Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Curacao CW

Domains (D1–D6)
3
Sources
7
Role actions
8
Horizon <90d
2
Jurisdiction profile
CleanTier BRisk: ImprovingMixed

Curaçao is a distinct AML/CFT jurisdiction within the Kingdom of the Netherlands (not an EU member state; classified as an EU Overseas Country and Territory).

MoreIt maintains its own AML/CFT ordinances (NORUT, NOIS), a Central Bank (CBCS) supervisory function, an FIU (MOT), a 2023 National Risk Assessment, and a 2024 UBO Decree, assessed by CFATF/FATF in a 2025 Mutual Evaluation as medium-high ML risk with substantial technical and effectiveness gaps.

Key deficiencies
  • FIU (MOT-Curaçao) lacks full operational independence
  • UBO portal not yet fully operational; limited sanctions for non-compliance and gaps in director registration
  • Historically unsupervised online-gambling sub-licensing model enabled global proliferation of unlicensed operators
  • TF and NPO risk assessment (2024) not published and insufficiently detailed to support its 'low risk' conclusion
  • Understaffing of law enforcement limiting ML prosecutions in high-risk sectors (e-zones, online gambling)
  • Gaps in effective control over cross-border cash movements
Recent developments (18m)
  • CFATF completed Curaçao's 4th-round Mutual Evaluation (on-site June 2024; report adopted CFATF Plenary May 2025; endorsed by FATF)
  • National Ordinance on Games of Chance (P.B. 2024, no.157) enacted, replacing the historic master-license/sub-license online gambling model with a direct Curaçao Gaming Authority licensing regime, under a multi-year transitional arrangement
  • Curaçao Public Prosecutor's Office reached its first-ever AML-related settlement with 12 online gambling operators (including crypto casino Stake) in July 2025, fining each the equivalent of $12,500
  • National Decree on UBO Registration issued (2024), with portal development and cross-verification mechanisms still incomplete at MER on-site
Brief

Lead signal

Lead Signal

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Lead Signal

Curacao's crypto-asset AML perimeter has extended materially this cycle through the convergence of two separate regulatory tracks that now touch the same gambling-sector market. The Curacao Gaming Authority's June 2026 crypto guideline requires B2C gambling licensees accepting cryptoasset payment to segregate player, operational and treasury wallets, screen deposits and withdrawals, trace fund origin and destination, exclude funds linked to mixers, tumblers or sanctioned blockchain addresses, and conduct counterparty due diligence on virtual-asset service providers, rolling out on a phased 2026-2027 timetable. This sits alongside, rather than inside, the Centrale Bank van Curacao en Sint Maarten's VASP National Ordinance, which has prohibited unlicensed professional or commercial provision of virtual-asset services since 1 July 2025. The result is two parallel but distinct supervisory perimeters converging on the same gambling-and-crypto market segment: a gaming regulator imposing payment-channel AML controls on licensees, and a central bank imposing licensing-based AML controls on virtual-asset service providers as such. Architecturally, this is the more significant development of the two, because it signals a gambling regulator building its own AML control layer rather than relying solely on the banking-sector gatekeeper.

Other Developments

CBCS public warning on virtual-asset-linked investment schemes. The central bank issued a public warning identifying three social-media-promoted investment programmes exhibiting pyramid-scheme and unauthorised virtual-asset-activity characteristics. No confirmed enforcement action against the named programmes has been reported in this pass; the warning itself is the confirmed act, reproduced from the regulator's own notice language. This is a single-episode signal rather than a structural finding, but it demonstrates active monitoring of retail-facing virtual-asset promotion activity outside the licensed VASP perimeter.

CBCS sanctions-notification formalisation. The central bank has formalised a 24-hour notification procedure for supervised institutions when UN, EU or Dutch sanctions-list changes occur, under the Omnibus-Sanctiebesluit Curacao (PB 2025 nr. 52). This is a procedural tightening of an existing gatekeeper function rather than a change to designation criteria themselves, and it evidences continued institutional build-out of the sanctions-compliance architecture supervised institutions must maintain.

