title: Curaçao Payments Regulation Monitor | World Payments Monitor canonical: https://payments.gi/jurisdictions/curacao/ date_modified: 2026-10-21 publisher: Asymmetric Intelligence # Curaçao CW schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-21 · 14 modules · 61 sourced findings · 125 sources in the cumulative register 14 Modules baseline.modules[] 61 Findings modules[].findings[] 24 Tier-1 sources run_metadata.t1_source_count Confidence mix (sums to 14 rendered modules; click to filter) ## Jurisdiction brief ###### Latest update · 11 October 2026 #### Lead Signal Curacao's payment-sector licensing gap moved from a standing industry grievance to an explicit legislative appeal this cycle. The Curacao FinTech Association wrote directly to the President of Parliament warning that the absence of a dedicated electronic-money-institution or payment-institution licensing mechanism under current law creates daily operational obstacles, limiting banking access and investment capital for payment firms incorporated in Curacao. The structural condition behind this appeal is that the Central Bank of Curacao and Sint Maarten currently operates a registration-only regime for virtual-asset service providers, payment service providers, and electronic-money institutions, rather than a full licensing framework with attendant prudential and conduct obligations. Draft national ordinances addressing payment services and VASP/FMI supervision remain before Parliament's central committee, with an expected adoption horizon around 2027. #### Other Developments **CBCS tightens its supervisory posture without new primary legislation.** The Central Bank of Curacao and Sint Maarten restructured its supervisory framework effective 1 January 2026, moving toward what has been described as a tougher enforcement approach. This shift operates within the existing registration-based perimeter rather than replacing it; CBCS is signalling intent to apply its current supervisory toolkit more assertively even while the underlying licensing gap that industry has flagged remains unresolved. **CGA crypto-policy guideline reaches an interim compliance checkpoint.** The Curacao Gaming Authority's crypto-handling guideline for B2C gambling licensees reached its first interim checkpoint in September 2026, part of a staged compliance timetable running through a December 2026 milestone to full technical compliance due by June 2027. This guideline operates on a track distinct from the CBCS's own VASP registration regime: it is a gambling-regulator instrument governing how licensees in that sector may handle digital assets, rather than a central-bank payments-licensing instrument, though both bear on the same underlying digital-asset activity in the jurisdiction. #### Cross-Monitor Connections The payment-institution licensing gap and the CGA's crypto-handling guideline together describe a jurisdiction where digital-asset and payment activity is regulated across two separate tracks of differing maturity: a central-bank registration-only regime for payment and e-money firms generally, and a more detailed phased compliance timetable specifically for gambling licensees handling crypto. Industry's own characterisation that the licensing gap constrains investment access is a commercial-intelligence signal worth noting, though no verified capital-flow statistic or discrete transaction was identified this cycle to quantify that constraint. #### Outlook The draft national ordinances before Parliament's central committee are the structural marker to watch, with an expected 2027 horizon. Their adoption would move Curacao from the current CBCS registration-only perimeter to a formal licensing regime for payment institutions, EMIs, and FMI managers. Nearer term, the CGA crypto-policy guideline's remaining milestones, in December 2026 and June 2027, are the next dated checkpoints for its phased rollout, and CBCS's restructured supervisory approach, effective since 1 January 2026, will be tested against how assertively it is in fact applied under the current registration-only framework. _1 earlier update not shown here._ ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Lead Signal Curacao's fourth-round CFATF mutual evaluation report was adopted at the CFATF plenary on May 29, 2025, placing the jurisdiction under CFATF's enhanced follow-up process and requiring a national action plan to demonstrate progress against identified deficiencies. This evaluation outcome represents a live grey-listing risk with direct implications for correspondent banking access and cross-border payment flows across the payments sector. The stakes are amplified by an already-chronic vulnerability: Curacao's banking system lost seven correspondent banking relationships between 2017 and 2018, part of a broader regional de-risking trend, and the Central Bank van Curacao en Sint Maarten's 2026-2028 Research Agenda now names correspondent banking de-risking explicitly as a financial-stability risk for small open economies, warning that de-risking can disrupt trade, remittances and cross-border payments even where local banks remain solvent. A Bank for International Settlements review, titled "Correspondent bank relations in Curacao - no quick fixes," underscores the structural difficulty of restoring lost relationships once severed. Together, the enhanced-follow-up status and the entrenched correspondent-access constraint form the defining risk axis for Curacao's payments sector this cycle: any underperformance against the national action plan could compound an already fragile USD-corridor position. #### Other Developments The most significant completed payments-infrastructure milestone of the baseline period is the introduction of the Caribbean guilder (XCG) as legal tender for Curacao and Sint Maarten on March 31, 2025, replacing the Netherlands Antillean guilder, which ceased legal tender status on July 1, 2025 after a co-circulation period, at a fixed peg of USD 1 = 1.79 XCG. In parallel, CBCS and Worldline are developing a second phase of the region's Instant Payments programme, aiming to extend the interbank rollout -- live since January 15, 2022 across Curacao, Sint Maarten and Bonaire with ten-second, 24/7/365, ISO 20022-compliant, dual-currency settlement -- into person-to-person, person-to-business and person-to-government functionality, with CBCS also signalling planned future linkage to Aruba and Netherlands instant-payment ecosystems. Curacao's payments licensing architecture remains structurally incomplete for non-bank payment service providers and e-money issuers. Banks and credit institutions require a CBCS license under the 1994 National Ordinance on Supervision of Banking and Credit Institutions, and money transfer companies require a CBCS license under the 2014 ordinance plus a Foreign Exchange Regulation authorisation -- but since July 2024, PSPs and EMIs operating from Curacao have needed only to register, not obtain a license, with no dedicated EMI/PI licensing statute yet in force pending a draft National Ordinance on the Supervision of Payment Service Providers. CBCS itself issued an official warning in April 2025 confirming that digital payment service providers currently operate without full regulatory oversight, leaving consumers without legal protection, while the Curacao FinTech Association has formally petitioned Parliament's President to fast-track the pending PSP legislation. Sint Maarten's equivalent MTC/PSP framework remains further behind still, with CBCS not currently accepting new Sint Maarten MTC applications. Conduct-side obligations are also shifting. New Curacao Gaming Authority rules taking effect October 8, 2026 will require licensees to evidence proactive, rather than passive, gambler agreement to terms and conditions and to publish a complete list of approved deposit and withdrawal payment methods together with normal processing times -- obligations not yet in force as of this baseline. The same CGA policy package steers licensees toward fiat-backed stablecoins for licensee transactions, treats any crypto transaction as high money-laundering risk, bars licensees from acting as an exchange or converting between cryptocurrencies and fiat, and mandates FATF Travel Rule compliance. Separately, CBCS's own market-conduct rulebook -- including a prospective prohibition on linked transactions -- remains only a stated intention, with no codified rule or forward date yet available. Litigation and enforcement activity has been active across the gaming-payments interface. The Dutch Supreme Court in March 2025 overturned a Joint Court of Justice ruling that had allowed First Curacao International Bank to withhold 15% of customer balances, finding the reasonableness of the withheld costs inadequately justified, and remanded the matter to the Willemstad court -- an echo of the bank's 2006 license revocation for VAT fraud that CBCS has administered the wind-down of ever since. Separately, the Joint Court of Justice declared Blockdance/Small House, operator of BC.Game, bankrupt on November 12, 2024 for breaching licensing conditions including failure to maintain a reputable local bank account, prompting the Gaming Control Board to issue a letter of intent to revoke the operator's license and triggering ongoing player-claimant proceedings and political corruption allegations against the gaming regulator. Scheme-level risk classification continues to shape acquiring economics: Visa's Global Acquirer Risk Standards and Mastercard's High-Risk Merchant Monitoring continue to classify Curacao-licensed gaming merchants as high-risk, with European acquiring banks remaining cautious even after the jurisdiction's LOK licensing overhaul. That overhaul has, however, extended formal