Curaçao Gaming Authority sets compliance deadlines for operators through October 2026

Curaçao Gaming Authority (CGA) licensees under the Landsverordening op de Kansspelen (LOK) have a stack of active compliance deadlines running now through October 2026. For high-risk PSPs and operators, the point is simple: this is not a “set it and forget it” license regime, and several items need action well before the calendar turns.

1. AML Policy review is due now. The Anti-Money Laundering (AML) Policy is currently due for review. The CGA notes that AML frameworks vary by operator, so there is no single template that fits everyone: some licensees only need a targeted update, while others need a full revision aligned with current CGA expectations.
2. The Player Complaint Policy must now reference ADR. The Player Complaint Policy is subject to annual review, and this year’s version has one specific requirement: it must clearly reference the Alternative Dispute Resolution (ADR) mechanism available to players. Operators that already appointed an ADR provider should make sure the policy says so. Operators that have not yet appointed one should treat that as the priority item.
3. Domain inactivity has to be communicated in advance. If an operator plans to remove an active domain from the CGA Portal, or expects a period of inactivity, the CGA should be told ahead of time. The notice needs to include when activities will cease, how long the inactivity is expected to last, and when operations are expected to resume. Separately, all CGA licensees need to launch the domain within six months of the date of licensing.
4. Six months of no activity can put the license at risk. Under the LOK, the CGA can revoke or decline to extend a license if the operator has not operated its licensed gambling activities for six consecutive calendar months. The practical takeaway is that operators in this position should proactively explain the reason for the delay so the CGA can evaluate it and avoid revocation.
5. An Operational Manual is mandatory before August 31, 2026. All B2C operators are required to have an Operational Manual in place before August 31, 2026. For PSPs and compliance teams, this is one of those documents that tends to get pushed down the stack until the regulator makes the stack shorter.

Crypto policy is already changing day-to-day operations. The CGA’s Crypto Policy guideline affects how B2C licensees handle digital-asset deposits, wagering, withdrawals, and treasury management. Effective immediately, operators cannot accept funds from sanctioned wallets or mixers, cannot use personal or ultimate beneficial owner (UBO)-linked wallets, and cannot act as an exchange, custodian, or virtual asset service provider (VASP) beyond accepting crypto as payment for gambling.

The policy also draws a line between prohibited activity and activity that needs extra scrutiny. Fiat-backed stablecoins are the CGA’s preferred asset. Privacy coins, meme coins, and wrapped tokens are not banned outright, but each requires a documented risk assessment; wrapped assets whose backing cannot be verified are off-limits. Operators must also vet any external crypto provider they use — such as an exchange, custodian, or payment processor — and that VASP must be regulated, registered, and able to show adequate controls against money laundering and terrorist financing.