Curaçao's AML Guidelines

August 6, 2025

Watch how iGaming operators are successfully implementing the 2025 Compliance requirements

The iGaming landscape in Curaçao has undergone signifant changes since the enactment of the LOK. Alongside this modernization, the island’s Anti-Money Laundering (AML) guidelines have been strengthened, presenting both challenges and opportunities for operators.

To help you navigate this new terrain, we’ve created a practical video guide that follows Alex, an iGaming entrepreneur, as she adapts her business to meet the latest AML standards. Her journey mirrors the real-world experiences of many operators currently updating their compliance frameworks.

Key changes in Curaçao's 2025 AML regulations

The updated guidelines emphasize a risk-based approach to compliance, requiring operators to adopt more comprehensive and proactive compliance strategies. Here are the most impactful changes:

Key changes in Curaçao's 2025 AML regulations - EM Group

Enhanced business risk assessments

Operators must now conduct detailed annual risk assessments that go beyond basic checks. These assessments must evaluate business operations, customer profiles, and transaction behaviors.

Revised client due diligence requirements

The new rules clearly separate identification from verification. While players provide basic information during onboarding, verification must be completed before a lifetime transaction threshold of 4,000 ANG (approx. €2,000) is reached.

Mandatory compliance officer appointments

All licensed operators are now required to appoint an independent AML/CFT Compliance Officer. This role is critical for maintaining regulatory standards, monitoring transactions, and enforcing AML controls.

Common Implementation challenges for operators

Many operators are finding the transition demanding. Key challenges include:

  • Updating policies to reflect a risk-based approach
  • Implementing effective PEP and sanctions screening
  • Managing verification without disrupting player experience
  • Recruiting qualified compliance professionals.

How EM Group simplifies AML compliance

At EM Group, we specialize in transforming complex regulatory requirements into streamlined, business-friendly solutions. Our services include:

Policy development and updates

We help revise your AML policies to align with the latest client due diligence, sanctions screening, and PEP identification standards

Risk assessment implementation

Our experts guide you through comprehensive business risk assessments and help establish annual review protocols.

Compliance officer services

We provide experienced AML/CFT Compliance Officers who understand both the regulatory landscape and operational realities.

Ongoing support

Compliance is not a one-time task. We offer continuous support to ensure your policies evolve with the regulatory environment.

Watch our AML compliance video

Our video brings these changes to life, showing how operators like Alex are adapting to Curaçao’s new AML framework. You’ll see:

  • The impact of the 4,000 ANG verification threshold
  • How to conduct effective risk assessments
  • The role of independent compliance officers in daily operations

Your next steps

The 2025 AML guidelines mark a pivotal shift in Curaçao’s regulatory environment. But with the right guidance, these changes can become a competitive advantage.

Start by reviewing your current policies, identifying compliance gaps, and setting clear timelines for implementation. Remember that AML compliance isn’t just about ticking boxes. It’s about building a resilient, trustworthy operation that supports long-term growth. 

Ready to simplify your AML compliance? Contact our experts today for a consultation tailored to your specific business needs.

Written by Arran McCarthy

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