oversight further into the payments chain: a new LOK B2B Supplier License now covers software developers, game providers, payment processors and other B2B infrastructure companies serving iGaming, bringing payment processors that previously operated without formal CGA authorisation within a compliance pathway for the first time. On the operational-resilience side, CBCS is preparing regional banks for Swift's structured/hybrid address data mandate, which takes effect November 14, 2026 and after which unstructured-address payments risk rejection or delay; CBCS hosted a Swift Payments Experience Roadshow toward that end, sitting alongside its standing IT, Cyber and Operational Risk supervisory pillar. #### Cross-Monitor Connections Two threads in this cycle's Curacao findings carry illicit-finance significance that sits outside WPM's remit and is more properly analysed by the Financial Integrity Monitor. The Curacao Gaming Authority's steer toward fiat-backed stablecoins, its high-money-laundering-risk classification of crypto transactions generally, and its FATF Travel Rule compliance mandate are captured here only for their stablecoin-as-payment-instrument dimension; the underlying illicit-finance policy rationale is a FIM matter. Likewise, Curacao's CFATF enhanced-follow-up status, and the consolidated 2024 AML/CFT statute integrating virtual asset service providers into client-identification and unusual-transaction-reporting obligations since May 16, 2024, are carried here as correspondent-banking and payments-access risk factors rather than as original illicit-finance analysis, which remains with FIM via the Sentinel feed. #### Outlook Two forward-dated regulatory events anchor the near-term horizon: the CGA's proactive-consent and payment-method disclosure rules become enforceable October 8, 2026, and Swift's structured-address messaging mandate takes effect November 14, 2026, the latter carrying direct rejection/delay risk for unprepared correspondent flows. Beyond those dates, the defining open question for Curacao's payments sector is whether the draft PSP Ordinance -- the subject of sustained CFA advocacy -- is enacted, closing the registration-only gap for non-bank PSPs and EMIs, and whether Curacao's national action plan under CFATF enhanced follow-up satisfies reviewers before its next assessment point, given the direct bearing either outcome would have on correspondent banking access and the jurisdiction's broader payments-infrastructure trajectory. trust tier: ai_unverified ###### Latest update · 11 August 2026 #### Regulatory Status Curacao's payments regulatory environment moved on several fronts this cycle. The CBCS formalised VASP, PSP and EMI as a distinct supervised licensing category, sitting alongside its existing money-transfer-company licensing gate. The Caribbean guilder became legal tender in March 2025, and CBCS has continued instant-payment and ISO 20022 infrastructure upgrades since. A Deposit Guarantee Scheme entered into force in July 2025, protecting bank, savings-fund and credit-union deposits up to specified XCG caps, with a Sint Maarten equivalent expected during 2026. Set against these positive infrastructure developments, CBCS has itself flagged persistent AML/CFT weaknesses as a driver of correspondent-banking de-risking risk, even after completing a 2025 risk-based supervisory overhaul covering roughly 400 institutions. #### Outlook Watch for the primary legislative basis behind the VASP/PSP/EMI licensing consolidation, the introduction of Sint Maarten's deposit guarantee scheme during 2026, and whether CBCS's acknowledged AML/CFT-driven de-risking risk shows signs of easing following its supervisory overhaul. ###### Standing brief · as of 8 July 2026 _Written before the update above. Where they differ, the update is the more recent position._ #### Regulatory Status Curacao enters this baseline cycle as a jurisdiction with an elevated, tightening risk profile across its payments-regulatory architecture. Licensing is bifurcated: banks and money transfer companies operate under full statutory licensing via CBCS (1994 and 2014 ordinances respectively), while payment service providers and e-money institutions have operated on a registration-only basis since July 2024, with no dedicated EMI/PI licensing statute in force and CBCS's own April 2025 warning confirming the resulting consumer-protection gap. Virtual asset service providers sit under a separate VASP Ordinance, integrated into the jurisdiction's core AML/CFT regime (LID/MOT) since May 16, 2024. Conduct and safeguarding obligations run through a 2017 complaints-handling regulation and a Deposit Guarantee Fund (50,000 XCG per depositor per bank, primary statute unverified), with new CGA payment-disclosure and consent rules scheduled for October 8, 2026. The jurisdiction's most consequential financial-crime finding is its May 2025 CFATF mutual evaluation outcome, which placed Curacao under enhanced follow-up -- a live grey-listing risk directly linked to its already-fragile correspondent-banking position, itself compounded by the loss of seven correspondent relationships in 2017-2018 and flagged as a named financial-stability risk in CBCS's own 2026-2028 Research Agenda. Against this backdrop, the completed March 2025 Caribbean guilder currency changeover and the live Instant Payments regional corridor (with Phase 2 in development) stand out as genuine infrastructure-modernisation achievements, while Visa/Mastercard continue to classify Curacao-licensed gaming merchants as high-risk notwithstanding the LOK licensing overhaul, and litigation involving FCIB and the BC.Game/Blockdance bankruptcy remains active. #### Outlook Two dated regulatory events fall within the coming months: CGA payment-disclosure and consent rules become enforceable October 8, 2026, and Swift's structured-address messaging mandate takes effect November 14, 2026. Beyond those, Curacao's trajectory turns on two open, undated questions -- whether the draft PSP Ordinance is enacted to close the registration-only licensing gap, and whether the jurisdiction's national action plan satisfies CFATF reviewers before its next assessment point, given the direct bearing either outcome carries for correspondent banking access and the broader payments-infrastructure trajectory of this structurally under-indexed Dutch Caribbean jurisdiction. 14 of 14 modules Signal Density Selections OR within a group, AND across groups. Press / to search. ### W1a Licensing, Authorisation & Market Access moved Confirmed confirmed 2026-07-04 Curacao's payments licensing regime is anchored in the Centrale Bank van Curacao en Sint Maarten (CBCS) as sole prudential/AML regulator. Banks are licensed under the 1994 National Ordinance on Supervision of Banking and Credit Institutions; money transfer companies (MTCs) require a full license under the 2014 National Ordinance on Supervision of Money Transfer Companies (effective March 2015). Critically, there is NO dedicated EMI/PI licensing statute yet: PSPs, EMIs and VASPs currently operate under a registration-only regime pending the draft National Ordinance on the Supervision of Payment Service Providers, which the Curacao FinTech Association is actively lobbying Parliament to pass. Movement — CHANGED FinTech Association advocacy + CBCS supervisory restructuring_Two new developments identified this cycle for W1a._ Standing sub-brief · as of 8 July 2026 472 words · last cycle 2026-10-11 #### Licensing, Authorisation & Market Access Curacao's payments licensing regime rests on CBCS as the sole prudential and conduct supervisor across the banking, money-transfer and payment-service layers, but the level of oversight varies sharply by entity type. Banks and credit institutions require a CBCS license or dispensation under Article 45(1) of the National Ordinance on Supervision of Banking and Credit Institutions 1994, with unlicensed fund-raising or credit-granting to the public prohibited outright. Money transfer companies sit under a dedicated statute: the National Ordinance on Supervision of Money Transfer Companies 2014, effective March 1, 2015, requires a CBCS license plus a separate authorisation under Article 10(1) of the Foreign Exchange Regulation 2010. Sint Maarten's equivalent MTC framework, however, remains pending, and CBCS is not currently accepting new Sint Maarten MTC applications -- a coverage gap that leaves the island's money-transfer sector in a holding pattern relative to Curacao's. The structural gap sits one layer up the value chain. Since July 2024, payment service providers and e-money institutions operating from Curacao have been required only to register, not to obtain a license, with CBCS; no dedicated EMI/PI licensing statute exists, and the matter awaits a draft National Ordinance on the Supervision of Payment Service Providers that has not yet been enacted. CBCS itself confirmed the consequence of this gap in an official warning issued in April 2025: digital payment service providers currently operate without full regulatory oversight, and consumers are left without legal protection as a result. The Curacao FinTech Association has responded with direct legislative advocacy, formally petitioning Parliament's President to fast-track the pending PSP Ordinance -- a market-development signal that reflects industry frustration with the registration-only status quo as much as it does regulatory urgency. This bifurcation is a defining feature of the jurisdiction's market-access architecture: bank-PSPs (deposit-taking credit institutions) and MTCs operate under full statutory licensing with defined prudential and foreign-exchange-authorisation requirements, while non-bank PI/EMI entities -- the segment most associated with newer fintech and payments innovation -- operate under the lighter registration-only regime pending the draft PSP Ordinance. This asymmetry has direct competitive consequences: non-bank entrants face materially different regulatory certainty and consumer-protection backstops than their bank-supervised counterparts, even where they compete for similar payment-services business. #### Outlook The pending draft National Ordinance on the Supervision of Payment Service Providers is the single most consequential forward-looking item in this module: its enactment would close the registration-only gap, but no confirmed date for enactment or even formal introduction has been identified this cycle. Continued CFA lobbying, and the reputational pressure created by CBCS's own April 2025 warning, suggest the political conditions for progress exist, but the absence of a scheduled legislative timetable means this remains a watch item rather than a dated horizon entry. Sint Maarten's parallel MTC/PSP framework lag is a secondary item to track, given its bearing on cross-island payment-services parity. Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access The Curacao FinTech Association pressed Parliament this cycle to fast-track a Payment Services Law, writing to the President of Parliament to warn that the absence of a dedicated electronic-money-institution or payment-institution licensing mechanism under current law is a daily operational obstacle, limiting banking access and investment capital for Curacao-based payment firms. The structural reality behind this appeal is that the Central Bank of Curacao and Sint Maarten's current framework requires mandatory registration, not licensing, for virtual-asset service providers, payment service providers, and electronic-money institutions. Registration and licensing are materially different market-access gateways: a licensing regime typically carries prudential capital requirements, fit-and-proper review, and ongoing supervisory obligations that a registration-only regime does not impose with the same force, and industry's letter frames this gap as a live constraint on access to banking relationships and investment capital for firms operating under the lighter registration standard. Alongside this, the Central Bank of Curacao and Sint Maarten restructured its supervisory framework effective 1 January 2026, adopting what has been described as a tougher enforcement approach. This is a conduct-of-supervision change operating within the existing registration-only perimeter rather than a change to the perimeter itself; it signals CBCS applying its current toolkit more assertively even as the underlying market-access question, whether payment institutions and EMIs should be brought into a full licensing regime, remains before Parliament. Draft national ordinances addressing payment services and VASP/FMI supervision are before Parliament's central committee, with an expected horizon around 2027 for adoption. Until enacted, market access for payment institutions and EMIs in Curacao continues to run through CBCS registration rather than licensing. #### Outlook The draft national ordinances before Parliament's central committee are the structural development to watch, with an expected 2027 adoption horizon. Their passage would convert the current registration-only market-access gateway into a formal CBCS licensing regime for payment institutions, EMIs, and FMI managers. Nearer term, watch for evidence of how CBCS's restructured, tougher supervisory approach, effective since 1 January 2026, is applied in practice against registered entities under the existing framework. **1 earlier distinct update(s)** Periodic update · new data 2026-08-11 #### Licensing, Authorisation & Market Access The Centrale Bank van Curacao en Sint Maarten (CBCS) has formalised virtual-asset service providers, payment service providers and e-money institutions as a distinct supervised licensing and registration category, confirmed via the CBCS's own application-forms register for supervised institutions. This sits alongside CBCS's pre-existing licensing gate for money-transfer companies, which require CBCS permission or a licence to operate under the central bank's supervision-general guidance. Together these confirm that Curacao's nonbank payments perimeter is now explicitly demarcated within the CBCS supervisory umbrella, rather than left as an informal extension of banking supervision. The bank-versus-nonbank distinction is explicit in the underlying claims: the VASP/PSP/EMI category is expressly nonbank, sitting apart from CBCS's credit-institution supervision, while the money-transfer-company licensing gate has historically applied to nonbank remittance businesses. This distinction matters for market entrants, since prudential expectations, capital requirements and ongoing supervisory intensity plausibly differ between the bank and nonbank tracks even where both ultimately answer to the same central bank. A second, cross-sector signal this cycle comes from the gambling regulator rather than CBCS itself: the Curacao Gaming Authority's June 2026 crypto policy guideline bars gambling licensees from acting as an exchange, payment service provider or virtual-asset service provider outside gambling transactions, explicitly delineating CGA-licensed gaming-sector crypto handling from CBCS-licensed PSP/VASP activity. This is boundary-setting between two regulators rather than a change to either regulator's own licensing criteria, but it is directly relevant to market-access analysis: an entity seeking to operate as a PSP or VASP in Curacao, as distinct from a gambling operator merely accepting crypto for wagering, sits under the CBCS licensing category rather than under a CGA gaming licence. No primary CBCS legislative text, such as a national ordinance or decree formalising the VASP/PSP/EMI licensing consolidation, was retrieved this cycle; the confirming evidence is the CBCS forms-register webpage itself rather than the underlying statutory instrument. This should be treated as a sourcing gap rather than a substantive uncertainty about whether the category exists, since the forms register is itself a CBCS primary source, but the precise legal basis and conditions attached to the category remain to be located. #### Outlook The clearest near-term test of this licensing formalisation is uptake: whether the distinct VASP/PSP/EMI category attracts new licensed entrants distinct from Curacao's existing gaming-sector crypto footprint, or whether it principally functions to formalise supervision of institutions already operating. Locating the primary legislative or regulatory instrument behind the category would materially improve confidence in the specific conditions, capital requirements and ongoing obligations attached to it. **Sources and findings (6)** 1. T1 [https://www.centralbank.cw/faq/supervision-general](https://www.centralbank.cw/faq/supervision-general) retrieved 2026-07-04 2. T1 [https://www.centralbank.cw/faq/supervision-general](https://www.centralbank.cw/faq/supervision-general) retrieved 2026-07-04 3. T3 [https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law](https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law) retrieved 2026-07-04 4. T1 [https://www.curacaochronicle.com/post/local/curacaos-central-bank-issues-warning-over-unregulated-digital-payment-services/](https://www.curacaochronicle.com/post/local/curacaos-central-bank-issues-warning-over-unregulated-digital-payment-services/) retrieved 2026-07-04 5. T4 [https://www.zitadelleag.com/news/zitadelle-ag-your-trusted-partner-for-psp-emi-mtc-licensing-in-cura%C3%A7ao](https://www.zitadelleag.com/news/zitadelle-ag-your-trusted-partner-for-psp-emi-mtc-licensing-in-cura%C3%A7ao) retrieved 2026-07-04 6. T1 [https://www.centralbank.cw/legislation-guidelines/foreign-exchange-regulations](https://www.centralbank.cw/legislation-guidelines/foreign-exchange-regulations) retrieved 2026-07-04 ### W1b Conduct, Safeguarding & Promotions 1 gap Probable confirmed 2026-07-04 CBCS conduct supervision rests on a 2017 complaints-handling Regulation applicable to all supervised institutions, backstopped by a bank deposit guarantee scheme (up to 50,000 XCG per depositor per bank) and a running series of public warning notices. A dedicated market-conduct rulebook (including prohibition of linked transactions) remains outstanding, and gaming-specific consumer-facing conduct rules (T&Cs, payment-method disclosure) are being tightened under the new LOK regime. Open gap — wpm-int-4 Formal Deposit Guarantee Fund statute text was not directly retrieved from a CBCS primary source; corroborated only via a secondary banking-directory site (T3)._Reliance on T3/T4 secondary sources for a customer-fund-protection mechanism warrants primary-source verification next cycle._ Horizon · 2026-10-08 (±quarter) CGA proactive-consent and payment-method disclosure rules in force_adopted · T_ Horizon · 2026-10-08 (±quarter) CGA proactive-consent and payment-method disclosure rules take effect_in_force_pending · TT3_ Standing sub-brief · as of 8 July 2026 410 words · last cycle 2026-08-05 #### Conduct, Safeguarding & Financial Promotions Curacao's conduct-of-business framework for CBCS-supervised institutions centres on the Regulation on complaints handling, effective May 5, 2017 following a six-month transition period, which requires supervised institutions to indicate a complaint-handling timeframe within two weeks of receipt. CBCS treats the resulting complaints data as a supervisory signal rather than as a mediation or adjudication function -- it does not itself resolve individual disputes. On the safeguarding side, major Curacao banks participate in a Deposit Guarantee Fund covering current and deposit