Alt Jurisdictions Options for Curaçao's iGaming homeless

the jurisdictions that Curaçao licensees might, or are, moving to.

maxd

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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.
 
Well at least we now know what all the kerfuffle was about, and what's looming over Curacao's fishing nets....

With its current elite Tier 1+ licensing, it would surprise almost no one if many of them simply waddled over to Costa Rica's equally worthless licensing in a heartbeat, given those alt jurisdictions! 🤔
 
According to the following summarized contents from fastoffshore.com/what-we-do/packaged-services/anjouan-gaming-license/, i think that Anjouan license will be sold at the speed of COVID-19 masks in the boom period.

It looks perfect for startups, but i'm certain it will open a door for a mass of operators with bad intentions.

Accessibility and Versatility
Anjouan Gaming License is becoming increasingly popular, especially for startups in the online gambling industry. It offers a single license that covers a wide range of games—Casino, Sports, Poker, Bingo, Lotto, Provably Fair Games, Blockchain-Based Games, and more. This makes it highly accessible and versatile for new businesses.

Quick and Cost-Effective Process
The licensing process in Anjouan is touted as the shortest globally, potentially taking as little as 3-5 business days. The setup and ongoing maintenance costs are also relatively low, making it financially accessible for startups.

Minimal Bureaucracy
The application process is straightforward, requiring less paperwork compared to other jurisdictions. This ease of process makes Anjouan an attractive option for those who want to quickly test their business concept in the market.

Zero Gaming Tax
One of the fiscal advantages of this license is that operators are not required to pay any tax on their gross gaming revenue (GGR), which is a significant benefit compared to many other jurisdictions.

Requirements for Application
The application necessitates a range of documents, including a valid passport, utility bill, police clearance certificate, CV, and more. All documents must be current, certified where applicable, and in English.

Ongoing Maintenance
Annual renewal fees are low, and the jurisdiction offers a comprehensive maintenance package, making it easier for businesses to sustain their operations in the long term.

Global Recognition
The Anjouan Gaming License is recognized and respected globally, providing businesses with the opportunity to reach a worldwide audience.

Ideal for Startups
Given its cost-efficiency, minimal bureaucracy, and quick processing time, the Anjouan license is particularly suited for startups looking to enter the online gambling market without heavy financial or time commitments.

-----------------------------

A redundancy solution for Curacao-sublicensed online gaming operators :D

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"The application necessitates a range of documents, including a valid passport, utility bill, police clearance certificate, CV, and more"

.....so easier than a UK SoW then! :eek:
 
Unlike Gibraltar / Isle of Man / Malta etc, is my understanding correct that the gaming servers are based in Curacao, but the companies operating them have offices physically located elsewhere?

For instance, when I worked for Ladbrokes at the start of the millennium in 2000, they had and still have offices in Gibraltar, which is where I moved to, to be able to work for them. Likewise, the Malta licensed operators have a physical footprint in Malta, same with the Isle of Man, Alderney and so on.

But I know of several operators that are "licensed" in and operate out of Curacao that actually do not have a physical office presence there, it is just the casino gaming servers which are located there. Or are there any or indeed many that do indeed have offices in Curacao.?

So, my point and question is, if yes some do and are located in Curacao, what staff members would want to jump ship with their employer and move to the delightful island of Anjouan? Which up until this thread, I had personally never heard of!

Now I know where it actually is, I also have no desire to go and visit either! 😆
 
Unlike Gibraltar / Isle of Man / Malta etc, is my understanding correct that the gaming servers are based in Curacao, but the companies operating them have offices physically located elsewhere?
Yes, that's certainly been my understanding as well: offices wherever. Apparently that's supposed to change with the new regime. And of course that'll be a fair part of the incentive for current licensees to bail and go elsewhere (where no such requirement exists).

- Max
 
Yes, that's certainly been my understanding as well: offices wherever. Apparently that's supposed to change with the new regime. And of course that'll be a fair part of the incentive for current licensees to bail and go elsewhere (where no such requirement exists).

- Max
From what I can see, Anjouan simply requires a business to be registered in Comoros - it doesn't mention anything about needing an actual office there. Although interestingly, some new information I've dug up shows that Anjouan is actually going to work with a similar blacklisted countries list as Curacao is supposed to.