Standing AML/CTF architecture confirmed stable. Curacao's gambling-sector AML regulations, administered by the Gaming Control Board and Curacao Gaming Authority, became a mandatory licensing component effective 10 April 2025 after a three-month transition, applying the National Ordinance on identification when rendering services customer-due-diligence framework to gaming service providers. Curacao is not on the FATF list of jurisdictions under increased monitoring as of the 19 June 2026 Plenary, and its fourth-round CFATF mutual evaluation, adopted May 2025 and published July 2025, found it Compliant on ten and Largely Compliant on twenty of the forty FATF Recommendations. A draft National Ordinance on the Supervision of Payment Service Providers remains pending enactment; payment service providers, e-money institutions and virtual-asset service providers currently operate under Centrale Bank registration, in force since 25 June 2024, rather than under full licensing, and local industry representatives are pressing parliament to accelerate the law.

Cross-Monitor Connections

The CGA crypto guideline's wallet-segregation and counterparty-diligence requirements connect directly to the gambling-sector licensing picture tracked by the advennt monitor, where the same guideline appears as an operational and payments obligation on B2C licensees with its own phased compliance deadlines running into 2027. The guideline's exclusion of mixer-, tumbler- and sanctioned-address-linked funds also intersects with the sanctions-architecture reading above: a wallet-screening control operated by a gaming regulator is, in substance, a sanctions-nexus check performed outside the banking-sector gatekeeper chain, which is a notable enablement-and-architecture signal for a jurisdiction whose gambling sector is a significant share of its licensed economic activity.

Outlook

Watch for confirmation of the CGA crypto guideline's remaining milestones: a risk-assessment, due-diligence and wallet-controls deadline around December 2026, and full compliance targeted for mid-2027. Watch also for whether the draft Payment Services Ordinance advances toward enactment, which would convert the current registration-only regime for payment companies, e-money institutions and virtual-asset service providers into a full licensing framework; current expectation places this in 2027 with a wide uncertainty band. Neither item is a prediction; both are dated regulatory processes already in motion whose resolution would narrow the two-perimeter structure described above into a single, more coherent regime or confirm its continuation.

weekly_brief_draft · JID CW
Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

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Curacao's sanctions architecture advanced procedurally this cycle rather than substantively: the Centrale Bank van Curacao en Sint Maarten formalised a 24-hour notification procedure for supervised institutions when UN, EU or Dutch sanctions-list changes occur, under the Omnibus-Sanctiebesluit Curacao (PB 2025 nr. 52). This is a tightening of the operational mechanics of an existing gatekeeper obligation rather than a change in designation criteria, scope, or the underlying sanctions lists Curacao applies; supervised institutions must now act within a fixed, short window once a list change is published, which compresses the time available for screening updates to reach transaction-monitoring and customer-due-diligence systems.

The sanctions dimension also intersects with the gambling sector's emerging crypto-AML controls. The Curacao Gaming Authority's crypto guideline requires licensees accepting cryptoasset payment to exclude funds linked to mixers, tumblers, or sanctioned blockchain addresses as part of a wallet-screening obligation phased through 2026 and into mid-2027. Although this guideline sits within the gaming regulator's own supervisory track rather than the central bank's sanctions-notification chain, its substance is a sanctions-nexus control: it requires licensees to screen counterparties and transaction flows against sanctioned-address lists, performing a function analogous to what the banking sector's 24-hour notification procedure supports from the supervised-institution side. Read together, Curacao now has two regulators each building sanctions-screening obligations into their respective supervised populations — banks and other CBCS-supervised institutions on one track, and gambling licensees accepting crypto on another — without a single consolidated sanctions-compliance framework spanning both.

No change to Curacao's underlying designation-list membership, no new UN, EU, or Dutch sanctions action specific to Curacao, and no sanctions-evasion typology finding were identified this cycle. The signal here is architectural: continued institutional build-out of the gatekeeper function at the banking-supervision level, paired with the first sign of a sanctions-adjacent control appearing inside a non-banking regulator's own guidance.

