REGULATORY REFORM
a point of comparison, and Malta offers the clearest one available in the European gaming sector. The Malta Gaming Authority ("MGA") has operated a direct licensing model since the jurisdiction first opened its doors to remote gaming operators, without ever passing through a master license or sublicense structure. Operators hold a direct relationship with the regulator from day one, covering ownership disclosure, source of funds, key function holders and ongoing reporting obligations. That structure, built up over two decades and reinforced by Malta's status as a European Union member state, is one of the reasons an MGA license is generally well regarded by banks, payment providers and institutional counterparties. Malta's experience is instructive for Curaçao in two respects. First, it demonstrates that a direct, supervisory model can coexist with a healthy, commercially attractive market; regulatory rigor and competitiveness are not mutually exclusive. Second, Malta's own history is a reminder that regulatory credibility is not static: even a mature, long- established regime faced renewed scrutiny in 2021, when the Financial Action Task Force placed Malta under increased monitoring over anti-money laundering and beneficial- ownership shortcomings, and it took a year of demonstrated reform to be removed from that list. The lesson for Curaçao is less about reaching Malta's starting point and more about the fact that credibility, once built, still has to be maintained. Curaçao is not attempting, and does not need, to replicate Malta's model in every detail; the two jurisdictions serve different segments of the market and are likely to continue doing so. What the LOK does is move Curaçao's supervisory architecture conceptually closer to the Malta approach – direct licensing, ongoing obligations, substance and accountability – while retaining the commercial characteristics that have long distinguished it. For operators holding licenses in both jurisdictions, or weighing where next to expand, that convergence in philosophy, even without full convergence in practice, is one of the more significant long-term implications of the reform. Has the reform been successful so far, and where does this leave Curaçao? At present, the most honest answer is that it is too early to know. The legislative transformation itself is undeniable.
Few jurisdictions have undertaken such a comprehensive restructuring of their online gaming framework in recent years. Regulatory reform should ultimately be assessed against measurable outcomes rather than legislative ambition. Increased regulatory requirements may lead some operators to reconsider their licensing strategy. However, the number of operators that remain in Curaçao may be less important than the type of operators that remain. One indicator of success will therefore be whether Curaçao succeeds in attracting and retaining operators that value regulatory certainty, sustainable banking relationships and long-term market acceptance. Equally important will be the response of external stakeholders. Banks, payment service providers, software suppliers and foreign regulators may ultimately have a greater influence on the perception of Curaçao than the legislation itself. The introduction of the LOK suggests that Curaçao is seeking to evolve beyond its traditional reliance on accessibility, speed and cost. However, the objective does not appear to be transforming the jurisdiction into a direct competitor to Malta or the Isle of Man. Those jurisdictions have spent decades building regulatory reputations, supervisory capacity and international recognition. Regulatory standing on that scale is not created through legislation alone and is not achieved overnight. Instead, Curaçao appears to be pursuing a more nuanced strategy: positioning itself between the traditional offshore model and the highly mature regulatory regimes, retaining the commercial advantages that have historically attracted operators, while introducing the oversight and accountability expected by banks, payment service providers, business partners and international stakeholders. There remains significant demand for jurisdictions that offer meaningful regulation without the complexity, cost and administrative burden of the most heavily regulated markets and Curaçao may be well positioned to serve operators seeking that balance. The challenge is that regulatory reform involves trade-offs. As compliance obligations, substance requirements and supervisory expectations increase, some operators may question whether Curaçao still offers sufficient advantages compared to alternative jurisdictions, and the success of the reform will depend on whether that burden is matched by tangible benefits such as stronger international recognition,
IMGL MAGAZINE | SEPTEMBER 2026
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