Official Curaçao Master License 365/JAZ is no more.

[maxd]

So it would appear that Curaçao Master License 365/JAZ aka Gaming Curaçao has ceased to be a thing. Unfortunately some of their sublicensees are still claiming to have a 365 sub-licence which is not cool. Doubtless they’re just slow to the mark but until they get their act together players should proceed with caution: playing at an unlicensed casino is often no better than throwing dice in a dark alley with guys named Jake and Mongo.

 

[conker]

Wow, appears to be a lot of changes going on over in Curaçao. No doubt we will start to see some out-of-favour jurisdictions rise back to prominence as these sub-license holders look to continue trading.

 

[jasonuk]

Wow, appears to be a lot of changes going on over in Curaçao. No doubt we will start to see some out-of-favour jurisdictions rise back to prominence as these sub-license holders look to continue trading.

I think we're entering the final phase of the Curacao license migration now (where the master licenses are removed) - so a number of the operator migrations have been happening in the past 12 months. Costa Rican "business licenses" have become a hot topic - no footprint, no oversight, no player protections...

So if people thought a Curacao license was worthless (which from a player perspective, it basically is), be ready for the rollercoaster of the new wave of even worse licenses...

 

[maxd]

Quite so! I’ve noticed that Anjouan appears to be in a particularly fertile area for this “new wave”. New "licensing bodies" in that area are popping up like mushrooms after a summer shower. I think I’ve seen at least two other islands in the Union of the Comoros decide that now is the time to enter the game.

- Max

 

[bamberfishcake]

I was wondering how this might work.

My understanding is that any new licence applications were to go through the new portal.

However, I noticed Master Licence Holders granting new licences after the change was announced.

I assume all existing licences are being migrated across? Can anyone clarify?

 

[maxd]

Last I heard the Curaçao government — Department of Finance specifically — had extended the right for Master License holders to do what they do for at least a year, possibly longer. So yes, they certainly can _extend_ sub-license agreements for that period and — IIRC — they can also add properties to an existing licensee's group. I think there was a stipulation that brand new licensees had to go through the GCB (Gaming Control Board) which, of course, is the new licensing body controlled by the Department of Finance.

As to the migration question I think the idea was that DoF still had to decide what the ultimate fate of the Master License holders was going to be. Would they be absorbed into the GCB and thereby retain their sub-licensees? Would they be disbanded and all the sub-licensees grandfathered into the GCB? AFAIK those details were TBD, at least as of earlier this year.

All this is from memory so I may have confuzzled some of the details. In my defence though there were a lot of grand pronouncements followed by a generous amount of waffling about when it came to actually doing the thing. The head of DoF was pretty obviously grandstanding for the middle months of 2023 and suddenly found that he was happier being busy in a closed office _without_ the media as company.

- Max

 

[bamberfishcake]

Last I heard the Curaçao government — Department of Finance specifically — had extended the right for Master License holders to do what they do for at least a year, possibly longer. So yes, they certainly can _extend_ sub-license agreements for that period and — IIRC — they can also add properties to an existing licensee's group. I think there was a stipulation that brand new licensees had to go through the GCB (Gaming Control Board) which, of course, is the new licensing body controlled by the Department of Finance.

As to the migration question I think the idea was that DoF still had to decide what the ultimate fate of the Master License holders was going to be. Would they be absorbed into the GCB and thereby retain their sub-licensees? Would they be disbanded and all the sub-licensees grandfathered into the GCB? AFAIK those details were TBD, at least as of earlier this year.

All this is from memory so I may have confuzzled some of the details. In my defence though there were a lot of grand pronouncements followed by a generous amount of waffling about when it came to actually doing the thing. The head of DoF was pretty obviously grandstanding for the middle months of 2023 and suddenly found that he was happier being busy in a closed office _without_ the media as company.

- Max

Thanks for reply.

That makes sense. Would have caused a storm if licences were being dished out only to be invalid as a result of the change.

 

[Guntis]

Thanks for reply.

That makes sense. Would have caused a storm if licences were being dished out only to be invalid as a result of the change.

I've seen some companies that help with casino licensing warning that all Curacao licenses issued by the Curacao Master Providers will expire in 2024. I don't know how true that is, as it could be a sales trick to push potential customers into getting licenses through them.

For example:

licensegentlemen.com/gcb-curacao-license/

 

[maxd]

Yeah, I’d be a little sceptical of that, at least until there was good evidence on hand to support it.
From what I’ve seen the Master License holders have a pretty significant amount of pull with the DoF. 365 was the smallest so maybe they didn’t have sufficient clout but 8048 in particular is _huge_ and I think has been able to shift the winds a fair amount in terms of that the DoF actually does and doesn’t do. I seriously doubt anything is going to happen to them without their cooperation and being sidelined doesn’t sound like something they’d be willing to put up with.

- Max

 

[dunover]

So in gambling safety relevance, they're swapping a cat turd for a dog turd. The fat bloke in the panama hat and stained white suit with cigar ash tumbling down the front, who takes a few one-hundred dollar bills slipped in between the pages of your license application paperwork plus a bottle of Jack Daniels, is simply relocating to some other sweaty tropical location?

Or is Boris Johnson now pursuing another career in the press?

