Historical Overview of Gambling Sector Sint Maarten (1996 - 2026)
This page provides a comprehensive historical analysis of the research, studies, and advisory reports conducted between 1996 and 2026 regarding the gambling sector of Sint Maarten. It chronicles the gradual transition from an era of fragmented oversight toward the intended establishment of an independent gambling regulator for Sint Maarten.
Three Decades of Analysis. One Consistent Message.
In total, 19+ major reports and studies have been produced over the past 30 years. Across different periods, authors, and methodologies, the core conclusion remains the same: Stronger regulation and an independent gambling authority are essential.
Reports consistently recommend removing oversight from direct political influence and fragmented ministerial control, through the intended establishment of the SMGA as an independent administrative body (ZBO).
Adherence to FATF standards is a recurring requirement across four successive CFATF evaluations (2013 - 2025). The most recent evaluation makes clear that effectiveness in practice, not legislation alone, determines the outcome.
A growing emphasis on the government's constitutional responsibility for public health. Reports call for addressing gambling addiction through a National Responsible Gaming Program, player registration, and structural funding for prevention and care.
Evolution from merely drafting laws to proactive enforcement. Implementing a Central Monitoring System (CMS) for data, and providing administrative powers to fine or revoke licenses.
Expanding scope from physical casinos to include lottery booths in neighborhoods, alongside formal licensing and transparent taxation of the online (e-gaming) market.
Moving from an industry that largely regulates itself, with revenue lost through unverified reporting, toward a professional cost-recovery framework that yields stable, predictable public income.
Gaming Industry Study
A gaming jurisdiction operating under minimal government authority
Coopers & Lybrand
This industry study evaluates market capacity, fiscal impact, licensing and internal controls. It concludes that a strong regulatory environment did not exist and describes Sint Maarten as a gaming jurisdiction subject to minimal government authority, noting unpaid casino taxes and fees dating back to 1989. The report recommends comprehensive gaming regulations, formal licensing criteria with background investigations, a government audit division, and a temporary moratorium on new casino licenses.
Casino Policy: Rules of the Game
Formal framework to balance tourism profitability with social resident protection
Government of Sint Maarten
This official policy framework codifies regulations to manage the evolving gaming industry. It prioritizes four objectives: industry profitability, tax revenue, managing resident participation, and preventing criminality. Key measures include a cap on casino licenses, strict vetting of owners, and the abolishment of ‘Letters of Intent’ to ensure a controlled market.
Final Report & GCB Recommendation
Blueprint for independent oversight to protect the integrity of the gaming sector
HPS Consulting
This comprehensive advisory report outlines the legal and operational requirements for establishing an independent Gaming Control Board (GCB). It identifies fragmented oversight and obsolete legislation as major risks. The report recommends a cost-recovery regulatory structure and a modernized Gaming Act to combat money laundering and optimize national revenue.
3rd Mutual Evaluation Report Anti Money Laundering and Combating the Financing of Terrorism
No comprehensive AML/CFT supervision regime in place for casinos
CFATF
This mutual evaluation assesses Sint Maarten’s compliance with international anti-money laundering and counter-terrorism financing standards. It finds that no comprehensive regulatory and supervisory AML/CFT regime existed for casinos and that customer identification thresholds did not meet the FATF standard. The report notes that the creation of a Gaming Control Board was under discussion within government at the time.
Doing the Right Things Right
An integrity review of public administration urging swift establishment of a Gaming Control Board
Commissie Integer openbaar bestuur
This report investigates integrity vulnerabilities within Sint Maarten's public administration following its 2010 status change, finding that patronage and practices such as vote buying persist and that transparency is often lacking in procurement. In its chapter on casinos, it notes overly close ties between government-employed casino controllers and the establishments they oversee, the absence of turnover and profit tax for casinos, and roughly ANG 11 million in uncollected controller fees. The committee regrets the repeated delays in establishing a Gaming Control Board and recommends making it operational within twelve months.
Integrity Inquiry into the functioning of the Government of Sint Maarten
The absence of a centralized gambling regulator: a highly visible institutional gap
PriceWaterhouseCoopers (PwC)
This integrity inquiry assesses vulnerabilities within Sint Maarten’s public administration. It identifies the weak regulatory framework surrounding casinos as a source of significant risks, including money laundering and organized criminal activity, and calls the absence of a centralized gambling oversight body a highly visible gap in the government’s institutional framework. It recommends establishing an independent gaming board staffed with financial and anti-money-laundering expertise, and conducting due diligence on casino owners without delay.
Brief/Report Problem analysis containing their findings on the Sint Maarten gambling industry
Technical oversight is needed to stop the industry from regulating itself
Gaming Laboratories International (GLI)
This operational analysis highlights the risks of a self-regulating industry. It identifies significant revenue leakage due to unverified tax reporting and a lack of technical oversight. The report advocates for digital monitoring and independent certification of gaming equipment to mitigate fraud and consumer abuse and to optimize the collection of government revenue.
Twelfth Follow-Up Report of Sint Maarten Compliance Report
Core deficiencies addressed: Sint Maarten exits the CFATF follow-up process
CFATF
This follow-up report reviews Sint Maarten's progress since the 2013 evaluation. It concludes that all core and key recommendations previously rated non-compliant or partially compliant, including AML/CFT requirements for casinos, were addressed to at least a largely compliant level, and recommends that Sint Maarten be allowed to exit the follow-up process.