accounts up to 50,000 XCG per depositor per bank, with business accounts and investment products generally excluded; however, the primary CBCS statutory text establishing the Fund has not been directly retrieved this cycle, and the finding is corroborated only via a secondary banking-directory source, a gap flagged for verification in a subsequent cycle. Beyond these standing mechanisms, CBCS has stated it will introduce market-conduct rules and regulations for supervised financial institutions in the near future, including a prohibition of linked transactions -- but this remains uncodified in Curacao or Sint Maarten law, with no forward date available from the source, and is therefore tracked here as a stated intention rather than added to the regulatory horizon. The live conduct-tightening item this cycle sits in the gaming-adjacent payments space rather than in mainstream banking: new Curacao Gaming Authority rules, scheduled to take effect October 8, 2026, will require licensees to evidence proactive -- not merely passive -- gambler agreement to terms and conditions, and to publish a complete list of approved deposit and withdrawal payment methods together with normal processing times. These obligations are not yet in force as of this baseline and apply to the non-bank, CGA-licensed payments layer rather than to CBCS-supervised banks and PSPs directly, illustrating the module's recurring bank-PSP-versus-non-bank-PI/EMI conduct-regime split: safeguarding and complaint-handling obligations run through CBCS for deposit-taking institutions, while payment-method transparency and consent obligations for the gaming-payments ecosystem run through the CGA on a separate, currently less mature, timetable. #### Outlook The October 8, 2026 CGA disclosure and consent rules are the nearest dated milestone and will be the first real test of enforceable payment-method transparency in the gaming-payments segment. CBCS's still-uncodified market-conduct rulebook, including the prospective linked-transactions prohibition, remains the larger open question for mainstream banking conduct; absent a stated timetable, it should be treated as directional rather than imminent. The Deposit Guarantee Fund's primary-source verification gap is worth resolving before the scheme's coverage terms are relied upon as settled. Periodic update · new data 2026-08-11 #### Conduct, Safeguarding & Financial Promotions The Caribbean guilder (XCG) became legal tender for Curacao and Sint Maarten on 31 March 2025, replacing the Antillean guilder (ANG), confirmed via a primary CBCS press release. This currency transition is now a completed structural fact rather than an in-progress reform, and it is the anchor against which subsequent payments-infrastructure developments this cycle should be read. Following the XCG rollout, CBCS has continued instant-payment-system, e-banking infrastructure and ISO 20022 migration upgrades through 2026, per secondary trade-press reporting; this is an infrastructure-modernisation signal rather than a conduct-rule change, but it bears on safeguarding and settlement practice insofar as instant-payment rails change the operational profile of consumer-facing payment flows. CBCS's 2026-2028 Research Agenda separately flags digital payment systems, contactless transactions, fintech services and a possible central bank digital currency as raising new regulatory, consumer-protection and monetary-control questions. This is explicitly a research-agenda item rather than a proposed rule or consultation with a defined instrument type, and it should be read as an early forward marker rather than as evidence of an imminent CBDC programme or fintech-specific conduct regime. No specific financial-promotions or safeguarding rule change, distinct from the currency transition and infrastructure upgrades, was evidenced for Curacao this cycle. The distinction between this settled currency-and-infrastructure track and the still-exploratory fintech/CBDC research track is itself analytically important: safeguarding and financial-promotions obligations tied to instant-payment and ISO 20022 rails are being built on a stable currency base, whereas any future CBDC-specific conduct regime remains speculative pending the research agenda's outcome. #### Outlook How CBCS's research agenda develops from an open scoping exercise into a concrete consultation or draft instrument is the key marker to watch; at this stage the fintech, digital-banking, CBDC and cyber-risk questions it raises remain unresolved rather than converging on a specific policy direction. The completed XCG transition and continuing ISO 20022 migration, by contrast, are settled infrastructure facts that future conduct and safeguarding rules will need to build on rather than open questions in themselves. **Sources and findings (5)** 1. T1 [https://www.centralbank.cw/faq/complaint](https://www.centralbank.cw/faq/complaint) retrieved 2026-07-04 2. T3 [https://thebanks.eu/countries/Curacao/major_banks](https://thebanks.eu/countries/Curacao/major_banks) retrieved 2026-07-04 3. T1 [https://www.centralbank.cw/](https://www.centralbank.cw/) retrieved 2026-07-04 4. T1 [https://www.centralbank.cw/faq/supervision-general](https://www.centralbank.cw/faq/supervision-general) retrieved 2026-07-04 5. T4 [https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/](https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/) retrieved 2026-07-04 ### W2 Stablecoins & Digital Money moved 1 gap Probable confirmed 2026-07-04 Curacao regulates virtual assets via the National Ordinance on the Supervision of Virtual Asset Service Providers (Landsverordening toezicht virtuele activa dienstverleners), administered by CBCS, with a public VASP register and full AML/CFT integration into LID/MOT since May 2024. There is no dedicated stablecoin-issuer/e-money-institution licensing statute (this sits inside the same pending PSP ordinance gap as W1a). Sector-specific stablecoin conduct rules are emerging fastest in the gaming vertical, where CGA now steers licensees toward fiat-backed stablecoins and Travel Rule compliance. Movement — CHANGED CGA crypto-policy Sept 2026 checkpoint reached_Interim compliance checkpoint fell within this window._ Open gap — wpm-int-3 No dedicated EMI/stablecoin-issuer licensing statute was found; the pending draft PSP Ordinance remains the only forward path, with no confirmed enactment date._no under-indexing note recorded_ Standing sub-brief · as of 8 July 2026 333 words · last cycle 2026-10-11 #### Stablecoins & Digital Money Virtual asset service providers in Curacao are regulated under the National Ordinance on the Supervision of Virtual Asset Service Providers, administered by CBCS, which maintains a public VASP register under Article 18 and may refuse a license under an "evasion of supervision" clause set out in Article 10. Since May 16, 2024, VASPs have also been brought within Curacao's core client-identification (LID) and unusual-transaction-reporting (MOT) compliance obligations, aligning the jurisdiction's crypto-asset supervision with FATF standards and integrating VASPs into the same AML/CFT regime that governs banks and MTCs. The most active development this cycle, however, sits at the intersection of gaming regulation and stablecoin policy rather than in dedicated crypto-asset law. New Curacao Gaming Authority policy treats any crypto transaction as high money-laundering risk and, in response, steers licensees toward fiat-backed stablecoins for licensee transactions; the same policy prohibits licensees from acting as an exchange or converting between cryptocurrencies and fiat, and requires FATF Travel Rule compliance. The stablecoin-as-payment-instrument dimension of this policy -- gaming operators' shift toward fiat-backed stablecoin rails for licensee transactions -- is the element captured here; the underlying illicit-finance risk classification and Travel Rule compliance mandate carry AML significance that is more properly analysed by the Financial Integrity Monitor. No dedicated stablecoin-issuer or EMI licensing statute exists in Curacao: the VASP Ordinance governs virtual-asset service activity broadly, but a specific stablecoin-issuance licensing pathway remains absent, with the pending draft PSP Ordinance the only forward route under discussion and no confirmed enactment date available. #### Outlook The near-term stablecoin story in Curacao is less about new issuance infrastructure than about the CGA-driven shift of an entire licensed vertical toward fiat-backed stablecoin rails for payment purposes. Whether that shift accelerates depends partly on how quickly gaming licensees can demonstrate Travel Rule compliance, and partly on whether the pending PSP Ordinance eventually creates a dedicated licensing pathway for stablecoin-adjacent payment activity. No forward date exists for either development, so both remain directional watch items rather than dated horizon entries. Periodic update · new data 2026-10-11 #### Stablecoins & Digital Money The Curacao Gaming Authority's crypto-policy guideline for B2C gambling licensees passed its first interim compliance checkpoint this cycle, with a September 2026 policy-upload milestone falling within this window. The guideline bars licensees from acting as virtual-asset service providers, exchanges, or payment service providers, and sets a staged compliance timetable: the September 2026 checkpoint is followed by a further milestone in December 2026, with full technical compliance due by June 2027. This is a gambling-sector-specific digital-money instrument, distinct from the Central Bank of Curacao and Sint Maarten's own mandatory registration regime for virtual-asset service providers, payment service providers, and electronic-money