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AML regulations take effect in Curaçao
The Curaçao Gaming Board has published comprehensive regulations for combating money laundering, financing of terrorism, and proliferation of weapons of mass destruction ( AML/CFT/CPF) in Curaçao’s gambling industry, both for land-based and online casinos. The regulations took effect earlier in January, with a three-month transitional period, after which all land-based and online casinos will be bound to comply.
Risk-based approach
Similar to other jurisdictions, the regulations emphasise a risk-based approach to AML/CFT compliance, meaning that casinos must design policies, procedures, and controls based on identified risks. This will allow casinos to improve the allocation of resources and enhance measures in higher-risk areas while permitting simplified measures for lower-risk scenarios.
Customer due diligence (CDD)
Detailed CDD measures include customer identification, verification, and ongoing monitoring. Casinos must conduct CDD when engaging in financial transactions equal to or above NAf. 4,000 (2130) as well as in other specified circumstances such as suspicion of money laundering or terrorist financing.
Enhanced due diligence (EDD)
For higher-risk situations, casinos will have to implement enhanced due diligence measures which may include obtaining additional information on the customer, their source of funds, and reasons for transactions involving politically exposed persons (PEPs) or residents of high-risk jurisdictions. The regulations mandate the reporting of unusual transactions to the Financial Intelligence Unit (FIU) of Curaçao.
Anti-Money Laundering compliance programme
Casinos are required to implement a comprehensive AML compliance programme, which reflects Curaçao’s commitment to aligning its gambling industry with international AML/CFT standards, particularly those set by the Financial Action Task Force (FATF). Curaçao’s efforts to align with FATF standards indicate a move towards greater international cooperation in combating financial crimes in the gambling sector.
In December 2024, the Parliament of Curaçao approved the National Ordinance for Games of Chance (LOK) legislation. The latest AML new regulations represent a significant step forward in Curaçao’s efforts to modernise its gambling industry and align with international AML/CFT standards. While they may present initial challenges for operators, they are likely to enhance the jurisdiction’s reputation and long-term viability as a hub for online gambling. Operators in Curaçao will need to adapt quickly to these new requirements, investing in robust compliance systems and personnel to meet the heightened regulatory expectations.
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