Aideen Shortt, the CGA and the façade of reform!

Why Curaçao’s gambling makeover deserves scrutiny, not applause!

Curaçao’s long-awaited gambling reform has been presented as a watershed moment for the island's regulatory credibility. Yet upon close examination, what emerges is not a story of structural progress, but one of systemic denial, conflict of interest and performative oversight.

Beneath the glossy presentations at international gaming expos and the steady drumbeat of press releases, the reform remains riddled with contradictions.

At the centre of this theatre of regulation stands Ms Aideen Shortt, a long-standing industry consultant, whose recent appearance in a German investigative documentary raises urgent questions about the legitimacy of the reform narrative. That documentary: “Suchtgeschäft. Doku über illegale Online-Casinos” (translated: “The Addiction Business: Documentary on Illegal Online Casinos”), aired on 6 July 2025, offers what may be the most direct and unfiltered insight yet into the true intent behind Curaçao’s rebranding.

Aideen Shortt’s recorded statements: selling flexibility, not integrity!

In a recorded exchange ARD Doku – Suchtgeschäft. Doku über illegale Online-Casinos (52 Min) from minute 28:00 to 31:30 of the ARD/SWR documentary, Ms Shortt, introduced as a senior adviser to the CGA and a consultant to the Ministry of Finance, discusses the regulatory approach of Curaçao with an undercover reporter posing as an affiliate seeking to promote gambling offers in restricted jurisdictions such as Germany.

She explains that Curaçao's gambling framework is “deliberately weak” to accommodate business interests, adding “we’re not selling soap here” to justify the lack of enforceable standards. Rather than prohibiting operators from targeting restricted markets, she explains that the CGA’s policy is to ask what the operator intends to do and then “tell you what is not possible”, a logic that inverts the basic principle of rule-based regulation.

When pressed on jurisdictions like France, Spain and Germany, Shortt confidently replies that Curaçao imposes no restrictions on any of them. The only country she claims is off-limits is North Korea.

This conversation alone, occurring in the public space of the SiGMA World conference in Malta, demolishes any notion that the CGA is attempting to bring its licence regime into alignment with EU or FATF expectations. It instead suggests a regulator that defines its own compliance boundaries according to operator convenience.

Ms Shortt’s language is not the language of a reformer. It is the voice of someone reassuring potential clients that despite the reform headlines, the underlying permissiveness remains intact.

“You screw another country, you screw us”: a telling contradiction…

Shortt’s remarks at minute 29:40 are particularly revealing. She insists that the relationship between the CGA and the operators relies on trust, stating: “If you screw over another country, you screw us.” But far from being a warning, her comment is framed as a matter of reputation management, not legal consequence. Her logic implies that as long as operators avoid attracting attention, Curaçao will look the other way.

She goes further still, arguing that the CGA discourages explicit prohibition of markets because “we don’t want to harm your business.” She even discusses Germany and Austria as “problematic” only because of “opportunistic” lawyers, citing ongoing litigation campaigns targeting Curaçao-licensed platforms.

She then references Malta’s Bill 55, suggesting that Curaçao should adopt something similar to protect licensees from cross-border enforcement.

That Ms Shortt is a direct adviser to the Ministry of Finance while actively promoting loopholes and reputational arbitrage raises serious governance questions. In most regulatory environments, such behaviour would warrant a suspension or formal investigation. In Curaçao, it appears to merit a consulting contract.

Shortt’s email rebuttal: denial unmoored from reality!

When ARD/SWR followed up with a written request for clarification, Ms Shortt responded on behalf of the CGA, “strongly rejecting” any suggestion that player protection in Curaçao is weak. She pointed to reforms under the National Ordinance for Games of Chance (LOK), claiming that new regulatory tools had been introduced to improve oversight.

But her earlier statements, captured without coercion or misrepresentation, tell a different story. The documentary carefully contrasts her public denial with her candid remarks at the conference, making clear that the CGA’s reforms, while technically enacted, are not being enforced with seriousness or independence.

In practice, there remains no evidence of a functioning compliance regime in Curaçao, merely the simulation of one.

Licensing as a legal workaround: how industry actors describe Curaçao.

The documentary also includes testimony from other SiGMA participants that reinforces the same concerns. At minute 24:30, a European slot supplier states plainly that his games are available to German players via Curaçao-licensed sites. He acknowledges that this is illegal under German law, but explains that “it’s the only way to make money in Germany.”

