Curaçao updates cryptocurrency rules for iGaming, requires compliance by 2027
The use of cryptocurrencies by online gambling operators licensed in Curaçao will be subject to stricter regulatory oversight in the coming months. This week, the Curaçao Gaming Authority (CGA) published new regulatory guidance for companies that accept digital assets on their platforms, introducing stricter rules for deposits, withdrawals, custody of funds and transaction monitoring.
The new measures are part of the regulatory reform introduced by the CGA following the entry into force of the National Ordinance for Games of Chance (LOK), which replaced the previous sublicensing system with a direct licensing model and centralised supervision. The regulator is also seeking to align the jurisdiction with international standards on anti-money laundering and counter terrorist financing applicable to the virtual assets sector.
The guidance makes it clear that gambling operators may continue to accept cryptocurrency payments but will be required to comply with a range of compliance obligations and demonstrate greater transparency regarding the origin of customer funds.
Operators will not be allowed to act as cryptocurrency exchanges
One of the main provisions of the new policy prohibits licensed operators from performing activities typically carried out by exchanges or Virtual Asset Service Providers (VASPs). In practice, companies licensed by the CGA may accept cryptocurrencies only as a payment method directly related to gambling activities. They will not be permitted to offer digital asset trading services, conversions between different cryptocurrencies, exchanges into fiat currencies or wallet custody for purposes unrelated to gambling.
The CGA also requires operators to clearly inform users that they are not responsible for services provided by external digital asset exchanges used by players to acquire or trade digital assets.
The measure reflects a trend observed in other jurisdictions, where regulators are seeking to clearly distinguish gambling activities from financial services that are subject to separate regulatory frameworks.
Blockchain analytics tools have become essential
Another key requirement introduced by the new guidance is the implementation of mechanisms to trace and assess the risk of blockchain transactions. According to the CGA, operators are not expected to become specialists in digital asset investigations, but they will no longer be able to claim ignorance regarding the financial transactions associated with their operations.
To meet this requirement, operators must implement systems capable of identifying the origin and destination of funds, analysing the transaction history of customer wallets, detecting links to illicit activities and assigning risk ratings to transactions.
The regulator cites widely used industry platforms such as Chainalysis, Elliptic and TRM Labs but makes it clear that there is no obligation to use a specific provider. According to the authority, the key requirement is that operators demonstrate they have sufficient resources to adequately monitor digital asset transactions. In addition to initial deposit screening, monitoring must be ongoing to detect new risk exposures throughout the customer relationship.
Stablecoins receive regulatory preference
The guidance also adopts a more cautious approach towards different categories of digital assets. The CGA considers cryptocurrencies high-risk instruments and recommends that operators prioritise using regulated stablecoins backed by fiat currencies. By contrast, digital assets that make transaction tracing more difficult will require additional scrutiny under operators’ internal compliance policies.
Among the examples cited are Monero, Zcash, and Dash when privacy features are enabled, and Litecoin through its MimbleWimble Extension Blocks (MWEB) functionality. According to the CGA, these assets may undermine fund verification procedures, reduce the effectiveness of blockchain analytics and hinder investigations into potential financial crimes. Meme coins have also come under the regulator’s scrutiny.
Although some of these assets offer high liquidity, many are characterised by extreme price volatility, limited governance and increased susceptibility to market manipulation. As a result, operators will be required to establish objective criteria when deciding whether to accept them on their platforms.
Another important restriction applies to wrapped tokens and assets transferred through blockchain bridges where the origin of the underlying asset cannot be verified.
Cryptocurrency mixers and sanctioned wallets are prohibited
Among the strictest measures introduced by the CGA is the prohibition on accepting digital assets originating from internationally sanctioned mixers or tumblers. These services are designed to obscure blockchain transaction histories, making it more difficult to trace the origin of funds.
Operators will also be prohibited from accepting cryptocurrencies linked to wallet addresses included on sanctions lists or identified by blockchain analytics providers as being associated with fraud, scams or other illicit activities.
The guidance follows broader international efforts to strengthen transparency requirements for virtual assets. In recent years, the Financial Action Task Force (FATF) has expanded the application of the Travel Rule to Virtual Asset Service Providers, requiring the sharing of information on both senders and beneficiaries of digital asset transfers.
Curaçao’s new policy incorporates this recommendation and requires operators to recognise the obligations established under FATF Recommendation 16 whenever transfers involve regulated entities.
Fund segregation will become mandatory
The guidance also introduces detailed requirements for the management of digital wallets used by licensed operators. Personal wallets belonging to employees or ultimate beneficial owners may not be used for licensed gambling operations.
In addition, player funds must remain segregated from corporate funds, reducing the risk of commingling and improving transaction traceability.
Operators may use a combination of hot, warm and cold wallets, provided they maintain auditable records, appropriate access controls and robust security procedures, including multi-factor authentication and multi-signature systems.
Compliance will be phased in until June 2027
The implementation of the new requirements will take place gradually. Some measures took effect immediately, including the prohibition on sanctioned wallets, cryptocurrency mixers and operators acting as exchanges.
By September 2026, all licensed operators must submit a dedicated internal cryptocurrency policy to the CGA outlining their roadmap for complying with the new requirements.
By December 2026, operators will be required to complete risk assessments, due diligence procedures for Virtual Asset Service Providers, controls to verify wallet ownership and employee training.
The full implementation of blockchain analytics tools, wallet segregation, financial reconciliation mechanisms and audit-ready record-keeping must be completed by June 2027.
This article was first published on the Portuguese SiGMA News Page on 26 June 2026.
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