"These countries are outlawed by the Anjouan Offshore Financial Authority: Australia, Austria, Comoros, France, Germany, Netherlands, Spain, United Kingdom, USA, all of the FATF’s “Blacklisted” nations, and/or any additional jurisdictions."

I don't know what "FATFs' Blacklisted nations" means, and have no idea whether this will be enforced - as it widely hasn't been in Curacao - but it's interesting to see this nonetheless.
 
But I know of several operators that are "licensed" in and operate out of Curacao that actually do not have a physical office presence there, it is just the casino gaming servers which are located there. Or are there any or indeed many that do indeed have offices in Curacao.?

The official Curacao requirements state:

"A company requires a minimum of one director and a minimum of one shareholder. At least one director must be resident in Curacao, but nominee shareholders and directors are permitted. It is not required for registration to be personally present in Curacao."

What "resident" means in reality, is anyone's guess I suppose. Given the last sentence, I assume a lot of companies simply pay a local to be the 'resident'.
 
So basically an individual from a law firm or such like could be the ‘resident’ director.

Therefore no requirement for the business to be located there.

I am particularly interested coming from an IT background as to who or what hosts the gaming servers. Just out of curiosity and how they are managed on site.
 
So basically an individual from a law firm or such like could be the ‘resident’ director.

Therefore no requirement for the business to be located there.

I am particularly interested coming from an IT background as to who or what hosts the gaming servers. Just out of curiosity and how they are managed on site.

From one of the many companies offering a FULL Curacao casino service: licensing, hosting, games, payments, company incorporation, etc:

"A fairly simple application process (2-4 Weeks) regarding operating compliance requirements for Curaçao eGaming License.

TECHNICAL REQUIREMENTS:

Domain ownership;
Presence of at least one physical server of the company in the jurisdiction;
Technical (Hardware and Software) audit of each gaming system;
Software Certification – RNG Certificate;
To be able to proceed with the eGaming Licence Curacao. they require servers hosting in Curacao,
as well as overseas if they would prefer."

When I was researching the new changes, I came across a few articles that mentioned a lot of sites tend to be hosted at a local... government facility! I.e:

"Cyberluck's Conet E-commerce Services division provides Curacao's only co-location centre located within the government-owned PTT. There is no local loop or point of failure when co-located within the PTT. 24x7 technical staff; unlimited bandwidth; bursting on demand; starter-packages; warranty services on major brands. DDOS mitigation; private VPNs."
 
So basically an individual from a law firm or such like could be the ‘resident’ director.

Therefore no requirement for the business to be located there.

I am particularly interested coming from an IT background as to who or what hosts the gaming servers. Just out of curiosity and how they are managed on site.
And therein lies the whole reason it will still be a shitshow. I believe the UKGC for example requires a physical entity with a UK address and funds held here.

A server requirement is pointless as they could just piggy back it.

Does nobody recall the physical Cup-o-cocoa 'address' of the behemoth Stake dot com?

A shack that looks like a portable khazi in a potholed car park with a broken air conditioning unit taped to it? :rolleyes:

Does Cure-a-cow have resident expertise to run game audits or will these be accepted if endorsed elswhere? Do they even know how to audit a game or RNG?

Sounds to me the whole exercise is providing some token legitimacy in return for vastly increasing revenues by selling more of their cornflake packet 'licenses'.

I mean allowing a 'nominee shareholder' who must be resident in the place - what bollocks. So they do just the same as what scam companies do in the UK when buying their £11 online incorporation certificates: give some wino £100 to use their name and address.

Emperor's new clothes blah blah...
 
Sounds to me the whole exercise is providing some token legitimacy in return for vastly increasing revenues by selling more of their cornflake packet 'licenses'.

Just posted this in another thread, but this fits with what's just been
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Minister Silvania is counting on 40 million guilders in revenues from online casinos. This is evident from the draft budget. The amount comes from the permits issued under the new National Ordinance on Gaming. The Cft recently issued advice and is of the opinion that this expectation should be adjusted. This has to do with the fact that the law has still not been introduced. It appears that the minister is counting on more than 200 online gambling companies that will receive a Curaçao license. It is not clear how many online casinos this will result in. The amount of 40 million guilders can be achieved with just over 400 license holders, each with a domain name, but also with 200 license holders who each register 200 domain names.
 
