- Joined
- Jan 20, 2004
- Location
- Saltirelandia
Alt Jurisdictions for Curaçao licensees looking for other options
by Max Drayman
A wee bit of backstory: since the early days of the online gambling scene Curaçao has only issued a small number of iGaming licenses, effectively four (4). They called these "Master Licenses" and they left it to the Master License holders to issue individual casino licenses -- called "sub-licenses" -- to companies that wanted to operate under a Curaçao gaming license.
As Curaçao moves toward killing off the Master License holders and starts issuing individual licenses itself we foresee that there will be a bit of an exodus from Curaçao to other jurisdictions that some operators might find more attractive. Why would they do that? A couple of reasons come to mind straight off: US customers and crypto-currencies. At this point in time -- obviously things may change as Curaçao settles into its shiny new "license issuer" role -- neither of those are on the table for Curaçao licensees.
So what are the "other" jurisdictions? Where might one go for a license if not Curacao? We're calling those the "Alt Jurisdictions".
Costa Rica
Curaçao's massive restructuring of its iGaming business is already proving to be a boon for Costa Rica, one of the oldest licensing jurisdictions in the business. They've been around since the very early days and back in the day everyone knew that because shedloads of casinos were licensed there.
However, right from the get-go there was a problem: Costa Rica never was in the casino _licensing_ business. What they did was they sold _business_ licenses, as you would to a shoe store or ice cream van for example, which simply made it legal for the casino to operate in Costa Rica. No regulation, no policing of activities, no verifications or meaningful legislations, no nothing. Just a business license.
In other words Costa Rica licensees were free to operate as they saw fit. Some good casinos got their start there but legions of completely corrupt, pirate-style, nasty casinos got started right along with them and that's what Costa Rica always was: a place to be whatever you wanted to be, for good or ++ungood, and no one was going to tell you any different.
Perhaps Costa Rica will reinvent its casino licensing system and join the rest of us in the 21st Century. I sincerely, desperately, hope they do but holding my breath I am not.
Antigua
Antigua Gaming started way back at the beginning as just another Caribbean paradise "do nothing" licensing jurisdiction that took all comers and asked nothing of them but taxes and fees. In latter years Antigua made a serious effort to become a "Tier 1" -- meaning regulated -- jurisdiction but by that time enormous changes were already in motion and it seemed they were drifting into insignificance. The UKGC came online, Gibraltar and Malta geared up, as did The Isle of Man, Alderney, Kahnawake and so forth: Antigua seemed to be destined for the dustbin of iGaming history. That was a shame because there were good reasons to believe that they could become one of the rarest things on the iGaming scene: a serious, respectable offshore licensing jurisdiction.
Fast-forward 15 years or so and Antigua is still around and very well may be back in the game precisely because of those casinos that aren't enamored with the changes in Curaçao. While today there are very few i-gaming companies registered there -- four from what I've seen -- that could change fairly quickly. I see they've recently partnered with Kahnawake to establish "an innovative regulatory relationship between the two Commissions" which could be great news, but we'll have to chase that story further at a later date.
Anjouan
We'd never heard of Anjouan until a few days ago and it seems that may not have been a great loss. Initial impressions are that this is just a "Stamp Jurisdiction", more or less like Costa Rica was/is, not to mention some of the Curaçao Master Licenses. They're obviously hoping to cash in on those leaving Curaçao who are none too picky about where they end up.
At this time there is no reason to believe that Anjouan is anything more to the iGaming industry now than what Liberia was to the oil tanker business back in the 70s and 80s: a piece of paper that said "you're legal" that you could wave around for the benefit of anyone that wanted to believe that BS. Staff writer Smithyy says "we've seen companies who used to offer 'start from scratch casinos' in Curacao pivoting to Anjouan - at least two or three" which is not a good thing. He'll have more for us on Anjouan in the coming days.
Philippines
The Philippine Amusement and Gaming Corporation (PAGCOR) handles on and offshore gambling licensing. Apparently the on-shore business is serious stuff -- claiming roughly USD 1.2B gross per quarter -- but they don't appear to publish similar stats for the offshore licensing. To be fair they look like they're making a real effort -- published regulations, complaints procedures, etc -- but the biggest news I found was that the government is pursuing 33 operators for unpaid fees and licensing, and those are operators who have recently _left_ the Philippines. Will the Philippines become a destination of choice for Curaçao's recently-homeless casino operators? What do your dice say? Mine look a lot like snake eyes.
The "Tier 1" Jurisdictions
Here we're thinking of the UKGC, Gibraltar, The Isle of Man, Alderney, Sweden, Belgium, state licensing in the US, and so forth. These all have two major problems for casinos looking to bail out of Curaçao: most are country specific and all of them are more costly than Curaçao. There may be a few operators that will be willing to relocate and step into whatever regulatory lines these jurisdictions may demand but there won't be many. Curaçao has traditionally been attractive to casino operators because it was cheap and relatively regulation-free so anyone there was probably there for one, if not both, of those reasons. The "Tier 1" jurisdictions do not offer a quick and easy migration path for a Curaçao licensee looking for a new home.
The "Tier 2" Jurisdictions
Jurisdictions like Malta and Kahnawake go a long way to being up there with the Tier 1 guys but don't have quite the same gravitas, often for reasons beyond their control. Malta provides too many loopholes and exemptions for casinos, and Kahnawake does not have the force of law behind them like the Tier 1 guys do. In both cases though they are big step up on the regulatory ladder from what Curaçao has ever been, but they're more expensive in the bargain. Here again, a few Curaçao-licensed casinos may find these jurisdictions attractive -- and more power to them! -- but likely not many.
by Max Drayman
A wee bit of backstory: since the early days of the online gambling scene Curaçao has only issued a small number of iGaming licenses, effectively four (4). They called these "Master Licenses" and they left it to the Master License holders to issue individual casino licenses -- called "sub-licenses" -- to companies that wanted to operate under a Curaçao gaming license.
