Curaçao Dispute: Consultation Firm Rejects Claims of Excessive Government Payments

The gambling jurisdiction of Curaçao is currently undergoing a radical transformation, but the process is mired in financial controversy and political tension. Random Consulting Limited (RCL), the Maltese firm responsible for the technical backbone of the new regulatory framework, has publicly rejected claims made by Finance Minister Charles Cooper. The minister had stated that the government pays RCL approximately 8.3 million ANG (4.6 million euros) annually. RCL countered this by asserting that the actual payments are tied to specific milestones and are significantly lower than the figures suggested by the administration.

This disagreement points to the complexities of dismantling a decades-old system where private entities held the power to issue sub-licenses. The transition to the Curaçao Gaming Authority (CGA) requires a completely new online portal and administrative tools. RCL explained that they even carried costs on their own books when the government asked to delay billing during the initial rollout phase. The company maintains that its financial records are transparent and correctly reflect the work performed for the island's modernization.

Numbers and facts

To provide clarity, RCL disclosed its actual revenue from the project, totaling roughly 3.43 million euros desde 2022. The payment schedule shows an uneven distribution: only 15,400 euros in 2022, zero payments in 2023, followed by 884,000 euros in 2024 and a projected 2.53 million euros in 2025. This breakdown contradicts the idea of a fixed annual retainer and instead follows the implementation timeline of the new licensing system.

Another key figure in this reform is Finance Minister Javier Silvania, who is pushing for higher standards despite the risk of operators leaving the island. He views the departure of low-quality operators as a necessary step for the jurisdiction's reputation.

"I have no issue at all with companies leaving Curaçao because at the current time Curaçao is not making much money from them. It’s the master licensees that are making the most money; the government is hardly making any." - Javier Silvania, Finance Minister of Curaçao

Experts like Mario Galea estimate that between 500 and 900 operators currently hold licenses under the old system, managing thousands of different gambling websites with very little government oversight.

Background

Curaçao's reform is heavily influenced by the Netherlands. As part of the Kingdom of the Netherlands, the island has faced pressure to stop being a hub for unregulated gambling targeting international markets. The new bill approved by the Council of Ministers aims to create the CGA as an independent licensing body. This authority will issue licenses to both B2C operators and B2B suppliers, implementing stricter anti-money laundering (AML) controls and requiring a local substance of at least three key employees on the island.

RCL's technology is designed to help the CGA identify operators who falsely use the Curaçao brand. The regulator has already had to distance itself from numerous illegitimate claims over the past year. By creating a centralized portal, the government hopes to increase direct revenue through application fees (approx. 4,000 euros) and annual license fees (approx. 12,000 euros), moving away from a system where private master licensees kept the majority of the profits.

Why it matters for German players

For players located in Germany, the changes in Curaçao are highly relevant because many offshore platforms operating in the German market utilize these Caribbean licenses. Historically, a Curaçao license offered very few protections regarding player safety or fair play. Under the German Interstate Treaty on Gambling 2021 (GlüStV 2021), only casinos on the GGL whitelist are legally permitted to offer services in Germany.

While the reforms on Curaçao will raise standards, they are unlikely to match the strict requirements of the German GGL, such as the 1 euro stake limit or the 1,000 euro monthly deposit cap. German players should remain cautious, as offshore sites do not participate in the LUGAS or OASIS systems, meaning there is no legal recourse in Germany if an operator refuses to pay out winnings. The tightening of rules in Curaçao might eventually reduce the number of these sites, but it does not make them legal in the eyes of German law.

What it means for GGL-licensed casinos

Casinos with a German license stand to benefit from the increased costs and scrutiny in Curaçao. As the "Curacao gateway" becomes more expensive and regulated, the unfair competitive advantage of offshore sites shrinks. GGL casinos can use this opportunity to emphasize their role as the only safe and legal harbor for German gambling enthusiasts.

Furthermore, if the new Curaçao Gaming Authority enters into cooperation agreements with European regulators, it could lead to more effective enforcement against illegal operators. Mario Galea noted that having an actual authority with the power to revoke licenses is a game-changer. For the GGL, this could mean a more coordinated international effort to protect the regulated domestic market from unlicensed competition.