Outlook

Watch for whether the CGA crypto guideline's remaining milestones, including the risk-assessment and due-diligence deadline around December 2026, produce any further sanctions-screening specificity, and whether CBCS publishes any guidance clarifying how the 24-hour notification procedure interacts with the gaming sector's parallel screening obligation. No further developments are asserted beyond what is dated above.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions

Not covered

Enabler Jurisdictions is not yet covered for this jurisdiction in this report.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Crypto / Digital Assets / Financial Innovation

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Curacao's crypto-asset regulatory perimeter has extended materially this cycle, with two distinct supervisory tracks now converging on the same market segment. The Centrale Bank van Curacao en Sint Maarten's VASP National Ordinance has, since 1 July 2025, prohibited professional or commercial provision of virtual-asset services in or from Curacao without a prior central-bank licence. Layered on top of that statutory licensing perimeter, the Curacao Gaming Authority issued a crypto guideline in June 2026 that applies specifically to B2C gambling licensees accepting cryptoasset payment: it requires segregation of player, operational and treasury wallets, screening of deposits and withdrawals to trace fund origin and destination, exclusion of funds linked to mixers, tumblers or sanctioned blockchain addresses, and counterparty due diligence on virtual-asset service providers the licensee deals with. Compliance is phased across 2026 and into 2027.

The practical effect is that a Curacao-licensed gambling operator accepting crypto now answers to two separate crypto-facing control regimes that were built by two different regulators for two different populations: the central bank's licensing-based VASP perimeter, which governs who may provide virtual-asset services at all, and the gaming regulator's payment-channel guideline, which governs how a gambling licensee must treat crypto funds moving through its own platform. These are parallel but distinct perimeters rather than a single integrated crypto-AML framework, and the overlap is most visible at exactly the point where a gambling operator's crypto-payment processor is itself a virtual-asset service provider subject to the central bank's licensing requirement.

Separately, the central bank issued a public warning this cycle identifying three social-media-promoted investment programmes — Quick Promo, Korsou Legacy Capital Group, and Elite Wealth Forum — exhibiting pyramid-scheme characteristics and unauthorised virtual-asset activity. No confirmed enforcement action against these named programmes has been reported in this pass; the warning itself, reproducing the regulator's own notice language, is the confirmed act and demonstrates active retail-facing monitoring outside the licensed VASP population.

Outlook

The CGA crypto guideline's next milestone, a risk-assessment, due-diligence and wallet-controls deadline around December 2026, falls ahead, with full compliance targeted for mid-2027. Watch for whether the two supervisory perimeters described above are formally reconciled, or whether CBCS takes any visible enforcement step regarding the three flagged investment programmes.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

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Curacao's standing AML/CTF architecture remained in place and largely stable this cycle, with one incremental development on its margins. The core framework rests on the National Ordinance identification when rendering services (NOIS, PB 2017 no. 92) and the National Ordinance Reporting Unusual Transactions (NORUT, NG 2010 no. 41), both of which set the customer-due-diligence and unusual-transaction-reporting backbone applicable across supervised sectors. Within the gambling sector specifically, the Gaming Control Board and Curacao Gaming Authority's AML Regulations became a mandatory licensing component effective 10 April 2025, following a three-month transition period, applying the NOIS customer-due-diligence framework directly to gaming service providers as a condition of licensure.

Curacao's international standing on this framework remains favourable: it is not on the FATF list of jurisdictions under increased monitoring as of the 19 June 2026 Plenary, and its fourth-round CFATF mutual evaluation — adopted in May 2025 and published in July 2025 — found it Compliant on ten and Largely Compliant on twenty of the forty FATF Recommendations, a combined thirty of forty recommendations rated at the two highest compliance tiers. This places Curacao's assessed AML/CTF technical compliance ahead of many comparably sized offshore financial centres and supports the regulator's own characterisation of the regime as institutionally mature, notwithstanding gaps the mutual evaluation itself may have identified in enforcement-record depth.

The one area of continued incompleteness is payment-sector supervision: a draft National Ordinance on the Supervision of Payment Service Providers remains pending enactment in the Curacao parliament. Payment service providers, e-money institutions and virtual-asset service providers currently operate under Centrale Bank registration only, a regime in force since 25 June 2024, rather than under a full licensing framework. Local financial-technology industry representatives are reported to be pressing parliament to fast-track the ordinance, though no enactment date has been confirmed.

