT-meldfunctionaris
Player Rights
Every licensee must designate an AML compliance officer (MOT-meldfunctionaris) responsible for the AML / CFT programme, NORUT reporting, training and liaison with FIU Curaçao. The appointment requires CGA approval and FIU Curaçao registration for goAML access.
Requirements
Designate an AML compliance officer at a sufficiently senior level
Obtain CGA approval and FIU Curaçao goAML registration for the officer
Resource the officer to lead training, monitoring and reporting
Maintain a deputy to cover absences without service interruption
Single point of accountability is essential; an unfilled MOT-meldfunctionaris role is a critical control gap.
AML risk assessment
Documented institutional risk assessment
Player Rights
Licensees must conduct and document an institutional money-laundering and terrorism-financing risk assessment covering customer, product, geography and delivery-channel risk. The assessment must be reviewed at least annually and on material change.
Requirements
Document an institutional ML/TF risk assessment at licence grant
Cover customer, product, geographic and delivery-channel risk dimensions
Review the assessment at least annually and on material change
Use the assessment to calibrate the risk-based approach to CDD and monitoring
The risk assessment is the foundation document for the entire AML programme; reviewers consult it first.
Record-keeping five years
Retention of identification and transaction records
Player Rights
Identification documents, CDD records and transaction records must be retained for at least five years after the end of the customer relationship. Records must be retrievable promptly on supervisory or law-enforcement request.
Requirements
Retain identification and CDD records for at least five years after relationship end
Retain transaction records for at least five years after the transaction
Maintain retrieval capability with response within supervisory deadlines
Apply the retention rule consistently across closed and dormant accounts
Five years is the FATF Recommendation 11 floor; longer retention may apply where other instruments require it.
9
Theme 9
Advertising, complaints & dispute resolution
The LOK restricts advertising of gambling services, prohibits targeting of Curaçao residents and minors, and requires every licensee to operate a complaints procedure with access to alternative dispute resolution.
5 standards5 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Marketing that targets Curaçao residents in violation of the geographic perimeter
No documented ADR mechanism for player complaints
Advertising creative that targets minors or vulnerable groups
Advertising controls 3
Marketing restrictions
LOK restrictions on gambling advertising
Bonus & AdsAffiliate Rules
The LOK restricts gambling advertising to channels and formats consistent with player protection. Advertising must not be misleading, must not minimise the risks of gambling and must not target persons under 18 or other vulnerable groups.
Requirements
Avoid misleading creative or false claims about odds or winnings
Avoid messaging that minimises gambling risk
Avoid targeting under-18s or other vulnerable groups
Maintain an advertising approval log and creative-review file
The standard tracks the EU-wide trend toward strict advertising controls for online gambling.
Geographic targeting prohibition
Prohibition on targeting Curaçao residents and Dutch residents
Bonus & AdsAffiliate Rules
Advertising must not target Curaçao residents (consistent with the geographic perimeter exclusion) and must not target residents of the European Netherlands (where KSA jurisdiction is exclusive). Affiliate marketing arrangements must be policed against the same perimeter.
Requirements
Block advertising creative that targets Curaçao residents
Block advertising creative that targets European Netherlands residents
Audit affiliate marketing for perimeter compliance
Terminate affiliate arrangements that cannot be brought into compliance
Affiliate channels are the most common vector for perimeter breach; direct policing is essential.
Bonus terms transparency
Plain-language disclosure of bonus and promotion terms
Bonus & AdsPlayer Rights
Bonus and promotion terms must be presented in plain language and must surface wagering requirements, eligible games, expiry and any restriction on withdrawal of bonus funds and winnings. Terms must be available before the player opts in.
Requirements
Present bonus terms in plain language before opt-in
Disclose wagering requirements, eligible games and expiry up front
Disclose any restriction on withdrawal of bonus funds and winnings
Maintain a versioned archive of bonus terms
Opacity around wagering requirements is the most common consumer complaint and an enforcement priority.
Complaints and ADR 2
Complaints procedure
Internal complaints handling
Player Rights
Licensees must operate a written complaints procedure with a documented acknowledgement timeline (typically 48 hours) and a substantive-response timeline (typically 30 calendar days). The procedure must be available in the player UI and must surface escalation paths.
Requirements
Operate a written complaints procedure
Acknowledge complaints within 48 hours and respond substantively within 30 days
Surface the procedure inside the player UI
Maintain a complaints register and report metrics to the CGA on request
Timely acknowledgement is the single largest driver of complaint satisfaction.
Alternative dispute resolution
Access to independent ADR
Player Rights
Where a complaint cannot be resolved through the internal procedure, the player must be offered access to alternative dispute resolution by an independent body recognised by the CGA. The ADR decision is binding on the licensee unless judicial review is sought.
