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Cross BorderLicensing

Guide

Moving from a Curaçao sub-licence to the LOK

The master licence system is gone. Here is what moving to a direct licence from the Curaçao Gaming Authority involves, step by step, and how to avoid the common mistakes.

What changed

Until the Landsverordening Openbare Kansspelen (LOK) took effect on 24 December 2024, most Curaçao operators held a sub-licence issued by one of four master licence holders. The LOK ends that structure. Every operator now holds a licence directly from the Curaçao Gaming Authority (CGA) and deals with the CGA itself.

Our article Curaçao's LOK reform: what actually changes for operators explains the reform. This guide is about what to do.

Before and after

TopicUnder a sub-licenceUnder the LOK
Who licenses youA master licence holderThe CGA, directly
Who answers for the fileLargely the master licensee, with you behind itYou, in your own name
DocumentationMore variable in practiceUBO transparency, evidence of source of funds and policies that describe how you really operate, applied consistently
Local presenceNot assessed operationallyAssessed under the LOK, and a registered-agent address alone does not satisfy it
FeesPaid under the master licence arrangementApplication fee of €4,592; annual fees of €47,450 for a B2C operator and €24,490 for a B2B supplier

For orientation. Fees are those in the CGA's schedule under the LOK; we confirm the current figures for your structure.

The move in eight steps

  1. 1

    Confirm your status with the CGA

    Do not rely on your former master licensee or a bundled service provider. Ask the CGA, in writing, where you stand, and keep the answer.

  2. 2

    Decide whether the CGA is still the right regulator

    The move is also a moment to ask whether a direct Curaçao licence still fits your markets, banks and partners, or whether another jurisdiction does.

  3. 3

    Map ownership to the UBOs

    Draw the full chain from the licensed company to the ultimate beneficial owners. An unclear chain is the most common reason files are returned.

  4. 4

    Rebuild the evidence

    Gather current source-of-funds and source-of-wealth evidence for each UBO. Evidence prepared for the old process is rarely enough.

  5. 5

    Rewrite the policies

    AML/CFT and responsible gambling policies must describe how you actually run, and meet the CGA's current standard, not the one your master licensee applied.

  6. 6

    Plan the local presence

    Decide where staff and infrastructure sit and which compliance roles you appoint in Curaçao, sized to your licence type.

  7. 7

    File and answer queries quickly

    Submit a complete file and answer the CGA's questions within days. Every answer must match the file.

  8. 8

    Update everything that refers to your licence

    Your website and licence seal, the licence details held by banks, payment providers and platforms, and the references your affiliates use.

The move is not an administrative formality

We have seen operators assume that the transition is something their former master licensee handles. It is not. It needs the same rigour as a fresh application, with the same documents. See UBO, source of funds and source of wealth for what the CGA looks for.

If you are a B2B supplier

Suppliers to Curaçao-licensed operators face their own requirements under the LOK. The LOK's two-year transitional period ends on 24 December 2026. From then, suppliers established in Curaçao that provide critical services or goods to licence holders must hold a CGA supplier licence and be registered, and foreign suppliers must be registered. If you supply platforms, games or services to operators in Curaçao, check your position now rather than at the end of the period.

Questions about the move

Sub-licences issued under the master licence system have been replaced by direct licences from the CGA. Operating on a pre-reform arrangement after the relevant deadline carries real regulatory risk, so confirm your status with the CGA directly.

Still on a pre-LOK arrangement?

A short call is usually enough to tell you where your plan stands and what the sensible next step is.

Plan a call