Outlook

The draft Payment Services Ordinance is the principal item to watch on the AML/CTF regime dimension; current expectation places enactment around 2027, with a wide uncertainty band given it remains at the proposed stage. Its enactment would convert payment-sector supervision from registration-only to a full licensing regime, closing a gap the current framework leaves open for payment companies and virtual-asset operators.

D8 Commercial Activity

Not covered

Commercial Activity is not yet covered for this jurisdiction in this report.

Regulatory horizon
Proposed2027-Q2 · ±year

Curacao National Ordinance on the Supervision of Payment Service Providers

Registration-only supervision for payment/e-money/virtual-asset providers would move to a licensing regime once enacted.
Source
In Force Pending2027-Q2 · ±half_year

CGA crypto guideline phased-compliance milestones

Phased tightening of crypto-payment AML controls for CW gambling licensees.
Source
2 dated · 3 pending date · baseline financial-integrity-2026-07-05
Role action cards
MLRO

Two parallel crypto-AML perimeters now apply to the same Curacao gambling-and-crypto market segment.

An MLRO overseeing exposure into Curacao should note that gambling licensees accepting crypto face a CGA wallet-segregation and screening obligation in addition to, not instead of, the CBCS VASP licensing perimeter. SAR-equivalent reporting lines and CDD thresholds under NOIS/NORUT remain the baseline obligation for gaming service providers since April 2025.

2 evidence refs
Compliance

CBCS formalised a 24-hour sanctions-list-change notification procedure for supervised institutions.

Compliance functions with Curacao-supervised entities in scope should confirm their sanctions-screening update process can meet a 24-hour notification window under the Omnibus-Sanctiebesluit Curacao (PB 2025 nr. 52).

1 evidence refs
Legal

A draft Payment Services Ordinance remains pending enactment in Curacao, leaving payment and VASP firms under registration rather than licensing.

Legal counsel advising payment companies, e-money institutions or VASPs with Curacao exposure should treat the current registration-only regime (in force since 25 June 2024) as the operative legal position; the draft ordinance has not been enacted and no date is confirmed.

1 evidence refs
Board

Curacao's AML/CTF standing remains favourable, with no FATF increased-monitoring listing and a largely compliant mutual evaluation.

Board-level risk appetite discussions involving Curacao counterparties can note the jurisdiction is not grey-listed and scored Compliant or Largely Compliant on thirty of forty FATF Recommendations as of its 2025 mutual evaluation.

1 evidence refs
CTO

Gambling-sector crypto wallets in Curacao must now be architecturally segregated by function.

Technology teams supporting Curacao-licensed gambling platforms accepting crypto need to implement segregated player, operational and treasury wallet architecture with transaction-tracing and sanctioned-address screening capability on a phased timetable through mid-2027.

1 evidence refs
Risk

Two distinct crypto-AML supervisory perimeters converging on one market segment is an emerging concentration-and-coverage-gap signal.

Risk functions should flag the structural overlap between CBCS's VASP licensing perimeter and the CGA's gambling-sector crypto guideline as a potential coverage-gap or duplication point requiring monitoring as both regimes mature through 2027.

1 evidence refs
Operations

No material change this cycle.

No material change for this persona this cycle

Audit

CBCS's public warning on three virtual-asset-linked investment programmes is a documented, dated regulatory act available for audit-trail review.

Internal audit can anchor control-testing scope for retail-facing virtual-asset monitoring to the dated 18 September 2026 CBCS public warning identifying Quick Promo, Korsou Legacy Capital Group and Elite Wealth Forum.

1 evidence refs
Decision lens
MLRO

Two parallel crypto-AML perimeters now apply to the same Curacao gambling-and-crypto market segment.

Compliance

CBCS formalised a 24-hour sanctions-list-change notification procedure for supervised institutions.

Legal

A draft Payment Services Ordinance remains pending enactment in Curacao, leaving payment and VASP firms under registration rather than licensing.

Board

Curacao's AML/CTF standing remains favourable, with no FATF increased-monitoring listing and a largely compliant mutual evaluation.

