12/08/25
During the last year, CuraƧao updated gaming regulations under the National Ordinance on Games of Chance (LOK), summarising the newly imposed licensing obligations, the legal risks for operators using foreign licences, and the rationale for tighter control. The main concern centres on ensuring operators hold valid CGA-issued licences and the penalties for non-compliance.
š”ļø Understanding CuraƧaoās New Gaming License Rules
The National Ordinance on Games of Chance (āLOKā), which came into force on 24 December 2024, replaces the previous offshore framework (LBH) and centralises authority within the newly structured CuraƧao Gaming Authority (CGA), formerly known as the Gaming Control Board. The CGA now exclusively issues B2B and B2C gaming licences directly, ending the master- and sub-licence regime. Under Article 1.2(1) of the LOK, only entities based in CuraƧao holding a CGA licence or another valid legal basis can lawfully conduct games of chance from the jurisdiction. Companies registered in CuraƧao but operating under foreign B2C licences are expressly illegal and may face criminal liability, including prosecution under the CuraƧao Criminal Code.
š What These Changes Mean for Operators and the Industry
Compared with the previous system, where licence holders granted sublicences with minimal oversight, the new regime demands direct CGA engagement, greater transparency, and strict adherence to local legal frameworks. The redesign aligns CuraƧao with international AML/CFT standards, enhancing regulatory credibility and addressing prior reputational risks associated with lax oversight. Unlike the past model, where master licence holders numbered only a few and accountability was limited, the CGA now assesses each operator directly, emphasising responsible gaming and regulatory cooperation. On balance, these changes strengthen legitimacy for compliant operators, although they raise entry costs and administrative obligations.
āļø RealāWorld Enforcement: Whatās Happening Now
Recent enforcement action illustrates these changes in practice. The CGA has begun issuing cease-and-desist warnings to CuraƧao-registered companies operating with foreign licences, clarifying that such operations-though superficially appearing lawful, are unlawful under CuraƧao law. The regulator emphasises that even unwitting participation by partners, payment processors, or software suppliers could result in criminal exposure. Operators in this position are advised to relocate operations or re-register under jurisdictions not subject to LOK or establish companies elsewhere to maintain legal continuity. The shift marks a definitive end to the āforeign licence under CuraƧao registrationā workaround.
In summary, CuraƧaoās LOK has fundamentally restructured its gaming regulation: the CGA now centrally issues B2B and B2C licences; the permissibility of foreign licences for CuraƧao-based entities has been eliminated; and enforcement actions have already begun. These reforms enhance regulatory legitimacy and protect players, but also impose significant legal responsibilities on operators. If you operateāor plan to operateāin this domain, NUR Legal can guide you through CGA compliance, restructure strategies, or application procedures. Contact NUR Legal for expert assistance in navigating CuraƧaoās evolving regulatory framework.
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Emil Korpinen