The Curaçao licence: five operators, two kinds of number

What a Curaçao licence arranges

A licence is a relationship between two parties: the licensor and the licence holder. The player is not a party to it. That sounds harsh, but it is the most useful little sentence on this whole page, because it explains why a foreign licence behaves differently from the Dutch one.

The Dutch licence imposes obligations on the operator that are directly about the player: connection to the exclusion register, a duty of care, restrictions on advertising, requirements for record-keeping. That package is described under what a Dutch licence requires.

A Curaçao licence also imposes obligations on the operator, but it is a different package, with a different regulator behind it, in a different jurisdiction. What remains in practice for a Dutch player is that somewhere there is a body with which he can file a complaint if the operator itself does nothing. That route exists and is not worthless. It is only longer, in another language, and without the means of enforcement a Dutch regulator has in the Netherlands.

What the number does not prove

A valid number proves that there is a licence. It does not prove that the operator abides by it, and it certainly does not prove that the operator meets Dutch requirements.

Nor does it prove that you are dealing with the party you think you are. Behind the four OGL numbers in this overview stand four different companies: Moon Technologies B.V. at Bitcasino.io, Oyine N.V. at Bitsler, Halcyon Super Holdings B.V. at Cloudbet and Medium Rare N.V. at Stake. The abbreviations B.V. and N.V. do not point to the Netherlands here; they are used in Curaçao for the same kind of company. Anyone who recognises the letters and thinks Dutch law alongside them is thinking wrongly — and that is a misunderstanding we come across in the wild often enough to write it down here.

And it proves nothing about the things that are not in the register. Of these five Curaçao operators, one publishes a cap on withdrawals that we were able to read: Bitcasino.io names one million USDT per week in article 6.10. At Bitsler, Cloudbet, Stake and Primedice there is nothing in that field — which means that we have not read it, and not that there would be no cap.

Verification at these five

On the point of document checks, too, the five diverge, and there as well the clause number is the only thing that counts.

Bitcasino.io is the only one of the five that names an amount: article 6.6 states a limit of 2,500 euros. That is a threshold, and a threshold is testable — you can establish afterwards whether it was applied as it was written down.

The other four describe an assessment at their own discretion: Bitsler in article 4.3, Cloudbet in article 18.1.1 and Stake in article 4.8. At Primedice we did find that rule but could not establish a clause number, and then we write it down that way rather than choosing a number that looks good. At Stake there is the further point that we read the terms from an archived copy and not from the current page; that is noted in how we read the register.

An assessment at one's own discretion is not a threshold with a secret value. It is the statement that there is no fixed value. Anyone who reads somewhere that checks at one of these operators start "from 2,000 euros" is reading a figure that is not in the terms.

What this comes down to in the overview

Five of the ten operators lean on a Curaçao document. Four of them have a number that can be found again at the regulator, one has a number that appears only on its own page. None of the five appears in the Dutch licence register, and none of the five therefore falls under the Dutch obligations.

That is the sober state of affairs. What additionally makes the other three operators with an Anjouan licence special — and why their row carries an extra note — is set out under the Anjouan licence.