At minute 25:00, a payment provider describes how transactions are processed through companies using Curaçao, an African island (Anjouan) or North American indigenous licences (Kahnawake).

And by minute 48:00, a sales agent tells the reporters that if they want a licence “with no regulation at all,” they should try Anjouan.

What is striking is that these conversations take place in proximity to the CGA’s own exhibition stand, without interference or contradiction. There is no indication that the CGA objected to such statements or attempted to clarify that their licence does not authorise operations in regulated EU markets. If the regulator disagrees with this interpretation of its authority, it has yet to demonstrate it.

Nardy Cramm: the journalist who exposed the system and paid the price

From minute 34 onward, the documentary features an extended and deeply personal account from Nardy Cramm, one of the most committed investigative voices against the Curaçao gambling regime. Formerly based on the island, Ms Cramm runs SBGOK and campaigned with the Knipselkrant Curaçao against the role of trust offices, political figures and opaque financial structures that facilitated online gambling under the guise of regulation.

In 2013, following the murder of whistleblower and politician Helmin Wiels (an outspoken critic of corruption within the Curaçao government and its ties to the gambling industry) Ms Cramm fled the country. She has since lived in hiding, citing persistent fear as she fears for her life. Despite these conditions, she continues to pursue over a dozen legal cases in Curaçao’s courts, which are still active.

Her testimony in the documentary lays bare the structural deceit underpinning Curaçao’s licensing model. She describes how local trust offices act as the legal directors for gambling companies, allowing the actual beneficial owners to remain concealed.

According to her estimates, over 20,000 online casinos have used this structure over the years, generating “hundreds of billions” in turnover annually. She notes that Curaçao’s population of roughly 150,000 remains largely unaware of the scale of these operations, let alone the public risks they create.

Her conclusion is stark: Curaçao is not a regulatory jurisdiction. It is a “protection mechanism” designed to create the illusion of legality for business models that would not survive scrutiny elsewhere.

What Malta Media has previously reported:

This is not the first time Malta Media has raised concerns about Curaçao’s reform agenda. In Curaçao’s Make-Believe Makeover?, we examined the 26 June 2025 UBO register extension and noted the complete absence of enforcement detail.

Historical UBOs may never be disclosed. Know-Your-Customer (KYC) checks remain undefined. The CGA itself admitted that many licence applicants failed to submit complete documentation, yet it continued to issue extensions to non-compliant operators.

In Curaçao’s New Gambling Rules: Cash Grab or Real Reform?, we deconstructed the LOK law’s fee structure and complaint handling mechanisms. While the CGA claims to introduce consumer safeguards, operators remain free to choose their own ADR bodies, and players are left with no meaningful recourse. The ADR process is non-binding, lacks independence and functions primarily as a delay mechanism.

In CGA Extends Provisional Licences Under LOK Law, we reviewed the decision to prolong provisional licences despite widespread non-compliance. The CGA’s justification was that it preferred “collaboration and education” over sanction. But this tolerance comes at the expense of integrity.

Our earlier piece Curaçao Gaming Licenses: What a Spectacular Sh*t Show documented the collapse of the master licence system and the chaos that followed. Promised direct licences were delayed. Thousands of operators were left in limbo. And far from transparency, the CGA closed its application portal, citing “necessary updates.”

Finally, in Corruption Fuels Curaçao’s Gambling Crisis, we explored how the CGA’s leadership (especially figures like Cedric Pietersz and Ms Shortt) has actively contributed to preserving the culture of secrecy. We examined the deep entanglement of trust offices, government advisors and platform operators, many of whom appear to move freely between roles.

The CGA’s passive role: licensing without enforcement!

A particularly notable example is BC.Game, a high-profile crypto gambling platform operating under a Curaçao licence, which attracted significant regulatory concern from multiple jurisdictions. Allegations surrounding BC.Game included the targeting of players in restricted markets, lack of transparent KYC procedures and the use of cryptocurrencies to obscure payment flows.

Despite these issues being publicly reported and flagged by compliance monitors, the Curaçao Gaming Authority took no visible enforcement action. The CGA neither suspended the licence nor issued any sanctions, instead remaining silent as the operator continued its activities across questionable markets.

A call for accountability: the Ministry of Finance must now investigate!