CTO

Gambling-sector crypto wallets in Curacao must now be architecturally segregated by function.

Risk

Two distinct crypto-AML supervisory perimeters converging on one market segment is an emerging concentration-and-coverage-gap signal.

Operations

No material change this cycle.

Audit

CBCS's public warning on three virtual-asset-linked investment programmes is a documented, dated regulatory act available for audit-trail review.

Shared evidence: 1 refs
Scenario sketches

AMLA direct-supervision transition and cross-border obliged entities

Illustrative scenario for analytical orientation only: as the EU AML Package transitions supervisory authority from purely national regulators toward the Anti-Money Laundering Authority's direct and indirect supervision of cross-border obliged entities under the AMLA Regulation (Reg (EU) 2024/1620), alongside the directly applicable AML Regulation (Reg (EU) 2024/1624) and per-state transposition of the sixth AML Directive, non-EEA financial centres with correspondent or counterparty links into the EU may face a reshaped evasion landscape: entities seeking to route around a single national supervisor's gaps may find EU-level supervision closes that gap for EU-facing exposure, potentially redirecting layering activity toward jurisdictions, such as Curacao, that sit entirely outside the AMLA perimeter. This is illustrative orientation on a structural transition, not a prediction about Curacao specifically and not a statement of observed fact.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)
TrackerStatusNote
T1 · Russian Sanctions-Evasion Architectureno_changeNo CW-specific dark-fleet, tech-procurement or commodity-rerouting signal surfaced this cycle.
T2 · EU AML Package / AMLAno_changeNot applicable: CW is not an EEA member and is not bound by AMLR/6AMLD/AMLA.
T3 · FATF Grey Listno_changeCW not on FATF increased-monitoring list as of 19 June 2026 Plenary; 4th-round MER Compliant/Largely Compliant on 30 of 40 Recommendations.
T4 · Beneficial-Ownership Register Statusno_changeNo new CW beneficial-ownership-register development surfaced this cycle.
T5 · Crypto & Digital-Asset IntegrityescalatingCGA's phased crypto-wallet guideline layers onto the CBCS VASP National Ordinance licensing prohibition, materially extending CW's crypto AML perimeter across two regulators.
T6 · Sanctions Regime DivergencestableCBCS formalized a 24-hour supervised-institution notification procedure for UN/EU/Dutch sanctions-list changes under its Omnibus-Sanctiebesluit Curacao (PB 2025 nr. 52).
Registers

Enforcement actions

  • First-ever accountability action against Curaçao's online gambling sector for identity-verification/AML failures, following a 2020 civil-society complaint dossier. Settlement involved fines rather than arrests or licence revocation. 1 Jul 2025
  • CFATF completed and the FATF endorsed Curaçao's 4th-round Mutual Evaluation, rating the country's technical compliance and effectiveness across 40 Recommendations and 11 Immediate Outcomes, flagging medium-high ML risk and priority actions on BO, FIU independence and TF risk assessment. 1 May 2025
  • Issuance and continued rollout of the National Decree on UBO Registration, a step forward on beneficial-ownership transparency, though the UBO portal and cross-verification mechanisms remained incomplete and sanctions for non-compliance limited at the time of MER assessment/endorsement. 1 May 2025
  • Ongoing transition of gambling operators from the legacy master-licence/sub-licence model to direct Gaming Authority licensing under the National Ordinance on Games of Chance (P.B. 2024, no.157), with a transitional arrangement permitting continued operation pending licence determination. 1 Jan 2025

Sanctions changes

  • EU's 19th Russia sanctions package (23 October 2025) targeted Russian energy, third-country banks and crypto providers, including shadow-fleet enablers and maritime registries. As an EU Overseas Country and Territory rather than a Member State, EU sanctions regulations do not self-execute in Curaçao; implementation instead depends on Kingdom-level Sanctions Act extension, creating a structural timing/scope gap versus direct EU-member enforcement. 23 Oct 2025
  • EU's 20th Russia sanctions package introduced a sectoral ban on Russia-established crypto service providers and decentralized platforms, and explicitly prohibited state-backed instruments (RUBx stablecoin, digital ruble CBDC) — the first sector-level (rather than entity-by-entity) crypto sanctions design, relevant to Curaçao's role as a licensing hub for globally-operating crypto exchanges and crypto casinos. 29 Apr 2026

