Curaçao Gaming Authority Faces a Governance Probe

Curaçao spent two years rebuilding its gaming regime. It retired the master/sub-licence model, stood up a direct regulator and asked every operator on the island to re-document itself. The regulator’s supervisory board is now commissioning an independent review of its agreement with Random Consulting, the consultancy that worked on that reform.

The story is being covered as a political scandal, which it partly is. The question that matters to anyone holding or applying for a Curaçao licence is narrower and more practical: does this change anything about your licence, your timetable, or your banking? Our answer is no on the first two and possibly on banking, which is the only one worth spending time on.

What is actually being alleged

The dispute became public when Curaçao’s minister of finance, Charles Cooper, raised concerns about payments made in connection with the gaming sector’s modernisation, referring to an alleged annual payment of ANG 8.3 million (about €4.1 million) to a Malta-linked person or company, and questioning what services justified it.

Random Consulting Limited, the Malta-based company linked to Maltese gaming consultant Mario Galea, rejects the annual framing. Its position is that it has received approximately €3,426,406 in total since 2022 for work on the reform and modernisation of Curaçao’s online gaming framework. The gap between “€4.1m a year” and “€3.4m over four years” is the whole dispute, and it is not one an outside observer can resolve from the public record — because the agreement, the invoices and the work reports have not been published.

The CGA’s supervisory board has responded by identifying ten international firms as candidates to conduct an independent investigation into the agreement: its terms, the payments made, who had authority to approve it, and when. Prime Minister Gilmar Pisas has said the board will select one of the ten, and that releasing the contract publicly is the CGA’s decision, not his — adding that he does not hold a copy himself.

One timing detail is worth noting because it explains part of the confusion. The engagement is said to have begun in 2022. The work began under the Gaming Control Board, which continued as the Curaçao Gaming Authority when the LOK (the National Ordinance on Games of Chance) entered into force on 24 December 2024. The body now being asked to account for the agreement is the same organisation under a new mandate, which is an awkward structure for any inquiry to unpick.

Why this does not touch your licence

It is worth being precise about the chain of authority, because the instinct in the market is to assume regulator trouble is licensee trouble.

The same portal was the subject of a separate incident, unauthorised access from December 2025 to September 2026, which we cover in our note on the CGA portal data leak.

The distinction between regulatory risk and reputational risk is the whole analysis here. Regulatory risk would be a suspended authority, frozen applications, or a legal challenge to the ordinance itself. None of that is on the table. What is on the table is a story that gets filed away and resurfaces, six or nine months later, in a payment provider’s periodic review of the jurisdictions it accepts.

We have watched this pattern before, and the cost is rarely dramatic. It shows up as a slower onboarding, one extra round of questions, a lower initial processing limit. That is manageable, and avoidable if the credential is not the only thing holding up the relationship.

What to actually do

Hold the timetable. The 8 October 2026 terms-and-conditions requirement is unchanged, and it is the near-term item with actual consequences attached. Our Curaçao T&C deadline guide sets out what has to be in place, and the 2027 substance obligations are the follow-on that too many operators are still treating as distant. If you are unclear where your file sits against the current regime, the LOK and CGA explainer is the plain version.

Keep your own record clean. In any jurisdiction going through a governance review, the licensees who are comfortable are the ones whose files need no explanation. Verify your own standing rather than assuming it — our Curaçao licence check guide covers how to confirm what the register actually says about you.

Fix the single-credential problem, if you have one. This is the lesson of the last three years in Curaçao, and it has nothing to do with Random Consulting. Operators who held one offshore licence and nothing else spent the LOK transition exposed to every wobble in a single jurisdiction. Operators who held a second credential did not. The case for a second licence would stand without this headline: our Curaçao alternatives comparison and the migration guide cover the realistic second options and what moving actually involves.

You don’t need to raise it with your bank. If your bank or PSP asks about it, answer fully and accurately; otherwise there is no reason to introduce a jurisdictional governance story into a live onboarding. What a payments committee wants from you is a licence in good standing, a clean corporate structure, and a payment agent in the right place — for gambling flow, that means a Cyprus payment agent and an EMI relationship built for the sector instead of a consumer fintech account.

Curaçao is doing something uncomfortable in public: asking who wrote its rules and what they were paid. We read that as healthier than a jurisdiction that never asks. The operators least exposed to it are those who meet the 8 October requirement and no longer depend on a single licence. If you want that mapped against your own file, book a free consultation.

Iryna H.

Gaming Licensing at Vantegris

Iryna H. is part of the Vantegris team, which prepares and files licence applications across 40+ jurisdictions. This article was reviewed by Vladyslav S. (Compliance & Legal).

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This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.