Curaçao

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.