institutions; a gambling licensee handling crypto in Curacao is therefore potentially subject to obligations under both the CGA guideline and the CBCS registration framework, depending on the nature of its activity. The practical effect of the CGA's phased timetable is that licensees face escalating technical and procedural requirements over an eighteen-month window running from the guideline's initial issuance through to mid-2027, rather than a single compliance date. This phased structure gives licensees a defined runway but also means that the full scope of the digital-money control regime for this sector will not be testable until the June 2027 full-compliance deadline is reached. #### Outlook The next dated checkpoint in this timetable is the December 2026 milestone, followed by the full technical compliance deadline of June 2027. Watch for any CGA confirmation of licensee compliance rates at the December milestone, and for any indication of how the CGA guideline interacts in practice with the CBCS's separate VASP registration track for firms subject to both. **Sources and findings (4)** 1. T3 [https://legalbison.com/crypto-license/curacao/](https://legalbison.com/crypto-license/curacao/) retrieved 2026-07-04 2. T3 [https://manimama.eu/cryptolicense/cryptolicense-in-curacao-accessing-the-caribbean-and-latin-american-markets/](https://manimama.eu/cryptolicense/cryptolicense-in-curacao-accessing-the-caribbean-and-latin-american-markets/) retrieved 2026-07-04 3. T4 [https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/](https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/) retrieved 2026-07-04 4. T3 [https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law](https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law) retrieved 2026-07-04 ### W3 Operational Resilience & Critical Infrastructure Probable confirmed 2026-07-04 CBCS maintains a dedicated IT, Cyber & Operational Risk supervisory pillar (IT Governance, Business Continuity Management, Information Security Management provisions) and has flagged fintech/cyber risk as a priority in its 2026-2028 Research Agenda. Payments-critical infrastructure centres on the Worldline-built Instant Payments clearing and settlement mechanism (CSM), which is ISO 20022 compliant, and on upcoming Swift structured-address requirements effective November 2026. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/curacao/) Horizon · 2026-11-14 (±quarter) Swift structured-address messaging mandate in force_adopted · TT3_ Horizon · 2026-11-14 (±quarter) Swift structured-address messaging mandate in force_adopted · T_ Horizon · 2026-11-14 (±quarter) Swift structured-address messaging mandate takes effect_in_force_pending · TT3_ Standing sub-brief · as of 8 July 2026 210 words · last cycle 2026-08-05 #### Operational Resilience & Critical Infrastructure CBCS maintains a dedicated IT, Cyber and Operational Risk legislation and guidance category covering software testing, IT governance, business continuity management and information security management, supplemented by computer risk management memoranda -- a standing supervisory framework applicable across the banking and PSP sector without a specific dated trigger event this cycle. The active resilience item in this baseline is external and scheme-driven: Swift's structured and hybrid address data mandate takes effect November 14, 2026, after which payments carrying unstructured address data risk rejection or delay. CBCS has responded by hosting a Swift Payments Experience Roadshow to prepare regional banks for the transition, indicating institutional awareness of the deadline well ahead of its effective date. This mandate intersects directly with the jurisdiction's correspondent-banking exposure: banks already navigating a fragile USD-corridor position face an added compliance deadline that could compound access friction if remediation is incomplete. #### Outlook The November 14, 2026 Swift structured-address deadline is the clearest dated operational-resilience milestone on the horizon for Curacao's correspondent-facing banks; institutions that have not completed structured-address remediation by that date face direct payment-processing risk. CBCS's roadshow activity suggests preparation is underway, but no completion-rate or readiness data has been identified this cycle to assess how far along the sector is. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.centralbank.cw/legislation-guidelines/it-cyber-operational-risk](https://www.centralbank.cw/legislation-guidelines/it-cyber-operational-risk) retrieved 2026-07-04 2. T2 [https://www.curacaochronicle.com/post/unknown/cbcs-to-examine-fintech-digital-banking-and-cyber-risks-in-curacaos-financial-system](https://www.curacaochronicle.com/post/unknown/cbcs-to-examine-fintech-digital-banking-and-cyber-risks-in-curacaos-financial-system) retrieved 2026-07-04 3. T3 [https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments](https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments) retrieved 2026-07-04 4. T3 [https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules](https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules) retrieved 2026-07-04 ### W4 Scheme & Network Compliance Probable confirmed 2026-07-04 Scheme-level activity centres on the CBCS-chaired National Payment Council, which coordinates card-scheme rollout (Visa/Mastercard debit) and Instant Payments alongside the 1% Foreign Exchange license fee applied to cross-border bank transactions. Visa and Mastercard both continue to apply high-risk merchant classification programs (GARS/HRM) to Curacao-licensed gaming merchants, materially shaping scheme access for the jurisdiction's largest payments vertical. Standing sub-brief · as of 8 July 2026 223 words · last cycle 2026-08-05 #### Scheme & Network Compliance Curacao's National Payment Council, chaired by CBCS and meeting January 25, 2024, coordinated the rollout of Instant Payments, the introduction of Mastercard and Visa debit cards, and the Caribbean guilder currency reform -- positioning scheme-level coordination as a standing feature of the jurisdiction's payments governance rather than an ad hoc response. Scheme risk classification, however, remains a persistent constraint on the acquiring side. Visa's Global Acquirer Risk Standards and Mastercard's High-Risk Merchant Monitoring continue to classify Curacao-licensed gaming merchants as high-risk, and European acquiring banks remain cautious even after the jurisdiction's LOK licensing overhaul -- indicating that domestic licensing reform alone has not been sufficient to shift international scheme risk categorisation for the gaming-payments vertical, the jurisdiction's largest payments segment. On the enforcement side, CBCS has since May 1, 2024 consistently applied the 1% Foreign Exchange license fee to all applicable resident and non-resident bank transactions -- an enforcement gap previously closed by Instant Payments technology, which revealed beneficiary residency status that had not been reliably visible before. #### Outlook The persistence of Visa/Mastercard high-risk classification despite the LOK overhaul suggests scheme-level risk recategorisation will lag domestic licensing reform, with the new LOK B2B Supplier License offering a potential, but as yet unproven, route to changing that external perception over time. No forward date exists for any scheme reclassification decision. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.centralbank.cw/publications/press-releases/2024/pb-2024-006-national-payment-council-curacao-and-sint-maarten](https://www.centralbank.cw/publications/press-releases/2024/pb-2024-006-national-payment-council-curacao-and-sint-maarten) retrieved 2026-07-04 2. T4 [https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide](https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide) retrieved 2026-07-04 3. T3 [https://www.mcb-bank.com/news/important-update-on-license-fee-for-bank-transactions](https://www.mcb-bank.com/news/important-update-on-license-fee-for-bank-transactions) retrieved 2026-07-04 4. T4 [https://blog.basistheory.com/high-risk-merchant](https://blog.basistheory.com/high-risk-merchant) retrieved 2026-07-04 ### W5 Payment Corridor Dynamics Probable confirmed 2026-07-04 Curacao's principal payment corridors are (a) the domestic/regional Instant Payments corridor linking Curacao, Sint Maarten and Bonaire with a stated ambition to connect to Aruba and the Netherlands; (b) the USD correspondent-banking corridor, under chronic de-risking pressure; and (c) MTC-driven remittance corridors serving a large migrant population, particularly into Sint Maarten. Foreign exchange corridor access is governed by the 2010 Foreign Exchange Regulation. Standing sub-brief · as of 8 July 2026 200 words · last cycle 2026-08-05 #### Payment Corridor Dynamics Curacao's payment corridors present a genuinely mixed picture. On the regional side, the Instant Payments clearing and settlement mechanism linking Curacao, Sint Maarten and Bonaire has, since January 15, 2022, settled all interbank payments within ten seconds, 24/7/365, via a Worldline-built, ISO 20022-compliant, dual-currency (ANG/USD) system, with CBCS stating that future linkage to Aruba and Netherlands instant-payment ecosystems is planned -- a corridor actively opening and deepening. The USD correspondent-banking corridor tells the opposite story. Curacao's banking system lost seven correspondent banking relationships between 2017 and 2018 as part of the broader regional de-risking trend affecting USD-corridor access, and that pressure has not been resolved: it recurs as a named financial-stability risk in CBCS's own 2026-2028 Research Agenda and is treated by the BIS as structurally difficult to reverse once relationships are severed. #### Outlook The regional instant-payments corridor is on an expansion trajectory, with Phase 2 (P2P/P2B/P2G functionality) and prospective Aruba/Netherlands linkage as the next milestones, though neither carries a confirmed date. The USD correspondent corridor is the more consequential watch item: its trajectory is directly tied to the outcome of Curacao's CFATF enhanced-follow-up national action plan, since further de-risking pressure would compound an already-diminished correspondent-banking base. