Will the Curaçao master licenses be renewed?

During the iGB Live conference in Amsterdam, from July 12-13, our team held talks with Gaming Curacao, one of the 4 master license holders in Curacao, and also listened to the position of the representatives of the Ministry of Finance of Curacao regarding the renewal of master licenses in 2023. 

Curaçao master license holders will be given the opportunity to renew their license for one year before the implementation of the new gambling legislation. This information was confirmed by the legal advisor of the Ministry of Finance of Curaçao, during iGB Live. The extension of the master license will allow sub-license holders to operate smoothly and enter into the transition period. 

Once the new gambling legislation, known as LOK, comes into effect, master license holders will automatically transition to the new regulatory regime provided they comply with the requirements and regulations within the prescribed timeframe. Sublicensees wishing to operate under the new regime will be given a three-month transition period to apply for a license under LOK. During the application and review period, sub-licensees may continue to operate as usual for nine months after the LOK comes into effect. However, operators who choose not to switch to the new licensing regime must cease operations upon expiration of the relevant master license.

When does the new regulation come into effect?

On September 1, the Gambling Control Board (GCB) will start issuing new licenses directly to operators. These licenses will be issued in accordance with current legislation and will come with certain conditions. It is important to note that holders of these licenses will not be able to issue sub-licenses and will be required to adhere to certain regulations on anti-money laundering (AML) and responsible gaming. 

Master license holders can continue to issue sub-licenses at their discretion until LOK is implemented (We have already received confirmation from our Master Holder that he will resume accepting new applications soon).

However, once LOK is implemented, sub-license-only operators will have to apply for a new license under LOK, following a standard transition process that includes KYC verification.

How do I get a license under the new procedure?

The process of applying for a license through the GCB is relatively straightforward and involves completing three forms along with the relevant supporting documentation. These include an online gambling license application, a personal declaration and corporate information. Applicants must provide information about the proposed business operations, the key persons involved and company details in Curaçao. Supporting documentation, including proof of identity and information on the source of funds, is required for verification, especially for any ultimate beneficial owner (UBO) with an ownership interest of 10% or more.

Once all required forms and documents have been submitted to the GCB, a license is issued. Audited policies and procedures covering areas such as player protection, AML procedures, KYC, responsible gaming measures, and a description of the technical and information security system must be submitted within six months of receiving the license.

Our summary

We are pleased to welcome the clarity from the Curaçao government authorities on the renewal of master licenses and will notify our clients of the opportunity to renew their sub-licenses shortly.

To our new customers who have not yet obtained a gaming license – we recommend that you contact us to discuss the options available to you, currently you will have the choice of obtaining a sub-license under the old procedure, obtaining a Curaçao license under the new procedure (when the legislation comes into force) or obtaining a license in alternative jurisdictions. 

Also note to our current clients, we have worked out and continue to work on a number of alternative licenses, in case the new Curaçao license requirements are excessive for you. We will also notify you of alternative options shortly. 

If you have any questions about future changes or would like to discuss a plan of action, please contact the lawyer accompanying your project. We will be happy to answer all questions.