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HomeIntelligenceDeep DiveWill Anjouan’s bet to be the new Curacao pay off?

Will Anjouan’s bet to be the new Curacao pay off?


Online gambling licensing jurisdictions catering to operators targeting pre-regulated markets are undergoing a period of change. Can the island of Anjouan become a new industry favorite?

Curacao has been a popular jurisdiction for grey market operators for many years, but change is afoot on the Caribbean island. Pushed by ever stricter global compliance requirements and a big regulatory stick being wielded from the far away Netherlands, the jurisdiction is currently working on new online gambling licensing laws that mean the old Master and Sub-License model will essentially cease to exist at the end of this month.

While it is laudable that Curacao is cleaning up its act and preparing to give places like Malta and the Isle of Man a run for their money (and they have a good chance of doing so if they get the recipe right), the cold hard truth is that there are many operators who do not wish to place themselves in a Tier 1 or equivalent jurisdiction.

This doesn’t mean they are doing anything wrong or are trying to hide something. Quite the opposite. Operators who are looking for a license, no matter from where, are inherently trying to do the right thing – but sometimes the cost and effort associated with a Tier 1 license is simply not the right match for them. Very often these are smaller brands, startups, and people trying out new ideas who simply cannot justify spending the time, money and work it takes to get something like an Isle of Man OGRA license. Those companies are increasingly looking towards another island, Anjouan, for the solution.

Located in the southwestern Indian Ocean, and part of the Union of the Comoros, Anjouan has been working hard to capitalize on the changes in Curacao and elsewhere, and has reportedly granted over 100 licenses in recent months with many more in the pipeline. Anyone interested in a license from the jurisdiction will be pleased to know that there’s no need to actually travel there (which is quite a trek) and instead everything can be done remotely, with there not even being any need to have a company on the island.

Online gambling licenses these days are a little bit like crypto altcoins. It’s really easy to create and sell one, but you always have to ask if they actually provide any value. After all, the license itself is just a piece of paper on your office wall. Its benefits and value derive from what it enables you to do. Anjouan claims that its license opens the same doors and carries the same weight as that of current-day Curacao, which is a good and a not so good thing. It’s good as it will likely be accepted by many games providers who these days ask for your license before they ask for your name. Not so good because the usual issues with banking and PSPs relationships will likely remain, but it appears the usual workarounds are also still viable here.

So anyone who has had a Curacao license in the past should feel right at home in Anjouan, even if some unknown factors remain. One of them is, of course, how long the sun will shine for the island to make hay. Regulatory pressures from names like FATF, Moneyval and others are a global factor and can kick the door of any local regulator in at any time. Anjouan is certainly aware of this and, contrary to some stories that are making the rounds, the regulator is carrying out due diligence and other background checks before accepting new applications and issuing them with a license.

Ultimately, the island does seem to slowly create a reputation for itself as a good startup or lower tier jurisdiction, and one look at its rulebook also tells you that targeting most grey markets the industry finds attractive is not an issue with an Anjouan license. At the time of writing, the list of banned countries is just nine names long (although legal opinions may be needed for others). At around $20,000 in license fees, a two week turnaround and no gaming tax, it’s also an attractive financial proposition.

The truth is that the regulated online gambling world will increasingly split itself into two camps. The Tier 1 operators who are moving to the Isle of Man or applying for the new Curacao license in an effort to operate at the highest level, and those who are quite happy to get started with a lower tier license and the reduced financial and regulatory burden (but also reduced opportunities) this comes with. Which path is right for a particular operator really depends on their business model and available resources. Some start on the lower tier and as things take off decide to step up. Others are forever happy where they are, may this be Kahnawake, East Timor or Anjouan.

If you are interested in an Anjouan, Curacao or other license, or maybe just want to have a chat about this or any other industry topic, then why not stop by the ASEAN Gaming Summit in Manila next week? The Asia Gaming Brief team will be at hand to chat, network, and also offer our bespoke consulting services should you wish to take the next step in your licensing or startup journey. With decades of experience and a rich network of quality contacts, we are ideally placed to help you on your road to success. Book your ticket at or drop us a line at [email protected] to arrange a meeting.

Frank Schuengel
Frank Schuengel
Frank Schuengel is an online gambling industry veteran with over twenty years of experience in Europe and Asia. Equally at home in the Isle of Man and the Philippines, he started his career as a sports trader before setting up and running whole operations, and more recently focusing on the regulatory and licensing side of things in the worlds of fiat and crypto eGaming. When he is not writing about gambling topics, he can be found cycling around Manila and advocating sustainable transport solutions for a Philippines based mobility magazine.