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Global changes in I-Gaming industry

Gediminas

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Oct 12, 2019
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The recent update to the i-gaming regulatory framework in Curacao has caused a lot of confusion and concern among Curacao i-gaming operators and those seeking a Curacao i-gaming license.

The government of Curacao is currently working on new i-gaming regulations called the "Landsverordening op de kansspelen" (LoK). Once LoK is enacted, all current Curacao i-gaming operators operating under sub-licenses of "master license holders" (such as Curacao e-gaming and Antillephone) will have 3 months to submit their applications for an i-gaming license issued directly by the government of Curacao under LoK.

Until LoK is enacted, the "master license holders" have received license extensions for at least 1 year and are still issuing sub-licenses to Curacao i-gaming companies. However, Antillephone has stopped issuing new sub-licenses, so applicants are applying to Curacao e-gaming for Curacao i-gaming sub-licenses.

To avoid waiting for LoK to be enacted, the government of Curacao will start issuing Curacao i-gaming licenses directly to Curacao operators under the existing i-gaming regulatory framework starting from November 15, 2023. These new governmental i-gaming licenses will be issued by the Curacao Gaming Control Board (GCB).

Considering these changes, Curacao companies that currently have or intend to apply for a Curacao i-gaming license have the following options:
  1. Apply for a Curacao i-gaming sub-license from Curacao e-gaming (CEG). CEG has not changed their operations and does not plan to do so until LoK is enacted. They currently have a license until approximately 2025, and there is no guarantee that LoK will be enacted before 2025, possibly even receiving an extension until 2026.
  2. Apply for a Curacao i-gaming license directly from the government of Curacao. The process and requirements for obtaining a license directly are not very clear at the moment. It is expected that UBOs (Ultimate Beneficial Owners) with 10% or more ownership will have to provide fully verifiable identity information, source of wealth, and source of funds. The software used must be tested by an independent qualified entity approved by the GCB, and the company must have a process to verify the identity of players using its services.
Due to these changes in Curacao, many i-gaming industry participants are looking for alternative jurisdictions. One popular alternative is the Anjouan Gaming License.

The Anjouan Gaming License is issued by the Autonomous Island of Anjouan, part of the Comoros archipelago in the Indian Ocean. This license can be obtained by companies established anywhere in the world and covers all forms of gambling, including white label solutions. The requirements for obtaining an Anjouan Gaming License are similar to those for obtaining a Curacao i-gaming license, such as due diligence on UBOs, internal company policies, software agreements, and GEO IP location restrictions.

The Anjouan Gaming License is suitable for standard crypto casinos or Web3 casinos and allows for operations with both crypto and fiat currencies. It is important to choose a reputable provider to assist with obtaining the license, as there have been cases of local companies scamming applicants and issuing fraudulent gaming licenses not approved by Comorian authorities.

Please note that while these alternatives provide options for i-gaming operators, they may not have the same level of stability and compliance as Curacao licenses, so having a backup bank account is advisable.
 
Can you show an official notice or reference on a gov.km or gouv.km website confirming the existence of this gambling law?

Of course not. Because the license is issued by the autonomous Island of Anjouan but not from Comoros. Comoros State does not support this license.

Recently one EMI sent an official inquiry to the Embassy of Comoros to reconfirm this, but I am quite sure that the answer will be that it is not recognized.

So from the legal point of view, Anjouan is somewhere between a licensed and non-licensed business.

On the other hand, as long as you can find EMI and payment gateways (if needed) and as long as you know that it will not cause legal issues in your home country, this is the easiest and fastest “license”.
 
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Of course not. Because the license is issued by the autonomous Island of Anjouan but not from Comoros. Comoros State does not support this license.

Recently one EMI sent an official inquiry to the Embassy of Comoros to reconfirm this, but I am quite sure that the answer will be that it is not recognized.
But have you seen even any official documents from the local government on Anjouan? Not even they seem able to verify the existence of the law and validity of licenses.

So from the legal point of view, Anjouan is somewhere between a licensed and non-licensed business.
I've seen all the marketing material and spoken with people who claim to represent Anjouan, but so far nothing has been independently verifiable. The license may carry the same amount of legal weight as one I can whip up in Paint in two minutes. There is a difference between offshore license and no license, even in the eyes of some regulators that issue local licenses. Not sure it would ever matter, though.

On the other hand, as long as you can find EMI and payment gateways (if needed) and as long as you know that it will not cause legal issues in your home country, this is the easiest and fastest “license”.
Which game providers have you seen that accept Anjouan?
 
But have you seen even any official documents from the local government on Anjouan? Not even they seem able to verify the existence of the law and validity of licenses.
I'm not even sure Anjouan government has a website, and the other websites advertising it seems really shady.

Who volunteers to put their feet on the ground and go to Anjouan to sort it out?

Anyway @Gediminas, very interesting, thanks for the update!
 
The recent update to the i-gaming regulatory framework in Curacao has caused a lot of confusion and concern among Curacao i-gaming operators and those seeking a Curacao i-gaming license.

The government of Curacao is currently working on new i-gaming regulations called the "Landsverordening op de kansspelen" (LoK). Once LoK is enacted, all current Curacao i-gaming operators operating under sub-licenses of "master license holders" (such as Curacao e-gaming and Antillephone) will have 3 months to submit their applications for an i-gaming license issued directly by the government of Curacao under LoK.

