About the Investigator
Drs. Luigi Faneyte
Drs. Luigi Faneyte, MSc, CFE, CICA, CCS, is a distinguished financial forensic investigator based in Curaçao, renowned for his in-depth expertise in uncovering financial irregularities and ensuring transparency in regulatory frameworks.
With a robust academic foundation and professional certifications that underscore his capabilities in fraud detection, internal controls, and compliance, he has dedicated his career to promoting integrity within complex financial systems.
Recently, his work has focused on investigating the modernization of Curaçao’s online gambling licensing system and the introduction of the Landsverordening op de Kansspelen ("LOK"). Through meticulous analysis and a methodical approach, he has uncovered serious concerns regarding corruption, embezzlement, and money laundering, raising awareness about the vulnerabilities in these processes.
Faneyte’s commitment to accountability is evident in his ability to trace financial flows and scrutinize compliance practices, drawing on his deep understanding of regulatory obligations and global standards. His efforts reflect a steadfast dedication to safeguarding the integrity of Curaçao’s financial and regulatory environment.
About the Investigation
About Other Investigations
The Public Prosecution Service ("OM") of Curaçao is conducting a judicial investigation into the so-called "tax debt cancellation affair," involving Minister of Finance Javier Silvania ("MFK").
In early 2023, Silvania reportedly instructed the tax collector to cease collecting tax debts from before 2017, an action that, according to the civic organization Fundashon Dos Bui pa Kòrsou, led by citizen journalist Yves Cooper, violates the law. After filing a complaint in April 2024 and receiving no response from the OM, the foundation approached the Court of Justice via an Article 15 procedure to compel prosecution.
The Socio-Economic Council ("SER") concluded that the minister was not authorized to issue such instructions, prompting the OM to launch its investigation. The case has caused significant political tension, resulting in a split within the ruling coalition. The Pisas administration has managed to stay in power with support from smaller factions. The OM will determine whether criminal prosecution is warranted based on the findings of the investigation.
The Investigation in a Nutshell
Drs. Faneyte, MSc, CFE, CICA, CCS, a seasoned financial forensic investigator, has recently filed a landmark criminal complaint against Curaçao’s Minister of Finance, Javier Silvania, and three Maltese individuals - Mario Galea, Aideen Shortt, and Mario Fiorini in connection with the issuance of "provisional" online gambling licenses in anticipation of the future rollout of Landsverordening op de Kansspelen ("LOK").
The complaint, submitted to the Public Prosecutor’s Office on November 24, 2024, is the result of a one-year investigation that is still ongoing. It spans hundreds of pages and outlines serious allegations of official misconduct, corruption, fraud, embezzlement, and money laundering.The investigation exposes a web of inconsistencies, questionable practices, and financial irregularities that have cast a shadow over Curaçao’s regulatory framework for online gaming.
Central to the case is the issuance of “provisional licenses” beginning in November 2023 through a portal operated by Mario Galea, a Maltese investor introduced by Silvania as a key figure in the gambling sector’s modernization. Galea claimed that 170 staff members from the Gaming Control Board ("GCB") were ready to manage the licenses, a statement Faneyte found implausible.
On 23 February 2024, Silvania presented Galea, Shortt and Fiorini to Curaçao parliament ("Staten") as "investors". After subjected to intense scrutiny - he could not explain what these investors invested in and what the promised return on investment as. He then reluctanly admitted - without offering an explanation - that no staff had been hired by GCB so far and the number of required personnel had been reduced to 85. Further scrutiny revealed that licenses were being granted with minimal oversight, facilitated by purported artificial intelligence solutions and bypassing standard regulatory protocols. The system resulted in financial losses, including the bankruptcy of the crypto-casino BC.Game, which left over NAf 15 million in unpaid debts.
The findings reveal a troubling pattern of misrepresentation and negligence. His complaint details how email accounts external to Curaçao’s governance, such as javiersilvania.onlinegaming@gmail.com, were used to coordinate payments and licensing arrangements, raising questions about transparency and accountability. The evidence also points to direct links between Mario Fiorini, one of Silvania’s appointees, and the now-bankrupt BC.Game, contradicting assurances that the investors had no active role in the licensing process.
The situation escalated further when it was uncovered that an attempt was made to transfer BC.Game’s license to a new entity just five weeks after issuance, following creditor disputes. This maneuver was thwarted by the courts, which declared both entities bankrupt, leaving Curaçao with significant financial liabilities. Faneyte’s complaint highlights the systemic risks posed by these failures, warning of broader legal and reputational fallout for Curaçao.
Adding to the controversy, Faneyte criticizes proposed amendments by Silvania to the LOK that would absolve third parties of liability, a move he argues serves to protect those implicated in the scandal rather than reform the industry. He draws parallels between this case and the Dutch “Mondkapjesaffaire,” emphasizing the importance of tracing financial flows to uncover the full extent of misconduct. Faneyte concludes with a call for rigorous investigation and accountability, asserting that Curaçao deserves a transparent, well-regulated system that prioritizes public interest over personal gain.
