Curaçao’s New Licensing Era

The New Curaçao Reality: KYC, Compliance, and the Rise of Anjouan

Curaçao online gambling regulation has gone from loophole-friendly to legally binding. The changes are real, enforcement is tightening, and operators need to choose: adapt under Curaçao, shift to looser regimes like Anjouan, or decentralize entirely. There’s no one-size-fits-all path anymore, and each carries trade-offs.

From Rubber Stamp to Real Regulation

For years, Curaçao was the license of choice for crypto casinos. The reasons were simple: it was cheap, quick to acquire, and, most importantly, light on oversight. A simple sub-license arrangement allowed hundreds of crypto casinos to operate under a handful of master licenses. Anonymous operators could launch overnight, add a Curaçao license badge on their homepage, and accept crypto deposits with virtually no oversight.

“For years, Curaçao was the license of choice for crypto casinos. The reasons were simple: it was cheap, quick to acquire, and, most importantly, light on oversight.”

However, the reality is now very different. From late 2024, the long-delayed reforms promised by Curaçao’s government and the newly created Curaçao Gaming Authority (CGA) began to be rolled out, and by late 2025, were essentially complete. Their aim? To end the era of “license by logo” and align the island nation with other top-tier international regulators. Indeed, former Chief executive of the Malta Gaming Authority (MGA), Mario Galea, was a consultant to the Curaçao government during the reform process. 

The result? Online casino operators have been forced to choose between adapting or fleeing. But how far has this reform really gone? And what does it really mean for operators, regulators, and players in a practical sense?

Caption: Licensing reform in Curaçao has been talked about for many years, but it was only in 2023 that concrete plans started to be acted upon.

What’s Changed in Practice

The headlines sound simple enough, but the reforms fundamentally alter how crypto casinos interact with licensing:

• End of sub-licenses: Operators must now apply directly to the CGA rather than piggybacking on a master license. This closes the door on the cheapest, fastest route to market.
• Local presence requirement: Operators must incorporate a Curaçao entity, complete with a local representative, increasing operational costs and binding them to Curaçao’s legal system. No more mailbox-only companies.
• Ownership disclosure: Anonymous ownership is no longer possible. Directors and beneficial owners must be declared, creating accountability.
• KYC/AML enforcement: Casinos must implement player identity and age verification before the first withdrawal. Anonymous, wallet-only gambling – once the hallmark of Curaçao’s crypto casinos – is effectively over, at least for any operator trying to remain compliant.
• Responsible gambling: Operators are now required to provide basic self-service safer gambling tools, like the ability to set wager, loss, and time limits, or self-exclude entirely – without contacting player support.
• Ongoing oversight: Non-compliant operators face fines, suspension or even revocation, at least in theory.

Impact in practice:

• For players, this means basic ID checks are now unavoidable at Curaçao-licensed casinos. Importantly, this has made using a VPN to play from a prohibited jurisdiction pointless. However, players now also have access to effective safer gambling tools giving them more control.
• For operators, the era of “add a wallet and go live” is over. Compliance infrastructure is now essential, and costs and liabilities have increased dramatically.

Caption: The new licensing requirements for Curaçao are significantly more demanding but should build trust with players.

Which Countries and Regions are Now Off Limits?

It should be pointed out that many jurisdictions were always technically prohibited by a Curaçao gaming license. However, because the old sub-licensing system did not enforce KYC requirements, in practice crypto casinos generally served players regardless of where they were – even advising players to use VPNs to bypass any geoblocking.

“However, because the old sub-licensing system did not enforce KYC requirements, in practice crypto casinos generally served players regardless of where they were – even advising players to use VPNs to bypass any geoblocking.”

To appreciate what these changes really mean in practice, let’s consider Stake.com – the world’s biggest and most successful crypto casino. The platform’s owner and operator, Medium Rare N.V. is registered and licensed Curaçao, and now cannot serve players from the following jurisdictions:

Afghanistan, Argentina, Austria, Australia, Belgium, Brazil, Cayman Islands, Colombia, Côte d’Ivoire, Cuba, Curaçao, Czech Republic, Cyprus, Democratic Republic of the Congo, Denmark, France, Germany, Greece, Iran, Iraq, Israel, Italy, Liberia, Libya, Lithuania, Malta, Netherlands, North Korea, Ontario, Peru, Poland, Portugal, Serbia, Slovakia, South Africa, South Sudan, Spain, Sudan, Syria, Sweden, Switzerland, United Kingdom, United States, and Zimbabwe.

Needless to say, not being able to accept players from the world’s biggest online gambling markets like the US and UK, exceptionally valuable European markets like Germany, the Netherlands and Sweden, and the most promising emerging markets like Brazil and Argentina, is a huge limitation.

 

Caption: Many major markets are now effectively off limits for Curaçao-licensed crypto casinos.

Pitfalls: Where Compliance Still Falls Short

Despite progress, Curaçao’s new regime is not yet watertight.