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T4 [https://globalbanks.com/curacao-banking-risks/](https://globalbanks.com/curacao-banking-risks/) retrieved 2026-07-04 2. T3 [https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments](https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments) retrieved 2026-07-04 3. T1 [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Sint%20Marteen-MER-Evaluation-CFATF-round4.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Sint%20Marteen-MER-Evaluation-CFATF-round4.pdf.coredownload.inline.pdf) retrieved 2026-07-04 4. T3 [https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules](https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules) retrieved 2026-07-04 5. T1 [https://www.centralbank.cw/legislation-guidelines/foreign-exchange-regulations](https://www.centralbank.cw/legislation-guidelines/foreign-exchange-regulations) retrieved 2026-07-04 ### W6 Industry Structure & Commercial Probable confirmed 2026-07-04 Curacao's payments-relevant financial sector is bank-dominated and concentrated: Maduro & Curiel's Bank (MCB) is the largest locally headquartered bank, alongside RBC Royal Bank, Orco Bank, Banco di Caribe and Vidanova Bank, with numerous international/regional bank branches also present. A nascent local fintech/payments layer (Girasol, ENVOY, Celery, CX Pay, and others under the Curacao FinTech Association) remains largely unfunded and structurally constrained by the absence of an EMI/PI licensing route. Standing sub-brief · as of 8 July 2026 194 words · last cycle 2026-08-05 #### Industry Structure & Commercial Dynamics Curacao's payments industry structure is bank-dominated and concentrated. By 2024 total assets, the largest institutions are Maduro & Curiel's Bank N.V., RBC Royal Bank N.V. (ANG 3,519.65 million), Orco Bank N.V., Banco di Caribe N.V. and Vidanova Bank N.V. -- a small set of established banks handling the bulk of the jurisdiction's payments and deposit-taking activity. The local fintech layer sitting alongside this bank-dominated core remains nascent and thinly capitalised. Twenty-six fintech startups have been identified in Curacao, including payments-focused firms Girasol, ENVOY, Celery, CONNECT and CX Pay, but only four are funded, and the sector has averaged roughly one new company launch per year over the past decade -- a pace consistent with, and likely constrained by, the registration-only PSP/EMI regime and absence of a dedicated licensing statute. #### Outlook Industry structure in Curacao is unlikely to shift materially until the licensing-gap constraint is resolved: a bank-dominated market with a thin, largely unfunded fintech layer reflects the current regulatory environment as much as it does market demand. Enactment of the draft PSP Ordinance would be the clearest catalyst for a change in this trajectory, though no confirmed timetable exists. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T4 [https://thebanks.eu/countries/Curacao/major_banks](https://thebanks.eu/countries/Curacao/major_banks) retrieved 2026-07-04 2. T1 [https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Sint%20Marteen-MER-Evaluation-CFATF-round4.pdf.coredownload.inline.pdf](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Sint%20Marteen-MER-Evaluation-CFATF-round4.pdf.coredownload.inline.pdf) retrieved 2026-07-04 3. T4 [https://tracxn.com/d/explore/fintech-startups-in-curacao/75cf4fbjdePCeE5STj0a6sEHKqCXyM9S4QvMMc558Ns/companies](https://tracxn.com/d/explore/fintech-startups-in-curacao/75cf4fbjdePCeE5STj0a6sEHKqCXyM9S4QvMMc558Ns/companies) retrieved 2026-07-04 4. T4 [https://www.connectingthedotsinfin.tech/curacao-based-girasol-payment-solutions-has-acquired-colombian-fintech-company-finzi/](https://www.connectingthedotsinfin.tech/curacao-based-girasol-payment-solutions-has-acquired-colombian-fintech-company-finzi/) retrieved 2026-07-04 5. T1 [https://www.centralbank.cw/publications/press-releases/2024/pb-2024-006-national-payment-council-curacao-and-sint-maarten](https://www.centralbank.cw/publications/press-releases/2024/pb-2024-006-national-payment-council-curacao-and-sint-maarten) retrieved 2026-07-04 ### W7 Legal & Litigation Probable confirmed 2026-07-04 The two dominant live/landmark litigation threads in Curacao's payments space are the two-decades-long First Curacao International Bank (FCIB) wind-down litigation (license revoked 2006 for VAT fraud involvement; Dutch Supreme Court remanded a fee-withholding dispute in March 2025) and the BC.Game/Blockdance/Small House bankruptcy litigation arising from gaming-license non-compliance, which has generated ongoing player-claimant proceedings and political corruption allegations against the gaming regulator. Standing sub-brief · as of 8 July 2026 236 words · last cycle 2026-08-05 #### Legal & Litigation Two litigation and enforcement threads dominate this cycle's legal picture, both sitting at the payments-gaming interface. First, the Dutch Supreme Court (Hoge Raad) in March 2025 overturned a Joint Court of Justice ruling that had allowed First Curacao International Bank (FCIB) to withhold 15% of customer balances, finding the reasonableness of the withheld costs inadequately justified, and remanded the matter to the Willemstad court -- an echo of the bank's 2006 license revocation for VAT fraud that CBCS has administered the wind-down of ever since. Second, the Joint Court of Justice declared Blockdance/Small House -- operator of the BC.Game brand -- bankrupt on November 12, 2024, for breaching LOK licensing conditions, including failure to maintain a reputable local bank account. That bankruptcy prompted the Gaming Control Board to issue a letter of intent to revoke the operator's license, and has generated ongoing player-claimant proceedings and political corruption allegations directed at the gaming regulator itself -- extending the litigation exposure beyond the operator to the regulator's own institutional standing. #### Outlook The FCIB matter now returns to the Willemstad court for a fresh determination on the reasonableness of withheld costs, with no confirmed date for resolution. The BC.Game/Blockdance bankruptcy proceedings, and the associated player claims and corruption allegations against the gaming regulator, remain live and unresolved, and warrant continued tracking given their bearing on both payment-processor risk and the credibility of Curacao's gaming-payments oversight architecture. Periodic update · new data 2026-08-11 #### Legal & Litigation The Curacao Deposit Guarantee Scheme entered into force on 1 July 2025 under P.B. 2025 no. 53, protecting bank and savings-fund deposits up to XCG 50,000 and credit-union deposits up to XCG 25,000, per secondary trade-press reporting on the scheme's introduction. This is new settlement-finality-adjacent and depositor-protection legal infrastructure for Curacao, distinct from and independent of the jurisdiction's offshore gaming and payments reputation; it applies to the core domestic banking and credit-union sector. An equivalent scheme is expected to be introduced in Sint Maarten during 2026, extending the same depositor-protection model to Curacao's sister jurisdiction within the same monetary union. The XCG-denominated coverage caps, 50,000 for bank and savings-fund deposits and 25,000 for credit-union deposits, are themselves a reference point for assessing the practical value of the guarantee relative to typical retail deposit balances in Curacao, though no data on typical balances was evidenced this cycle to support that comparison directly. Read together with the March 2025 XCG currency transition, the Deposit Guarantee Scheme represents a substantive strengthening of Curacao's core banking-sector legal infrastructure this cycle. Both developments sit in the domestic-banking-law track rather than in the cross-border payments or correspondent-banking-access track, and neither is tied to the AML/CFT-driven de-risking risk that CBCS has separately flagged for correspondent relationships. #### Outlook Whether Sint Maarten's equivalent scheme is actually introduced during 2026, as currently expected, is the clearest forward marker for this module; if it slips beyond 2026 that would be a notable deviation from the currently-expected timeline. No litigation or court-judgment development specific to the deposit-guarantee scheme itself was evidenced this cycle. **Sources and findings (5)** 1. T2 [https://www.curacaochronicle.com/post/local/dutch-supreme-court-overturns-ruling-on-first-curacao-international-bank-case/](https://www.curacaochronicle.com/post/local/dutch-supreme-court-overturns-ruling-on-first-curacao-international-bank-case/) retrieved 2026-07-04 2. T2 [http://www.firstcuracao.com/](http://www.firstcuracao.com/) retrieved 2026-07-04 3. T3 [https://news.worldcasinodirectory.com/curacao-regulator-poised-to-announce-bc-game-license-decision-116265](https://news.worldcasinodirectory.com/curacao-regulator-poised-to-announce-bc-game-license-decision-116265) retrieved 2026-07-04 4. T4 [https://sbgok.org/](https://sbgok.org/) retrieved 2026-07-04 5. T3 [https://igamingbusiness.com/legal-compliance/licensing/curacao-gcb-corruption-claims/](https://igamingbusiness.com/legal-compliance/licensing/curacao-gcb-corruption-claims/) retrieved 