WILLEMSTAD – Casinos and online gambling operators licensed in Curaçao have until February 1, 2027, to fully comply with revised anti-money laundering requirements issued by the Curaçao Gaming Authority (CGA). The updated regulations, which took effect on November 1, 2026, introduce a three-month transition period for operators to review and adjust their internal procedures.
The requirements are intended to prevent Curaçao's gambling industry from being used for money laundering, terrorist financing, and the financing of weapons of mass destruction.
They apply to both land-based casinos and online gambling businesses, including operators offering sports betting, online poker, and other forms of digital gambling.
The revised regulations cover customer identification, monitoring of financial transactions, international sanctions screening, and the reporting of unusual financial activity.
Although the November publication establishes a new compliance deadline, many of the obligations are not entirely new. The CGA previously published extensive anti-money laundering regulations in January 2025, requiring gambling operators to comply by April of that year.
The latest publication updates the existing regulatory framework rather than introducing an entirely new system of financial supervision.
Customer Verification Required at XCG 4,000
Under the revised requirements, gambling operators must conduct comprehensive customer due diligence when financial transactions reach XCG 4,000.
This process requires operators to verify a player's identity, assess the potential risks associated with the customer, and determine whether the individual appears on international sanctions lists.
Operators must also establish whether a customer qualifies as a politically exposed person, a classification that can require additional scrutiny because of the potential risks associated with public office or political influence.
Even before a player reaches the financial threshold, gambling companies must collect basic identifying information when an account is opened.
This includes the customer's name, date of birth, and residential address.
If a player reaches the XCG 4,000 threshold without completing the required verification process, the operator may block deposits and withdrawals.
When the necessary documentation is not provided within 30 days, the business relationship must be terminated.
The CGA's earlier regulations already included the XCG 4,000 threshold, meaning that this obligation should not be interpreted as a newly introduced requirement.
Unusual Transactions Must Be Reported
The regulations also reaffirm the obligation to report unusual financial transactions to the Financial Intelligence Unit (FIU) Curaçao.
Transactions of XCG 5,000 or more fall under an objective reporting indicator.
This applies to different payment methods, including cash transactions, bank transfers, electronic payments, and withdrawals of gambling funds.
The reporting requirement also applies when several separate transactions collectively reach the threshold during a single gaming day.
Importantly, transactions involving suspected money laundering or terrorist financing must be reported even when the amount involved is below XCG 5,000.
Reports must be submitted without delay to the FIU, which analyzes unusual transactions and may refer suspicious financial activity to the Public Prosecutor's Office.
The reporting system is intended to help authorities identify potentially criminal financial flows before they become more difficult to trace.
Cryptocurrency and High-Risk Customers Face Additional Scrutiny
The CGA also addresses payment methods and customer behavior that could make it more difficult to determine the origin of gambling funds.
These include cryptocurrency transactions, prepaid cards, electronic wallets, and the use of multiple gambling accounts.
Transfers between player accounts may also trigger additional investigation.
Operators must apply enhanced due diligence to customers considered to present higher risks, including politically exposed persons and individuals associated with jurisdictions where money laundering or corruption risks are elevated.
Casinos must be able to assess whether a customer's gambling activity and financial transactions are consistent with what is known about that person's income and financial resources.
These requirements are designed to prevent gambling accounts from being used to move or disguise funds originating from criminal activity.
Independent Annual Audits Required
Beyond customer verification and transaction monitoring, gambling companies must maintain internal compliance programs to prevent financial crime.
Each operator must designate a compliance officer responsible for overseeing the implementation of anti-money laundering measures.
Employees must receive appropriate training to recognize unusual transactions and carry out customer due diligence.
The company's anti-money laundering policies and procedures must also undergo an independent review at least once a year.
During inspections, the CGA may request access to risk assessments, customer records, unusual transaction reports, and audit documentation.
These internal control obligations were also included in the previous regulatory framework.
The February 1, 2027, deadline therefore represents an opportunity for operators to ensure that their existing compliance systems meet the updated requirements.
The revised rules form part of Curaçao's broader efforts to strengthen financial integrity and regulatory oversight within its gambling industry following the introduction of the National Ordinance on Games of Chance (LOK).