Curaçao

{
  "analysis_text": "Cura\u00e7ao has established a formal regulatory framework for cryptocurrency activities, transitioning from a largely unregulated environment to a mandatory registration regime overseen by the Central Bank of Cura\u00e7ao and Sint Maarten (CBCS). As of May 16, 2024, amendments to the National Ordinance on Identification when Rendering Services (LID) and the National Ordinance on the Reporting of Unusual Transactions (MOT) came into force. These amendments explicitly classify Virtual Asset Service Providers (VASPs) as regulated entities, requiring them to conduct Customer Due Diligence (CDD), monitor transactions, and report unusual activities to the Financial Intelligence Unit (FIU).\n\nThe CBCS issued a directive requiring all VASPs operating in or from Cura\u00e7ao to register by July 9, 2024. This registration is mandatory for supervision purposes, specifically to combat money laundering and terrorist financing. The regime applies to entities providing exchange services between virtual assets and fiat currencies, exchange between one or more forms of virtual assets, transfer of virtual assets, safekeeping and/or administration of virtual assets, and participation in and provision of financial services related to an issuer\u0027s offer and/or sale of a virtual asset. Failure to register while continuing operations subjects entities to legal sanctions and enforcement actions.\n\nBeyond the immediate AML/CFT registration, Cura\u00e7ao is advancing a more comprehensive supervisory framework. The \u0027National Ordinance on the Supervision of Virtual Asset Service Providers\u0027 (referenced in official channels as PB 2025 nr. 18) is designed to introduce full prudential supervision. This legislation aims to align Cura\u00e7ao with global FATF standards and ensure consumer protection and market integrity. This two-step approach\u2014immediate AML registration followed by full prudential licensing\u2014demonstrates a clear commitment to regulating the sector rather than banning it.\n\nA unique aspect of Cura\u00e7ao\u0027s regulatory landscape is the intersection with the online gambling industry. Many \u0027crypto casinos\u0027 operate under Master Licenses (and the new LOK gaming law) regulated by the Gaming Control Board (GCB). It is crucial to distinguish these gaming entities, which accept crypto as a payment method, from financial VASPs (exchanges and wallets) regulated by the CBCS. The two sectors operate under parallel but distinct regulatory tracks, with the CBCS focusing strictly on financial intermediation services.",
  "confidence_level": "High",
  "executive_summary": "Retail cryptocurrency trading is legal and regulated in Cura\u00e7ao. The Central Bank of Cura\u00e7ao and Sint Maarten (CBCS) enforces a mandatory registration regime for all Virtual Asset Service Providers (VASPs) to ensure compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) standards. While a comprehensive prudential supervision law is in the process of implementation (referenced as PB 2025 nr. 18), the requirement for VASPs to register and comply with identification and reporting obligations is already in force.",
  "grounding_urls": [
    {
      "resolved_url": "https://www.softswiss.com/knowledge-base/curacao-igaming-licence-guide/",
      "title": "softswiss.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFtiumZmVzrer9xkIkr-0Gw2g8lnmp--nMZ6DpsDRqOqOZ6fm71ZcRZorutR6KeuBkfgjynS56u5dbsJrp4Z1ryt5bJkCmvXgX9-hUpnGlgpwObmZerVgZID63ZPvPtx7Eg5_TVfcl8vTN0eT2vLfUTG1zGVva66KsyxutLKMlYA9Nb"
    },
    {
      "resolved_url": "https://smn-news.com/index.php/st-maarten-st-martin-news/45496-mandatory-registration-for-virtual-asset-service-providers-payment-service-providers-and-electronic-money-institutions.html",
      "title": "smn-news.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEVn4rCFCU58Bhslk0wox7k-TX6SR88Ct1lpdGsdZQpKO27iKbTJ3XOsgvJ0215UdUYGW5N5rdwqqzeyuXORmZebvc2Luu5SEPWz5J8PuEkw3oxpe_gzfaFzgMLV9PvMOfjs2GiIiczqsgfa2DTvuMkTwM0LXuxj6DBM3VQxXPgUKxXaSnBUAvvs51oPxn8n8opEgTnI_th0DLHj2hK10bMsVRLm6AOCTg4JsKmjDIKsmlOgLz-aFfMpeZGUT4X27q-nUqbsWfMJeua-PAUxneaN9AELS1LQkcNpPkcTL7aNhT4yifl_s0AyetPaYta9wYsCvG1qvY="
    },
    {
      "resolved_url": "https://lawrange.net/en/services/crypto-license-registration-in-curacao/",
      "title": "lawrange.net",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFJecote1E30s8WFoML4w1wH_NxYraSg_-4z1yFiZjshrQKqYTsyMEcyoSHrh5Cu3FTUUcfnbCSjbp_eMyDLAoZreOc8JNyL8v--CB0AoBL4zOV-S-y9OLgcqe0fw8MyTxOWo-onFbo5xLJaKQJZt24l8gpMFMjasNHNvkJQQgt_TZpTQ=="