• Temporary Certificates: Some operators are actually operating on a temporary certificate rather than a full license. The temporary certificate (orange rather than green), does not necessarily mean an operator has achieved the required regulatory standards yet. For players, this creates confusion.
• The affiliate problem: The vast majority of crypto gambling content online is created and published by affiliate marketers and many publish misleading or outdated licensing information. Understandably, many players take this information at face value. While the CGA may not have the authority to order changes, they could launch information initiatives to address the issue.
• Rogue crypto-only brands: Some shady casinos continue as if nothing has changed, falsely giving the impression they are licensed in Curaçao, even though they either never had a license or it has lapsed. They continue allowing deposits and withdrawals via wallet alone, with no meaningful KYC or AML.
• Enforcement gap: The regulator has not yet stripped badges from all non-compliant sites. Indeed, in practical terms, there is no way it can stop offshore platforms displaying a CGA badge. As a result, the Curaçao seal can be found on both serious, reformed operators and those that remain effectively unregulated.

The result: credibility remains fragile. Curaçao’s badge should now mean full oversight, but it remains to be seen if enforcement standards will be sufficient.

   Caption: The use of both the temporary “Certificate of Operation” and full license “Certificate” has caused confusion among players.

Progress: How Leading Casinos Are Adapting

The reforms have created a divide in the crypto casino industry.

At the top end, Tier 1 operators (e.g. Medium Rare N.V. and Dama N.V,) – those with significant funding, global sponsorships, and mainstream partnerships – are leaning into compliance. Some of these brands have even exceeded minimum requirements – now conducting KYC at signup or before a first deposit. They’ve upgraded AML systems, hired compliance officers, and are preparing to meet incorporation and reporting standards.

Why? Because credibility is part of their growth strategy. These operators need to attract institutional partners, payment processors, and avoid incurring the wrath of authorities in other jurisdictions where the company may have separate, locally regulated brands. For them, compliance isn’t just a box-ticking exercise; it’s the cost of long-term legitimacy.

“Because credibility is part of their growth strategy… For them, compliance isn’t just a box-ticking exercise; it’s the cost of long-term legitimacy.”

A striking example: some of the biggest crypto casinos that built their reputation on anonymity now require ID before deposits. Just a few years ago, that would have been unthinkable. Today, it’s becoming standard practice for any operator serious about sponsorships, influencer deals, or mainstream visibility.

However, other operators have opted to abandon Curaçao and seek alternatives.

Caption: Curaçao-licensed crypto casinos are now required to verify player age via official government-issued ID, effectively closing the VPN loophole.

Anjouan: The New Crypto Casino Refuge

As Curaçao tightens up, another small jurisdiction has stepped into the vacuum: Anjouan, part of the Union of Comoros – an impoverished and notoriously unstable archipelago nation in the Indian Ocean off East Africa.

Why operators are flocking there:

• Low cost: Licensing is cheap, with minimal ongoing obligations.
• Speed: Approval can be granted in weeks.
• No real compliance: Little in the way of KYC, AML, or corporate presence requirements.
• No local presence requirements: Operating companies can remain registered in tax havens like Belize and Costa Rica. 

In practice, Anjouan has become the new Curaçao-lite – a quick, affordable way to add a license seal to a crypto casino homepage. 

By mid-2025, many established operators had migrated to Anjouan, includingTwocent Technology Ltd (BC.Game), Stellar Ltd, Apex Dynamics Ltd, and Ensoft Group Ltd, flocking to the island. While the low barriers to entry has also attracted a number of new iGaming operators like Star Bright Media SRL and BetHog Operations Ltd. 

The problem is credibility. Unlike Curaçao, which at least has decades of industry recognition, Anjouan is starting from scratch. Player protection is virtually nonexistent, and the license is little more than a digital certificate.

“Unlike Curaçao, which at least has decades of industry recognition, Anjouan is starting from scratch. Player protection is virtually nonexistent, and the license is little more than a digital certificate.”

For operators, Anjouan may solve short-term launch headaches. But in the long term, association with a “wild west” jurisdiction could prove damaging. 

Furthermore, it seems very likely that Anjouan will eventually be subject to the same pressures to reform as Curaçao – with the country being very vulnerable to action from international financial regulators like the FATF (Financial Action Task Force). 

Tobique and St Kitts Join the Game

In an attempt to capitalize on the exodus of crypto casinos from Curaçao, two new online gambling licensing jurisdictions have also emerged. The first is Tobique – a tiny Canadian First Nation located within the province of New Brunswick. The second is the Caribbean island nation of St Kitts and Nevis.

In general, the Tobique license requirements are very similar to those of Anjouan (even the license certificate looks almost identical). And while it is early days, it seems highly unlikely that such a tiny, inexperienced jurisdiction has the expertise or resources to effectively regulate international crypto casinos. Logically, the same can be said for St Kitts. 

Caption: The Anjouan (left) and Tobique (right) Internet Gaming License Validation pages are almost identical. 

Practical Advice for Operators

For crypto casino operators, the reform period is a moment to choose between long-term credibility and short-term convenience.

