AML Compliance for Online Gaming Operators in Curaçao –2025 Policy Guide

As Curaçao continues its strategic transformation into a respected and transparent iGaming jurisdiction, regulatory compliance remains at the forefront of its licensing framework. Following the release of the Responsible Gaming Policy in April 2025, the Curaçao Gaming Control Board (GCB) introduced another critical regulatory pillar earlier this year — the Anti-Money Laundering and Counter-Terrorist Financing Policy, effective from January 9, 2025, with full enforcement by April 10, 2025.

This blog summarizes the key requirements and expectations set out in the AML/CFT Policy and outlines what prospective and current Curaçao license holders must do to align their operations.

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Scope and Applicability

The AML/CFT Policy applies to all licensed online gambling providers under Curaçao’s jurisdiction. Compliance is mandatory and enforced by the GCB. Violations may result in administrative or criminal penalties, including license revocation.

Risk-Based AML Framework

Online gaming operators must adopt a Risk-Based Approach (RBA) to AML compliance. This includes conducting:
- Business Risk Assessments (BRA) to evaluate overall AML exposure
- Customer Risk Assessments (CRA) to classify players as low, medium, or high risk

Operators must adjust controls and due diligence levels based on identified risks. Enhanced Due Diligence (EDD) is required for higher-risk scenarios.

Customer Due Diligence (CDD) Requirements

Operators must collect and verify customer identity before processing financial transactions of NAf 4,000 or more. CDD includes:
- Player identification and verification using government-issued ID
- Understanding source of funds and intended use of the account
- Ongoing transaction monitoring to detect unusual behavior

Failure to complete CDD results in account freezing or termination.

Unusual Transaction Reporting

Transactions of NAf 5,000 or more must be flagged and reported to the FIU Curaçao through the goAML platform. This includes:
- Cash-ins, chip sales, e-wallet payments, and large withdrawals
- Linked or structured transactions that exceed the reporting threshold

Operators must ensure staff are trained to recognize and report these activities internally and externally.

Sanctions & PEP Screening

All players must be screened against UN and EU sanctions lists, as well as PEP status checks. If a player is identified as a Politically Exposed Person (PEP), operators must:
- Conduct Enhanced Due Diligence
- Verify source of wealth and funds
- Obtain senior management approval

Internal Controls and Training

Operators must:
- Appoint an independent AML Compliance Officer
- Implement internal AML/CFT policies and procedures
- Conduct regular staff training on AML detection and prevention
- Perform independent audits of the AML program annually

Third-party partners and affiliates must also adhere to the operator’s AML standards.

Conclusion

Curaçao’s AML Policy reflects global regulatory expectations. Online operators must prioritize:
- Risk assessment and transaction monitoring
- Comprehensive due diligence and documentation
- Real-time compliance with sanctions and PEP obligations

AML compliance not only supports licensing but also protects your platform's integrity and player trust.

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📌 Need support navigating Curaçao’s AML or Responsible Gaming requirements? Feel free to reach out.