REGULATORY REFORM
as one of the most accessible gateways into regulated online gaming. The jurisdiction attracted entrepreneurs, start-ups and international operators seeking a practical route into global markets. The LOK represents a modernization of Curaçao’s regime, with the attempt to further align its position with international markets, while preserving Curaçao’s commercial attractiveness. Why change became necessary Any assessment of the LOK must begin with an understanding of why reform became unavoidable. For almost three decades, Curaçao’s online gaming industry was regulated indirectly by the government. A handful of license holders, otherwise known Master License Holders, had been granted a license by the government to operate games of chance under the NOOGH and established a global gaming industry in Curaçao by issuing a sublicense to operators throughout the world. As the market expanded, a growing number of businesses came to operate under the Curaçao banner, making it one of the largest online gaming licensing jurisdictions globally. The system delivered undeniable commercial success. It was relatively straightforward, comparatively affordable and capable of supporting rapid industry growth. Many businesses that later became major international operators began their journeys under a Curaçao license. However, the regulatory weaknesses of the model gradually became more apparent as international standards regarding supervision, including AML compliance, beneficial ownership transparency, corporate governance and consumer protection, evolved significantly over the past decade. Regulators across numerous sectors faced increasing pressure to demonstrate active supervision and effective enforcement. In gaming, the expectation increasingly became that regulators should know who their licensees are, understand their business models and intervene where risks arise. Yet under the old framework, direct engagement between regulator and operator wa s
limited, a degree of separation that became increasingly difficult to justify in a modern compliance environment. The LOK can therefore be understood as more than an exercise in modernizing legislation. It is a strategic response to a changing international environment, intended to protect the long-term viability of Curaçao’s established gaming industry. A fundamental shift in regulatory philosophy The abolition of the master license system has understandably attracted most of the attention surrounding the LOK. Yet the more significant change may not be structural at all, but philosophical. At its core, the reform reflects a shift in how Curaçao views its role in the gaming industry. Historically, the jurisdiction was often perceived primarily as a place that issued licenses. Under the LOK, Curaçao is seeking to become a jurisdiction that actively regulates those license holders throughout their business lifecycle. That distinction is important. A licensing jurisdiction can largely function as a gateway to market entry, focusing on the initial approval process. A regulatory jurisdiction, by contrast, maintains an ongoing relationship with its licensees 2 . It supervises compliance, monitors risks, gathers information, investigates potential breaches and takes enforcement action when necessary. The LOK clearly embraces this more interventionist approach. The CGA is intended to act as an active supervisory authority aligned with international standards 3 . Licensees are expected to engage directly with the regulator, submit reports, and demonstrate ongoing compliance with their regulatory obligations. The introduction of supplier licensing further expands the regulator’s reach, while consumer protection and responsible gambling measures are embedded within the regulatory framework rather than being treated as matters of voluntary corporate responsibility. In many respects, Curaçao is following a broader international trend. Across mature gaming jurisdictions, regulators have increasingly moved away from a model focused on formal
2 Guideline census and application for under the new framework: https://media.licdn.com/dms/document/media/v2/D4E1FAQGV_pVecWwfLw/ feedshare-document-pdf-analyzed/feedshare-document-pdf-analyzed/0/1710399072518?e=1787184000&v=beta&t=tY9ZJviTnQDCnss7UmAMk- WjgSuS6GoQepDBZzgs7QEk 3 Presentation CGA in November 2024: https://portal.cga.cw/uploads/publications/Ys6XwebWuizpR8ciXbupAFXvqtqqOHQvVWBn627r.pdf
IMGL MAGAZINE | SEPTEMBER 2026
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