Player Rights · 7 September 2026 · 7 min read

Non-GamStop Casino VIP Losses: What Duty of Care Applies, by Licence

A VIP host's bonuses, rising limits and steady encouragement to keep depositing raise a duty-of-care question whose answer depends on the casino's licence, Curaçao, Anjouan or something else. What is actually provable today, and what to check first.


Written by Jake Thomas, Co-founder and DirectorPublished 7 September 2026Last reviewed 7 September 2026Editorial standardsAbout the team
Contents

A VIP host who brings reload bonuses, rising deposit limits and steady encouragement to keep playing is running a commercial programme, and what duty of care sits behind it depends on whether the casino holds a Curaçao licence, an Anjouan licence or a UK one. Check the licence type first, then save every host message and offer with its date before deciding what the pattern actually shows.

CauseHow to tellWhat to doHow long it takes
A reload offer or free spins landed within hours of a losing sessionThe offer's timestamp sits close to a deposit or loss shown in your account historySave the offer with its terms and log the date against your deposit recordOngoing, this is evidence you build as it happens
A deposit or stake limit was raised at the host's suggestionA limit change appears in account settings you did not request, or a message proposes oneScreenshot the change and any message proposing it, with the dateImmediate to capture
Gifts, hospitality or event invitations arrived while losses were climbingDated confirmation emails or chat messages for tickets, trips or merchandise sit alongside a rising deposit totalKeep every confirmation with its date and rough value, uneditedOngoing
The host went quiet once a large withdrawal was requestedA contact who replied daily stops responding, though general support still answersMove the request into the operator's written complaints channel rather than waiting on the hostHowever long the operator says its written channel takes to answer
No licence-specific VIP rule for the casino to answer toThe register puts this brand under Curaçao or Anjouan, and neither is the Gambling CommissionCheck the licence type before deciding what duty could realistically applyImmediate, via the licence checker

Does VIP treatment from a non-GamStop casino mean anything on its own?

On its own, no. Plenty of high-value customers are treated well, gamble comfortably within their means and lose money that stays fairly lost. What can matter is the pairing: a host who kept extending offers, limits and encouragement while your account was showing visible harm, set against a licence that may or may not have required anyone to notice. That pairing is what the rest of this page works through, licence by licence, rather than assuming the host relationship alone proves anything.

Why does the licence type decide what duty of care applies?

A Gambling Commission licensee has answered since 31 October 2020 to a detailed, published rulebook for exactly this scenario. A Curaçao or Anjouan licensee answers to a different regulator with a different, and in places far less detailed, published position. Before asking what a host relationship shows, it is worth knowing which rulebook, if any, the casino actually sat under while it was running. Our free licence checker confirms the licensee, licence number and current status against the register rather than the casino's own footer claim.

What does a Curaçao licence require of a VIP scheme?

Curaçao's own regulator pages, cga.cw and its licensing portal, returned an access error when checked on 7 September 2026, so this page does not state a specific Curaçao statutory provision on VIP schemes, inducements or affordability, because it could not be verified from source on the day this page was written. That gap is not proof no such duty exists, only that this page will not assert one it cannot show you. What is verifiable is the licensee, licence number and register status behind the brand, which the licence checker confirms, and the operator's own written complaints channel, which exists regardless of what the regulator additionally requires.

What does an Anjouan licence require?

Anjouan's regulator publishes more than Curaçao's page allowed for on the day this was checked. Anjouan Gaming's own site says licensees are expected to keep meeting anti-money-laundering and responsible-gambling standards for the whole life of the licence, and a separate responsible-gaming page sets out named conditions: a working self-exclusion mechanism, tools letting players cap their own deposits, stakes, losses and session length, age checks, clear signposting to support, and advertising rules that bar targeting anyone underage or already showing signs of harm. None of that is written as a VIP-specific rule, and nothing published names hosts, reload offers or high-value customer checks the way the UK regime does. The limit-setting and advertising conditions are the closest anchor available if a host relationship ran alongside deposit limits that kept being raised rather than offered as a genuine, resistible control.

What if the casino turns out to hold a UK licence instead?