Regulatory horizon (register)

  • CFATF post-MER enhanced follow-up report on Curaçao
  • Full operationalization of Curaçao UBO portal and cross-verification
  • Completion of Gaming Authority licensing transition for online operators

Active schemes

  • [HIGH] Curaçao online-gambling sub-licensing proliferation model
  • [HIGH] Conflict-tainted Venezuelan gold transited via Curaçao
  • Underground banking and money-transfer abuse in Curaçao
Sources
  1. Caribbean Financial Action Task Force (CFATF) / FATF
  2. OCCRP
  3. OCCRP
  4. Bloomberg
  5. Council of the European Union (Consilium)
  6. European Commission (International Partnerships)
  7. Elliptic
Coverage gaps
Curaçao's FIU (MOT) complies with technical FIU requirements…
Curaçao's FIU (MOT) complies with technical FIU requirements but lacks full operational independence, per CFATF's 2025 MER (R.29), alongside understaffed law-enforcement agencies that leave high-risk sectors like e-zones and online gambling largely uninvestigated for ML.
Despite the 2024 UBO Decree, CFATF found limited sanctions f…
Despite the 2024 UBO Decree, CFATF found limited sanctions for non-compliance and gaps in director registration for certain entity types, with trustee CDD/BO record-keeping inadequately aligned to FATF definitions and lacking timely updates.
For years Curaçao's master-licence/sub-licence gambling mode…
For years Curaçao's master-licence/sub-licence gambling model let operators proliferate globally with 'no oversight or legal right to operate in regulated jurisdictions,' a structure exploited by a Turkish organised-crime network (the Falyali betting empire) for large-scale mule-account laundering; the jurisdiction had never fined an operator or revoked a licence until 2025.
No direct CBCS (Centrale Bank van Curaçao en Sint Maarten) e…
No direct CBCS (Centrale Bank van Curaçao en Sint Maarten) enforcement-action primary publication could be retrieved within the 18-month window; the enforcement register for this baseline relies on the CFATF/FATF multilateral MER and Bloomberg/OCCRP investigative reporting rather than a national supervisory enforcement-log primary.

Evidence

Confidence-tiered claims

CGA crypto guideline (June 2026) requires B2C licensees accepting cryptoasset payment to segregate player/operational/treasury wallets, screen deposits/withdrawals, trace fund origin/destination, exclude mixer/tumbler/sanctioned-address-linked funds, and conduct VASP counterparty due diligence, via a phased 2026-2027 timetable. SRC-fim-CW-001
Probable · 1 source
CBCS issued a public warning identifying three social-media-promoted investment programmes (Quick Promo, Korsou Legacy Capital Group, Elite Wealth Forum) exhibiting pyramid-scheme and unauthorized virtual-asset-activity characteristics; no confirmed enforcement action against the operators this pass. SRC-fim-CW-002
Probable · 1 source
Curacao is not on the FATF Jurisdictions-under-Increased-Monitoring list as of the 19 June 2026 Plenary; its 4th-round CFATF MER (adopted May 2025, published July 2025) found it Compliant on 10 and Largely Compliant on 20 of the 40 Recommendations. SRC-fim-CW-003
Probable · 1 source
The GCB/CGA AML Regulations became a mandatory licensing component effective 10 April 2025 after a three-month transition, applying the NOIS (National Ordinance identification when rendering services) CDD framework to gaming service providers. SRC-fim-CW-004
Probable · 1 source
CBCS formalized a 24-hour supervised-institution notification procedure for UN/EU/Dutch sanctions-list changes under its Omnibus-Sanctiebesluit Curacao (PB 2025 nr. 52), evidencing continued gatekeeper-function build-out. SRC-fim-CW-006
Probable · 1 source
A draft National Ordinance on the Supervision of Payment Service Providers remains pending enactment; PSPs, EMIs and VASPs currently operate under CBCS registration (since 25 June 2024) rather than full licensing. SRC-fim-CW-001
Probable · 1 source