Regulatory Arbitrage in Action: Curaçao, BVI and Gibraltar!

How jurisdictional shopping enabled oversight avoidance in the Mansion Group network.

In today’s fragmented global regulatory environment, cross-border corporate structuring has become an effective tool to weaken enforcement, obscure ownership and bypass accountability. Nowhere is this more evident than in the case of Mansion-linked entities and their operational presence across Curaçao, the British Virgin Islands (BVI) and Gibraltar.

This article explores how these three jurisdictions (often lauded for their business-friendly frameworks) have, when used together, enabled Mansion-associated entities to operate in ways that exploit the blind spots and asymmetries of international financial and regulatory systems.

This is not merely a matter of technical non-compliance. Rather, it reflects a systemic failure in regulatory coordination, where firms can claim full licensing status while eluding the spirit of anti-money laundering (AML) and transparency obligations.

Curaçao: A Gateway of Minimal Interference

At the centre of Mansion's offshore operational structure lies Midas Entertainment B.V., a Curaçao-licensed vehicle linked to figures such as Herman Behr and Elaine Behr.

Curaçao’s licensing regime, long critiqued for its lack of independent regulatory enforcement, offers licensees near-total operational autonomy. Once a master licence is granted, sub-licensees often function with limited oversight. Key concerns include:

• Minimal AML supervision at the operator level
• No public disclosure of beneficial ownership
• No effective cooperation with EU or FATF-standard regulators

Despite the presence of a new supervisory body, the Curaçao Gaming Authority (CGA), the transition from the legacy regime remains patchy. Companies like Midas Entertainment have continued to operate under the old framework, even while expanding their reach through affiliate networks and white-label partnerships.

This has allowed Mansion-linked entities to anchor gaming operations in a zone of weak scrutiny, while publicly claiming licensing legitimacy.

British Virgin Islands: Structuring Secrecy as a Service

The use of the BVI (and in particular entities such as Violet Star Group Ltd) provided another layer of opacity. With the administrative support of Alliance Corporate Services, this structure offered:

• Nominee directorships and secretarial proxies
• No public UBO registry
• Zero corporate tax liabilities
• No requirement for locally substantiated economic activity

The BVI Financial Services Commission (BVI FSC) maintains formal regulatory competence, but in practice, company formation agents serve as primary gatekeepers. With no clear mechanisms for cross-border enforcement or real-time disclosure, BVI entities can easily be used to obscure links between shareholders and operational funds.

It is within this context that individuals such as Guy Gussarsky and his close network were able to administer control without revealing their true roles in public documentation.

The result is a separation between ownership, control and liability; a separation that is legally permissible but strategically exploitative.

Gibraltar: The Illusion of Prudence

Gibraltar has long promoted itself as a jurisdiction of serious gaming oversight. Yet, in Mansion’s case, it formed the final node in a tri-jurisdictional arbitrage strategy.

Entities such as Mansion (Gibraltar) Ltd, Convertonet Ltd and Apollo Online Consultancy Ltd operated under the regulatory purview of the Gibraltar Gambling Division, but public information suggests that real control rested elsewhere.

Gibraltar’s reliance on key legal figures and political facilitators (including Albert Isola, Peter Isola, Marcus Killick, James Lasry and Michael Castiel) provided firms with an effective combination of reputational shielding and flexible structuring. Gibraltar’s strengths for operators lie in:

• Favourable tax rulings for IP-heavy companies
• A willingness to recognise foreign licences or cross-border equivalency
• Confidentiality surrounding legal and corporate advisory roles

The result is a situation where Gibraltar-based entities can act as public-facing compliance representatives while decision-making and financial control remain elsewhere, often in less regulated jurisdictions.

Interlocking Weaknesses: One Ecosystem, Not Three Islands

While each jurisdiction offers plausible deniability and its own legal justifications, the combined effect is a regulatory vacuum. A simplified schematic of the Mansion structure reveals:

• Curaçao for operations
• BVI for secrecy and wealth protection
• Gibraltar for tax optimisation and public legitimacy

No single regulator has a full view of the network. No single entity accepts responsibility for full oversight. And no jurisdiction is compelled to cooperate across borders unless compelled by treaty or legal challenge.

The UBOs behind these operations (including Putera and Michael Sampoerna) remain shielded not because of criminal cunning, but due to regulatory architecture that allows such compartmentalisation to persist.

Our Conclusion

This is not an isolated loophole. It is a structural feature of international business regulation. The Mansion Group's use of Curaçao, BVI and Gibraltar showcases how legal structuring, when carefully designed, can operate with the outward appearance of legitimacy while avoiding the obligations expected of high-risk sectors like gambling and crypto-finance.

Regulators must recognise that jurisdictional shopping is not merely a compliance strategy. It is a threat to transparency, investor protection and financial crime prevention.

Without harmonisation of standards, meaningful cross-border enforcement and public pressure for reform, such arbitrage will continue and the public will remain unaware of who truly controls the platforms handling their money.

FAQs

What is jurisdictional shopping?
Jurisdictional shopping refers to selecting favorable legal systems across different countries to reduce regulatory scrutiny and legal obligations.

How did Mansion Group use Curaçao in its operations?
Mansion Group used Curaçao for its lax gaming regulations and minimal AML enforcement, enabling operational autonomy without effective oversight.

Why is the British Virgin Islands (BVI) attractive for secrecy?
BVI offers corporate anonymity, no public UBO registry, and tax-free structures, which help conceal ownership and wealth management activities.

What role did Gibraltar play in Mansion’s network?
Gibraltar provided public legitimacy and favorable tax treatment, acting as a face of compliance while real control lay elsewhere.

Are these jurisdictions breaking any laws?
Not necessarily. These jurisdictions allow legal structures that, while technically compliant, undermine transparency and accountability.

Who are the key individuals linked to the Mansion Group?
Notable figures include Herman Behr, Elaine Behr, Guy Gussarsky, and ultimate beneficial owners Putera and Michael Sampoerna.

What is the main regulatory concern raised in the article?
The lack of cross-border regulatory coordination enables firms to exploit legal differences, making oversight nearly impossible.

Why is there limited transparency in these offshore jurisdictions?
These regions often lack public ownership registries, enforce weak AML laws, and prioritize business privacy over transparency.

How do these structures impact global financial crime prevention?
They create blind spots that hinder the tracking of illicit funds, weakening anti-money laundering efforts worldwide.

What can be done to address jurisdictional shopping?
Coordinated international reforms, standardised transparency rules, and treaty-based cooperation are needed to close these regulatory gaps.

Legal Disclaimer

This article is intended for informational purposes and reflects the author's analysis based on publicly available records, regulatory data and credible sources. No allegations of unlawful conduct are made. The mention of any individual or entity, including Mansion (Gibraltar) Ltd, Midas Entertainment B.V., Violet Star Group Ltd and persons such as Putera Sampoerna, Michael Sampoerna, Herman Behr, Elaine Behr, Guy Gussarsky, Albert Isola, Peter Isola, Marcus Killick, James Lasry and Michael Castiel, does not imply wrongdoing unless established by a competent authority.

Nothing in this article constitutes legal advice. All views expressed are those of the author and are protected under applicable laws governing freedom of expression and investigative journalism.

If any party believes that information presented is inaccurate, they are invited to contact the editorial team at [email protected] for clarification or response.