Curaçao’s Make-Believe Makeover?

A reform story riddled with delays, loopholes and unanswered questions!

The past week has been eventful for Curaçao's gambling sector. On paper, the headlines suggest progress: new dispute resolution rules, a six-month licence extension and an updated UBO registry deadline. But beneath the surface, the island’s much-publicised regulatory reform appears more like an elaborate illusion than a clean break with the past.

A UBO register without UBOs?

On 26 June 2025, Curaçao’s Finance Minister Javier Silvania announced yet another delay in implementing the country’s mandatory Ultimate Beneficial Ownership (UBO) register. Entities now have until 30 September to submit their data to the Chamber of Commerce, pushing the original July 1 deadline further down the road.

But more worrying than the delay itself is the glaring absence of detail.

• Will historical UBOs be included or only newly appointed nominees?
• Will the Ministry of Finance carry out proper KYC checks on the disclosed individuals or will this sensitive task be left (once again) to corporate service providers acting as de facto trustees?

For a jurisdiction under scrutiny for lax enforcement and hidden ownership structures, the failure to answer these basic questions is not just troubling. It’s telling.

Provisional licences… provisionally extended

On 24 June, the Curaçao Gaming Authority (CGA) extended a range of provisional licences for another six months. The move was framed as a practical measure, giving applicants more time to comply with the new National Ordinance for Games of Chance (LOK).

But what it really signals is this: Curaçao still isn’t ready.

The CGA itself admitted that a significant portion of operators failed to submit complete documentation. In other words, even after years of planning, the regulator continues to hand out licences to companies that fall short of baseline compliance.

The new structure is supposed to ensure tighter AML procedures, dispute resolution mechanisms and direct regulation under the CGA. But delays, extensions and selective enforcement suggest that little has changed in practice.

The master licence era may be ending, but the culture of opacity persists.

New complaint rules, old enforcement problems

The CGA’s recently published complaint-handling guidelines are, on the face of it, a welcome addition. Operators must now provide clear, multilingual complaint procedures and timelines. Issues must be handled by human staff and are required to report dispute data biannually.

Yet the CGA has explicitly stated it will not intervene in individual cases.

A player files a complaint, like the recent one against Bizzo Casino and its affiliate Playamo Partners (alleging excessive KYC, unpaid winnings, GDPR breaches and payments processed under the label “Affiliate”) the regulator may record the data, but will likely stay silent.

According to the complaint, the operator’s web of companies stretches across Curaçao, Cyprus and Estonia, with shared directors and payment infrastructure. The accusations also include breaches of European licensing laws, particularly targeting Portuguese users without legal authorisation.

If this complaint doesn’t warrant direct action, what does?

A jurisdiction still selling shadows

Despite the legislative fanfare, Curaçao remains attractive for all the wrong reasons. With tax rates as low as 2% on net profits and minimal enforcement risk, the island continues to offer an offshore haven for high-revenue operators seeking to limit liability and maximise opacity.

Stake (a platform that reportedly generated over $1 billion in profit last year) paid a mere $20 million in taxes under its Curaçao licence. It’s little wonder why so many companies still cling to their Curaçao footprint, regardless of the reforms.

Meanwhile, cases like Cyberluck and the Bahsine dispute (where a player’s winnings were withheld and the master licensee eventually declared bankruptcy) illustrate how even judicial rulings against operators often lead nowhere.

Reform or rebranding?

The CGA and Curaçao’s government continue to promote their transition as a genuine attempt to meet international standards. But transparency means more than publishing guidelines. It means enforcing them, here my questions:

• Will the new UBO register actually expose the real owners of these companies?
• Will historical UBOs be included or conveniently left out?
• Will the CGA begin investigating serious operator misconduct or merely log statistics?

Until those questions are answered and until the CGA proves it can do more than issue licences and extensions, the reforms will remain cosmetic. The house may look newly painted. But the foundations are still crumbling.

FAQs

What is the UBO register and why is it important?
The UBO register is intended to disclose the Ultimate Beneficial Owners of gambling entities. It is a key tool for financial transparency and anti-money laundering compliance.

Has the Curaçao UBO register been implemented yet?
No, its implementation was delayed again on 26 June 2025. The new deadline for data submission is 30 September 2025.

Will historical UBOs be included in Curaçao’s register?
As of now, the government has not clarified whether historical UBOs will be included or only newly appointed ones.

Are Curaçao gambling licences still being issued?
Yes, provisional licences have been extended for another six months, indicating ongoing regulatory delays.

Is the Curaçao Gaming Authority (CGA) enforcing new rules?
Despite new complaint-handling rules and updated licensing requirements, enforcement remains weak and selective.

What are the key features of Curaçao’s new complaint-handling rules?
Operators must now provide clear, multilingual complaint procedures, human response staff, and biannual reporting of disputes.

Does the CGA investigate individual player complaints?
No, the CGA has stated it will not intervene in specific cases, merely logging the information without taking enforcement action.

Why do operators still prefer Curaçao licences?
Low taxes (as low as 2%), loose oversight, and minimal enforcement make Curaçao attractive for high-profit offshore operators.

Are there known cases of unresolved complaints in Curaçao?
Yes, cases like Bizzo Casino and the Bahsine dispute illustrate how some complaints and even court decisions are ignored or unenforced.

Is Curaçao’s reform genuine or superficial?
While reforms are presented as progress, persistent delays, vague regulations, and non-transparent enforcement suggest cosmetic change rather than real accountability.