Rebuttal leads to more Questions
Drs. Faneyte feels that Mr. Silvania's explanation collapses under scrutiny, as it fails to reconcile key inconsistencies and raises more questions than answers.
The claims of Silvania remain unsubstantiated, as the minister has failed to provide any evidence supporting these allegations of a political elite trying to defend one or more families. This narrative also lacks coherence, as those accused of opposing him have proposed a system that guarantees transparency, equality, and fairness. Importantly, these individuals have not insisted on being part of the solution themselves but have advocated for an impartial framework that benefits all stakeholders, while those mentioned in the criminal complaint do advocate that they are an essential part of the solution and the only ones available to properly regulate said licences. At the same time they have admitted that no rules and regulations have been designed by them at this time, while the proposed bill now does include provisions that are designed to shield any third party from liability.
The admission by the minister and his associates that the Landsverordening op de Kansspelen ("LOK") bill does not yet provide any concrete rules or regulations highlights a significant flaw in its implementation. As it stands, the framework lacks essential provisions on critical aspects of governance. There are no established protocols for handling complaints, leaving operators and stakeholders without a clear mechanism for resolving disputes. Similarly, the LOK fails to address how to manage operators who target forbidden jurisdictions, creating potential risks for international regulatory compliance. The absence of rules governing the revocation of licenses or the handling of partial payments of fees further underscores the bill’s incompleteness. Without these fundamental guidelines, the system operates in a regulatory vacuum, fostering uncertainty and raising serious questions about its capacity to ensure fairness, transparency, and accountability in Curaçao’s gaming industry.
The statements made on AI and workload, directly contradict earlier statements. Previously, they attributed their ability to manage this enormous workload with only one or two untrained executives to the use of advanced, albeit opaque, technology and artificial intelligence. Now, by retracting this explanation and insisting the work is done manually, they have created a glaring inconsistency: if neither AI nor sufficient personnel are involved, who exactly is performing this work? This defense does not provide a plausible answer, further validating the findings of Faneyte’s investigation. Also, they have previously admitted that the "temporary licences" have remained unchecked.
Silvania's Rebuttal
The defense provided by Minister Silvania and the other individuals named in the complaint, claims that Curaçao is in the midst of a socio-economic battle between the rich and the poor, with Silvania portrayed as a hero redistributing wealth to the people.
Silvania claims that members of a so-called political elite - anyone who has criticized him - are allegedly working to defend the interests of wealthy, powerful families seeking to prevent him from redistributing wealth to the poor. The investigation of Drs. Faneyte - although extensive and backed up by evidence - therefore cannot be trusted.
Galea in his defense in the "LOK" investigation, denies the use of artificial intelligence, asserting that all tasks related to the 155 issued licenses were completed manually by a small team within the Gaming Control Board ("GCB"), supported by (self-proclaimed) international "specialists". Failure of the Staten to quickly pass the proposed bill is, so claims Silvania, the real cause of the recent problems.
Mr. Silvania
Mr. Galea
Rebuttal in Conclusion
The shifting and contradictory defenses of Silvania and Galea, coupled with the lack of tangible evidence, starkly contrast with the meticulous investigation conducted by Drs. Faneyte. In addition, other than repeated statements, neither Minister Silvania nor the other involved individuals have supplied any documentation or evidence to substantiate their claims. This is especially concerning, as providing evidence to back their narrative would not be complex if their assertions were truthful. The lack of evidence is compounded by their failure to deliver on promises made during their technical presentation in the Staten on February 23, 2024, where they pledged to provide a clear explanation and plan of action. Despite being afforded ample time, they have refused to produce any such plan or explanation.
How Others are Weighing In
Mr. Stanley Betrian, a former interim Prime Minister of Curaçao and experienced civil servant, critiques Silvania in an opinion piece for Antilliaans Dagblad of 30 November, 2024.
In his opinion, Betrian highlights concerns over Silvania's response to his earlier commentary on the Landsverordening op de Kansspelen ("LOK"), suggesting the Minister misinterpreted or deliberately distorted his points.
Betrian underscores a recent parliamentary motion in Dutch parliament, which calls for strict safeguards to prevent criminal misuse of LOK, warning that neglecting these recommendations could harm Curaçao’s reputation and autonomy. He criticizes the Silvania for failing to adopt crucial advice from the Raad van Advies and raises doubts about the current capability to oversee the gambling sector effectively, citing inadequate resources and staffing.
Betrian concludes with a call for the Minister to adopt a more transparent and collaborative approach, ensuring both local and international standards are upheld.
Solutions
Drs. Faneyte feels that the solution to the issues exposed in Curacao's gambling licensing system lies in implementing robust checks and balances to establish impartial oversight founded on clear and transparent rules. Oversight should be executed by local government civil servants who are trained and accountable to the public, ensuring that the system operates free from undue influence.
A crucial step is creating a clear separation of powers between those authorized to issue licenses and those tasked with collecting revenues. Assigning the responsibility for revenue collection to Curacao's tax administration would enhance transparency and ensure fairness, as all providers of games of chance would be subject to the same standards and cost allocations. Additionally, any external assistance required by the country should be secured through official tender procedures.