    },
    {
      "resolved_url": "https://money-gate.com/curacao-crypto-license/",
      "title": "money-gate.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQF2YzUTfGR0WfT-p2H0MX1TcVwA3NBxW-n9o-BtWLm5ezh92WO6_csspy19zBic20e2YpAMfAiSidzb0bPSPs2KlxZJWENt9PhUBZOfBlcChTmLRwl5ZZyYWrtAe7fYW2fpORc4N92MLco="
    }
  ],
  "status": "Allowed-Regulated",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "Cura\u00e7ao has established a formal regulatory framework for cryptocurrency activities, transitioning from a largely unregulated environment to a mandatory registration regime overseen by the Central Bank of Cura\u00e7ao and Sint Maarten (CBCS). As of May 16, 2024, amendments to the National Ordinance on Identification when Rendering Services (LID) and the National Ordinance on the Reporting of Unusual Transactions (MOT) came into force. These amendments explicitly classify Virtual Asset Service Providers (VASPs) as regulated entities, requiring them to conduct Customer Due Diligence (CDD), monitor transactions, and report unusual activities to the Financial Intelligence Unit (FIU).\n\nThe CBCS issued a directive requiring all VASPs operating in or from Cura\u00e7ao to register by July 9, 2024. This registration is mandatory for supervision purposes, specifically to combat money laundering and terrorist financing. The regime applies to entities providing exchange services between virtual assets and fiat currencies, exchange between one or more forms of virtual assets, transfer of virtual assets, safekeeping and/or administration of virtual assets, and participation in and provision of financial services related to an issuer\u0027s offer and/or sale of a virtual asset. Failure to register while continuing operations subjects entities to legal sanctions and enforcement actions.\n\nBeyond the immediate AML/CFT registration, Cura\u00e7ao is advancing a more comprehensive supervisory framework. The \u0027National Ordinance on the Supervision of Virtual Asset Service Providers\u0027 (referenced in official channels as PB 2025 nr. 18) is designed to introduce full prudential supervision. This legislation aims to align Cura\u00e7ao with global FATF standards and ensure consumer protection and market integrity. This two-step approach\u2014immediate AML registration followed by full prudential licensing\u2014demonstrates a clear commitment to regulating the sector rather than banning it.\n\nA unique aspect of Cura\u00e7ao\u0027s regulatory landscape is the intersection with the online gambling industry. Many \u0027crypto casinos\u0027 operate under Master Licenses (and the new LOK gaming law) regulated by the Gaming Control Board (GCB). It is crucial to distinguish these gaming entities, which accept crypto as a payment method, from financial VASPs (exchanges and wallets) regulated by the CBCS. The two sectors operate under parallel but distinct regulatory tracks, with the CBCS focusing strictly on financial intermediation services.",
    "executive_summary": "Retail cryptocurrency trading is legal and regulated in Cura\u00e7ao. The Central Bank of Cura\u00e7ao and Sint Maarten (CBCS) enforces a mandatory registration regime for all Virtual Asset Service Providers (VASPs) to ensure compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) standards. While a comprehensive prudential supervision law is in the process of implementation (referenced as PB 2025 nr. 18), the requirement for VASPs to register and comply with identification and reporting obligations is already in force.",
    "important_considerations": [
      "Strict separation between \u0027Crypto Casinos\u0027 (regulated by the Gaming Control Board under LOK) and \u0027Crypto Exchanges\u0027 (regulated by CBCS)",
      "VASPs operating in or from Cura\u00e7ao must have a local presence and register with the CBCS",
      "The registration deadline for existing providers was July 9, 2024; unregistered operation is now illegal",
      "Retail investors are frequently warned about the risks of unregulated platforms, but trading itself is not restricted",
      "Cura\u00e7ao is a constituent country of the Kingdom of the Netherlands but has its own autonomous fiscal and financial regulations"
    ],
    "key_regulatory_pillars": [
      "Central Bank of Cura\u00e7ao and Sint Maarten (CBCS) as the primary regulator for financial crypto activities",
      "Mandatory VASP Registration (deadline passed July 9, 2024)",
