Responsibility of Curaçao Licensors in the BC.Game Debacle

Raoul Armando Behr, a prominent figure in Curaçao's business and gaming industries, has held significant roles over the past decades. As a member of the Curaçao Chamber of Commerce & Industry for the past 10 years, and COO of both e-Management Group and HBM Group for over two decades, his expertise spans corporate governance and gaming services.

Mr. Behr also serves as Managing Director of C.I.L. Curaçao Interactive Licensing N.V., a master license holder responsible for granting sublicenses to entities such as BC.Game’s previous operators, BlockDance B.V. and Small House B.V.

Curaçao Licensors Under Fire

Recent developments cast doubt on the role of master license holders like C.I.L. in ensuring compliance among sublicensees. Following the Dutch Supreme Court's landmark ruling, master license holders are now held accountable for unpaid winnings by their sublicensees. This judgment, authored by Zak Thomas-Akoo and published on iGamingNext, highlighted Cyberluck Curaçao N.V.'s liability for its sublicensee's failures. The case established a critical precedent: master license holders must uphold their duty of care to players globally.

C.I.L. Curaçao Interactive Licensing N.V., under Behr’s leadership, faces similar scrutiny. With BlockDance B.V. and Small House B.V.—both former operators of BC.Game—recently declared bankrupt, players and stakeholders are left with unpaid winnings totaling millions. Notably, both companies were implicated in attempts to circumvent player claims by shifting responsibilities between entities.

The BC.Game Bankruptcy Saga

On November 12, 2024, the Joint Court of Appeal of Curaçao ruled that BlockDance B.V. and Small House B.V. had failed to meet their financial obligations, resulting in bankruptcy. Evidence presented by SBGOK, the Foundation for the Representation of Victims of Online Gaming, demonstrated that both entities deliberately avoided paying winnings.
Claims from players, totaling over $2.6 million, and a €5 million fine from Spanish authorities remain unresolved. Despite this, Curaçao's Gaming Control Board (GCB) has avoided revoking their licenses, citing administrative disputes.

BC.Game has since moved its operations under Twocent Technology Limited, a company registered in Belize, and now operates under a license from the Union of Comoros. This relocation effectively shields its new operations from direct Curaçao jurisdiction, leaving unresolved claims in legal limbo.

Similarities with Cyberluck: A Warning for C.I.L.

The Cyberluck case serves as a cautionary tale for C.I.L. Curaçao Interactive Licensing N.V. Both companies issued numerous sublicenses under Curaçao’s historically lax two-tiered licensing system. The Dutch Supreme Court condemned this system as “out of hand,” emphasizing that master license holders bear ultimate responsibility for ensuring compliance. If Cyberluck can be held liable for its sublicensees’ unpaid winnings, the same logic could apply to C.I.L.

The parallels are undeniable. Like Cyberluck, C.I.L. issued licenses without stringent oversight. BlockDance and Small House failed to maintain sufficient funds to honor player winnings, a direct violation of licensing conditions. As SBGOK’s successful arguments in court show, the division of responsibilities between these entities was a façade to escape accountability.

The Role of Curaçao’s Gaming Control Board

Curaçao’s Gaming Control Board (GCB) has faced widespread criticism for its failure to act decisively against violators. In the BC.Game case, the GCB refrained from revoking licenses despite clear evidence of non-compliance. This leniency mirrors its inaction in other cases, such as Rabidi and similar offshore operators. Such negligence undermines trust in Curaçao’s regulatory framework and perpetuates the exploitation of players.

Legal Implications for C.I.L. and Curaçao’s Reform

With the Dutch court’s ruling as a precedent, SBGOK and other advocacy groups are likely to pursue similar claims against C.I.L. Curaçao Interactive Licensing N.V. The foundation has already demonstrated its ability to hold bad actors accountable, securing judgments against BlockDance, Small House and even Cyberluck. As Curaçao transitions away from its two-tiered licensing system under the new

National Ordinance for Games of Chance (LOK), the legal and financial liabilities of master license holders like C.I.L. could escalate.

Conclusion: A Call for Accountability

Raoul Armando Behr and C.I.L. Curaçao Interactive Licensing N.V. now face mounting pressure to address their role in the BC.Game scandal. The bankruptcy of its sublicensees, coupled with unpaid winnings and unresolved fines, highlights the systemic failures of Curaçao’s licensing system. The precedent set by the Dutch Supreme Court leaves no doubt: master license holders can no longer evade responsibility.

For players, advocacy groups like SBGOK offer a glimmer of hope. For C.I.L. and the Curaçao GCB, the stakes are clear: reform is not optional—it is inevitable. Failure to adapt will only invites further legal challenges and erodes the island’s standing in the global gaming industry.

FAQ's

Who is Raoul Armando Behr?
Raoul Armando Behr is a prominent figure in Curaçao's business and gaming sectors. He serves as the COO of e-Management Group and HBM Group and as Managing Director of C.I.L. Curaçao Interactive Licensing N.V.

What is C.I.L. Curaçao Interactive Licensing N.V.?
C.I.L. is a master license holder responsible for granting sublicenses to operators in the gaming industry, including previous operators of BC.Game like BlockDance B.V. and Small House B.V.

Why is C.I.L. facing scrutiny?
C.I.L. is under scrutiny due to the bankruptcy of two sublicensees, BlockDance B.V. and Small House B.V., who failed to meet financial obligations, leaving millions of dollars in unpaid winnings.

What is the BC.Game bankruptcy saga about?
The BC.Game bankruptcy saga involves claims of unpaid player winnings and legal issues surrounding its operators, BlockDance B.V. and Small House B.V., who were declared bankrupt in November 2024.

What happened in the Dutch Supreme Court ruling?
The Dutch Supreme Court ruled that master license holders, like Cyberluck, are responsible for ensuring compliance with their sublicensees and can be held accountable for unpaid winnings.

How is the Cyberluck case relevant to C.I.L.?
The Cyberluck case sets a precedent that master license holders, including C.I.L., are liable for their sublicensees' failures to meet financial obligations, including unpaid winnings to players.

Why hasn't the Gaming Control Board revoked licenses of violators?
Despite clear violations, the Gaming Control Board (GCB) has refrained from revoking licenses, citing administrative disputes, which has led to criticism for its lack of decisive action.

What is Curaçao's two-tiered licensing system?
Curaçao's two-tiered licensing system allows master license holders like C.I.L. to issue sublicenses to other operators. However, the system has been criticized for lacking adequate oversight and accountability.

What are the legal implications for C.I.L. under the new licensing reforms?
With Curaçao's new National Ordinance for Games of Chance (LOK), master license holders like C.I.L. face increased legal and financial liabilities, especially in light of past failures.

What can players and advocacy groups do in this situation?
Players and advocacy groups like SBGOK are pursuing legal claims to hold license holders accountable for unpaid winnings and to advocate for reform of Curaçao's regulatory framework.