Curaçao Gaming Lawsuits and the Netherlands Antilles Overhaul

Lawsuits against Curaçao-licensed online gambling operators have reshaped the industry over the past several years, with Dutch courts holding both individual casinos and the master license holders that authorized them liable for unpaid winnings and player losses. The litigation, driven largely by a Dutch player-advocacy foundation, has produced Supreme Court rulings, bankruptcies, criminal settlements, and ultimately a complete overhaul of how Curaçao licenses online gambling.

Why Operators Licensed in Curaçao Became a Legal Target

For most of its history, Curaçao did not license online casinos directly. The government issued four “master licenses” to private companies — Antillephone N.V., Curaçao Interactive Licensing N.V., Cyberluck Curaçao N.V. (Curaçao eGaming), and Gaming Services Provider N.V. — which were then permitted to sub-license an unlimited number of operators worldwide with little government involvement.¹²

The result was scale without oversight. A 2021 investigation identified roughly 12,000 illegal online gambling sites operating out of Curaçao, and a 2020 Financial Action Task Force review flagged the regime as a potential hub for money laundering.²³ Master license holders and regulators had a poor record of enforcing licensing terms, and players who lost money or had winnings withheld had almost no meaningful dispute mechanism.⁴ That gap is what the lawsuits filled.

The SBGOK Campaign Against Roughly 100 Operators

The most sustained legal pressure has come from the Foundation for the Representation of Victims of Online Gaming, known by its Dutch acronym SBGOK. Founded on March 27, 2019 and led by Nardy Cramm, the foundation has sued approximately 100 online casinos operating under Curaçao’s jurisdiction. Cramm reports that many chose to shut down rather than fight.⁵

SBGOK’s core argument attacks the master/sub-license structure itself: it says the system lacks transparency about who actually holds sub-licenses and who is accountable, and that the operators it has investigated — an estimated 10,000 to 20,000 sites — target addicted players, encourage excessive gambling, and ignore rules against underage gambling.⁶

Courts have increasingly accepted that argument. The Joint Court of Justice issued appellate rulings in November 2022 finding the sub-license system illegal, and the Dutch Supreme Court confirmed the illegality of the sub-license system in two rulings on December 22, 2023.⁶

Cyberluck: Master Licensees Held Liable for Unpaid Winnings

The most consequential decision for players came on December 24, 2024, when the Dutch Supreme Court held Cyberluck Curaçao N.V., one of the four master license holders, liable for unpaid winnings owed by one of its sub-licensees. A Turkish player had sought to recover 620,000 Turkish lira (roughly €16,910) from Bahsine, a casino operated by Trigonon Group N.V. under a Cyberluck sub-license. Both Trigonon and Cyberluck were ordered to pay.⁷

The court rejected Cyberluck’s argument that it owed no special duty of care to players, stating that the master licensees “let it get out of hand” by permitting a system with minimal oversight. The player had assigned the claim to SBGOK, which pursued the case on their behalf. The court did not, however, make the ruling immediately enforceable against Cyberluck, citing the significant financial implications and other pending cases.⁷

BC.Game and 1xBet

SBGOK also secured a bankruptcy declaration against Small House B.V., the company operating the BC.Game brand, when Curaçao’s Court of First Instance declared the company bankrupt in November 2024 following SBGOK’s lawsuit alleging failure to pay out player funds.⁸ The foundation has also secured bankruptcy claims against 1xBet, though detailed proceedings have not been publicly reported.⁷

Operation Nebraska: Criminal Settlements Over KYC Failures

Criminal enforcement has moved more slowly. Operation Nebraska, an investigation by the Special Police Taskforce under the Curaçao Public Prosecutor’s Office, was launched in response to media reports and criminal complaints from SBGOK. It found that 17 gambling websites had allowed users to bypass mandatory identity verification, enabling account creation and deposits without KYC checks in violation of Curaçao’s national ordinance on client identification. The prosecutor’s office called it the first time the online gambling industry in Curaçao had been held accountable for non-compliance with identification requirements.⁹¹⁰

The office reached an out-of-court settlement with 12 operators for a combined total of 360,000 Caribbean guilder (approximately €170,000). Eleven companies each paid 22,500 guilder per casino operated; a twelfth failed to meet its payment obligations, so the prosecution cancelled that settlement and moved to court. The operators did not admit guilt, and their identities were not disclosed.⁹

