Cyberluck Curaçao N.V.

The various sources cover different aspects of Cyberluck’s history. Bankruptcy reports prove existence of the legal entity and the way of handling its assets. Licence expiration is established based on the Gaming Control Board announcement and contracts with casino relationships and player payments are explained in court decisions.

However, the date when these documents were issued must be considered too. As court decision may refer to gambling that happened before the licence expiration, its publication does not mean any further active licencing. Also, the description of the situation in bankruptcy report relates only to the report issuance date, not necessarily to the proven facts of a case.

Unlike a casino company that runs different brands, Cyberluck held an offshore gambling licence issued by the government and contracts with other Curaçao corporations to allow offering services under such a licence. These businesses had to provide their players with gambling via their casino websites, while the offshore corporation remained responsible for fulfilling requirements stemming from the terms of its gambling licence.

As explained in the Supreme Court judgement of 20 December 2024, this difference was not enough to relieve Cyberluck of its responsibility for players. Any contract between two firms will not free the holder of the licence from certain requirements as regard winnings, payments and available money for transactions. Problems in these aspects led to a lawsuit together with the casino operator.

The commercial arrangements might include annual payments and access to the records of the casino operator. As can be seen in the case of Suncast, in the agreement signed in 2018 it was stipulated about an annual payment fee equal to €12,500 and an opportunity to examine commercial and electronic records of the operator. It represents a licensing payment scheme but cannot be considered as proof of ownership of the brand.

The first bankruptcy report from 22 January 2025 informs that Forosa Private Foundation is Cyberluck’s sole shareholder. It specifies that on the moment of filing bankruptcy petition (26 September 2024) there were two directors – Minnaar and Snel-Guttenberg who quit their position the next day. First Quest Financial Services N.V. got the right to act as the proxy holder.

Moreover, the trustee mentions the operating agreement signed with Data Global B.V. in November 2020, and which came into effect in January 2019. As can be stated according to the provided data in the reports, it was about performance of activities connected with licensing and contracts of the corporation. Thus, the question of licensing, Curaçao eGaming brand name and all related rights raised investigation concerns. Therefore, any historical trading name should not be used to determine whether all subsequent services with similar brand belong to Cyberluck.

Cyberluck held master licence 1668/JAZ which came into effect on 1 October 1996 according to the previous offshore gambling regulation regime. This number was a marker of the master licence holder and any casinos running business under contract terms related to it could display that number. Therefore, various sites that were not connected with each other had been able to use the same master licence number without being a part of one casino family.

The Gaming Control Board announcement of 7 August 2024 gave the expiry date as 1 October 2024 and stated that renewal and extension of master licences will not take place. Also, temporary certificates for operators qualified for getting a decision regarding their complete application for direct licences were defined. These provisions referred to a transition period, not the extension of Cyberluck’s master licence.

The National Ordinance on Games of Chance ("LOK") became active on 24 December 2024. The CGA General Information Page on Curaçao Gaming Authority's site shows that CGA is the regulator responsible for issuance and control of licences under this legislation framework. A historical 1668/JAZ licence cannot be a replacement for checking on a casino operator’s current licence status.

The examples below can be found in publicly available judgments and illustrate historical licence relations between Cyberluck and operators, not the present owner/operator relations of those casinos. The following table shows only some selected information on its former business relationships.

In relation to the Bahsine case, where the amount of the balance was 620,000 Turkish lira, the appeal court found that Trigonon and Cyberluck were jointly liable, while appeals of Trigonon and Cyberluck to the Supreme Court were dismissed on 20 December 2024. It was concluded in such a way due to the conclusion regarding the fact that Cyberluck did not provide guarantees of compliance with player protection terms and did not appropriately respond to requests for obtaining information. It is necessary to emphasize that it was an ordinary civil case regarding a specific claim, not a regulatory fine or an obligation to return all the gambling losses.

Separately, in accordance with the decision of 27 March 2023 of Curaçao court, the company Cyberluck was ordered to pay US$255,000 along with statutory interest and costs in the case regarding 1X Corp. The proceedings against 1X Corp were stayed due to its bankruptcy. Moreover, Cyberluck did not succeed in proving that their complaint handling decisions prohibited the court considering player’s claims.

Usoftgaming’s case of 13 May 2024 concerns the termination of a commercial agreement, and not player’s unpaid winnings at all. The court found that Cyberluck violated the contract, but further submissions regarding damages were required. Thus, very high figures of damages, which were requested by Usoftgaming, could not be presented as amounts awarded in that case.

The bankruptcy is registered with case number CUR202403705, with trustee C.M. van Liere. In the fourth report of public proceedings, on 12 February 2026, proceedings were still pending in relation to former directors and Data Global and the bankruptcy completion timetable had not yet been determined. The report sets out trustee's claims and investigations but not a final verdict in regard to all allegations.

Selected dated events.