December 27, 2024

Curaçao LOK Compliance 2025: What You Need to Know

The National Ordinance on Games of Chance (LOK) introduces a modernized framework for Curaçao’s iGaming sector, reshaping compliance, licensing, and local presence requirements.

Here’s what you need to know.

What is included in this newsletter?

Approval of the LOK
Understanding the Impact of the LOK
LOK requirements
Step-by-Step Guide to LOK Applications
EM Group’s relevant services

Approval National Ordinance on Games of Chance (LOK)

The National Ordinance on Games of Chance (LOK) was approved on December 17, 2024, and made effective as per December 24^th, 2024. This legislation introduces a direct government licensing system under the Curaçao Gaming Authority (CGA), enhancing transparency and compliance in the iGaming sector.

The parliamentary vote came down to 13 in favor, with 6 against, completing a 4-year journey for the Minister of Finance and the Curaçao igaming sector, which process consisted of political conflicts, Kingdom discussions (over covid relief and legal reforms), and the discontinuation of the renowned Master License Holders.

The CGA is established as an independent administrative body as referred to in Article 111, first paragraph of the Constitution of Curaçao, and its task is to implement the rules established by or pursuant to the LOK, as well as tasks relating to games of chance that have been assigned to the CGA by or pursuant to other national ordinances.

Understanding the impact of the LOK

The LOK prohibits organizing games of chance in or from Curaçao without a CGA-issued gaming license. Suppliers of critical services or goods will also require a CGA permit. Existing license holders, operating under the former NOOGH license with GCB Orange or Green seals, will transition into the new framework through a grandfathering clause, granting them a provisional six-month compliance period, extendable by an additional six months.

LOK requirements

Under the LOK, license applicants must meet the following requirements:

Be incorporated and established in Curaçao, managed by at least one Curaçao resident (service provider).
Disclose the identity and involvement of all ultimate beneficial owners (UBOs) and qualifying persons.
Maintain financial and tax obligations in accordance with Curaçao’s laws.
Comply with regulations such as the National Ordinance on the Reporting of Unusual Transactions and the Sanctions Ordinance.
Implement policies to prevent gambling by minors and vulnerable individuals.
Provide ongoing employee training in areas like responsible gambling, anti-money laundering, and player communication.
Submit (upon request) compliance reports to the CGA.
Meet local presence requirements by employing at least one key person within the first four years and three by the fifth year (excluding the local director), based in an immovable property carrying out exclusively the business activities under its gaming license.
Local presence requirements will be exempted for qualifying startups. Speak to us for more information.

Step-by-step guide to LOK applications

The application process for a remote gambling license involves two phases:

Phase 1: The CGA assesses the applicant’s integrity, stakeholders, and financial viability within eight weeks.
Phase 2: The CGA evaluates additional compliance requirements and issues a decision within eight weeks. Timelines may extend by up to four weeks in each phase.

EM Group’s relevant services

With nearly two decades of experience, EM Group specializes in guiding businesses through Curaçao’s evolving iGaming regulations. Our local team offers personalized solutions to meet the LOK’s compliance, licensing, and operational requirements, ensuring a seamless transition into the new framework.

With our expertise, dedicated team, and diversity of services, EM Group can guide you through the complexities of this new era, offering you a one-stop shop for your licensing requirements.

Upon request a detailed fact sheet can be provided by one of our in-house experts.

Ready to navigate Curaçao’s new gaming regulations? Contact EM Group today to ensure your compliance and success under the LOK framework.

Written by Arran McCarthy