LOK, a comprehensive guide - Curaçao iGaming license

April 30, 2025

The modernizing Curaçao iGaming License

The National Ordinance on Games of Chance (LOK) modernizes Curaçao's gaming industry regulation. This guide outlines the application process for Curaçao iGaming licenses under the new legislation.

Available Licensing Frameworks (B2C and/or B2B)

Two distinct types of licenses are available:

Operator License: a mandatory B2C gambling license for providing games of chance in or from Curaçao to end users. This license is available for application as per March 13, 2025; and a
Supplier License: a non-mandatory B2B license for providers of critical services or goods who supply services in or from Curaçao - strictly limited to pure games of chance developers. This license is available for application as per June 1, 2025.

Licensing Application Process

The licensing process occurs in two phases:

Phase 1: Assessment of integrity of key persons and the applicant's financial condition.

Phase 2: Verification of compliance with all other regulatory requirements.

The initial phase focuses on integrity and financial stability. During this phase, the Curaçao Gaming Authority (CGA) conducts thorough background checks on the company, its ultimate beneficial owners, and key personnel. The CGA also evaluates the company's financial position and overall business viability.

Standard processing time is 8 weeks per phase, with possible 4-week extensions. Provisional licenses may be granted for up to 6 months while the second phase is pending. Licenses are generally granted indefinitely but subject to ongoing compliance requirements.

LOK - Licensing Application Process - Phases

Corporate Structure and Management

Requirements for company structure:

Companies must be established under Curaçao law with a genuine physical presence and appropriate office facilities.
At least one board member must be a Curaçao resident actively involved in operations.
All directors and key personnel must meet integrity and expertise standards.
Staffing requirements: First 4 years - minimum 1 local staff member; From year 5 - minimum 3 local staff members.

Operational Costs and allocations

The financial framework under the new legislation includes various fees, contributions, and operational requirements. Initial application fees start at EUR 4,592, with additional charges for each ultimate beneficial owner (EUR 150), qualified shareholder (EUR 150), and listed ultimate beneficial owner (EUR 2,551).

The license fee is composed of a flat fee owed to the CGA to cover the estimated costs associated with continuous monitoring by the CGA; and a flat fee owed to the National Treasury for holding the license.

Annual license costs for an Operator include

A CGA supervision fee of EUR 22,960
A government license fee of EUR 24,490

Annual license costs for an Supplier include

A government license fee of EUR 24,490

The legislation also introduces a unique social contribution structure, collections related to the license fees will be contributed, by specific percentages, to a Curaçao Sports Fund, a Curaçao Vulnerable Persons Protection Fund, the Curaçao Anti-Addiction Foundation, and the Curaçao Old Age Pension and Widow/Orphan Funds.

Policies and Procedures:

Real Economic Presence

Licensees must maintain:

Years 1-4: At least 1 local Key Person (excluding managing director)
Year 5 onward: At least 3 local Key Persons
A properly equipped business space in Curaçao

Staff Training and Development

Operators must implement ongoing training programs covering:

Mental health awareness
Anti-bribery procedures
Crime prevention
Responsible gambling practices

Compliance Monitoring and Reporting

Required reports:

Bi-annual changes reports: June 15 and January 15
Incident reports: Within 24 hours of occurrence
Annual financial statements: Due by June 30

Operators must maintain internal control systems for compliance monitoring, risk assessment, and transaction tracking.

Prohibited Activities

Key prohibitions:

Offering credit to players or allowing minors to participate
Games based on natural disasters, exploitation, cruelty, or life-threatening events
Game manipulation or staff participation in own games
Mixing player funds with operational funds
Marketing to vulnerable persons or making false claims

Enforcement Framework

The Curaçao Gaming Authority (CGA) has extensive enforcement powers including:

Conducting on-site inspections and real-time monitoring
Accessing documentation and examining technical systems
Interviewing staff and management
Investigating complaints

Enforcement tools available to the CGA include:

Formal warnings and administrative fines
Cease and desist orders
License suspension or revocation
Mandated corrective actions

Administrative penalties can reach the highest category of fines, with additional penalties for continuing violations. Criminal penalties may include imprisonment up to four years, fines, and asset seizure in serious cases.

Enforcement Process

When potential violations are identified, the CGA follows a structured process:

Investigation including evidence collection and documentation review
Technical analysis and financial audits where appropriate
Formal notice of violation with opportunity for operator response
Review of evidence before enforcement decisions
Appeal process for challenging enforcement actions

The CGA coordinates with law enforcement, tax authorities, and international regulators to ensure comprehensive enforcement across relevant jurisdictions.