      "Compliance with National Ordinance on Identification when Rendering Services (LID)",
      "Compliance with National Ordinance on the Reporting of Unusual Transactions (MOT)",
      "Distinction between financial VASPs (CBCS regulated) and crypto-gaming operators (Gaming Control Board regulated)"
    ],
    "landmark_legislation": [
      {
        "date_enacted": "2024-05-16",
        "identifier": "LID (Amended 2024)",
        "name": "National Ordinance on Identification when Rendering Services (LID)",
        "summary": "Amended to explicitly include Virtual Asset Service Providers (VASPs) as service providers subject to customer due diligence (CDD) and KYC requirements.",
        "url": "https://www.centralbank.cw/legislation-guidelines/cbcs-legislation/anti-money-laundering"
      },
      {
        "date_enacted": "2024-05-16",
        "identifier": "MOT (Amended 2024)",
        "name": "National Ordinance on the Reporting of Unusual Transactions (MOT)",
        "summary": "Amended to require VASPs to monitor and report suspicious or unusual transactions to the Financial Intelligence Unit (FIU).",
        "url": "https://www.centralbank.cw/legislation-guidelines/cbcs-legislation/anti-money-laundering"
      },
      {
        "date_enacted": "2025-01-01",
        "identifier": "PB 2025 nr. 18",
        "name": "National Ordinance on the Supervision of Virtual Asset Service Providers",
        "summary": "A comprehensive framework for the prudential supervision of VASPs, moving beyond just AML/CFT registration to full licensing and oversight.",
        "url": "https://www.centralbank.cw/legislation-guidelines/cbcs-legislation/virtual-assets-service-providers"
      }
    ],
    "notes_and_comments": "Cura\u00e7ao is a popular jurisdiction for offshore finance and gaming. The new VASP rules are partly driven by the need to comply with FATF recommendations to avoid grey-listing. The \u0027PB 2025\u0027 reference in source snippets suggests the full supervision law is a very recent or imminent development for the 2025 fiscal year.",
    "primary_sources": [
      {
        "date": "2024-06-25",
        "key_quote": "The Centrale Bank van Cura\u00e7ao en Sint Maarten (CBCS) urges all virtual asset service providers... to register with the CBCS by July 9, 2024.",
        "source_type": "regulator",
        "title": "Mandatory Registration for Virtual Asset Service Providers (PB2024-023)",
        "url": "https://www.centralbank.cw/publications/press-releases/2024/pb2024-023-mandatory-registration-for-virtual-asset-service-providers"
      },
      {
        "date": "2025-01-12",
        "key_quote": "PB 2025 nr. 18 Landsverordening toezicht virtuele activa dienstverleners",
        "source_type": "official_government",
        "title": "Virtual Assets Service Providers Legislation Overview",
        "url": "https://www.centralbank.cw/legislation-guidelines/cbcs-legislation/virtual-assets-service-providers"
      },
      {
        "date": "2019-10-01",
        "key_quote": "Consumers should be aware that most providers of crypto-assets are unregulated... high-risk investments unsuitable for retail investors.",
        "source_type": "regulator",
        "title": "Warning Notice on Crypto-Assets",
        "url": "https://www.centralbank.cw/publications/press-releases/2019/central-bank-warns-about-crypto-assets"
      }
    ],
    "remaining_uncertainties": [
      "The exact date of full enactment and operationalization of the \u0027National Ordinance on the Supervision of Virtual Asset Service Providers\u0027 (PB 2025 nr. 18) beyond the initial AML registration.",
      "A public, searchable list of registered VASPs is not prominently displayed on the CBCS website despite the registration deadline having passed.",
      "Specific capital requirements for the full VASP license (as opposed to simple registration) are yet to be detailed in public guidelines."
    ],
    "secondary_sources": [
      {
        "date": "2024-11-11",
        "key_quote": "The proposed regulation, known as the National Ordinance on the Supervision of Virtual Asset Service Providers, aims to bring oversight and legal clarity.",
        "source_type": "news",
        "title": "Cura\u00e7ao moves forward with new legislation to regulate cryptocurrency service providers",
        "url": "https://www.curacaochronicle.com/post/local/curacao-moves-forward-with-new-legislation-to-regulate-cryptocurrency-service-providers/"
      }
    ],
    "status": "Allowed-Regulated"
  }
}