Comtado Carib: Don't shoot the messenger
Estimation of Curaçao's revenue (including online gambling): Nearly 1% of the world's GDP. For comparison: the Netherlands has approximately 12% of the world's GDP flowing through its mailbox companies.
WILLEMSTAD - The 4th seminar on Investigation & Law Enforcement E-gaming, with the theme 'Money flows: banking and payment service providers 1.0,' presented a shocking picture of a situation that the average Curaçaoan is unaware of.
Everyone is accustomed to living their 'normal' life with all its ups and downs but has no real understanding of what is actually happening in Curaçao and the economic consequences it will have for themselves. And the worst part is that the 'average' Curaçaoan is unaware of the cause simply because they do not concern themselves with it, as this shadow economy is barely objectively portrayed in the local press.
The fact is that a global online gambling sector has established itself within the sovereign territory of Curaçao, generating billions in revenue, an almost unpronounceable figure. However, there is little supervision and no data is collected on this massive revenue, despite international requirements for such reporting by countries. According to international agreements, every country is obligated to have sufficient oversight and measures in place to prevent money laundering, terrorist financing, and proliferation within its legal and regulatory framework, as well as in its implementation.
Research indicates that from Curaçao, where this global online gambling sector operates, there is a significant lack of oversight and the necessary measures that should follow. This could result in Curaçao being placed on the 'grey-list' or even being 'black-listed' after evaluation by the CFATF in 2024.
In either case, this would lead to (international) correspondent banks severing ties with all banking institutions in Curaçao. As a consequence, international payment transactions would no longer be possible, severely crippling the local economy. The effects of this would directly impact every resident and business owner in Curaçao. Don't shoot the messenger, but there is a high probability that this could become the reality.
Summary of Guest Speakers
Mr. Ruben J. Suriel, balance of payments expert and former head of statistics and internal audit at the Bank of the Netherlands Antilles (BNA), provided insights into the background of gambling in the Antilles. Suriel, a highly knowledgeable speaker familiar with Curaçao, explained the challenges associated with not collecting statistics and was able to provide an initial estimate of the revenue generated.
He highlighted the correspondent banking problem, which arose when the United States tightened regulations on illegal gambling from the Curaçao offshore industry starting from October 2006. This issue continues to persist as Curaçao apparently lacks control over the trust sector that drives the gambling industry.
Preliminary calculations suggest that the annual revenue generated within Curaçao, including the online gambling industry, amounts to nearly 1% of the world's GDP. However, the tax contribution relative to this revenue is negligible, and there is a lack of supervision.
Mr. Charles van der Voort, former chief advocate general and public prosecutor specialized in fiscal procedural law and financial criminal law, provided a clear explanation of the legal significance of money laundering and the corresponding articles as defined in the Criminal Code.
Van der Voort also demonstrated his clear expertise and comprehensive understanding of the technical aspects of money laundering. The realization that the revenue within the online gambling sector surpasses that of the drug industry, along with the acknowledgment that no Dutch public prosecutor will venture into investigations, had a profound impact. It has become even more evident that the supervision, investigation, and law enforcement in the financial services related to the online gambling sector are completely out of control.
During the subsequent debate with the panel, unanswered questions remained: Who will solve this enormous problem, and what are the consequences of the current situation or the lack of change?
Looking ahead to Seminar 5, "Money Laundering, Fiscal Aspects & Case Study," on May 23, 2023:
Mr. Dr. Jan van Koningsveld, owner of the Offshore Knowledge Center NL, will specifically attend this seminar in Curaçao on Tuesday, May 23, 2023, from 14:00 to 17:00. He will provide explanations on money laundering and the risks associated with online gambling, discuss the (Supra) National Risk Assessment on money laundering, to which he contributed, and, last but not least, present a case study involving an analysis of a practical case related to F.A. Entertainment NV (Edobet), which was the focus of the Taxus investigation.
From the Edobet case, which is still pending in the Netherlands, it becomes apparent how this criminal organization was able to establish itself as an online gambling operator within a Curaçao-based shell company under the supervision of a trust office and license holder. Additionally, Jan van Koningsveld will provide further clarification on gathering and analyzing information from open sources. During his stay in Curaçao, on behalf of the Offshore Knowledge Center, he will conduct a separate training session specifically on this topic.
An extra training session has been scheduled, specifically designed for supervisors, compliance staff, and investigators.
In collaboration with Comtado Carib, the Offshore Knowledge Center is organizing a unique training session on obtaining relevant information from open sources. While the specifics may vary from country to country, the general principles remain the same. The situation in Malta will be discussed as an example, including how and which documents can be obtained from the Companies House in Malta. This seminar serves as a complement to the six-day training series on "Investigation & Law Enforcement in E-gaming" organized by Comtado Carib.
After this training, participants will be able to independently conduct open source investigations and understand the relevant information. This will enable them to ask better questions to their clients. Save the date: Thursday, May 25, 2023, from 14:00 to 16:00, at the University of Curaçao, Jan Noorduynweg 111.