As Curaçao moves toward killing off the Master License holders and starts issuing individual licenses itself we foresee that there will be a bit of an exodus from Curaçao to other jurisdictions that some operators might find more attractive. Why would they do that? A couple of reasons come to mind straight off: US customers and crypto-currencies. At this point in time -- obviously things may change as Curaçao settles into its shiny new "license issuer" role -- neither of those are on the table for Curaçao licensees.
So what are the "other" jurisdictions? Where might one go for a license if not Curacao? We're calling those the "Alt Jurisdictions".
Costa Rica
Curaçao's massive restructuring of its iGaming business is already proving to be a boon for Costa Rica, one of the oldest licensing jurisdictions in the business. They've been around since the very early days and back in the day everyone knew that because shedloads of casinos were licensed there.
However, right from the get-go there was a problem: Costa Rica never was in the casino _licensing_ business. What they did was they sold _business_ licenses, as you would to a shoe store or ice cream van for example, which simply made it legal for the casino to operate in Costa Rica. No regulation, no policing of activities, no verifications or meaningful legislations, no nothing. Just a business license.
In other words Costa Rica licensees were free to operate as they saw fit. Some good casinos got their start there but legions of completely corrupt, pirate-style, nasty casinos got started right along with them and that's what Costa Rica always was: a place to be whatever you wanted to be, for good or ++ungood, and no one was going to tell you any different.
Perhaps Costa Rica will reinvent its casino licensing system and join the rest of us in the 21st Century. I sincerely, desperately, hope they do but holding my breath I am not.
Antigua
Antigua Gaming started way back at the beginning as just another Caribbean paradise "do nothing" licensing jurisdiction that took all comers and asked nothing of them but taxes and fees. In latter years Antigua made a serious effort to become a "Tier 1" -- meaning regulated -- jurisdiction but by that time enormous changes were already in motion and it seemed they were drifting into insignificance. The UKGC came online, Gibraltar and Malta geared up, as did The Isle of Man, Alderney, Kahnawake and so forth: Antigua seemed to be destined for the dustbin of iGaming history. That was a shame because there were good reasons to believe that they could become one of the rarest things on the iGaming scene: a serious, respectable offshore licensing jurisdiction.
Fast-forward 15 years or so and Antigua is still around and very well may be back in the game precisely because of those casinos that aren't enamored with the changes in Curaçao. While today there are very few i-gaming companies registered there -- four from what I've seen -- that could change fairly quickly. I see they've recently partnered with Kahnawake to establish "an innovative regulatory relationship between the two Commissions" which could be great news, but we'll have to chase that story further at a later date.
Anjouan
We'd never heard of Anjouan until a few days ago and it seems that may not have been a great loss. Initial impressions are that this is just a "Stamp Jurisdiction", more or less like Costa Rica was/is, not to mention some of the Curaçao Master Licenses. They're obviously hoping to cash in on those leaving Curaçao who are none too picky about where they end up.
At this time there is no reason to believe that Anjouan is anything more to the iGaming industry now than what Liberia was to the oil tanker business back in the 70s and 80s: a piece of paper that said "you're legal" that you could wave around for the benefit of anyone that wanted to believe that BS. Staff writer Smithyy says "we've seen companies who used to offer 'start from scratch casinos' in Curacao pivoting to Anjouan - at least two or three" which is not a good thing. He'll have more for us on Anjouan in the coming days.
Philippines
The Philippine Amusement and Gaming Corporation (PAGCOR) handles on and offshore gambling licensing. Apparently the on-shore business is serious stuff -- claiming roughly USD 1.2B gross per quarter -- but they don't appear to publish similar stats for the offshore licensing. To be fair they look like they're making a real effort -- published regulations, complaints procedures, etc -- but the biggest news I found was that the government is pursuing 33 operators for unpaid fees and licensing, and those are operators who have recently _left_ the Philippines. Will the Philippines become a destination of choice for Curaçao's recently-homeless casino operators? What do your dice say? Mine look a lot like snake eyes.
The "Tier 1" Jurisdictions
Here we're thinking of the UKGC, Gibraltar, The Isle of Man, Alderney, Sweden, Belgium, state licensing in the US, and so forth. These all have two major problems for casinos looking to bail out of Curaçao: most are country specific and all of them are more costly than Curaçao. There may be a few operators that will be willing to relocate and step into whatever regulatory lines these jurisdictions may demand but there won't be many. Curaçao has traditionally been attractive to casino operators because it was cheap and relatively regulation-free so anyone there was probably there for one, if not both, of those reasons. The "Tier 1" jurisdictions do not offer a quick and easy migration path for a Curaçao licensee looking for a new home.
The "Tier 2" Jurisdictions
Jurisdictions like Malta and Kahnawake go a long way to being up there with the Tier 1 guys but don't have quite the same gravitas, often for reasons beyond their control. Malta provides too many loopholes and exemptions for casinos, and Kahnawake does not have the force of law behind them like the Tier 1 guys do. In both cases though they are big step up on the regulatory ladder from what Curaçao has ever been, but they're more expensive in the bargain. Here again, a few Curaçao-licensed casinos may find these jurisdictions attractive -- and more power to them! -- but likely not many.
