In 2026, Curaçao authorities launched a formal investigation into multimillion-euro payments made to a consultancy firm led by Mario Galea, the Maltese gaming expert who once headed the Malta Gaming Authority and was instrumental in establishing the island as a global iGaming hub. The probe, announced by Finance Minister Charles Cooper, centered on whether annual fees exceeding €4M paid to Random Consulting Limited represented value for money or raised concerns about governance and transparency.
Why This Mattered
• Reputational risk: Malta's gaming sector reputation faced potential scrutiny given Galea's prominent role in its development from 2004-2008.
• Transparency test: The investigation highlighted how offshore gaming jurisdictions scrutinize consultancy arrangements amid pressure for accountability.
• Disputed figures: Random Consulting contested the €4M annual claim, asserting it received €3.4M total across three years with significant payment deferrals.
• Prior allegations: Galea was previously named in a 2024 fraud report by a Curaçao opposition MP, claims he categorically denied.
The Scale of the Arrangement
Minister Cooper's concern revolved around proportion. According to his calculations, the consultancy fees paid to Random Consulting Limited represented more than 35% of all online gambling revenue entering Curaçao's treasury. For a small Caribbean jurisdiction attempting to modernize its gaming framework, such a concentration of funds flowing to a single external adviser raised immediate red flags within the finance ministry.
The €4M annual figure cited by Cooper converted to approximately 8.3M Caribbean Guilders, a sum large enough to fund significant portions of government operations in a territory with limited fiscal resources. Cooper publicly questioned whether the technical services rendered—primarily building and maintaining a licensing portal and advising on regulatory reform—justified such substantial outlays.
Random Consulting pushed back firmly. In statements following the minister's announcement, the Malta-based firm clarified its actual payment schedule: €15,406 in 2022, zero in 2023, €884,250 in 2024, and €2.5M in 2025. The company emphasized that certain owed payments were deferred at the explicit request of Curaçao officials during budget constraints, a meeting Cooper himself reportedly attended.
The discrepancy between the minister's claims and the company's accounting formed a central pillar of the investigation. Financial records reviewed by Curaçao authorities determined whether the €4M figure represented a misunderstanding of payment structures, future commitments, or something else entirely.
What the Consultancy Actually Did
Random Consulting Limited was hired to guide Curaçao through a comprehensive overhaul of its gaming legislation. The territory, long known as a licensing jurisdiction for online operators, sought to modernize its framework with the National Ordinance on Games of Chance (LOK), a regulatory system designed to meet evolving international standards.
Galea's firm was tasked with constructing the technology infrastructure underpinning this transition: an online licensing portal, administrative systems for the Curaçao Gaming Authority (CGA), and monitoring tools to oversee operator compliance. The engagement began in February 2022 and formally concluded in January 2023, though technical support appeared to have continued through 2025 based on payment records.
This wasn't Galea's first foray into shaping gaming jurisdictions. During his tenure as CEO of Malta's Lotteries and Gaming Authority from 2004 to 2008, he co-authored the Remote Gaming Regulations of 2004, making Malta the first EU member state to regulate remote gaming. That framework transformed the island into one of the world's largest online gaming hubs, generating billions in licensing fees and attracting hundreds of operators.
Galea also contributed to New Jersey's internet gaming initiative, earning a Certificate of Appreciation from the state's Division of Gaming Enforcement. His 2008 departure from the MGA was described at the time as his own decision, with no specific reasons publicly disclosed. He briefly returned as chairman in 2013 before transitioning entirely to international consultancy work.
Political Crossfire and Prior Allegations
The 2026 investigation emerged against a backdrop of intense political scrutiny. In 2024, opposition MP and financial forensic investigator Luigi Faneyte released a 400-page report accusing several individuals, including Galea, of fraud and embezzlement related to Curaçao's gaming sector reforms. Faneyte's document alleged that consultancy arrangements lacked transparency and proper oversight, raising questions about conflicts of interest and inflated billing.
Galea categorically rejected the accusations, describing them as "baseless and unfounded." His firm maintained that all contracts were executed through proper government channels and that services were delivered as specified. The 2024 report did not result in criminal charges, but it appears to have triggered renewed attention from finance ministry officials who began reviewing consultancy expenditures more closely.
Curaçao's online gambling sector generates significant revenue for the territory, but it has long faced criticism from European regulators over inadequate consumer protection and anti-money laundering controls. The government's reform effort, which Galea's firm was hired to facilitate, aimed partly to address these concerns and preserve the jurisdiction's attractiveness to operators seeking licensing.
What This Meant for Malta's Gaming Sector
While the investigation focused on Curaçao's arrangements, it carried indirect implications for Malta's iGaming industry. The island's reputation as a well-regulated jurisdiction rested partly on the credibility of its regulatory architects. Galea's prominent role in establishing Malta's framework meant any controversy surrounding his subsequent work inevitably invited questions about governance standards more broadly.
Malta hosts over 300 licensed gaming operators, employing thousands of residents and generating substantial tax revenue. The Malta Gaming Authority has worked for years to distance itself from the more lightly regulated Caribbean jurisdictions, emphasizing strict compliance standards and cooperation with European authorities. Regulatory alumni from Malta commanding premium fees abroad is not inherently problematic—it reflects the jurisdiction's expertise—but transparency in such arrangements matters considerably.
For Maltese professionals in the gaming consultancy space, the Curaçao probe served as a reminder that offshore jurisdictions face mounting pressure to justify expenditures and demonstrate accountability. The days when small territories could award lucrative contracts with minimal scrutiny appeared to be waning, even in traditionally opaque licensing hubs.
Investigation Outcome and Current Status
As of the conclusion of Curaçao's 2026 investigation, financial auditors examined the full scope of payments made to Random Consulting Limited and other external advisers involved in the gaming sector reforms. The investigation assessed whether contractual terms were followed, whether services rendered matched invoiced amounts, and whether proper procurement procedures were observed.
Random Consulting provided documentation supporting its accounting of the €3.4M total, maintaining that its work was essential to Curaçao's regulatory transition and that the licensing portal and administrative systems it built continued to function as the backbone of the jurisdiction's gaming oversight.
The outcome influenced how Caribbean and other offshore jurisdictions structured consultancy arrangements going forward. With international pressure mounting on smaller licensing territories to demonstrate robust regulatory standards, transparency in how public funds are spent on external expertise became a significant governance concern.
The dispute centered on conflicting figures: one side asserting €4M annual payments that demanded explanation, the other documenting €3.4M across three years with legitimate deferrals. For Malta residents and gaming sector observers, the investigation highlighted the ongoing tension between offshore jurisdictions seeking specialized expertise and the public accountability required when deploying significant public funds.
