Compliance Updates
Critial Milestones Curacao License
The National Ordinance for Games of Chance (LOK) has been officially submitted to Parliament and the Minister of Finance has initiated a sequence of procedures to facilitate a seamless transition from the existing framework to the new system upon the law’s enactment.
Licenses under the new framework (issued by NOOGH and the LOK)
All licenses and license holders will be granted under the same rights and conditions. There is flexibility as to the corporate and license structure entities can set up with regard to their individual operations.
- Any account can have one or more licenses.
- Any UBO(s) can have one or more accounts.
- Any license can have unlimited domains.
Prospective renewal of Current Gaming Licenses (Master Licensees)
From this point forward, there will be no new extensions or renewals of Master Licenses. Master Licensors will only be able to continue to operate and permit sublicensees to do so until current renewals expire, or LOK come into force, whichever happens first. On the passing of LOK or when there are no less 12 weeks of the current renewal remaining, again which ever happens first, the Master Licensor must promptly notify the GCB which sublicences remain contracted to it. After this time Master Licensors should they wish to continue operations in their own right will need to wait until LOK is implemented and apply for a license then.
1st January
- All license holders under the NOOGH will be allowed to use a new Digital Seal on domains of their websites. This Digital Seal will be issued by the GCB.
- In addition, the GCB has the discretion to permit operators in contractual arrangements with license holders (the sublicensees) with license applicants in progress, that have satisfied the due diligence required by the GCB to offer the same Digital Seal.
A Digital Seal Policy will shortly be issued by the GCB and will require operators to include the “token” associated with each domain registered on the GCB portal to be inserted into the websites’ DNS.
License holders will be responsible for actively monitoring their sub-licenses to ensure they do not employ a variant of the official Digital Seal without enforcement. The GCB will take enforcement measures against license holders found to be in violation of this policy.
31st March 2024
Registration of sublicense on the GCB portal and the subsequent application for direct licenses of those sublicense operators will no longer be possible after the 31st March 2024.
The following are the scenarios based on sublicense registration and NOOGH license applications from this date.
Sublicense and domains | Sublicense and domains not | |
registered on GCB portal | registered on GCB portal | |
Application in progress on the | Operations continue | N/A |
GCB portal or license issued by | uninterrupted under | |
the GCB under NOOGH | sublicense agreement until | |
direct license is issued. | ||
Direct license if held at the | ||
time of the LOK coming into | ||
force will be grandfathered | ||
into the new framework as a | ||
provisional license without any | ||
interruption of business | ||
operations. | ||
Applications in progress will | ||
continue under the LOK | ||
framework and sublicense | ||
operations can continue | ||
uninterrupted. | ||
No application in progress on | Continue operations under | Immediately cease operations |
the GCB portal and/or license | current agreement with | under any sublicense |
issued by the GCB under | Master License holder until | contractual agreement from |
NOOGH | expiry ceases or LOK comes | this date. |
into force, whichever is first. | ||
Any application to be made | ||
Any subsequent application to | will be a new application and | |
be made will be treated as a | not “grandfathered” at | |
new application and not | changeover from NOOGH to | |
“grandfathered” at changeover | LOK giving rise to a rsk of | |
from NOOGH to LOK giving rise | temporary interruption to | |
to a risk of temporary | operations in-between | |
interruption to operations in- | licenses. | |
between licenses. |
- Any license application from a brand new entity/applicant (i.e. not under any existing license or sublicense) under NOOGH will be processed under NOOGH, and if not yet completed at the point the LOK comes into force will have the same status as sublicensees.
- Current “sublicense” holders who receive a new direct license under the NOOGH will have their business operations transferred immediately to the GCB regulatory system and be subject to the license conditions. Any existing contractual arrangement with the master license holder is the responsibility of the two parties to that agreement without interference by the GCB.
