In the existing regulatory landscape of Curaçao, licenses are not bifurcated into B2B (Business-to-Business) and B2C (Business-to-Consumer) distinctions.
Instead, both B2B and B2C activities are bundled into a single license category.
This single-license type incurs no application fee upfront, with an annual fee of ANG36,000 (£15,958/€18,623/$20,090) and a monthly fee of ANG7,000. Each license encompasses up to 40 domains.
However, a new legislative framework known as the LOK draft introduces separate regulations for B2C licenses.
Under this forthcoming framework, the B2C license application will necessitate an ANG9,000 fee, along with one-time due diligence charges ranging between ANG250 and ANG500 per person, contingent upon their role.
The annual fee for B2C licenses will amount to ANG48,000, with a monthly fee of ANG4,000.
Additionally, a sum of ANG500 per annum will be levied for each domain, and there will be no limitations on the number of domains under B2C licenses.
Operators obtaining a direct license under the existing law transitioning to LOK are exempt from the ANG48,000 annual fee upon enactment, deferring the payment until their first license anniversary. Subsequently, the monthly fee will decrease from ANG7,000 to ANG4,000.
Under the LOK framework, all entities must hold a B2C license, including companies directly engaging with players and those facilitating B2C operations through player funds and data.
Turning attention to B2B licenses within the LOK framework, the licensing fees mirror those of B2C.
The application fee remains ANG9,000, complemented by one-time due diligence costs between ANG250 and ANG500 per person, contingent on their role.
The annual fee remains ANG48,000, but there is no monthly fee for B2B licenses, and domain allocation does not apply.
The implementation of the LOK commenced on September 1st, with the Gaming Control Board (GCB) launching its license application portal.
This portal serves a dual purpose, facilitating the processing of new applications under the existing legislation (NOOGH) alongside the GCB and registering sublicensees intending to operate under the LOK.
Sixiènne Jansen, legal advisor to Curaçao’s Ministry of Finance, elucidated the new licensing process in July during the iGB L!VE event.
Hilary Stewart-Jones, an independent consultant at gambling law firm Harris Hagan, joined the GCB as an advisor in September.
Simultaneously, the Minister emphasized that the LOK would function as a “safety net” to guard against the possibility of grey-listing.