WILLEMSTAD – Illegal gambling and a large cash-driven informal economy are emerging as a reinforcing pair of vulnerabilities in Curaçao’s fight against money laundering, according to the island’s latest Mutual Evaluation Report under the fourth round of the Caribbean Financial Action Task Force (CFATF).
The report describes how illicit cash flows generated through unlicensed gambling activities can be quickly absorbed into everyday economic life, where informal transactions, limited documentation, and weak verification practices make it easier to disguise the origin of funds.
A long-running blind spot: illegal lotteries and cash circulation
While Curaçao has a visible, regulated gambling sector, the CFATF evaluation points to persistent risks tied to illegal gambling—particularly lottery-style games that operate outside licensing structures. These schemes are not just a social nuisance; they generate large volumes of cash that can be layered into the legitimate economy through routine spending, cash deposits, third-party accounts, and front businesses, the report warns.
The concern is amplified by Curaçao’s broader cash usage and informal economic activity. The evaluation highlights that where large segments of commerce occur with limited paper trails, money launderers have more opportunities to “blend in,” especially when the proceeds originate from cash-heavy crimes such as illegal gambling.
Online gambling’s international footprint raises the stakes
Beyond street-level or neighborhood gambling, Curaçao’s online gaming sector adds another layer of exposure because of its cross-border nature. The CFATF report flags the inherent money-laundering risks of online gambling models, including high transaction volumes, remote onboarding, and the ability to move funds internationally at speed.
These risks are also part of why Curaçao has been under pressure for years to modernize supervision of the sector. Curaçao’s Gaming Control Board confirms that the new National Ordinance on Games of Chance (LOK) has entered into force, framing it as a major reform designed to strengthen regulation of online gaming.
The CFATF evaluation, however, focuses less on intent and more on effectiveness: whether Curaçao’s system consistently detects and disrupts laundering linked to gambling activity, including illegal gambling proceeds that may be introduced into the financial system through intermediaries, payment channels, or cash-intensive businesses.
Why illegal gambling and the informal economy feed each other
The report notes that these risks are not isolated. Illegal gambling produces cash. The informal economy provides the pathways to circulate that cash with fewer questions asked. The combination, the CFATF evaluation suggests, can weaken the effectiveness of controls even when the formal banking sector has compliance rules on paper.
This dynamic also complicates enforcement and intelligence. When transactions are normalized as “everyday cash business,” it becomes harder for authorities to distinguish between legitimate cash activity and the laundering of criminal proceeds—unless there is strong data collection, inspections, and follow-through on suspicious transaction reporting across sectors exposed to gambling-related flows.
What the report implies for Curaçao’s next steps
For Curaçao, the evaluation adds urgency to closing gaps that allow cash-based illegal gambling proceeds to be cleaned through informal channels. That includes tightening oversight where gambling-related funds enter the system, improving risk-based supervision, and increasing the practical ability to trace cash from origin to end use—especially where informal trade, unregistered services, and limited invoicing make concealment easier.
The broader challenge is credibility. Curaçao’s financial system and its international reputation depend not only on new laws and institutions, but on proof that high-risk areas—such as illegal gambling and cash-driven informal activity—are being actively detected, investigated, and disrupted.