Cramm called the settlements inadequate, describing the government’s response as “a big bird in your face” given years of underage gambling and identification failures.⁵

Dutch Player Restitution Suits Against Operators

Running parallel to the Curaçao-specific cases is a much broader wave of lawsuits in the Netherlands. Players are suing operators, including those licensed in Curaçao, to recover losses incurred before the Dutch market was formally regulated on October 1, 2021. Until that date, the Dutch Betting and Gaming Act did not provide for online gambling licenses at all, so operators serving Dutch players were technically doing so without legal authorization.

Plaintiffs argue the pre-2021 gambling agreements are null and void, entitling them to full restitution.¹¹ Rulings so far are mixed. In April 2024, the Court of Overijssel ordered two unnamed operators to repay customer net losses of up to €200,000, finding the agreements were null and void because the operators were active illegally.¹² Other courts have rejected similar claims, citing the Dutch Gambling Authority’s pre-2021 “prioritization” policy that tolerated operators not actively targeting Dutch consumers.¹³

Two district courts referred the question to the Dutch Supreme Court. On December 1, 2025, Advocate General Siewert Lindenbergh issued a non-binding opinion advising that historical online gambling contracts should not be deemed null and void solely because the operator lacked a Dutch license, reasoning that the Betting and Gaming Act was intended to be enforced through administrative and criminal law rather than civil nullity.¹⁴ The Supreme Court’s final ruling had not been issued as of mid-2026.¹⁵

The advocacy organization Gokverliesterug has initiated a class action against Unibet, Bwin, PokerStars, and Bet365, though Bet365 has disputed claims that it was active in the Dutch market before regulation.¹² In July 2025, the Amsterdam District Court dismissed Gokverliesterug’s related lawsuit against Unibet over personal data access, finding the organization had not sufficiently proven it was a nonprofit entity and noting that its 36% cut of recovered losses raised questions about its motives.¹⁶

Claimants have been filing Data Subject Access Requests under the GDPR to force operators to disclose gambling histories and losses, using privacy tools to build the underlying cases. The Netherlands’ opt-out class action system raises the exposure, since representative organizations can bring collective actions covering large groups of consumers without individual sign-ups. An estimated 1.9 million Dutch consumers participated in online gambling as of 2018.¹³

The CJEU Ruling That Reaches Curaçao Operators

On April 16, 2026, the Court of Justice of the European Union issued a ruling in Case C-440/23 that strengthened players’ position across the EU. The court held that EU law does not prevent member states from prohibiting online gambling services even when operators hold valid licenses in other EU countries, and that national courts may declare such contracts void and order operators to refund consumer losses.¹⁷

The case involved Malta-licensed operators, but its logic applies equally to operators licensed in non-EU jurisdictions like Curaçao: holding a license elsewhere does not authorize an operator to bypass national gambling prohibitions in a consumer’s home country. Malta’s own attempt to shield its licensed operators from foreign judgments through Bill 55 is now facing European Commission infringement proceedings that were initiated in June 2025.¹⁸

How Curaçao Overhauled Its Licensing in Response

The Dutch government used its financial leverage over Curaçao to force reform, making pandemic-era financial relief contingent on restructuring the gambling sector.⁴

On December 17, 2024, Curaçao’s parliament approved the National Ordinance on Games of Chance (LOK) by a vote of 13 to 6. The law took effect on December 24, 2024. It abolished the master/sub-license system entirely: all operators must now obtain licenses directly from the new Curaçao Gaming Authority, which replaced the old Gaming Control Board.⁴¹⁹

Existing licenses were automatically converted into provisional licenses with an initial six-month duration. In June 2025, Curaçao extended those provisional licenses by an additional six months to facilitate the transition.³ The CGA holds broad enforcement powers, including authority to seize servers, shut down websites, impose administrative fines, and refer violations for criminal prosecution carrying penalties of up to four years of imprisonment.²⁰

As of October 2025, the Prime Minister of Curaçao intervened to directly oversee the gambling regulator, and several of the key legal questions driving the litigation — most importantly, whether pre-2021 Dutch gambling contracts are void — remain unresolved in courts across the Netherlands and the EU.³

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