Casino Beneficial Ownership in Belize: Transparency Challenges and Regulatory Gaps
August 22, 2025
By Catalina Samaniego
The Central American nation of Belize has become a bellwether about beneficial ownership transparency. However, limited attention has been given to the gaming and casino sector within this context. While the country has made notable progress in strengthening its anti-money laundering (AML) and Countering Financing of Terrorism (CFT) frameworks, significant gaps and challenges remain between real-world systems and the law.
Current regulatory landscape
Belize’s financial oversight structure presents a complex picture of supervision and regulation. The Financial Intelligence Unit (FIU) oversees 1,311 Designated Non-Financial Businesses and Professions (DNFBPs), including lawyers, notaries, and accountants, which are sectors recognized as high-risk for money laundering activities. To address these risks, authorities have implemented enhanced oversight through expanded supervisory processes and sector-specific guidelines.
The Mutual Evaluation Report (MER) features how legal professionals, much like registered agents, facilitate transactions involving high-value assets. One of them is real estate, a function that parallels their involvement in structuring casino ownership and financial flows. Despite the casino sector’s relatively modest asset size (USD 14 million), the 2019 National Risk Assessment categorized it as medium-high risk. The MER affirmed that ownership opacity, not just volume of assets, is a critical AML/CFT concern. Also, the MER notes that even small-scale casino operations can serve as conduits for illicit finance when offshore legal intermediaries obscure beneficial ownership structures.
The Financial Services Commission (FSC) regulates Belize’s nonbank financial sector, including international trusts, foundations, and company formation agents. Historical records indicate that approximately 175,000 international business companies (IBCs) were registered prior to the repeal of the International Business Companies Act in November 2022. The introduction of the unified Belize Companies Act, 2022, replaced the former offshore framework with a single companies regime administered by the Belize Companies and Corporate Affairs Registry (BCCAR), a reform aimed at improving beneficial ownership transparency and modernizing corporate oversight.
In the gaming sector specifically, Belize currently has eight regulated casinos, but many others operate without proper AML/CFT supervision. The country has issued only one online gaming license, and virtual asset activities remain restricted until December 31, 2025, under the Financial Services Commission Act.
Recent legal developments
From 2020-2024 alone, the country passed or amended 17 laws, including significant updates to the Belize Criminal Code, the introduction of the Civil Asset Recovery and Unexplained Wealth Act (CARUWA), and amendments to key financial sector legislation such as the Business Companies Act, Money Lenders Act, International Banking Act, Domestic Banks and Financial Institutions Act, and Credit Unions Act.
Several additional pieces of legislation await final approval, including the Criminal Procedure (Plea Discussion and Plea Agreement) Bill. These reforms demonstrate Belize’s commitment to aligning with international standards, supported by its mutual legal assistance treaty with the United States, FIU membership in the Egmont Group, and participation in the Caribbean Financial Action Task Force (CFATF).
Persistent challenges
Despite these legislative advances, significant regulatory gaps remain. Several gaming entities continue to operate outside AML/CFT controls, creating potential vulnerabilities in the financial system. The FIU responded by expanding its investigative and prosecutorial staff in 2023, with further expansion expected as CARUWA implementation proceeds. The agency has also undertaken more complex investigations and updated its National Risk Assessment, while civilian financial experts now support police investigators following the adoption of Belize’s AML/CFT/CPF policy and national action plan in February 2023.
A troubling case study
The challenges of beneficial ownership transparency in Belize’s gaming sector are perhaps best illustrated by the case of Brad’s Gaming Group Ltd. (BGGL). From 2009 until early 2023, BGGL held an exclusive license from the Belizean government to operate the government’s boledo and lottery games—a significant and lucrative contract that required a clear understanding of ownership structures.
However,it has been reported that there was significant opacity in BGGL’s ownership structure. Company registry searches showed that BGGL was majority-owned (60 percent) by Good Lee Limited, an offshore company registered in St. Lucia, with the remaining 40 percent owned by Kim Y. Chee (owner of Brad’s Store); government information released in January 2023 also identified Countach Technologies Ltd, registered in Grand Cayman, as a shareholder.
The critical issue lies in the fact that the beneficial owners of Good Lee Ltd remain unknown. Three of its directors are companies registered in St. Lucia and Dominica—jurisdictions that do not provide publicly available information on beneficial owners. This suggests that weak government regulations created potential risks for fraud and conflicts of interest, given that accurate beneficial ownership information was not provided to government officials.
Implications and moving forward
The BGGL case presents the broader challenges facing Belize and similar jurisdictions in ensuring transparency of beneficial ownership. While the country has made significant progress in strengthening its legal and regulatory framework, the practical implementation of these measures, particularly in high-risk sectors such as gaming, remains under development, necessitating further analysis to address gaps.
The upcoming expiration of virtual asset activity restrictions in late 2025, combined with ongoing regulatory gaps in the gaming sector, suggests that Belize will need to maintain its momentum for reform. The success of recent legislative changes will ultimately depend on practical implementation and enforcement, especially in ensuring that all gaming operations—not just the ten currently regulated casinos—come under proper AML/CFT supervision.
For international observers and potential business partners, the Belize example serves as a reminder of the importance of conducting thorough due diligence, particularly when dealing with offshore entities in jurisdictions still strengthening their transparency frameworks. While Belize’s reform efforts are commendable, current gaps, such as those in the BGGL case, demonstrate that significant work remains to ensure that beneficial ownership verification becomes a reality rather than just a regulatory aspiration.
Photo: Drift in Belize