Licensing Big changes coming for Curaçao casino licensing

[maxd]

Apparently the changes in Curacao licensing are finally gaining some momentum. This letter is now making the rounds as Curacao law firms look to find new clients among the casino operators facing the tsunami of change headed their way:

Dear *snip*,

We are writing to inform you about significant upcoming changes in the online gaming laws of Curacao, which will impact your operations. As a company that currently holds a gaming license for online gaming in Curacao, it is essential for you to be aware of these developments.

Effective from 15 November 2023, the current licensing structure for online gaming will undergo a transformative shift. From this date, every online gaming company can apply for its own individual gaming license with the Government of Curacao. That is great news.

Companies that do not apply for an individual license, will still need to register their sublicense with the Government and will then be allowed to operate under their sublicense. However, the Master License Holder system will be abolished when new legislation comes into effect (expected in Q1 or Q2 in 2024). When that happens, the company will still need to apply for its own individual gaming license, so why not do this now already?

If a gaming company has not received an individual license, when the Master Licenses will be invalidated, then the company will be without a valid license. This may cause a business interruption. Therefore, it may be a good idea to apply for the individual license as soon as possible.

At *snip* Attorneys at Law, we understand that navigating these regulatory changes can be both complex and time-consuming. To assist you during this transition, our experienced legal team can facilitate the gaming license applications for your company. We offer an all-inclusive and comprehensive range of services, including a local Director and a registered domicile in Curacao, all at significantly reduced costs compared to traditional solutions.

We are a one-stop-shop for online gaming companies in Curacao. For more information, please check our website *snip*

We are happy to assist you further and look forward to your response.

Kind regards,

Needless to say the law firm in question is trying to scare potential clients into jumping on the "individual license" process and thereby give them lots of money. As it ever was, of course. This article (thank you CM Staffer) adds some official perspective on the matter:

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What follows (next post) is a conversation we've recently had regarding these changes, and related issues.

 

[maxd]

I thought this conversation might be of interest to people, an office conversation regarding the upcoming changes:

Staffer: I wonder if they will begin enforcing kyc checks. That will be such a massive help for problem gamblers if they actually do and enforce it​

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Max: My guess is that yes, they likely will. Curacao is trying to go "legit" with all these changes and my suspicion is that KYC will be part of that.​

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Staffer: Could that also mean they enforce stricter financial codes? I.e. an end to crypto? And it so, where do they go - Costa Rica?​

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Max: "end of crypto"? That's a tough one because it's currently such a big part of Curacao casino business. At a guess I'd say they'll get a lot of pushback on that if they try it.​

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Staffer: Depends if SoW checks are required or not I guess​

It so I imagine a lot of the crypto players are done​

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Max: FWIW Curacao licensing has always been driven by pragmatics and the biggest pragmatic has traditionally been revenue. They're cleaning things up because it's become a real problem for them being the biggest outlier in the industry. That and pressure from the Netherlands. The end result is that they're trying to move closer to "respectability". Taking an axe to a good percentage of their revenue stream(s) is something I'd be surprised to see them do.​

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Staffer: Weren't they facing mounting pressure from Dutch government though? I remember some parliamentary hearings or their equivalents of them​

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Max: Exactly, thus the changes.​

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Staffer: And will we ever find out the true face behind the master four? Lol​

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Max: I wouldn't bet on it.​

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Staffer: So I'd be curious how much freedrom Curacao have been given​

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Max: They've already been given a fair bit TBH. The Dutch gov has been pressuring Curacao for some years now. Ok, so Curacao decided to finally do a little house-keeping. If history is any example the Dutch gov will remain at arm's length, and thus I rather doubt the changes for Curacao gaming will end up being _too_ invasive.​

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I think the big losers in all of this are going to be the Master License guys. They're effectively out of business AFAICT since they've been the defacto licensing bodies since the beginning. Curacao is obviously stepping up to take over -- hence the individual licenses -- and that puts the Master License guys out in the cold.​

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Needless to say there'll be a whole lot more discussion on this. This article (thank you Staffer) adds some official perspective on the matter:

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Got questions you think we might be able to answer? Ask away!
What are your thoughts? Feel free to let us know.

 

[maxd]

FWIW @Casinomeister has been doing some serious digging into this and it looks like there is some BIG news coming our way. Stay tuned.

- Max

 

[satchnz]

As soon as online slotting becomes too hard, I’m giving up. It’s only entertainment for me after all. I’ve got other backup hobbies like hitting my thumb with a hammer and amateur self dentistry.