Just posted this in another thread, but this fits with what's just been
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So they reckon 100,000gu for each of these 400 individual licenses with a domain name? 40m yes? Or that equates in the second example to 200 license holders registering 200 domain names each, so 40,000 casinos? Bargain, 'cos that's only 1000gu each, 1% of the first example in that paragraph. Something doesn't add up there at all.

The Cure-a-cow 'Finance Ministry' wants to get a new calculator.

Mind you, they don't usually need one as most payments they collect are greenbacks surreptitiously placed between the pages of the documents, happily collected by the fat bloke with cigar ash rolling down the front of his dirty white tropical suit, sitting under the rickety ceiling fan, sipping his home-distilled stingo.

I've also heard Vladimir Putin is going to set up elections he can actually lose in.
 
The Cure-a-cow 'Finance Ministry' wants to get a new calculator.

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Interestingly, (can't paste the text here as the website won't allow copy)
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the new Finance Minister actually states that companies will be required to have - and maintain - a physical presence.

I suppose they are seeing jack all from the Master License holders right now anyway, that even 200 licenses would be better than now. I have a feeling the reality may be very different from the proposed reality, however.
 
What.....am I seeing here!

"....money laundering, tax evasion, and forgery...."

Not usually what I'd associate these places with. Mind you, with these new puppet licensees all over the shop, I'd like to think the new legislations will be adhered to for at least a week, with some luck 🙏
 
What.....am I seeing here!

"....money laundering, tax evasion, and forgery...."

Not usually what I'd associate these places with. Mind you, with these new puppet licensees all over the shop, I'd like to think the new legislations will be adhered to for at least a week, with some luck 🙏
Yes, he's a real beacon of inspiration isn't he:

"He is also wanted in the brutal murder of Helmin Wiels knows as “Maximus”.

At
least the new finance minister appears somewhat genuinely committed to making change - whether for self gain or, as he says, to benefit his country remains to be seen.
 
So they reckon 100,000gu for each of these 400 individual licenses with a domain name? 40m yes? Or that equates in the second example to 200 license holders registering 200 domain names each, so 40,000 casinos? Bargain, 'cos that's only 1000gu each, 1% of the first example in that paragraph. Something doesn't add up there at all.
It seems a bit odd because it encourages the master license model again, but using white label operations - rather than pay 100k for your own base license, you can pay 500 + fees to be part of an existing base license.

I guess the devil will be in the detail - if both US-based player and crypto payments are off the table, 200-400 may seem rather optimistic? Is there a ballpark figure of how many sub-licenses exist currently?
 
It seems a bit odd because it encourages the master license model again, but using white label operations - rather than pay 100k for your own base license, you can pay 500 + fees to be part of an existing base license.

I guess the devil will be in the detail - if both US-based player and crypto payments are off the table, 200-400 may seem rather optimistic? Is there a ballpark figure of how many sub-licenses exist currently?
I don't know. I would imagine it's gone down somewhat with more awareness that the scammer's number 1668/JAZ is toxic so the conmen realize that they don't even need one anyway, just make a number up or don't bother at all.
 
It seems a bit odd because it encourages the master license model again, but using white label operations - rather than pay 100k for your own base license, you can pay 500 + fees to be part of an existing base license.

I guess the devil will be in the detail - if both US-based player and crypto payments are off the table, 200-400 may seem rather optimistic? Is there a ballpark figure of how many sub-licenses exist currently?
8,000 sub-licenses is the last estimation from a Dutch news site
 
Just a reminder that there is a difference between a regulator and license provider. Government regulators like the UKGC, states in the US (RE New Jersey), MGA, Gibraltar, etc. require not only the servers, but a physical presence in the jurisdiction.

Then you have licensing providers like Kahnawake, Curacao, Sweden, which allow the companies to be elsewhere (not the servers) - so having a physical presence is not always required. They may give tax incentives to be in-country, but it's not required.
 
Curacao loves money, and big casinos have lot of it, I don't think anything will change for players, regards to KYC they do accept UK id, but you need bill to show you dont live in UK, making a bill online is very easy
 
There are lots of casinos that turn a blind eye to the fact you are a UK resident, hence the proliferation of all these Non Gamstop affiliate sites...

Talking of which, I am in the process of completing a video of me installing BetBlocker on an old 2011 iMac I have. Just need to make a few changes and edits and hope to have this up on the Casinomeister YouTube channel after the weekend.
 

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