From Licensing Jurisdiction to Regulatory Jurisdiction

Curaçao's National Ordinance on Games of Chance (the LOK) came into force on 24 December 2024, abolishing the former NOOGH legislation and its master-sublicensing system after a parliamentary vote. As Cindy Drommond writes in the September 2026 issue of IMGL Magazine, it marks the moment Curaçao moved from a jurisdiction regarded as an accessible gateway to one that actively regulates those license holders throughout their business lifecycle.

In her article, "Curaçao's LOK reform: from licensing jurisdiction to regulatory jurisdiction," EM Group's Legal Director explains the shift in practice: rather than serving mainly "as a gateway to market entry," the LOK requires the CGA to maintain "an ongoing relationship with its licensees." She examines the LOK's expanded AML and governance requirements, new substance requirements for license holders, and the introduction of licensing for suppliers of critical gaming-related goods and services, comparing Curaçao's approach with Malta's established direct licensing model.

Her conclusion: the LOK "is far more than a licensing reform," and Curaçao's standing will depend on "the consistency of supervision, the credibility of enforcement" that follow. Read Cindy's full article in IMGL Magazine.