WILLEMSTAD – “The lottery sector in Curaçao is a free for all.” This can be deduced from the advice of the Social and Economic Council (SER), which has gone through new legislative proposals to reform the sector. An average of about 62.4 million guilders per year is circulated in the sector, generated by 24 license holders.
WILLEMSTAD
– “The lottery sector in Curaçao is a free for all.” This can be deduced from the advice of the Social and Economic Council (SER), which has gone through new legislative proposals to reform the sector. An average of about 62.4 million guilders per year is circulated in the sector, generated by 24 license holders.
The SER concludes that there are large cash flows associated with offering numbered lotteries. The 24 number lottery license holders have been excluded from primary banking services since 2022 due to their risk profile.
The SER concludes that there are large cash flows associated with offering numbered lotteries. The 24 number lottery license holders have been excluded from primary banking services since 2022 due to their risk profile.
Incidentally, this had hardly any influence on the operations in the sector, according to the SER. The impact of de-banking the lottery sector in Curaçao is still small because Curaçao is still a cash-intensive economy: cash is accepted everywhere as a means of payment and there is a strong preference from the population to pay with cash.
Incidentally, this had hardly any influence on the operations in the sector, according to the SER. The impact of de-banking the lottery sector in Curaçao is still small because Curaçao is still a cash-intensive economy: cash is accepted everywhere as a means of payment and there is a strong preference from the population to pay with cash.
Risk profile
Risk profile
The risk profile of the lottery sector is influenced by several factors, including the cash-intensive nature of the sector, the inadequate enforcement of the lottery sector, and the existing illegal lottery sales.
The risk profile of the lottery sector is influenced by several factors, including the cash-intensive nature of the sector, the inadequate enforcement of the lottery sector, and the existing illegal lottery sales.
According to the SER, the lack of supervision of the sector stems from the fact that the Lottery Regulation 1909 contains no provisions regarding compliance supervision.
According to the SER, the lack of supervision of the sector stems from the fact that the Lottery Regulation 1909 contains no provisions regarding compliance supervision.
As a result, no unambiguous supervisor has been appointed to supervise compliance with the entire Lottery Regulation. There is therefore no question of administrative enforcement in the event of non-compliance with the prohibitions included in the Lottery Regulation, since no supervisor has been appointed to carry out compliance supervision.
As a result, no unambiguous supervisor has been appointed to supervise compliance with the entire Lottery Regulation. There is therefore no question of administrative enforcement in the event of non-compliance with the prohibitions included in the Lottery Regulation, since no supervisor has been appointed to carry out compliance supervision.
In addition, the government has not opted for policy enforcement through a consistent and uniform enforcement policy.
In addition, the government has not opted for policy enforcement through a consistent and uniform enforcement policy.
Concrete cases
Concrete cases
However, the SER notes that it is not indisputable that the assumed high-risk profile of the lottery sector has led to a large number of concrete practical cases of money laundering and/or counterterrorism. Unless the government has forgotten to mention this in the explanatory memorandum to the draft bill.
However, the SER notes that it is not indisputable that the assumed high-risk profile of the lottery sector has led to a large number of concrete practical cases of money laundering and/or counterterrorism. Unless the government has forgotten to mention this in the explanatory memorandum to the draft bill.
Due to the lack of quantification of the money laundering problem within the sector, the SER is therefore not reasonably able to form an opinion about the proportionality and subsidiarity of the proposed tightened regulation that is envisaged.
Due to the lack of quantification of the money laundering problem within the sector, the SER is therefore not reasonably able to form an opinion about the proportionality and subsidiarity of the proposed tightened regulation that is envisaged.
It is unclear to the SER whether the proposed stricter regulation is in proportion to the existing money laundering problem within the lottery sector. If possible, this should be looked at, because otherwise it will not be clear whether the new legislation achieves its goal.
It is unclear to the SER whether the proposed stricter regulation is in proportion to the existing money laundering problem within the lottery sector. If possible, this should be looked at, because otherwise it will not be clear whether the new legislation achieves its goal.
Enforcement
Enforcement
The SER expects that there will be a greater need for enforcement capacity with the new legislation to achieve effective compliance. The expectation is that the sector will not spontaneously comply with the new permit conditions.
The SER expects that there will be a greater need for enforcement capacity with the new legislation to achieve effective compliance. The expectation is that the sector will not spontaneously comply with the new permit conditions.
According to the SER, investing in the new supervisors, the Gaming Control Board GCB and Financial Intelligent Unit FIU is a precondition for efficient and effective enforcement of the Lottery Regulation 1909.
According to the SER, investing in the new supervisors, the Gaming Control Board GCB and Financial Intelligent Unit FIU is a precondition for efficient and effective enforcement of the Lottery Regulation 1909.
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