Investigation into suspected large-scale misconduct within Curaçao's new gambling licensing system.
WILLEMSTAD - Financial forensic investigator Drs. Luigi Faneyte has filed an extensive report with the Public Prosecutor’s Office against Finance Minister Javier Silvania and three other individuals. The report contains serious allegations of official misconduct, corruption, fraud, embezzlement, and money laundering related to the issuance of online gambling licenses under the National Ordinance on Gambling (LOK).
Major Questions Raised About "Maltese Investors"
The investigation focuses on the issuance of “provisional licenses” in November 2023 through a portal managed by Mario Galea, a "Maltese investor" proposed by Silvania. During a technical briefing in the parliament on February 23, 2024, Galea, Aideen Shortt, and Mario Fiorini were presented by Silvania as investors in the modernization of the gambling system. After critical questions from parliament regarding their roles and Silvania’s promises, a plan of action was promised, but it never materialized. Now, according to Faneyte, as Silvania refuses parliamentary scrutiny, it is time for the case to be referred to criminal justice.
Details of the Report
Faneyte’s report is extensive, spanning hundreds of pages. When asked why he is bringing the case to light now, Faneyte provided a clear answer:
"On November 15, 2023, Mr. Galea announced that the Gaming Control Board, with 170 employees, was ready to start issuing licenses. That comment caught my attention—170 Curaçaoans suddenly working in our gaming industry. That would be spectacular for our country. It sounded 'too good to be true.' From that moment, I began looking into the case, and unfortunately, my suspicions were confirmed. During the technical briefing in parliament, more than three months later, Silvania stated that no one had been hired and that they were looking for 85 people."
From that point, Faneyte's investigation picked up pace. More inconsistencies came to light. According to Faneyte, the statements made by Mario Galea, the investor appointed by Silvania to oversee the licensing process, contradicted the minister's statements on critical points.
This was particularly concerning to Faneyte due to the significant financial interests involved. He explained:
"At that point, it was clear to me that the process surrounding the issuance of these licenses was chaotic. For example, the Dutch Gambling Authority manages only a fraction of the number of licenses compared to Curaçao and employs over 100 people. When, during an organized meeting, representatives from the GCB stated that Galea was using 'Artificial Intelligence' to issue licenses, I knew things had gone seriously wrong. When crypto-casino BC.Game was declared bankrupt on November 12, 2024, I decided that enough was enough and began preparing the report."
The filing marks a pivotal moment in an ongoing investigation that could have significant implications for the future of Curaçao’s online gaming sector.
The case involving BC.Game, an online crypto-casino, has confirmed the most serious suspicions regarding Curaçao's gaming license issuance process. According to Faneyte, licenses were granted without adequate oversight, leading to the bankruptcy of operators and financial damages exceeding NAf 15 million in one case alone. There are also indications of money laundering activities and violations of anti-money laundering laws, including the Landsverordening Melding Ongebruikelijke Transacties (LMOT).
Faneyte refers to the bankruptcy of BC.Game, which occurred on November 12, 2024, just months after it had been granted a license. The casino left behind a debt of at least NAf 15 million. Court rulings reveal that one of the investors proposed by Silvania, Mario Fiorini, provided trust services to the company behind BC.Game. This raises questions about the role of investors and the reliability of the licensing system.
During his investigation, Faneyte discovered that Fiorini was actively involved in BC.Game, despite earlier claims by Silvania that investors would "not necessarily" play an active role in offering licenses. This is particularly concerning as a Maltese investor is now directly connected to the local trust sector.
Moreover, court judgments from the Joint Court of Justice reveal an attempt to transfer BC.Game's license to a new company just five weeks after it was issued. This move was made due to issues with creditors, including the Spanish Gambling Authority and two players. However, the court saw through the structure and declared both companies bankrupt. As a result, Curaçao is left with a debt of at least NAf 15 million, while the Ministry of Finance/GCB remains unreachable for comment. "Suddenly, no one answers the phone anymore," Faneyte notes.
In his complaint and letter to the Prosecutor General, Faneyte expressed his concern that Curaçao will ultimately bear the responsibility for these debts. He points to the risk of further lawsuits and the negative impact on the country's financial situation and international reputation.
Faneyte also criticizes a new proposal in the LOK (Landsverordening Kansspelen), which includes a provision that "third parties" can no longer be held liable. He claims that Minister Silvania is pressuring the Staten (Parliament) to quickly adopt this provision. Faneyte questions who exactly is meant by "third parties" and sees this as an attempt to provide legal protection for those involved in the case. He concludes that this move does not contribute to the reform of the gaming market, but rather indicates a personal interest on the part of the minister. Moreover, this also casts doubt on the tax treaty with Malta, which, according to Silvania, needed to be urgently signed.
Faneyte, who is a Certified Fraud Examiner (CFE), emphasizes in his letter to the Prosecutor General that more complaints may follow. He explains:
"The circle of involved parties appears to be larger than the individuals named in this first complaint. It seems to extend to people within the trust sector and the Gaming Control Board (GCB)."
According to Faneyte, an exceptional amount of evidence is available in this case:
"This is primarily due to statements from the minister himself, Mr. Galea, and Ms. Shortt. Secondly, many conversations with these individuals have been meticulously recorded by industry stakeholders. These conversations reveal, among other things, that Mr. Galea has told stakeholders they could make a lot of money if they worked with him. Thirdly, there is extensive communication between now 155 license holders and these individuals via email addresses that are outside the reach of our government. For example, javiersilvania.onlinegaming@gmail.com. This includes discussions about payment amounts, destinations, payment arrangements, and how to make the payments."
Faneyte’s findings raise serious concerns about the integrity of Curaçao's licensing process and the possible involvement of key figures in the local gaming and trust sectors. The ongoing investigation may uncover even more details about the scale of the issue and the people involved.
Faneyte has announced that he is now going public with his investigation because the evidence can no longer be ignored:
"There is a very extensive money trail. So we have to follow the money. And that’s exactly what I will be focusing on in the coming months, because our country deserves so much better. I have offered my selfless support to the Public Prosecution in conducting further investigations. Given the scale of this case, which seems to extend far into Malta, they could use all the help they can get."
Faneyte also intends to conduct further investigations into statements made by Minister Silvania, particularly related to his mention in the Panama/Paradise Papers, which list individuals allegedly involved in questionable tax schemes. Faneyte sees a pattern in the way Silvania defends himself:
"Earlier this year, the minister claimed in his defense, in response to questions from the States, that he invited questioners to provide evidence that he owns companies in Panama. But anyone who knows more than the basics about the Panama Papers knows that they got that name because the leak occurred at a law firm in Panama. It has nothing to do with whether someone owns a company in Panama. This is what the minister does: he diverts attention with a sharp reaction. But that trick has run its course."
"Follow the Money"
Faneyte stresses that this case could have far-reaching consequences and likely involves more parties. These details will need to come to light through further complaints. With a substantial dossier full of evidence—including statements, recorded conversations, and extensive communication with license holders—he is calling for a thorough investigation into the financial flows:
"There is a detailed money trail. This is a unique opportunity to uncover the truth and restore justice. Curaçao deserves transparency, integrity, and a chance to do better. This investigation must be pursued to the fullest."
Faneyte’s commitment to ensuring that the truth is exposed underscores the gravity of the situation, and his call for transparency resonates strongly as the investigation progresses.