 

[slot_zombie]

Well as the article says, AML and KYC are incoming so that will be the end of us UK slotters as far as the decent offshore outfits are concerned. Shitty news but we had a good run.

As above I have ZERO interest in resuming playing in the UK. Most other countries will be able to play in Curacao still, with no problems, but not us special UK citizens - who require nannying to death!

Remains to be seen if any workarounds or "alternative jurisdictions" can be found (but why would the casinos bother). Guess I'll invest more time in Netflix and wine making.

 

[Smithyy]

Well as the article says, AML and KYC are incoming so that will be the end of us UK slotters as far as the decent offshore outfits are concerned. Shitty news but we had a good run.

As above I have ZERO interest in resuming playing in the UK. Most other countries will be able to play in Curacao still, with no problems, but not us special UK citizens - who require nannying to death!

Remains to be seen if any workarounds or "alternative jurisdictions" can be found (but why would the casinos bother). Guess I'll invest more time in Netflix and wine making.

It remains to be seen what the specific regulations will look like - although it's worth mentioning that according to Curacao's own regulations (2019) AML and KYC checks have always been required (LOL) - although it's far more likely they'll be enforced now under the new centralised licensing system.

While their website appears to be a work in progress, you can see the regulator already has their website up and running

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. They do appear to be taking a pretty serious approach from what we can see so far - looking to bring up their operation to EU standards.

Regarding your comment about "the end of us UK slotters" - that may be the case, but it looks as though many Curacao-licensed sites may be 'jumping ship' to a new jurisdiction as a result of these changes. Many of the companies that help new casinos get up and running in Curacao (white label software, payment solutions, gambling license, etc), and now adding disclaimers / info on their websites advertising a "hot new licensing jurisdiction" - Anjouan.

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.

 

[Smithyy]

Also, if (as is looking likely) after the changes Curacao licensed casinos are required to run KYC checks properly, then it's not just the UK that will be affected. Curacao's regulations have two categories of banned/restricted countries:

"BLOCKED ZONES FOR CURACAO
Afghanistan, France, Iran, Netherlands, Netherlands Antilles, USA, United Kingdom, Curacao

RED ZONES FOR CURACAO
Australia, Austria, Belgium, Bulgaria, Croatia, Denmark, Estonia, Finland, Germany, Gibraltar, Greece, Greenland, Ireland, Isle of Man, Italy, Jersey, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Poland, Portugal, Romania, Spain, Sweden, Switzerland"

What the "Red Zones" means - I am unsure, perhaps @maxd can offer more perspective. But needless to say, there's going to be plenty of US, UK, French, and Dutch players in the same boat - so I'm sure we'll see new sites cropping up in new time at all in a new jurisdiction - potentially, operating in an even worse manner to how Curacao's been operated!

 

[maxd]

... What the "Red Zones" means - I am unsure, perhaps @maxd can offer more perspective. ...

Sorry, news to me. I have no idea what their "red zone" means and a quick Gooble search didn't turn up anything useful either.

 

[slot_zombie]

Interesting information. I can't see anything immediate to jump ship to "now" under other jurisdictions- well, there's Bitcoin.com games, trustworthy but running "secondary RTP" settings so kinda defeats the point.. Let's see how this plays out.

 

[Smithyy]

Sorry, news to me. I have no idea what their "red zone" means and a quick Gooble search didn't turn up anything useful either.

From some digging, it looks like the "BLOCKED" countries refer to countries that have signed a specific treaty with Curacao, so operators can't take players from said countries. However, I find it odd Afghanistan would have signed such a treaty of all places - and also, Australia has, I believe, such a treaty - so why they're not included, I do not know.

As for the "Red Zones", it looks like it has something to do with countries that have their own licensing bodies. I believe Curacao licensed casinos are legally allowed to accept players from these countries, but CANNOT be based in, or have any business operations in those countries themselves. Happy to be corrected if anyone knows differently!

P.S. Try using Google next time, not Gooble - it's much more reliable IMO

 

[Smithyy]

Interesting information. I can't see anything immediate to jump ship to "now" under other jurisdictions- well, there's Bitcoin.com games, trustworthy but running "secondary RTP" settings so kinda defeats the point.. Let's see how this plays out.

