As Curaçao moves forward with implementing the National Ordinance on Games of Chance (LOK), certain regulatory requirements for gaming operators are becoming clearer. However, some aspects of the new framework are still under development, and final guidelines from the Curaçao Gaming Authority (CGA) are expected in the coming months.

Based on current estimations, operators seeking to comply with the new licensing regime should prepare for the following key requirements:

• Company Establishment in Curaçao – It is anticipated that businesses will need to be incorporated locally and have at least one Curaçao-based representative managing the entity.
• Full Disclosure of Beneficial Ownership – Operators are likely to be required to fully disclose the identities of Ultimate Beneficial Owners (UBOs) and other key personnel.
• Financial and Tax Compliance – Adherence to Curaçao’s tax laws and financial reporting obligations is expected to be a mandatory condition for license holders.
• AML & KYC Obligations – Compliance with anti-money laundering (AML) regulations and unusual transaction reporting requirements will likely be enforced under the new system.
• Responsible Gaming Policies – Operators may need to implement protective measures for minors and vulnerable individuals, including mandatory staff training on responsible gambling practices.
• Operational Compliance – Businesses will likely be required to submit compliance reports to the CGA upon request.
• Local Workforce Requirements – A gradual staffing requirement is expected, with at least one key employee (excluding the local director) working from Curaçao within the first four years and a total of three key employees by the fifth year. These employees must operate from a physical office in Curaçao.
• Startup Exemptions – Some exemptions from local presence conditions may be available for certain new market entrants, although the exact criteria have yet to be finalized.

While these estimates provide insight into the expected regulatory landscape, the final details are still being refined. The Curaçao Gaming Control Board (GCB) is expected to release additional guidelines that will clarify compliance obligations, application procedures, and enforcement measures.

Operators should begin preparing for these anticipated changes to ensure a smooth transition. For the latest updates and expert assistance in navigating the evolving Curaçao licensing framework, feel free to reach out to us.

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