Requirements
Offer access to ADR where the internal procedure does not resolve the complaint
Use only ADR providers recognised by the CGA
Comply with the ADR decision unless seeking judicial review
Report ADR outcomes to the CGA as part of supervisory reporting
Independent ADR is the standard EU consumer-protection layer; the LOK incorporates it.
The CGA exercises sanctioning powers under the LOK ranging from warnings to licence revocation. The geographic perimeter excludes Curaçao residents and the European Netherlands (Kansspelautoriteit jurisdiction). Curaçao coordinates with the Dutch KSA, CFATF and FATF on cross-border supervision.
6 standards6 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Servicing players resident in the European Netherlands in breach of KSA jurisdiction
Servicing Curaçao residents in breach of the LOK perimeter
Ignoring CGA sanction notices or revocation triggers
Supervisory powers and sanctions 3
CGA supervisory powers
Inspection, information and audit powers
Player Rights
The CGA holds supervisory powers under the LOK to demand information, inspect premises and records, audit operations and require external assurance. Licensees must cooperate fully and may not invoke commercial confidentiality against the CGA.
Requirements
Cooperate fully with CGA information requests
Provide access to premises, records and systems on request
Commission external assurance where required by the CGA
Do not invoke commercial confidentiality against the supervisor
Refusal to cooperate is itself a stand-alone sanctionable offence.
Sanction ladder
Range from warning to licence revocation
Player Rights
The CGA may impose sanctions ranging from warnings through administrative fines and licence conditions to suspension and revocation. The choice of sanction must be proportionate to the breach and may be cumulative where appropriate.
Requirements
Recognise the sanction ladder from warning to revocation
Treat administrative fines as immediately payable
Comply with any licence conditions imposed as part of the sanction
Use the LOK administrative-appeal route where the sanction is challenged
Proportionality is the legal anchor; recidivism shifts the proportionate response upward.
Revocation triggers
Grounds for licence revocation
Player Rights
The CGA may revoke a licence on grounds including loss of fit-and-proper status of key personnel, persistent breach of LOK obligations, failure to pay annual fees within the 71-day cycle, conviction for serious offences and operation outside the licensed scope.
Requirements
Treat loss of fit-and-proper status as an existential risk to the licence
Address persistent compliance breaches before they crystallise into revocation grounds
Settle CGA invoices within the 71-day cycle to prevent automatic revocation
Operate strictly within the licensed scope
Revocation is rarely the first response but is the unavoidable consequence of unaddressed serious breach.
Cross-border supervision 3
KSA coordination
Coordination with the Dutch Kansspelautoriteit
Affiliate Rules
The CGA coordinates with the Dutch Kansspelautoriteit on cross-border enforcement, particularly where Curaçao-licensed operators are alleged to target Dutch residents. Information exchange is conducted through inter-supervisor channels consistent with data-protection law.
Requirements
Expect CGA-KSA information exchange where Dutch perimeter breach is alleged
Maintain documentation that demonstrates Dutch-perimeter compliance
Respond to CGA-KSA joint requests through the CGA channel
Treat KSA prioritisation criteria as practical exposure indicators
The 19 August 2025 transfer of the CGA into the Justice portfolio sharpens cross-border cooperation.
FATF / CFATF context
Mutual-evaluation overlay on the LOK regime
Player Rights
Curaçao's gambling regime is evaluated through the CFATF mutual-evaluation cycle. Findings shape supervisory priorities and may trigger LOK amendments. Operators should track CFATF follow-up reports and prepare for sector-specific scrutiny in any mutual evaluation cycle.
Requirements
Track CFATF follow-up reports for Curaçao
Anticipate sector-specific scrutiny of gambling DNFBPs in mutual evaluations
Maintain documentation that demonstrates FATF Recommendation 22 implementation
Engage with sector consultations during mutual-evaluation preparation
Mutual evaluations are the international anchor that disciplines the LOK regime against drift.
Extraterritorial perimeter enforcement
Geo-blocking and KYC residency as perimeter controls
Player Rights
The extraterritorial perimeter (excluding Curaçao residents and European Netherlands residents) is enforced through a combination of IP geo-blocking, KYC residency verification and payment-method controls. Failure to enforce the perimeter is treated as a serious LOK breach.
Requirements
Operate IP geo-blocking against excluded jurisdictions
Verify residency through KYC documentation
Restrict payment methods that signal residence in excluded jurisdictions
Audit perimeter-enforcement controls at least quarterly
Belt-and-braces enforcement (IP + KYC + payments) is the only durable defence against VPN-based circumvention.
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