Well I don't believe anything noticeable will change (at least from a player's perspective) until next year at least. Operators, on the other hand, I'm sure, are already busy preparing. I also believe the cost of a Curacao license will also increase - so it may also not be financially viable for some of the smaller operators to remain in Curacao. Exact pricing is said to be released later this month

 

[Mr Wild]

Well, all these brands will move their operations to Costa Rica and things will remain the same.

 

[Smithyy]

Well, all these brands will move their operations to Costa Rica and things will remain the same.

The problem with this, I believe, is that most of the major game developers aren't licensed in Costa Rica. So sites will either need to offer crappy games to players (which will be a major turn off for most), or offer pirated games - the latter of which could potentially be the bigger issue IMO.

 

[Mr Wild]

The problem with this, I believe, is that most of the major game developers aren't licensed in Costa Rica. So sites will either need to offer crappy games to players (which will be a major turn off for most), or offer pirated games - the latter of which could potentially be the bigger issue IMO.

To my knowledge all game providers that are in Curacao are in Costa Rica as well, however you can only deposit and withdraw with crypto while in Curacao you have more payment options.

 

[Smithyy]

To my knowledge all game providers that are in Curacao are in Costa Rica as well, however you can only deposit and withdraw with crypto while in Curacao you have more payment options.

Worth noting there is no such thing as a Costa Rican gaming license - it doesn't exist. So reputable game developers, anyway, won't work with any casino based there.

 

[Mr Wild]

Worth noting there is no such thing as a Costa Rican gaming license - it doesn't exist. So reputable game developers, anyway, won't work with any casino based there.

I have seen the list of game providers available there so I know for a fact that most are available.
You are right that there is no gaming license in Costa Rica. But you cant really call Curacao a gaming licence either. You pay for a stamp thats the only difference. B2B providers have no licence at all in Curacao either.
As I see it, all reputable game providers are moving to the black market.

 

[maxd]

... P.S. Try using Google next time, not Gooble - it's much more reliable IMO

I don't like typing the G word.

Also, do have citations for your "As for the 'Red Zones' ..." statement or are you taking an educated guess?:

As for the "Red Zones", it looks like it has something to do with countries that have their own licensing bodies. I believe Curacao licensed casinos are legally allowed to accept players from these countries, but CANNOT be based in, or have any business operations in those countries themselves.

FWIW, as soon as we see what a new Curacao license attribution looks like that would be great thing to share. There are already a fair few casinos making fake Curacao license claims and the new changes are obviously a golden opportunity for them to fly under the radar.

 

[Smithyy]

Also, do have citations for your "As for the 'Red Zones' ..." statement or are you taking an educated guess?:

A combination of an educated guess, along with some info from the restrictions mentioned on

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page.

 

[dunover]

From some digging, it looks like the "BLOCKED" countries refer to countries that have signed a specific treaty with Curacao, so operators can't take players from said countries. However, I find it odd Afghanistan would have signed such a treaty of all places - and also, Australia has, I believe, such a treaty - so why they're not included, I do not know.

As for the "Red Zones", it looks like it has something to do with countries that have their own licensing bodies. I believe Curacao licensed casinos are legally allowed to accept players from these countries, but CANNOT be based in, or have any business operations in those countries themselves. Happy to be corrected if anyone knows differently!

P.S. Try using Google next time, not Gooble - it's much more reliable IMO

Aaaahh damn! - you mean my favourite 'grey' site Taliban Games is gonna go??

It's all window dressing. A load of bollocks. Like scraping all the turds into one corner and leaving them there. The Cup-o-cocoa scammers like the 1668/JAZ kollectiv have seen the number be panned so much (especially on here over the years) that they now disassociate themselves from the useless 'license' and either don't bother even putting it on their scam casinos or simply invent one.

So from displaying a 'real' scam number like 1668/JAZ they now don't have one or have a fake one - the effect on the player is still exactly the same: zero protection from any regulatory authority and zero comeback on the scammers.

As for the Cup-o-cocoa license holders with good intent (apparently there are a few about) if the direction of travel is toward a useful authority with some degree of actually giving a fuck after the cash is collected, then if they are going to put the genuine sites through those costs and procedures then those sites may as well invest in a license which has some status, like a MGA one rather than a Poundland equivalent.

Even when all this has come to pass, what will happen to existing complaints about Cup-o-cola operators and the previous scammers still under their umbrella and the millions they have defrauded? Sod-all.

 

[Deeplay]

Well if it does end up blocking UK players that would not force me back to the bitter shores of UK gaming. I suppose that would be me out. I do have a secondary address in the EU - which when im here I can play without the need for VPN. But I wouldnt go through the hassle of KYC for the other EU address. And wont do SOW for anyone.