It is no longer sufficient for Minister Javier Silvania to issue assurances while avoiding substantive questions. The CGA’s reform process is not credible. The statements made by Ms Shortt, the lack of enforcement against non-compliant actors and the repeated delays in implementation have undermined the entire structure.

The Ministry of Finance must initiate an independent investigation into both the leadership and advisory structures of the CGA. This should include a review of all consultant contracts, disclosures of conflicts of interest and a complete audit of all licence issuance decisions since the start of the LOK transition.

Final thoughts: the risk of international isolation

Until Curaçao confronts these issues head-on, the risk of international censure grows. The Financial Action Task Force (FATF) and European regulators will not continue to accept Curaçao’s paper reforms if they are not matched by demonstrable enforcement. A regulatory model that permits hidden ownership, forum shopping and unlicensed access to restricted markets will ultimately collapse under its own contradictions. If this level of passivity defines Curaçao’s approach to oversight, it undermines the very notion of regulation.

The comments made by Ms Aideen Shortt, recorded on the floor of a gaming conference, have lifted the curtain. What lies behind it is not reform. It is a carefully constructed illusion, one that now stands exposed. We encourage international regulators, financial crime units and responsible  gambling  advocates  to  listen  to  the  ARD  investigation  themselves:

🔗 ARD Doku – Suchtgeschäft. Doku über illegale Online-Casinos (52 Min)

Do you have documents, recordings or knowledge of wrongdoing involving the CGA or their representatives?

If you are in possession of information relating to misconduct, conflicts of interest, regulatory failures or politically influenced licensing decisions involving the Curaçao Gaming Authority, its consultants or associated trust service providers, we encourage you to come forward.

This includes but is not limited to:

• Internal emails, memoranda or correspondence disclosing deliberate regulatory omissions or market targeting strategies.
• Evidence of interference by political actors or advisors in licensing or dispute resolution
• Material showing that the CGA knowingly licensed operators who breached national laws
• Communications related to the concealment of Ultimate Beneficial Owners (UBOs) or falsified compliance
• Documents showing collusion between trust companies and CGA
• Evidence related to retaliation or intimidation against whistleblowers, journalists or

 

Your confidentiality will be protected. If you are concerned about professional repercussions or legal exposure, we can arrange secure communication channels, redaction protocols or intermediary handling in cooperation with legal professionals and press protection groups.

Our editorial team takes extensive steps to verify, anonymise and responsibly handle all sensitive material.

 If you have information to share, please reach out to us securely via: https://malta-media.com/whistleblower/. Your testimony, documents or evidence could help hold the appropriate actors accountable and protect future victims from regulatory neglect.

FAQs

What is the main criticism of Curaçao’s gambling reform?
The reform is criticized as performative, lacking genuine enforcement, with regulatory practices shaped more by convenience than compliance.

Who is Aideen Shortt and why is she controversial?
Aideen Shortt is a consultant for the Curaçao Gaming Authority (CGA) and the Ministry of Finance. Her statements in an undercover documentary suggest she promotes regulatory loopholes rather than reforms.

What did the ARD documentary reveal about Curaçao’s gambling oversight?
The documentary uncovered systemic weaknesses, conflicts of interest, and a deliberate lack of enforcement allowing operators to access restricted markets unlawfully.

Does Curaçao restrict online gambling access to EU countries?
According to Shortt’s comments, Curaçao imposes no restrictions on operators targeting countries like Germany, France, and Spain—except North Korea.

Why are trust offices in Curaçao problematic?
They act as proxy directors for online casinos, enabling anonymity of real owners and facilitating massive unregulated gambling operations.

What is the CGA accused of ignoring?
The CGA is alleged to have ignored red flags such as illicit market targeting, incomplete documentation from licensees, and violations of national laws by license holders.

What role did journalist Nardy Cramm play in the exposé?
Cramm provided key testimony, having investigated and criticized Curaçao’s gambling regime for years. She fled the island in fear after exposing corruption.

How are Curaçao-licensed casinos operating in restricted markets?
License holders often use Curaçao as a legal façade while targeting countries where online gambling is restricted, bypassing national regulations.

What action is being demanded from Curaçao’s Ministry of Finance?
An independent investigation into the CGA’s leadership, consultant roles, and all licence decisions since the LOK law’s inception is being called for.

What is the international response to Curaçao’s reform claims?
Regulatory bodies like the FATF and EU may impose sanctions if the island continues to show paper reforms without real enforcement.