Curaçao: The Licensing Core of the B2C Structure

Curaçao remains a relevant jurisdiction within the landscape of international iGaming, particularly for entities engaged in business-to-consumer (B2C) activities. A central player within this framework is Midas Entertainment B.V., a company formally licensed under the Curaçao eGaming regime.

Historically recognised for its accessible licensing procedures and flexible operational allowances, Curaçao’s regulatory system has also been the subject of international attention due to its comparatively limited transparency requirements and ongoing reforms related to anti-money laundering (AML) compliance.

While steps towards regulatory modernisation have been initiated by the newly formed Curaçao Gaming Authority, the existing framework continues to accommodate a range of structuring options. These have included the use of sub-licensing arrangements, third-party service providers and outsourced technical infrastructure, in line with prevailing regulatory provisions.

Within this environment, entities such as Midas Entertainment B.V. have been able to operate in accordance with local requirements, including those governing corporate disclosures.

Documentation reviewed by Malta-Media refers to Herman Behr TEP, Elaine Behr and Steve Croes in various administrative and support roles related to Midas Entertainment B.V.

Herman Behr, a recognised Trust and Estate Practitioner (TEP), is affiliated with the HBM Group, a Curaçao-based provider of corporate services and infrastructure support for gaming-related businesses. Mr Behr is referenced in regulatory filings, financial records and correspondence related to corporate governance. His qualifications in cross-border structuring and discretionary planning are relevant to the establishment of foundations and complex corporate arrangements commonly used in the industry.

Elaine Behr, identified in documentation as a co-owner of HBM, is mentioned in connection with banking and compliance-related matters. Her participation appears to include responsibilities at an administrative level, as indicated in reviewed internal agreements.

Steve Croes is named in operational and support materials, and is understood to act in a liaison capacity between the Curaçao-licensed entity and international stakeholders. Available records suggest his role concerns operational matters and support services.

Collectively, the recurring references to these individuals (particularly those associated with the HBM Group) indicate a functional structure in which the Curaçao-licensed company operates within a broader system involving private foundations, service providers and intermediaries. However, these configurations cannot be independently verified in full, owing in part to the regulatory framework in Curaçao, which does not mandate public disclosure of beneficial ownership or detailed AML-related reporting.

The position of Midas Entertainment B.V. within this legal architecture allows it to operate in accordance with applicable laws, while benefiting from the jurisdictional attributes of Curaçao, including its reporting requirements and fiscal regime.

Legal Disclaimer and Ongoing Investigations

As with all editorial content published by Malta-Media, no allegation of unlawful conduct is made against any individual or entity referenced herein. The information presented is derived from publicly accessible registries, corporate databases, internal documentation, and confidential submissions believed to be accurate and reliable at the time of publication. Interpretations, where offered, reflect the editorial team’s understanding of jurisdictional structures and regulatory environments, and are not intended to imply misconduct or unlawful intent.

This article forms part of an ongoing investigative series examining the legal, financial and operational structures within the online gambling sector. The aim is to contribute to public understanding by outlining governance models, licensing regimes and cross-border frameworks. Malta-Media acknowledges the complexity of these issues and welcomes clarifications or formal responses from any individuals or organisations named. Substantiated responses will be published in full, unedited and with equal prominence.

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FAQs

What is the significance of Curaçao in the iGaming industry?
Curaçao remains a key jurisdiction for international iGaming businesses, particularly for companies engaged in B2C activities, due to its accessible licensing and operational flexibility.

Who is Midas Entertainment B.V.?
Midas Entertainment B.V. is a company licensed under the Curaçao eGaming regime and operates within the iGaming sector, complying with local regulatory requirements.

What makes Curaçao’s licensing system attractive?
Curaçao is known for its relatively accessible licensing procedures, flexible operational allowances, and favorable fiscal regime, making it an attractive option for gaming-related businesses.

What changes are being made to Curaçao's regulatory system?
The newly formed Curaçao Gaming Authority has initiated reforms aimed at modernizing the regulatory framework, particularly focusing on improving anti-money laundering (AML) compliance.

How does the Curaçao regulatory system affect corporate disclosures?
Curaçao’s regulatory framework does not require public disclosure of beneficial ownership or detailed AML reporting, which limits transparency but also offers privacy advantages for operators.

What role do Herman Behr, Elaine Behr, and Steve Croes play in Midas Entertainment?
Herman Behr, Elaine Behr, and Steve Croes are involved in administrative, support, and operational roles within Midas Entertainment B.V. and are affiliated with the HBM Group, a Curaçao-based service provider.

What is the HBM Group’s role in the iGaming industry?
The HBM Group provides corporate services and infrastructure support for gaming businesses, including assistance with cross-border structuring, compliance, and operational matters.

Are there any issues with transparency in Curaçao’s regulatory system?
Yes, the lack of public disclosure requirements and limited AML reporting creates transparency challenges, making it difficult to fully verify the ownership and structure of companies like Midas Entertainment B.V.

Is Midas Entertainment B.V. compliant with Curaçao’s laws?
Yes, Midas Entertainment B.V. operates in compliance with local Curaçao laws, adhering to the jurisdiction’s regulatory framework, fiscal regime, and reporting requirements.

What is the purpose of the ongoing investigations by Malta-Media?
Malta-Media is conducting an ongoing investigation into the legal, financial, and operational structures of the online gambling sector, aiming to improve public understanding of governance models and regulatory frameworks.