• Be transparent: Don’t just display a logo. Communicate openly about your KYC, AML, and fairness policies. Trust comes from clarity, not just badges.
• Invest beyond licensing: Demonstrate commitment to players with verified provably fair systems, clear dispute resolution mechanisms, and robust responsible gambling tools.
• Make a strategic choice:
  • If you’re a Tier 1 operator, Curaçao is likely worth the effort. The credibility will pay dividends.
  • If you’re smaller, weigh the trade-off carefully. Anjouan might get you online fast, but it may limit growth and reputation.
• Be aware of the limitations: Both Curaçao and Anjouan licenses prohibited players from many major online gambling markets, including the US and UK. However, in reality, Anjouan does not currently enforce strict KYC practices.

Practical Advice for Players

Players are often left navigating a fog of logos and claims. Here’s what matters:

• Expect KYC at Curaçao casinos: If you’re playing at a legitimate Curaçao-licensed casino, ID checks are now part of the deal before you can make a withdrawal. This means no more using a VPN to play from prohibited jurisdictions.
• Curaçao casinos provide more protection: From effective responsible gambling tools to a clear channel for escalating complaints, if you are from an accepted jurisdiction, a Curaçao license now offers higher levels of player protection.
• Be cautious with Anjouan/Tobique/St Kitts casinos: Treat the license as window dressing. Real trust must come from transparency – provably fair systems, independent audits, and reliable withdrawal policies. Remember that the regulators will refuse to accept complaints from users playing from prohibited jurisdictions.
• Never take a license badge at face value: Always check a license is valid. Click the seal to open the full license. If in doubt, check the license number on the official register, and check that the company details in the footer match those on the license.

Do not assume any license guarantees professionalism: Even online casinos that technically meet all of the required standards can be run badly. Consider things like the fairness of promo terms, the responsiveness of customer service, and the overall quality of the platform itself.

Caption: All Curaçao-licensed online casinos are now required to provide players with self-service responsible gambling tools.

The Bigger Picture

Curaçao’s reforms represent genuine progress. They bring the jurisdiction closer to international standards and force operators to take compliance seriously. But the new system is still in its early days and has yet to prove itself. 

However, one thing is clear, crypto casinos now face a fork in the road:

• Adapt and professionalize under Curaçao, shouldering the cost and cutting off many markets entirely, but gaining more legitimacy in those that remain.
• Flee to weaker jurisdictions like Anjouan or Tobique, saving money but losing credibility.
• Go completely unlicensed and either operate from jurisdictions like Costa Rica, or go fully decentralized and establish DAO (decentralized autonomous organization) governance.

Crypto casino operators need to appreciate that the days of playing the system to serve prohibited markets from Curaçao are over. And, while Anjouan, Tobique, and St Kitts, with their light rules and even lighter enforcement, may allow operators to conduct “business as usual” for a while, they also come with a host of issues. 

“Crypto casino operators need to appreciate that the days of playing the system to serve prohibited markets from Curaçao are over.”

Meanwhile, fully decentralized models, including DAO-governed casinos, may appeal to developers and communities seeking to bypass licensing entirely. But even these will eventually face pressure from payment providers, listing platforms, and regulators – and of course, they are inherently limited regarding the games they can offer. 

The long-term winners will be those that combine crypto’s strengths – provable transparency, open auditability – with credible licensing standards that reassure both players and partners. Critically, these operators will have to target very clear markets – a strategy that may require obtaining multiple local licenses and offering geographically ringfenced products.

“The long-term winners will be those that combine crypto’s strengths – provable transparency, open auditability – with credible licensing standards that reassure both players and partners. “

Notably, the latter strategy appears to be the one chosen by Medium Rare – which has maintained its flagship Curaçao-licensed platform while also acquiring numerous locally licensed platforms in various international markets. For example, by 2025 the company had already acquired locally-licensed MocinoPlay in Denmark, Baldo Line in Italy, and BetFair Colombia, and secured a local Brazilian license.

Caption: Stake operator Medium Rare has kept its Curaçao-licensed platform while also expanding into locally regulated markets via acquisitions.

Conclusion: Things Just Got More Complicated

Curaçao is no longer the easy one-stop option for global access that it once was. The regulatory reforms mark a shift toward genuine oversight, but enforcement gaps and the rise of alternative iGaming licensing jurisdictions like Anjouan, Tobique and St Kitts, mean the future is still far from certain.

For operators, embracing reform is the only viable path to long-term trust. A Curaçao license can still be a valuable pillar of a successful crypto gambling business, but things have gotten much more complicated. For players, Curaçao should be seen as “better, but not bulletproof.” Anjouan, Tobique, and St Kitts, by contrast, very much remain “buyer beware.”

“For operators, embracing reform is the only viable path to long-term trust. A Curaçao license can still be a valuable pillar of a successful crypto gambling business, but things have gotten much more complicated.” 

The next two years will be decisive. Curaçao has the chance to evolve into a respected mid-tier regulator – but only if enforcement matches ambition. If not, crypto gambling risks sliding back into the cycle of low-effort licensing and fragile credibility.

Are you an industry stakeholder looking for the most effective crypto casino licensing solution? Here at Mondus, our iGaming experts are dedicated to providing practical advice and solutions to help you achieve sustainable success. Get in touch today to find out how we can help.