Just have to wait to see how this plays out ... it will be interesting. I gamble less and less these days anyway so if the door is shut then so be it. I would not bother with going to a casino in costa rica - its risky enough playing off shore in Cur ... even though I never had one issue ever on withdraws and so on.

 

[maxd]

... It's all window dressing. A load of bollocks. ...

My guess is that you'll be proven wrong about that. Then again I suppose I'm just as likely to end up being the one who's wrong about this. A lot of sturm und drang for no end result though. We'll know soon enough I expect, once we hear back from some our trusted industry people who currently hold Curacao sub-licenses.

 

[jasonuk]

It's a bit of a weird situation, and I'd have to agree with @dunover.

For the dishonest part of the spectrum - they had no intention of following the previous regulations (I burst out laughing at the earlier comment about AML/KYC checks since 2019) and there's nothing to suggest that would change - many of their target markets are on the list of restrictions, and many of their dishonest schemes (targeting addicts, underage players, or straight up fraud) are obviously contrary to a regulated jurisdiction. I'd expect them to move to another low-regulated or unregulated jurisdiction - and players will need to tread very carefully when that transition happens (because not only will they have no rights, we could see a return to pirated games or providers further capitulating and offering horrendous RTP versions - think 80% or less).

For the more honest part of the spectrum - you're going to lose a significant part of your client base with the US on the blocked list (although Canada isn't listed on either section - yet), and if the cost of licensing is too high then a more valuable license like MGA could make sense. As Max mentioned earlier, Curacao tend to be pragmatic about revenue, so when the inevitable collapse in revenue happens from losing US players (similar to what is happening in the German markets) do they stick to their principles or start to water down the regulations?

As a "regulator", I applaud them for finally making positive steps forward - however overdue it may be. As for operators, the value of a next generation Curacao license seems unclear... I guess time will tell.

 

[nisosbar]

It's interesting to remember that CM did a survey a while back of its own members as to what features they most value in an online casino. I'd have to go back and find that thread, but licensing was very low on the list. Meaning that, for whatever reasons, online gamblers (to the extent they are represented by CM's membership) don't consider licensing very important in determining where they play.

Also, KYC is a double-edged sword, because in many cases you hand over your documents and details to an organization whose ownership and principals are mostly clouded in mystery and obfuscation. .

 

[maxd]

... when the inevitable collapse in revenue happens from losing US players (similar to what is happening in the German markets) do they stick to their principles or start to water down the regulations? ...

My bet would be that whatever they _eventually_ decide to do it'll be too late for it to make a huge difference.

If they freak out and water down the regs early in the game they'll get kicked in the privates by the Netherlands lawmakers who are now on a roll _against_ toothless licensing. Chances of success: not good.

If they wait for the crash and then move to plug the holes they'll not only have the Netherlands to contend with but also the fact that many of the people who want to continue offering services to US players will have made their move, if they haven't made those plans already. Chances of success: not good.

My guess is that the "alt" jurisdictions are already taking meetings with those that are so inclined. I've seen a few operators recently move to Costa Rica -- not necessarily a great choice IMO but any port in a storm I guess -- and there'll be more of this to come.

Well, all these brands will move their operations to Costa Rica and things will remain the same.

Let's not forget that Mr Wild said it first. IMO he's pretty much 100% reliable on such things.

 

[jasonuk]

It's interesting to remember that CM did a survey a while back of its own members as to what features they most value in an online casino. I'd have to go back and find that thread...

I think you're referring to this thread (although I can't see the results - you still have to vote to view results, and the thread is locked, perhaps the mods can help?).

Gambling is a trust game fundamentally - and regulation can and should be part of that trust chain, but it can't be exclusive - we've seen reputable Curacao operations and we've seen rogue UKGC and MGA operations. As a UKGC player, my biggest concerns right now - the lack of transparency over RTPs and game design, the death of promotions, and more and more manipulation of withdrawal and complaints procedures - have basically no visibility at all on the UKGC radar, they're focusing more on spin speed (so twice the house edge at half the speed) and paperwork

If they freak out and water down the regs early in the game they'll get kicked in the privates by the Netherlands lawmakers who are now on a roll _against_ toothless licensing. Chances of success: not good.

It'll be interesting to see if their lawmakers turn on their own regulatory body (KSA) at some point, it's probably been one of the bumpiest roads to regulation that we've seen, and there's still a number of outstanding issues to be resolved.