Executive summary
A newly launched online casino approached us for a lean, practical route to launch with a direct gambling licence from the Curaçao Gaming Authority (CGA). We handled company formation, preparation and submission of the licence application, direct communications with the regulator, selection and onboarding of Compliance & AML officers, implementation of AML/KYC policies and all CGA technical and corporate requirements. The result: the client obtained a direct licence and proceeded to appoint us for further services (additional entity registrations, bank account openings, financial statements and document certification). The project was delivered on schedule and the client reported high satisfaction with the pragmatic, no-friction approach.
Challenge
The client needed to go live quickly and compliantly in a competitive market while avoiding unnecessary bundled services. Specific constraints included:
- Achieve a direct B2C licence to retain full operational control.
- Design corporate and operational structures that meet CGA’s enhanced AML/CFT expectations.
- Mitigate the well-known banking and payments friction for gambling operators.
- Keep cost and time-to-market reasonable, avoiding scope creep.
Context: The global online gambling market exceeded tens of billions in annual revenue (industry estimates put 2024 revenue near USD 78–79 billion and projected robust growth), increasing the urgency for operators to secure compliant foundations.
Our approach (what we did)
- Initial legal strategy & structuring: recommended a Curacao-based licence vehicle aligned to the client’s commercial model and jurisdictional reach, while minimizing unnecessary add-ons.
- Company registration: formed the required Curacao legal entity and local presence as required by the regulator.
- Documentation & policies: drafted AML/KYC, Responsible Gambling, Security and Compliance manuals tailored to CGA expectations and international best practice.
- Compliance & AML officer selection: assisted the client in appointing compliant, experienced officers with documented professional credentials and clear reporting lines, as required under CGA supervisory rules.
- Licensing application & regulator liaison: prepared and submitted the full application package, responded to regulator requests and managed the process end-to-end.
- Banking & payments guidance: advised on realistic timelines and documentation EMIs typically require for high-risk merchant onboarding; prepared the client to meet enhanced due diligence required by financial partners.
Result
- Licence obtained: Direct Curacao license (B2C) issued to the client following successful regulator review and compliance validation. (Outcome: full operational permission under CGA framework)
- Operational readiness: AML & KYC policies in place; Compliance & AML officers appointed; reporting procedures ready.
- Client satisfaction & follow-on work: Due to a clear, cost-conscious approach and ongoing legal support, the client engaged us for additional services: cross-jurisdiction entity registrations, bank account openings, financial statement prep and document certification.
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