Until LoK is enacted, the "master license holders" have received license extensions for at least 1 year and are still issuing sub-licenses to Curacao i-gaming companies. However, Antillephone has stopped issuing new sub-licenses, so applicants are applying to Curacao e-gaming for Curacao i-gaming sub-licenses.

To avoid waiting for LoK to be enacted, the government of Curacao will start issuing Curacao i-gaming licenses directly to Curacao operators under the existing i-gaming regulatory framework starting from November 15, 2023. These new governmental i-gaming licenses will be issued by the Curacao Gaming Control Board (GCB).

Considering these changes, Curacao companies that currently have or intend to apply for a Curacao i-gaming license have the following options:
  1. Apply for a Curacao i-gaming sub-license from Curacao e-gaming (CEG). CEG has not changed their operations and does not plan to do so until LoK is enacted. They currently have a license until approximately 2025, and there is no guarantee that LoK will be enacted before 2025, possibly even receiving an extension until 2026.
  2. Apply for a Curacao i-gaming license directly from the government of Curacao. The process and requirements for obtaining a license directly are not very clear at the moment. It is expected that UBOs (Ultimate Beneficial Owners) with 10% or more ownership will have to provide fully verifiable identity information, source of wealth, and source of funds. The software used must be tested by an independent qualified entity approved by the GCB, and the company must have a process to verify the identity of players using its services.
Due to these changes in Curacao, many i-gaming industry participants are looking for alternative jurisdictions. One popular alternative is the Anjouan Gaming License.

The Anjouan Gaming License is issued by the Autonomous Island of Anjouan, part of the Comoros archipelago in the Indian Ocean. This license can be obtained by companies established anywhere in the world and covers all forms of gambling, including white label solutions. The requirements for obtaining an Anjouan Gaming License are similar to those for obtaining a Curacao i-gaming license, such as due diligence on UBOs, internal company policies, software agreements, and GEO IP location restrictions.

The Anjouan Gaming License is suitable for standard crypto casinos or Web3 casinos and allows for operations with both crypto and fiat currencies. It is important to choose a reputable provider to assist with obtaining the license, as there have been cases of local companies scamming applicants and issuing fraudulent gaming licenses not approved by Comorian authorities.

Please note that while these alternatives provide options for i-gaming operators, they may not have the same level of stability and compliance as Curacao licenses, so having a backup bank account is advisable.
Thanks for sharing this.
Moreover, i already checked with many EMIs and PSPs and Anjouan license is acceptable by some of them. The rest told me that they are considering seriously on accepting this license.
After discussing internally with our regulatory department, seems like Anjouan is going to be a good substitute to Curacao. For now the license is pretty affordable and easy to get, we do think that the prices will go up when it will gain some popularity and higher demand.
 
I would say if you are planning to approach tier 1 providers (it includes game and payment providers) you could stay in Curacao (to apply for a Government license) or go with the Isle of Man or even Malta.

Anjouan is a less solid option, however, it might work for some operators.
 
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I haven't seen any of the major game providers accept Anjouan yet. So while you can get a license, PSPs, and banking, you'll be stuck with pretty bad looking second/third tier games if you plan to run a casino with slot machines and table games.

Might be OK for betting, until more game providers accept Anjouan.
What is the drawback with getting an official Curaçao licence, compared to dealing with Master Licence holders?
 
Is there any official Anjouan government website or any regulator contact information? Tried to Google it by myself, but all websites looks very dodgy or even worse.

BTW found 3 online casinos with the Anjouan licence and they are not banned by local authority (EU county).
 
I haven't seen any of the major game providers accept Anjouan yet. So while you can get a license, PSPs, and banking, you'll be stuck with pretty bad looking second/third tier games if you plan to run a casino with slot machines and table games.

Might be OK for betting, until more game providers accept Anjouan.
I have checked with numerous EMIs and the license is acceptable. With PSPs you are right its a bit more complicated, but there are solutions depending on the target countries.
For example African, Asian and LATAM psp accept Anjouan license (checked and verified)
For EU market its a problem, same as for Curacao.
 
The problem remains game providers. If you want a compelling, competitive product, you're going to need casino games from tier 1 providers. AFAIK, none of them currently accept Anjouan.

Anjouan is probably fine for sports betting and mediocre casinos that are OK with second/third tier games and don't have very high ambitions, or make their own games and get the RNG certified.
 
The problem remains game providers. If you want a compelling, competitive product, you're going to need casino games from tier 1 providers. AFAIK, none of them currently accept Anjouan.

Anjouan is probably fine for sports betting and mediocre casinos that are OK with second/third tier games and don't have very high ambitions, or make their own games and get the RNG certified.
Yes it makes sense, i guess it requires more research.
So far we were only informed by clients that softswiss is fine with anjouan license.
 
The issue is that there is lack of official information from Anjouan government.
You can ask ChatGPT to generate a license that is probably just as legally valid as whatever the people peddling Anjouan licenses are handing out.

But that's not stopping EMIs and some PSPs from accepting Anjouan. It will be interesting to see what happens to those accounts when/if it becomes known that the license is a sham.