If the licence checker shows a Gambling Commission number rather than Curaçao or Anjouan, the position changes substantially. From 31 October 2020 onward, a British-licensed firm running a high-value customer scheme has had to confirm that a player's spending is genuinely affordable, look actively for signs of harm or vulnerability rather than waiting to be told, keep current paperwork on who the customer is, what they do for work and where their money comes from, revisit all of that for as long as the arrangement continues, and put a licence-holding senior manager in charge of the whole scheme. A host relationship that skipped those steps on a UK licence is a materially stronger starting point than the same relationship on a Curaçao or Anjouan licence, precisely because the rulebook is explicit and published.

What should I preserve from a VIP host relationship?

Keep everything, unedited. Host messages and emails with their dates and the sender visible, every offer as received with its terms, records of limit changes including who proposed them, and gifts, hospitality or event confirmations with dates and rough values. Export your deposit and withdrawal history while access still allows it, and set it against the messages so the two timelines can be read together. Where deposits went through your bank rather than the casino's own payment page, a bank dispute route exists separately from any of this; recovering casino deposits through your bank deals with that route separately.

When is this worth building into a case?

There is no minimum amount and no promise attached to what comes back either way. Bringing in a specialist review is usually worthwhile once three things are true at once: the loss itself is a large one, the host contact and your deposit record actually line up against each other rather than merely sitting close in time, and you are not starting from memory because the evidence is already saved. Short of that, checking the licence and preserving the record costs nothing and loses nothing by being done early.

Register checked 7 September 2026 against the Curaçao Gaming Authority register edition of 3 September 2026 (662 licences: 63 Active, 206 Indefinite, 311 Assessment in progress, 50 Revoked at the operator's request, 32 Expired). A brand's row can be read as it currently appears in the licence checker, which is safer than a footer badge.

If the pattern above matches your account, our Curaçao refunds service sets the host relationship against your deposit record and, where the two support each other, builds that into a file that gets handed on to the regulated legal partners who take the case forward. No sum is too small to raise, a free eligibility check tells you frankly whether the facts add up to a claim, and nothing about the result is promised beforehand.

Operator files whose licence position has been checked

Each operator file below records who holds the licence, the number it prints and what the Curaçao register said when it was read, taken from the register itself and not from the casino's own copy; these were chosen because VIP complaints cluster around large crypto-facing brands.

  • Stake: the entity behind this brand, Medium Rare N.V., holds Curaçao licence OGL/2024/1451/0918, which the register currently shows as Assessment in progress.
  • BitStarz: this brand sits under Gareton B.V., Curaçao licence OGL/2024/165/0185, with a register status of Indefinite.
  • Cloudbet: Halcyon Super Holdings B.V. is the named licensee, holding Curaçao licence OGL/2024/328/0599, shown on the register as Assessment in progress.
  • Thunderpick: the register lists Curaçao licence OGL/2024/677/0722 against Paloma Media B.V. as Assessment in progress, yet the operator's own homepage, when it was read, gave a different company and an Anjouan licence; a host relationship at a site whose paperwork points two ways deserves that check before anything else.

If the host worked for a brand that is not in that list, the operator directory holds many more files, and any name can be run through the licence checker against the register as it stands.

Sources

  • Gambling Commission, new rules on high value customer schemes: the 31 October 2020 affordability, harm-check, evidence, ongoing monitoring and personal management licence requirements. Read 7 September 2026.
  • Anjouan Gaming: the licence-term expectation that operators keep meeting anti-money-laundering and responsible-gambling standards. Read 7 September 2026.
  • Anjouan Gaming, responsible gaming: self-exclusion, deposit/wager/loss/session limit controls, age verification and advertising standards required as a condition of licence. Read 7 September 2026.

Last reviewed: 7 September 2026.

General information, not legal advice. We are not solicitors or a law firm. We connect clients with regulated legal partners.

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FAQ

Common questions

Is it illegal for a non-GamStop casino to run a VIP scheme?

No. Running a VIP or high-value customer programme is not itself unlawful on any licence. What varies enormously is how much a regulator has published about what such a scheme must do, and on the date this page was checked, Curaçao's own regulator pages could not be read to confirm a specific VIP rule, while Anjouan's published only general responsible-gaming conditions. Neither gap proves a duty was breached or that none exists; it means this page will not assert a rule it cannot show you.

It matters for a separate reason. A bank dispute route exists independently of anything a VIP host said or did, and it runs on its own terms rather than through the casino at all. Our guide to recovering casino deposits through your bank covers that route on its own; it sits alongside the duty-of-care question here, not instead of it.

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