2026-07-04 ### W8 Merchant Acquiring & Risk Probable confirmed 2026-07-04 Merchant acquiring in Curacao is structurally shaped by its status as a leading global online-gaming licensing hub: gaming merchants are near-universally classified high-risk by Visa and Mastercard's respective risk programs, forcing a standard advisory structure of Curacao-licensed gaming entity plus EU-domiciled merchant account/EMI. The new LOK regime's B2B Supplier License (effective 2024/2025) now brings payment processors serving the sector within formal CGA oversight for the first time. Standing sub-brief · as of 8 July 2026 162 words · last cycle 2026-08-05 #### Merchant Acquiring & Risk The new LOK B2B Supplier License marks a genuine expansion of formal oversight into the payments layer of Curacao's iGaming sector. The license category covers software developers, game providers, payment processors and other B2B infrastructure companies serving iGaming operators, bringing payment processors that previously operated without any formal Gaming Control Board or Curacao Gaming Authority authorisation within a compliance pathway for the first time. This development sits directly alongside the persistent Visa/Mastercard high-risk merchant classification: bringing payment processors under formal licensing oversight is a plausible, though as yet unproven, mechanism for addressing the underlying risk perception that has kept European acquiring banks cautious about Curacao-licensed gaming merchants even after the broader LOK licensing overhaul. #### Outlook Whether the B2B Supplier License meaningfully changes acquiring-bank risk appetite toward Curacao gaming merchants is the key open question for this module; no scheme-level reclassification has been identified this cycle, and the license category itself is too newly established to assess enforcement outcomes. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T4 [https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide](https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide) retrieved 2026-07-04 2. T4 [https://gbo-licensing.com/curacao-corporate-structure/](https://gbo-licensing.com/curacao-corporate-structure/) retrieved 2026-07-04 3. T4 [https://blog.basistheory.com/high-risk-merchant](https://blog.basistheory.com/high-risk-merchant) retrieved 2026-07-04 4. T4 [https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide](https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide) retrieved 2026-07-04 ### W9 Product Innovation & Market Development Probable confirmed 2026-07-04 The dominant product-development event of the baseline period is the March 2025 launch of the Caribbean guilder (XCG), the new common currency for Curacao and Sint Maarten replacing the Netherlands Antillean guilder. In parallel, CBCS is developing Instant Payments Phase 2 (P2P/P2B/P2G), and the gaming sector has gained a new B2B Supplier License category; the fintech sector's principal innovation constraint remains the absent EMI/PI licensing framework. Standing sub-brief · as of 8 July 2026 195 words · last cycle 2026-08-05 #### Product Innovation & Market Development The most significant completed payments-infrastructure event of the baseline period is the introduction of the Caribbean guilder (XCG) as legal tender for Curacao and Sint Maarten on March 31, 2025, replacing the Netherlands Antillean guilder, which ceased legal tender status on July 1, 2025 following a co-circulation period, at a fixed peg of USD 1 = 1.79 XCG. The changeover represents a full currency-infrastructure transition across the jurisdiction's banking, payments and cash-handling systems, coordinated in part through the National Payment Council. Alongside the currency changeover, CBCS and Worldline are developing Phase 2 of the Instant Payments programme, aimed at expanding online and in-store instant payments with person-to-person, person-to-business and person-to-government functionality beyond the initial interbank rollout live since January 2022. No confirmed launch date for Phase 2 has been identified this cycle. #### Outlook The XCG changeover is now a completed transition rather than a forward-looking item, but its full bedding-in across all payment channels and cash infrastructure should be monitored for residual friction. Instant Payments Phase 2 is the clearer forward-looking product-development item in this module, though its lack of a confirmed date means it remains directional rather than dated. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.centralbank.cw/functions/banknotes-coins/caribbean-guilder](https://www.centralbank.cw/functions/banknotes-coins/caribbean-guilder) retrieved 2026-07-04 2. T3 [https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments](https://www.finextra.com/pressarticle/90978/centrale-bank-van-curaao-en-sint-maarten-implements-instant-payments) retrieved 2026-07-04 3. T4 [https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide](https://www.zitadelleag.com/news/offshore-igaming-curacao-license-guide) retrieved 2026-07-04 4. T3 [https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law](https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law) retrieved 2026-07-04 ### W10 Consumer Protection & APP Fraud Probable confirmed 2026-07-04 Consumer protection runs through CBCS's 2017 complaints-handling Regulation (two-week response requirement) and the consumer association Fundashon pa Konsumidó, with CBCS itself limited to a supervisory-signal role rather than adjudication or mediation. Gaming-specific consumer protections are being strengthened under LOK (proactive T&C consent, payment-method/timing disclosure). No dedicated APP-fraud mandatory-reimbursement regime, of the kind seen in the UK/EU, was identified for Curacao's banking sector. Standing sub-brief · as of 8 July 2026 188 words · last cycle 2026-08-05 #### Consumer Protection & APP Fraud No dedicated authorised-push-payment fraud mandatory-reimbursement regime equivalent to the UK's PSR rules was identified for Curacao's banking sector this cycle -- a genuine regulatory absence rather than a research gap. Consumer recourse for payments disputes instead runs through the 2017 complaints-handling Regulation described in W1b and through the Fundashon pa Konsumidor consumer association, neither of which provides a reimbursement mechanism specific to APP fraud. The consumer-protection dimension that is tightening sits in the gaming-payments space: from October 8, 2026, CGA-licensed operators must evidence proactive consumer agreement to terms and conditions and publish a complete list of approved deposit and withdrawal payment methods together with estimated normal processing times -- the same forthcoming rule described in W1b, viewed here through its consumer-disclosure lens rather than its conduct-obligation lens. #### Outlook The absence of an APP-fraud reimbursement regime remains a structural consumer-protection gap in Curacao's mainstream banking sector, with no indication this cycle that CBCS or Parliament is actively developing one. The October 2026 CGA disclosure rules will be the more immediate test of whether tightened payment-method transparency actually improves gaming-sector consumer outcomes once in force. no periodic updates on record for this sub-brief ** Sources and findings (4)** 1. T1 [https://www.centralbank.cw/faq/complaint](https://www.centralbank.cw/faq/complaint) retrieved 2026-07-04 2. T1 [https://www.centralbank.cw/functions/supervision/conduct-supervision](https://www.centralbank.cw/functions/supervision/conduct-supervision) retrieved 2026-07-04 3. T4 [https://thebanks.eu/countries/Curacao/major_banks](https://thebanks.eu/countries/Curacao/major_banks) retrieved 2026-07-04 4. T4 [https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/](https://eegaming.org/news/2026/07/04/142046/curacaos-crypto-haven-status-challenged-by-new-regulations/) retrieved 2026-07-04 ### W11 AML/CFT & Financial Crime (Sentinel-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/curacao/#sec-dom-D7) Probable confirmed 2026-07-04 Curacao completed its 4th-round CFATF mutual evaluation (on-site June 2024, report adopted May 29, 2025), placing it under CFATF's enhanced follow-up process. The core statutory AML/CFT framework -- NORUT (unusual transactions reporting) and NOIS/LID (client identification) -- was consolidated in 2024 (Landsverordening bestrijding witwassen, financieren van terrorisme en het financieren van proliferatie, PB 2024 nr. 41), with VASPs folded into the same regime since May 2024. Standing sub-brief · as of 8 July 2026 202 words · last cycle 2026-08-05 #### AML/CFT & Financial Crime This module's findings are sourced from the Sentinel.gi feed and are carried here for their correspondent-banking and payments-access relevance rather than as original illicit-finance analysis, which remains Sentinel/FIM's domain. Curacao's fourth-round CFATF mutual evaluation report was adopted at the CFATF plenary on May 29, 2025, following a 2023-2025 evaluation process; the jurisdiction now falls under CFATF's enhanced follow-up process, requiring a national action plan to demonstrate progress and avoid FATF grey-listing. Full detail is available via the primary FATF-GAFI mutual evaluation report (fatf-gafi.org/en/publications/Mutualevaluations/mer-curacao-2025.html). Curacao's core AML/CFT statutory framework -- the NORUT/MOT unusual-transaction-reporting regime and the NOIS/LID client-identification regime -- now sits alongside a consolidated 2024 Landsverordening bestrijding witwassen, financieren van terrorisme en het financieren van proliferatie (PB 2024 nr. 41), with virtual asset service providers integrated into the same regime since May 16, 2024. This statutory consolidation is the structural backdrop against which the CFATF enhanced-follow-up assessment will be judged. #### Outlook Curacao's enhanced-follow-up status is a live grey-listing risk with direct bearing on correspondent banking and cross-border payment access; performance against the national action plan is the determinative variable, and WPM will continue to track its payments-sector consequences via the Sentinel feed rather than conducting independent illicit-finance analysis. no periodic updates on record for this sub-brief ** Sources and findings (5)** 1. T3 [https://www.knowyourcountry.com/curacao/](https://www.knowyourcountry.com/curacao/) retrieved 2026-07-04 2. T? FIM (sentinel.gi) per-JID baseline profile — Curaçao (Kingdom of the Netherlands) — 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). It 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. 3. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness 4. T2 FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-002) — Sanctions: EU listing 5. T? FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: capacity-deficit ### W12 Correspondent Banking, Settlement & Access Probable confirmed 2026-07-04 Correspondent banking de-risking is a chronic, CBCS-acknowledged structural vulnerability for Curacao given the jurisdiction's exposure to gaming/crypto-adjacent business and small-open-economy status; the CBCS 2026-2028 Research Agenda explicitly names it as a financial-stability risk. Settlement infrastructure access runs through the domestic Instant Payments CSM and, for cross-border messaging, through Swift, which is imposing new structured-address requirements from November 2026. Standing sub-brief · as of 8 July 2026 239 words · last cycle 2026-08-05 #### Correspondent Banking, Settlement & Access Correspondent banking access is Curacao's most structurally entrenched payments vulnerability, and the module's analytical spine is the asymmetry between bank and non-bank access to that infrastructure: licensed banks retain (albeit narrowing) direct correspondent relationships for USD clearing, while non-bank PSPs, EMIs and gaming-payments processors depend on those same banks as gatekeepers, with no independent correspondent-access route of their own. CBCS's 2026-2028 Research Agenda names correspondent banking de-risking explicitly as a financial-stability risk for small open economies, warning that de-risking can disrupt trade, remittances and cross-border payments even when local banks remain solvent -- language that applies with particular force to Curacao's gaming-payments vertical, which relies disproportionately on bank-intermediated USD access given its Visa/Mastercard high-risk classification (see W4). A Bank for International Settlements review, "Correspondent bank relations in Curacao - no quick fixes," addresses the structural difficulty of restoring lost correspondent relationships once severed -- a finding that aligns with the seven relationships lost between 2017 and 2018 (see W5) and suggests the current base of relationships, however reduced, should be treated as fragile rather than stable. #### Outlook The determinative variable for this module over the coming cycles is Curacao's performance against its CFATF enhanced-follow-up national action plan (see W11): a credible plan and demonstrated progress would support the existing correspondent-banking base, while underperformance risks further relationship losses on top of an already-diminished position. No new correspondent relationships or replacement mechanisms were identified this cycle. Periodic update · new data 2026-08-11 #### Correspondent Banking, Settlement & Access CBCS has explicitly flagged persistent AML/CFT weaknesses as a driver of correspondent-banking de-risking risk for Curacao and Sint Maarten institutions in its own 2026-2028 Research Agenda, a rare instance of a central bank naming its own jurisdiction's AML/CFT profile as a live access-risk factor rather than treating de-risking purely as an external correspondent-bank decision. This sits alongside CBCS's completion, in 2025, of a risk-based 'New Style of Supervision' that now covers approximately 400 supervised financial institutions with intensified AML/CFT and virtual-asset oversight. The analytical spine of this module is the bank-versus-nonbank access asymmetry: the New Style of Supervision and the de-risking risk both apply most directly to the bank-and-credit-institution population, while nonbank PSPs and EMIs newly formalised under the VASP/PSP/EMI category face a comparatively less mature supervisory track record from which correspondent banks can assess counterparty risk. The scale point matters: approximately 400 institutions under intensified supervision is not a narrow segment of Curacao's financial sector but close to its full regulated population, meaning correspondent-access risk tied to AML/CFT weaknesses is a system-wide rather than institution-specific concern this cycle. This module's evidence base rests on CBCS's own research-agenda framing rather than on a specific correspondent-bank withdrawal event or de-risking incident; the finding is therefore forward-looking risk-flagging by the regulator itself rather than documentation of an already-realised access disruption. #### Outlook Whether the New Style of Supervision's intensified AML/CFT and virtual-asset oversight measurably improves correspondent-banking relationships, as distinct from simply being CBCS's own acknowledgement of the underlying risk, is the key marker to watch; CBCS's own framing this cycle treats the risk as live and unresolved despite the new supervisory framework being in place. **Sources and findings (5)** 1. T2 [https://www.curacaochronicle.com/post/main_news/cbcs-puts-housing-and-systemic-risk-back-on-the-agenda-but-curacao-still-lacks-clear-visibility-on-key-vulnerabilities](https://www.curacaochronicle.com/post/main_news/cbcs-puts-housing-and-systemic-risk-back-on-the-agenda-but-curacao-still-lacks-clear-visibility-on-key-vulnerabilities) retrieved 2026-07-04 2. T4 [https://globalbanks.com/curacao-banking-risks/](https://globalbanks.com/curacao-banking-risks/) retrieved 2026-07-04 3. T1 [https://www.bis.org/review/r220906g.pdf](https://www.bis.org/review/r220906g.pdf) retrieved 2026-07-04 4. T3 [https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules](https://www.bes-reporter.com/news/banking-finance/91964/cbcs-preps-banks-for-new-swift-rules) retrieved 2026-07-04 5. T2 [https://www.curacaochronicle.com/post/unknown/cbcs-to-examine-fintech-digital-banking-and-cyber-risks-in-curacaos-financial-system](https://www.curacaochronicle.com/post/unknown/cbcs-to-examine-fintech-digital-banking-and-cyber-risks-in-curacaos-financial-system) retrieved 2026-07-04 ### W13 Commercial Intelligence (M&A, Investment & Product) Probable confirmed 2026-07-04 No confirmed M&A, funding round, or major product-release event specific to Curacao's payments/fintech sector was identified within the trailing 12-month baseline window (July 2025-July 2026). The most notable prior payments-sector M&A (Girasol Payment Solutions' acquisition of Colombian fintech FinZi) predates the window (January 2024) and is carried as background context under W6 rather than as a W13 commercial_event. Standing sub-brief · as of 8 July 2026 113 words · last cycle 2026-08-05 #### Commercial Intelligence No confirmed M&A transaction, investment or funding round, or product-release event specific to Curacao's payments/fintech sector was identified within the trailing-12-month baseline window. The one dated item this cycle is advocacy rather than a commercial transaction: within the trailing-12-month window, the Curacao FinTech Association issued a formal letter to Parliament's President urging fast-tracking of PSP licensing legislation -- a market-development signal, not an M&A, funding or product event, and accordingly no commercial_event record is attached. #### Outlook With no active commercial event this cycle, this module remains quiet; the CFA's legislative advocacy is the item most likely to translate into future commercial activity (new licensed entrants) if the draft PSP Ordinance advances. no periodic updates on record for this sub-brief ** Sources and findings (1)** 1. T3 [https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law](https://www.curacaochronicle.com/post/unknown/curacao-fintech-association-urges-parliament-to-fast-track-payment-services-law) retrieved 2026-07-04 ** No modules match.** Filters combine as OR inside a group and AND across groups. ## Editorial metadata Provenance only. Nothing below gates publication or affects the render. Editorial metadata for Curaçao| Field | Value | |---|---| | `trust.lawyer_review.status` | never_reviewed | | `trust.lawyer_review.reviewer` | no reviewer on record | | ` trust.content_source` | ai_generated | ## Provenance and declared absence **Disclosure model:** module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. **Sentinel-fed modules** receive no special rendering treatment. `sentinel_feed` is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. **Family taxonomy** is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. **Suppressed by doctrine:** derived risk score; per-module RAG traffic light; `derived_scores` = `{}`. **Band honesty:** uncertainty bands are computed against a frozen build clock of 2026-10-21. A year-precision row is never promoted into a tighter band. **Orphan deltas:** 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card. **Envelope:** baseline resolved at `jurisdiction_json.baseline`; 14 module(s), 61 finding(s), 125 source(s) in the cumulative register. Think something on this page is wrong? [Report an error](https://payments.gi/legal/#contact).