 

[Genia]

actually we've been strong-armed by our gaming clients to find feasible solutions to the slowly dying Curacao license, so we've conducted a thorough research, read loads of legal paperwork, crossed-referenced information from various different sources and we found is that Anjouan license is, well, good enough. for startups is the training wheels they need. more and more PSPs, Banks and platforms start to recognize Anjouan as the new Curacao. some argue that its validity is reinforced mainly by its growing popularity. most Curacao operators never sought it to be UKGC or even MGA equivalent in terms of regulatory requirements and respectability and they were looking to reach just the minimal threshold to get good enough PSPs, Banks, platforms etc, and Anjouan arguably does just that.
time will tell how the story with the new GCB regulation will unfold, being the costs nearly tripled, but for now Anjouan seems to take its place for time being.
P.S. there is ever newer license in town - VGA. issued recently by Vanuatu. seemingly it has more solid legal basis to it than the alternatives but its issue for another thread.

 

[Guntis]

Vanuatu, is this where sea cucumbers deal with casino licenses?

 

[maxd]

The trouble with Anjouan is the same problem we’ve seen with Costa Rica for decades: invisibility. Casinos with the Anjouan license ignore player complaints, for example, quite freely. And having looked into it briefly it seems there is little or no recourse in terms of getting Anjouan to deal with their licensees bad behaviour.

So how is Anjouan anything but another useless rubber stamp? I get that it’s (maybe) better than saying “sorry, we have no license” but that’s a pretty low bar and nothing Anjouan should be applauded for.

- Max

 

[jasonuk]

So how is Anjouan anything but another useless rubber stamp? I get that it’s (maybe) better than saying “sorry, we have no license” but that’s a pretty low bar and nothing Anjouan should be applauded for.

I would say that makes it worse - if they have no license, a player is at least somewhat alert to the "I'm about to be ripped off" situation... if they have a worthless license, a player will wrongly infer rights (that don't exist) and get the bad news when they've been scammed.

Only have to look at the number of threads out there of people trying to file resolver complaints (a free pro-consumer website for filing reports against UK-based companies) against Curacao (and worse) operators... they don't know their rights, they therefore don't understand they don't have any meaningful rights in that situation... and then the penny drops they've been scammed and get angry.

I appreciate there are a few operators in Curacao (I always mention 3Dice as an example) that have stood the test of time in the high seas, but many of the big names are clearly dishonest in their behaviour and when the dark times come they will be ready and willing to rugpull their customers - after all, we're already seeing that in the recent exodus.

To summarise - it may be better for the operator, but that's it.

 

[bamberfishcake]

Mind you, it wasn't that long ago that many wouldn't dare go to Curacao licenced sites.

While licencing is important and most certainly creates some boundaries, in off-shore territories with lax licencing, the operator is often the mitigating factor.

Were it not for the murky waters of Curacao, there would be some decent casinos missing from the playlist.

I doubt it will be long before the occasional name starts appearing as a recommended casino from an unfavourable jurisdiction.

 

[Genia]

Exactly.
Curacao and its contemporary versions will always be the training wheels for newcomers as not everyone has millions of $ as starting capital as opposed to less than 50K "entry Level" license that these jurisdictions offer.

 

[jasonuk]

Exactly.
Curacao and its contemporary versions will always be the training wheels for newcomers as not everyone has millions of $ as starting capital as opposed to less than 50K "entry Level" license that these jurisdictions offer.

That's a double-edged sword though. It aligns with @bamberfishcake's point about upstarts that have made a positive name for themselves - but also a casino with insufficient capital (to me, $2m sounds like an absolute minimum for liquidity) is a walking insolvency - it only takes one lucky winner, or a poorly designed bonus offer, or a third party to stiff them on payment and they're done for.

 

[Genia]

That's a double-edged sword though. It aligns with @bamberfishcake's point about upstarts that have made a positive name for themselves - but also a casino with insufficient capital (to me, $2m sounds like an absolute minimum for liquidity) is a walking insolvency - it only takes one lucky winner, or a poorly designed bonus offer, or a third party to stiff them on payment and they're done for.

I agree but look what happened to Genesis group. I know their story first-hand so i'm confident in what i'm saying.. they started as 2 entrepreneurs and a dog, but they they were heavily funded (way more than 2m) and they had a pretty good run for a few years to the extent they were second before going public. until everything collapsed and everyone was let go.
what i'm saying is yes, being well funded sure helps but it doesn't guarantee longevity in any way. and I don't think spending 50K on a license is enough, no, but sometimes you can do just fine with 300K-500K as initial capital. I've seen it happening already numerous times.

 

[jasonuk]

what i'm saying is yes, being well funded sure helps but it doesn't guarantee longevity in any way.

I don't think anyone was suggesting otherwise - I certainly didn't.

and I don't think spending 50K on a license is enough, no, but sometimes you can do just fine with 300K-500K as initial capital. I've seen it happening already numerous times.

This only makes sense if you are capping your liability suitably low (e.g. $25k or $50k) - if a casino is offering $250k liability slots with $300k liquidity, people should run away as fast as they can... because either they are borderline insolvent when the hit happens, or they're going to use increasing aggressive terms to slow-pay or no-pay.

Given how many sites have seen a $50k+ winner and baulked at the idea of paying them in a timely fashion - this isn't a theoretical concern, this is very much present day Curacao.