CURAÇAO GAMING AUTHORITY SETS OUT RESPONSIBILITIES OF LOCAL EXECUTIVE DIRECTORS UNDER THE NEW LOK FRAMEWORK
On the 14th of August 2025, the Curaçao Gaming Authority (CGA) issued a formal notice to corporate service providers and directors of licensed iGaming companies.
In this notice, the regulator clarified the role of locally established managing directors under the Landsverordening op de Kansspelen (LOK), emphasizing the very real responsibilities that come with the position.
The requirement itself is not new. Article 2.1(4) of the LOK makes it clear that every licensed operator must have at least one executive director based in Curaçao. However, the CGA has now stressed that this director cannot be non-executive or passive. The role demands active involvement in the daily running of the business and genuine authority in decision-making. For many operators, this will mean that their corporate service provider may need to step into the role of local director.
In its notice, the CGA set out the areas where directors are expected to take responsibility. These range from ensuring operators meet their obligations on responsible gaming – such as keeping minors and self-excluded players out, and maintaining proper complaints and dispute procedures – to safeguarding player funds. Directors must make sure that customer money is held in segregated accounts, that accurate records are kept, and that financial statements are submitted on time.
Another central responsibility is compliance with Curaçao’s anti-money laundering and counter-terrorist financing framework. The CGA expects effective systems for customer due diligence, monitoring of transactions and reporting of unusual activity to the Financial Intelligence Unit. Technical standards are also in focus, with operators required to use certified systems that protect player data and guarantee fair, secure play.
The regulator has also reminded directors of their duties to engage with oversight. This means ensuring that operational manuals, incident reports and notifications of changes reach the CGA promptly, as well as complying with Curaçao’s substance and server requirements. On the question of where operators may offer services, the CGA made an important point: it is not the Authority’s role to approve or forbid markets. That responsibility lies with the operator, which must ensure its activities comply with the laws of every jurisdiction it enters. Where gambling services are provided unlawfully, the CGA may take regulatory action, including revocation of a licence.
Finally, the notice underlines the broader supervisory obligations of directors. Both current and former directors are required to cooperate fully with the CGA when asked for information, and in some circumstances the Authority may share relevant information with the Central Bank of Curaçao and Sint Maarten.
Should you require further guidance or wish to review your governance and compliance arrangements, please do not hesitate to contact the team at [email protected]
