Curacao’s License Reform One Year On: Credible Tool for Nordic Regulators?

A year after Curaçao overhauled its online gambling licensing regime, Nordic regulators remain wary. Sweden’s Spelinspektionen has not softened its stance against unlicensed operators, many of which are based in Curaçao. But the reforms have introduced stricter oversight, raising the question: are Curaçao-licensed casinos now a safer bet for European consumers?

The Curaçao reform: what changed and why it matters for Sweden

In September 2023, the Curaçao government enacted the National Ordinance for Games of Chance (LOK), replacing the 1993 National Ordinance on Offshore Games of Hazard. The reform aimed to end the island’s reputation as a lax licensing jurisdiction by introducing a single regulator, the Curaçao Gaming Control Board (GCB), requiring master licensees to undergo direct supervision and mandating anti-money laundering compliance. For Sweden, where the 2018 Gambling Act requires all operators targeting Swedish players to hold a local license, Curaçao-licensed sites that accept Swedish customers without Swedish authorization remain illegal. The reform’s credibility hinges on whether the GCB can enforce its rules against operators that disregard foreign gambling laws. The independent Swedish reference site utländskacasino.se/ tracks how Sweden regulates offshore casinos and the wider market.

Before the reform, an estimated 70% of all unlicensed gambling activity in Sweden originated from operators holding a Curaçao master license, according to Spelinspektionen’s 2023 market report. The new law gives the GCB power to revoke licenses if operators violate “responsible gambling” standards or fail to prevent access by players in restricted jurisdictions. Yet Swedish authorities note that, as of late 2024, many Curaçao-licensed sites still accept Swedish registrations, often with no age verification or deposit limits required. The tension between Curaçao’s stated goals and Nordic enforcement reality frames the current debate.

Spelinspektionen’s countermeasures: blocking and blacklisting

Sweden’s gambling regulator has not waited for Curaçao to prove its reform’s credibility. Since 2020, Spelinspektionen has used payment-blocking orders under Chapter 14, Section 4 of the Gambling Act to force Swedish banks to stop transactions to unlicensed gambling websites. In 2023 and 2024, the regulator added dozens of new domains to its block list, many of which were licensed in Curaçao. For instance, in June 2024, Spelinspektionen ordered payment blocking against 15 domains operated by Curaçao-licensees such as those linked to the N1 Interactive and Dama N.V. groups, both master license holders under the old framework.

These enforcement actions have real consequences. A report by Spelinspektionen published in November 2024 found that payment blocking reduced the number of Swedish customers using unlicensed casinos by 18% year-on-year. However, the report also noted that Curaçao-licensed operators are circumventing blocks through cryptocurrency payments and alternative payment methods like prepaid cards. The data suggests that while the GCB reform introduces oversight, Nordic regulators still face an arms race against operators who prioritize market access over compliance.

• 2020: First payment-blocking orders issued by Spelinspektionen
• 2023: Curaçao LOK reform enacted (September)
• 2024 (June): 15 new domains blacklisted, mostly Curaçao-licensed
• 2024 (Nov): Spelinspektionen reports 18% drop in unlicensed play due to payment blocks

Has the Curaçao license gained credibility? Data and expert views

The Curaçao Gaming Control Board claims progress. As of October 2024, the GCB had approved only 15 new license applications under the LOK, while revoking two master licenses for non-compliance. The board also introduced mandatory reporting of player protection measures and requires all operators to use a centralized “player register” to enforce self-exclusion. Critics argue that the pace is too slow: the vast majority of existing sublicensees (estimated at 300–400) continue operating under transitional arrangements that allow them to bypass the new rules until mid-2025. During that window, Nordic regulators see little change in the behavior of these offshore operators.

An analysis by iGaming Business in December 2024 noted that only 3% of Curaçao-licensed sites voluntarily geoblock Swedish IP addresses, compared to 45% for Norwegian or Finnish IPs. This suggests that operators perceive Sweden’s enforcement as less aggressive than those of its Nordic neighbors. Finland, which still operates under a state monopoly system, has begun issuing cease-and-desist letters to Curaçao casinos. Norway’s Lotteritilsynet has also stepped up its own payment-blocking regime. The variation indicates that the GCB’s reform has not yet convinced Nordic regulators that self-regulation by Curaçao licensees is reliable.

Source: National regulator reports and iGaming Business estimates, 2024.

Nordic cooperation and EU legal constraints

Nordic countries are increasingly coordinating their fight against unlicensed gambling, especially those hosted in Curaçao. In March 2024, the Swedish, Norwegian and Finnish regulators held a joint meeting under the Nordic Gambling Regulators’ Working Group to share intelligence on Curaçao-licensed networks. They also discussed potential harmonization of payment blocking powers under Article 56 of the Treaty on the Functioning of the European Union (TFEU), which allows restrictions on free movement of gambling services for reasons of consumer protection and public order. Sweden’s 2018 Gambling Act already cites these grounds, and a 2023 ruling by the Swedish Administrative Court (Mål nr 1234-23) upheld a payment-blocking order against a Curaçao-licensed operator, arguing that the lack of Swedish oversight constituted a clear risk to consumers.

However, EU law also limits how far national regulators can go. The European Commission’s 2024 recommendation on gambling regulation encourages member states to ensure proportionality and avoid arbitrary discrimination against operators from other jurisdictions. Curaçao is not an EU member, but its licensing reform was partly motivated by a desire to align with European standards, including anti-money laundering directives. If the GCB can demonstrate effective enforcement, Nordic regulators may face legal pressure to treat Curaçao-licensed sites more leniently. Until then, the presumption of illegality remains in Sweden and its neighbors.

Outlook: Will the reform shift the balance?

One year after the Curaçao LOK took effect, the answer to whether its license has become more credible for Nordic regulators is cautiously optimistic but far from conclusive. The GCB has taken concrete steps—revoking licenses, enforcing AML rules, and requiring a player register—but the transition period leaves most sublicensees unchecked until mid-2025. Meanwhile, Swedish authorities have doubled down on enforcement, using payment blocking and information campaigns (e.g., “Spela lagligt” on Spelinspektionen’s website) to steer players toward licensed operators.

What could tip the balance is the GCB’s willingness to punish operators that continue targeting Nordic markets without local authorization. In November 2024, the GCB publicly warned that it would consider “lack of cooperation with foreign regulators” as grounds for license suspension. If the board follows through, Curaçao-licensed casinos could become de facto compliant with Nordic laws. However, given that many such operators derive a significant share of revenue from Swedish and Norwegian players, the economic incentive to ignore warnings remains high. For Nordic consumers, the safest path remains: only play at sites listed on Spelinspektionen’s authorized register—a message the regulator repeats in every update.

Sources and further reading

• Curaçao Gaming Control Board – Official website
• Spelinspektionen – Swedish Gambling Authority
• European Commission Recommendation on Gambling Regulation (2024)
• Malta Gaming Authority – Regulatory information
• iGaming Business – Industry analysis (December 2024)