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Curaçao regulators set binding rules for remote customer onboarding

By jili tutorial · August 31, 2026

Curaçao Regulators Set Binding Rules for Remote Customer Onboarding

New Binding Rules for Remote Customer Onboarding

Operators that do not yet use a remote onboarding tool must comply with new standards before launching one. Those already running a solution have until 1 May 2027 to meet the requirements. Until the National Ordinance on Identification when Rendering Services (NOIS) was amended in May 2024, Curaçao accepted only one way to verify the identity of a customer who was not physically present: a certified copy of an identity document.

On 21 August 2026, the Curaçao Gaming Authority (CGA), the Central Bank of Curaçao and Sint Maarten (CBCS), and the Financial Intelligence Unit Curaçao (FIU) jointly enacted provisions that now govern how remote identification and verification must be carried out.

Key Provisions at a Glance

What the Provisions Cover

The Provisions for Identification and Verification without Physical Contact implement Article 3, paragraph 1 of the NOIS. This article requires supervisory authorities to set rules for identifying natural persons who are not physically present. The provisions apply to all service providers under the scope of the NOIS identity verification rules—not only gaming licensees—and form part of the existing anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing framework.

Identity Verification Requirements

Identity must be established using one of the following documents:

The same rules apply to controllers, proxy-holders, directors, representatives, and ultimate beneficial owners of corporate clients.

Validation and Verification Processes

How Validation Works

Certification remains an acceptable method to validate a document. This can be done either through a certified copy or extract from the civil registry, or by sending the document electronically and following up with a certified copy within two weeks.

Providers may instead use technology such as:

Verification then links the validated document to the person appearing on screen. For unattended solutions, the system must:

Attended solutions require trained staff and a defined escalation process. If the evidence is too poor to produce a clear result, onboarding must be stopped and either restarted or moved to a face-to-face check.

Testing, Monitoring, and Compliance

Pre-Implementation Testing

The paperwork comes first. No tool may go live until the provider has:

Supervisors can request to see these results at any time.

Ongoing Monitoring

Monitoring must continue after launch. Unscheduled reviews are required when:

From a technical standpoint, the provisions demand:

Deadlines and Penalties

Providers that do not yet use a remote onboarding solution must comply before implementing one. Those already running a solution have until 1 May 2027 to achieve full compliance. In the meantime, they may keep their existing setup provided they have started the work and can demonstrate it upon request.

Non-compliance will trigger administrative and criminal sanctions, including:

The announcement closes by urging operators to act now rather than wait for the deadline: “All operators are encouraged to review the provisions carefully, take note of the applicable requirements, and take the necessary steps to ensure that their procedures, controls and systems are aligned accordingly.”

Why It Matters for Operators

The immediate work is largely documentary. Most operators already run a KYC vendor. However, far fewer will have:

Outsourcing does not shift this burden—the provider, not the vendor, must demonstrate compliance.

The provisions apply a uniform approach across all sectors under supervision. This means gaming licensees and institutions overseen by the CBCS now work to the same onboarding standard. The rules follow the National Ordinance on Games of Chance, which took effect on 24 December 2024, and sit alongside the CGA’s other guidance issued since, including its rules on alternative dispute resolution.