Definitions
GCB – Curacao’s Gaming Control Board
GCB Portal – https://portal.gamingcontrolcuracao.org/
LOK – Incoming legislation: National Ordinance for Games of Chance
NOOGH – Current legislation: National Ordinance on Offshore Games of Hazard
Compliance Updates
IAGR confirms new Board members
The International Association of Gaming Regulators (IAGR) has announced the appointment of four new trustees to its Board, each bringing unique expertise and leadership to strengthen IAGR’s global regulatory efforts:
- Anders Dorph, Danish Gambling Authority (Europe)
- Peter Kesitilwe Emolemo, Gambling Authority of Botswana (Africa)
- Kevin Mullally, General Commercial Gaming Regulatory Authority (Asia/Oceania)
- Louis Rogacki, New Jersey Division of Gaming Enforcement (North America)
IAGR President Ben Haden said, ‘I’m delighted to welcome our four new trustees to the IAGR Board. Their diverse expertise and leadership across different jurisdictions will bring fresh perspectives to our work, further strengthening our global approach to gaming regulation.
‘I look forward to collaborating with Peter, Louis, Kevin and Anders as we continue to foster innovation and drive forward effective, responsible regulation for the benefit of the global gaming community.
‘We also extend a big thank you to Trude Høgseth Felde and Mabutho Zwane for their dedicated service as they complete their terms on the Board, and I’m pleased to announce that Jason Lane will continue for another term as a Trustee.’
As a leading forum for gaming regulators worldwide, IAGR enables members to meet, share information, discuss legislative developments, exchange views and learn best practices in gaming regulation.
In recent news, IAGR has also confirmed that its 2025 annual conference will be held in Toronto, Canada, from 20 to 23 October 2025, with registrations opening in early 2025.
Compliance Updates
MGA Issues First ESG Code Approval Seals to Licensees
The Malta Gaming Authority (MGA) has awarded its first-ever ESG (Environmental, Social and Governance) Code Approval Seals to licensees in the online gaming sector, marking a milestone in the Authority’s commitment to promoting responsible and sustainable industry practices.
This initiative follows the launch of the voluntary ESG Code of Good Practice last year, which invited licensees to submit their ESG disclosure returns. The Code, which covers 19 topics categorised under Environmental, Social and Governance pillars, offers a strategic roadmap for online gaming companies to streamline their reporting efforts.
Following the first annual reporting cycle, 14 gaming operators have been awarded the ESG Code Approval Seal. The Code supports two levels of reporting: Tier 1, which establishes foundational ESG standards, and Tier 2, which represents a more aspirational approach.
Seals are valid for one year, with flexibility for renewal in the subsequent reporting period, allowing operators to advance or adapt their reporting tier year by year.
“We believe this initiative will significantly enhance the industry’s reputation and sustainability credentials,” MGA CEO Charles Mizzi said.
“By integrating ESG considerations into their operations, gaming companies not only contribute to the wellbeing of society and the environment but also strengthen the trust and confidence that consumers, investors, and regulators have in the industry. This initiative sends a clear message: sustainability, in the broadest sense of the word, is integral to the future of the gaming sector.”
Compliance Updates
Turkish Football Federation to Penalise Clubs Promoting Illegal Betting
The Turkish Football Federation (TFF) has introduced new regulations to crack down on illegal betting advertisements in professional football.
According to the TFF, clubs found violating the new rules will face fines and, in case of repeated offenses, the deduction of points.
Under the updated guidelines, any club in the Turkish Super League involved in unauthorised betting promotions will face a tiered penalty system.
The first violation will result in a fine of 2 million Turkish Liras (around $58,000), and the second offense will incur a 5 million lira fine and a third violation will see the fine increased to 10 million liras. For subsequent breaches, clubs will be fined 10 million liras for each offense, along with a three-point deduction from their league standings.
“It is forbidden to promote or advertise betting organizations not licensed by competent authorities. This includes any media, billboards and other equipment used within stadium,” the TFF stated.
The TFF emphasised that the ban also applies to entities affiliated with these betting organisations, including those involved in promoting and advertising activities in a way that suggests endorsement of illegal betting.
The global scale of the illegal betting market is staggering, with the United Nations Office on Drugs and Crime estimating its worth at $1.8 trillion. In Türkiye alone, the sector is projected to exceed 100 billion liras, according to the Financial Crimes Investigation Board.
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