REGULATORY REFORM
compliance and towards one based on outcomes and effective risk management. Similar to a jurisdictions’ FATF standing, the mere existence of policies and procedures is not sufficient. Regulators expect operators to demonstrate the effectiveness of these responsibilities and processes. Viewed in that context, the LOK is about far more than replacing the NOOGH regime. It represents an attempt to reposition Curaçao within the modern regulatory landscape and to signal that a Curaçao license should be associated not only with market access, but also with meaningful regulatory oversight 4 . What has changed for operators? For operators, the LOK changes the nature of the relationship between gaming businesses and the regulator and, in doing so, alters many of the assumptions that historically underpinned the Curaçao licensing model. For many operators, the most significant consequence is that regulatory engagement becomes an ongoing process rather than a one-time licensing exercise: operators must continuously demonstrate that they remain suitable license holders throughout the license lifecycle, rather than simply qualifying at the point of application. The new framework also demands considerably greater transparency into ownership structures, governance arrangements, sources of funding, key personnel and operational activities, which is a notable departure from historical perceptions of Curaçao as a jurisdiction defined primarily by accessibility. The same applies to compliance obligations more generally. AML systems, customer due diligence procedures, transaction monitoring, risk assessments, reporting mechanisms and responsible gambling frameworks are no longer peripheral functions, but central operational requirements demanding dedicated resources, expertise and management attention, and the cost of compliance has increased accordingly. For smaller operators and start-ups that historically selected Curaçao for its flexibility and relatively low barriers to entry, the new obligations may require a fundamental reassessment of their business models: compliance functions once outsourced,
lightly resourced or viewed primarily as administrative necessities may now require a more significant investment. However, the LOK does have provisions that favor start-ups and smaller operators new to the industry, thus ensuring that Curaçao remains open to all stakeholders. The analysis is often very different for larger and more established operators. Many international groups already operate under multiple regulatory regimes and maintain sophisticated compliance, legal and governance infrastructures. For these operators, the reforms may not represent a dramatic increase in regulatory burden. Instead, they may be viewed as a welcome development that strengthens confidence in the jurisdiction itself, particularly since banks, payment service providers and institutional partners increasingly conduct their own due diligence before entering into commercial relationships. In practice, the reform is likely to create a degree of market segmentation and consolidation. Operators today must actively diversify their regulatory exposure to protect their revenue streams, and respond efficiently to regulatory, political, or enforcement shifts. As such, the more important question is not whether certain operators will exit the market, but whether the industry appreciates the necessity for a modernized international license framework that is aligned with international standards. Economic substance: one of the most significant changes One of the most transformative aspects of the LOK is the intention for economic substance 5 . While direct licensing and enhanced supervision have attracted much of the industry’s attention, the intended introduction of meaningful substance requirements may ultimately have an even greater impact on how Curaçao is perceived internationally. For many years, regulators, international organizations and financial institutions have expressed concerns about structures that allow businesses to obtain licenses in a jurisdiction while maintaining little or no meaningful connection to that jurisdiction. In such circumstances, the regulator may have legal authority over a licensee, but relatively limited practical
4 Vision of CGA published on multiple occasions: https://www.linkedin.com/posts/curacao-gaming-authority_cga-raising-the-bar-activity- 7478120464876355585-yu2e , :Curaçao Online Gaming Industry Future Collaboration | Curacao Gaming Authority posted on the topic |… and https://www.curacaochronicle.com/post/unknown/curacao-gaming-authority-brings-gaming-sector-together-for-industry-seminar 5 Postponement of local substance requirement: https://portal.cga.cw/uploads/publications/fGYi2F2IUWqXOEi5hXgQVaDZirjAJGvqAcX4XKA1. pdf
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IMGL MAGAZINE | SEPTEMBER 2026
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