Sint Maarten Gaming Authority, Plan of Approach and Verification Report
A strategic roadmap and factual baseline for modernizing gaming oversight
Workgroup SMGA
These foundational documents establish the framework for ‘Country Package Measure H2.’ The Plan of Approach details the transition toward an independent Sint Maarten Gaming Authority (SMGA), focusing on international compliance and legislative reform. The accompanying Verification Report provides a critical baseline measurement, revealing a market with 13 active casinos and over 2,150 slot machines. Together, they document structural shortfalls in the collection of casino license fees, the absence of local data and of a specific policy on gambling addiction, and the intention to reform both the land-based and online gambling sector.
Mini Audit: Responsible Gambling
Government's public-health responsibility amid an absence of reliable gambling data
General Audit Chamber
This audit examines what government does to promote responsible gambling. It finds that reliable local data on resident gambling and addiction is unavailable, and points to the government's constitutional responsibility for public health. It identifies opportunities including interlinked monitoring of casino visits, self-exclusion programs, consulting the Ministry of VSA when issuing licenses, public information on problem gambling, and using the Lottery Ordinance to allocate funds toward prevention and care.
Vision Document Establishing The Sint Maarten Gaming Authority
A strategic blueprint for an internationally respected and socially responsible regulator
Ministry of TEATT
This strategic policy paper outlines the mission and operational standards for the intended SMGA: an independent and transparent regulator with enforcement authority, providing a basis for consumer protection and optimizing the collection of fees and taxes. The document introduces a National Responsible Gaming Program, including self-exclusion and player registration.
Step by Step Plan objectives 2 and 4 of the Measure H2 Plan of Approach
Technical manual for turning strategic gaming visions into operational reality
Ministry of TEATT
This operational manual translates long-term goals into concrete tasks for establishing the SMGA. It focuses on drafting the overarching ‘Gaming Act’, designing the organizational structure, and defining enforcement protocols. The plan emphasizes the need for legislative expertise and formal cooperation with the FIU and Tax Office to ensure success.
Advice and Assessment: Lottery Oversight
Strengthening lottery oversight now, assigning it to a Gaming Authority in the long term
SOAB
This advisory memo summarizes draft recommendations for improving lottery oversight. Short-term measures include formalizing the oversight committee and the inspectorate's powers, introducing fees for booths on public land subject to safety assessment, limiting the number of sales locations per license holder, and publishing areas where booths may not be established. For the long term, it recommends assigning lottery oversight to the Gaming Authority.
The Las Vegas of the Caribbean White Paper
A high likelihood of gambling addiction among residents
Ministry of VSA
This public health white paper compiles the evidence on problem and disordered gambling. It concludes that Sint Maarten faces a high likelihood of gambling addiction, citing an exceptionally dense gambling offer relative to the population, and challenges the assumption that the sector primarily serves tourism. It calls for an expeditious paradigm shift toward responsible gambling, consumer protection and prevention through a multisectoral, multi-ministerial approach, including addiction policy and prevention legislation.
Lottery Booths in Lower Income Areas
Limiting lottery booths near schools and in lower income communities
Social Economic Council - SER
This advisory letter examines the placement of lottery booths, which are predominantly located in lower income communities, where research links proximity to gambling facilities to higher addiction risks. The SER unanimously advises accelerated enforcement, limits on the number of sales points per license holder, a prohibition within 100 meters of schools, clinics, churches and similar establishments, structural allocation of gambling tax revenue to prevention and care, and insurance coverage for addiction treatment.
Sint Maarten Anti-Money Laundering and Terrorist Financing National Risk Assessment
Casino sector rated highly vulnerable to money laundering
Financial Intelligence Unit (FIU)
This national risk assessment rates the money-laundering vulnerability of the casino sector as high, pointing to cash-intensive, often round-the-clock operations with high volumes of large cash transactions. It notes that a Sint Maarten Gaming Authority is yet to be established for the casino sector, and that bodies across the supervisory chain report shortages of expertise, capacity, budget and tools.
More Than Just a Game
The first prevalence study of gambling and its consequences since 1996
Ipsos I&O / RE-Quest
This large-scale prevalence study provides the first data-driven look at gambling behavior on Sint Maarten in decades. It finds that high accessibility combined with socio-economic vulnerability is creating fertile ground for risky behavior and cycles of dependency, and reports that residents call for stronger regulation and oversight of the sector, with priority for consumer protection and accessible addiction care.
Anti-money laundering and counter-terrorist financing measures Sint Maarten Mutual Evaluation Report
Legislative progress acknowledged, but practical effectiveness rated low
CFATF
This fourth-round evaluation assesses both technical compliance and effectiveness in practice. It rates Sint Maarten's effectiveness as low on most immediate outcomes, finds that only part of the casino sector is registered for AML/CFT supervision and that no on-site examinations took place during the assessment period, and records that Sint Maarten is in the process of establishing the Sint Maarten Gaming Authority as a license-issuing body.
Draft Sint Maarten Gambling Authority Business Case v4.0
A draft operational and financial roadmap for the proposed regulator
GLI
This draft business case sets out the proposed operational and financial design for the Sint Maarten Gambling Authority, drawing on government datasets, stakeholder interviews and the draft ordinance. It details a cost-recovery model through licensing fees, technical integration with a Central Monitoring System, and formal cooperation with the FIU. As a draft supporting the legislative process, its proposals remain subject to decision-making.