WILLEMSTAD – The Curaçao Gaming Authority (CGA) relied heavily on foreign private companies to carry out important parts of its gambling licensing process, raising questions about how independently the regulator has been operating under the country's new gambling legislation. Although the CGA retained the legal authority to approve or reject license applications, external companies were involved in examining documents, assessing applicants and preparing recommendations that influenced the licensing process.
The involvement of foreign advisers has attracted renewed attention following the departure of two Maltese consultants who played significant roles in the reform of Curaçao's gambling sector.
Minister of Justice Shalten Hato visits the Curaçao Gaming Authority (archive)
At the center of the controversy are Random Consulting, a Malta-based company associated with Mario Galea, and HSJ Consult, a company based in Cyprus.
Random Consulting was responsible for developing and supporting the digital licensing portal used by the CGA. However, its activities extended beyond maintaining the technology.
According to information previously provided by the CGA to investigative journalists from Follow the Money, Random Consulting also assisted with processing applications, checking documentation and carrying out administrative activities related to license applications.
The regulator explained that the scale of the gambling reform and the shortage of specialized expertise made it necessary to engage external professionals.
HSJ Consult performed a different but equally important function.
The Cyprus-based company conducted suitability assessments of gambling license applicants and prepared recommendations on whether applications should be approved or rejected.
On October 6, the CGA confirmed that HSJ Consult had been providing these recommendations under a service agreement since late 2023.
According to the authority, the recommendations were reviewed internally before any final decision was made.
Nevertheless, the extent of the companies' involvement has raised questions about whether the CGA possessed sufficient internal expertise to evaluate applications independently.
An investigation into the licensing portal identified accounts associated with seven Random Consulting employees and 18 HSJ Consult employees, alongside accounts believed to belong to CGA personnel.
These figures were obtained through examination of the system and do not represent an official staffing report from the regulator.
They nevertheless indicate that substantial parts of the licensing process involved external personnel.
Concerns About Potential Conflicts of Interest
The involvement of private companies has also raised questions about potential conflicts of interest.
Random Consulting had participated in developing Curaçao's new licensing framework before assuming an operational role in its implementation.
The company was also internationally active in providing services to gambling operators and suppliers.
This combination has prompted questions about the safeguards used to prevent advisers with commercial relationships in the gambling industry from influencing assessments involving their clients or business associates.
It remains unclear whether the CGA required external consultants to disclose all relevant commercial relationships with gambling operators, trust companies and other service providers.
There are also questions about whether consultants were required to withdraw from assessments when potential conflicts arose.
Random Consulting has previously emphasized that it had no authority to grant or refuse gambling licenses and that all final decisions remained the responsibility of the CGA.
However, the preparation of assessments and recommendations can play an important role in determining the outcome of a licensing procedure.
The central issue is therefore not simply who signs the final decision, but how independently the regulator examines the information and recommendations supplied by external companies.
Reform Intended to Strengthen Government Control
The controversy is particularly significant because Curaçao's new gambling legislation was introduced to strengthen government oversight of the international online gambling industry.
Under the previous system, international gambling companies frequently operated through sublicenses issued by private master license holders.
The National Ordinance on Games of Chance (LOK) was intended to replace that arrangement with a system in which gambling licenses are issued directly by the Curaçao regulator.
The reform was designed to give the government greater control over companies offering online gambling services from Curaçao.
However, the continued involvement of private foreign companies in license assessments has prompted questions about how much practical control the government exercises over the process.
The role of these advisers differs legally from that of the former master license holders because the consultants do not issue licenses themselves.
Nevertheless, their participation in evaluating applicants means that important parts of the licensing process have continued to take place outside the regulator's own organization.
The CGA has previously stated that its employees were involved in assessments from the beginning and that the organization has since developed additional internal expertise.
It remains unclear whether the regulator can now conduct all parts of the licensing process independently.
Questions also remain about whether HSJ Consult continues to perform suitability assessments following the termination of the CGA's cooperation with Random Consulting.
The developments have intensified scrutiny of whether Curaçao's gambling reform has achieved its intended objective of establishing a genuinely independent and professionally equipped regulatory authority.