In the dynamic realm of crypto iGaming, choosing the right jurisdiction for licensing is a strategic decision that can impact an operator’s success, stability, and adaptability. As we step into 2024, two jurisdictions, Anjouan and Curacao, have become focal points in the industry. This in-depth comparison explores the transformations in the Curacao license, scrutinizes the new rules and heightened costs, and contrasts these developments with the emerging appeal of Anjouan as a cost-effective, agile, and crypto-friendly alternative.
Curacao’s Transition from Master License and Sub-License Structure
Historically, Curacao has been a hub for iGaming licenses, known for its flexibility in the master license and sub-license system. However, a significant shift is underway as the traditional structure is being replaced by a more centralized model. The government is now directly overseeing and issuing all licenses, marking a departure from the decentralized approach that allowed for greater flexibility.
Regulatory Changes
The impetus behind these changes is the introduction of the LOK law, a legislative move compelling individual licensing for all sub-licensees. Compliance with this new requirement is mandatory by March 2024. The regulatory landscape is evolving, with a more stringent renewal process for existing gaming licenses, the removal of extensions, and increased notification requirements for Master Licensors.
Financial Implications
Beyond procedural changes, the financial landscape of obtaining and maintaining a Curacao crypto license has undergone a substantial transformation. Annual license fees, application fees, and other financial obligations have been revised, rendering the process more expensive for operators compared to previous years.
Uncertainties Looming Over Curacao
Despite the regulatory changes, uncertainties persist in the Curacao crypto iGaming sphere. The transition from the established National Ordinance on Offshore Games of Hazard (NOOGH) to the impending National Ordinance for Games of Chance (LOK) has introduced a level of unpredictability. The evolving regulatory landscape leaves operators with unanswered questions and concerns about the practical implications of the new framework.
Anjouan’s Crypto-Friendly Appeal
Amidst the shifts in Curacao, Anjouan has risen as a viable and attractive alternative for crypto iGaming licenses. Situated in the Indian Ocean, Anjouan is gaining prominence for its streamlined, low-cost, and crypto-friendly licensing process. Unlike Curacao, Anjouan offers quick approvals, making it an appealing choice for operators in the crypto space.
Advantages of Choosing Anjouan for Crypto iGaming:
Cost-Effective Licensing
- Anjouan’s licensing structure is notably cost-effective, providing a favorable environment for crypto iGaming startups and established operators. The affordability factor, combined with an expedited application process, positions Anjouan as a cost-effective choice.
Legitimacy and Recognition
Despite being a newer player in the crypto iGaming licensing scene, Anjouan has garnered legitimacy and recognition. Its commitment to ensuring a legitimate and transparent licensing process has contributed to its acceptance within the crypto industry.
Crypto-Friendly Regulations
- Anjouan stands out for its crypto-friendly approach. The jurisdiction understands the nuances of the crypto space and has crafted regulations that cater to the specific needs and challenges of crypto iGaming operators.
Partnerships with Banks and Payment Providers
- Anjouan’s flexibility extends beyond its licensing process. Operators appreciate the jurisdiction’s openness to partnerships with banks and payment providers, crucial for facilitating crypto transactions seamlessly.
Agility and Adaptability
- Anjouan is known for its agility and adaptability to the evolving crypto landscape. This ensures that operators remain compliant with industry standards and regulations, especially considering the dynamic nature of the crypto iGaming sector.
Choosing Between Anjouan and Curacao for Crypto iGaming
The decision between Anjouan and Curacao for a crypto iGaming license in 2024 hinges on several factors. Operators must carefully weigh the increased costs, uncertainties, and regulatory changes associated with Curacao against the cost-effectiveness, crypto-friendly environment, and agility offered by Anjouan.
Comparative Analysis of Costs
Curacao Costs Under the LOK Framework
Under the new LOK framework, Curacao’s crypto iGaming license has become more expensive compared to its predecessor, NOOGH. The application fees, annual fees, and other associated costs have witnessed a notable hike. This increased financial burden may pose challenges for both existing operators and new entrants.
The fees under the current NOOGH legislation were as follows:
- Application Fee: 0 ANG (Approx. EUR equivalent: 0)
- Annual Fee (payable on license issuance): 36,000 ANG (Approx. EUR equivalent: 18,500)
- GPT Tax / Revenue Share: 0%
- Monthly Fee: 7,000 ANG (Approx. EUR equivalent: 3,600)
- Domains: Up to 40 included in the license, with a fee of 500 ANG for any additional domain above 40 (without upper limit) (Approx. EUR equivalent: Up to 40 included in the license, with a fee of EUR 250 for any additional domain above 40 without an upper limit)
TOTAL annual license fee: 120,000 ANG + 500 ANG per domain per license above 40 (Approx. EUR equivalent: EUR 61,700 + 250 per domain per license above 40)
The fees for a B2C business under the new LOK rules are planned to be as follows and remain subject to government approval:
- Application Fee: 9,000 ANG + one-off Due Diligence fees between 250 and 500 ANG per person (depending on role) (Approx. EUR equivalent: 4,600 + one-off Due Diligence fees between 125 and 250 EUR per person, depending on role)
- Annual Fee (payable on license issuance): 48,000 ANG (Approx. EUR equivalent: 24,600)
- Monthly Fee: 4,000 ANG (Approx. EUR equivalent: 2,050)
- GPT Tax / Revenue Share: 0%
- Domains: 500 ANG per annum per domain – unlimited number (Approx. EUR equivalent: 250 EUR per annum per domain – unlimited number)
TOTAL annual license fee in ANG: 96,000 ANG + 500 ANG per domain (Approx. EUR equivalent: EUR 49,200 + EUR 250 per domain)
The guidance issued by the government points out that companies grandfathered in from a direct license under the old NOOGH to the new LOK rules do not have to pay the ANG 48,000 on enactment. This amount instead becomes due for the first time on the anniversary of the company’s license, and the monthly fee will drop from ANG 7,000 to ANG 4,000, and the per-domain fee will also come into force at that point for every domain.
The costs for a B2B license under the new rules are now given as follows:
- Application Fee: 9,000 ANG + one-off Due Diligence fees between 250 and 500 ANG per person (depending on role) (Approx. EUR equivalent: 4,600 + one-off Due Diligence fees between 125 and 250 EUR per person, depending on role)
- Annual Fee (payable on license issuance): 48,000 ANG (Approx. EUR equivalent: 24,600)
- GPT Tax / Revenue Share: 0%
- Monthly Fee: 0
- Domains: Not applicable
While receiving more clarity from the Curacao government is undoubtedly a positive step, the fact that fees appear to remain subject to parliamentary approval leaves a lingering trace of uncertainty in the air. The new fees are also significantly higher than the old ones, which should not come as a surprise. What also isn’t fully known are the additional costs that come with enhanced compliance under the new regime.
Anjouan’s Cost Structure
Anjouan’s cost structure for crypto iGaming licenses positions itself as a competitive and economical choice for operators. While specific fee details may vary, the overall cost-effectiveness of Anjouan’s licensing process is evident.
Comparative Analysis of Regulatory Framework
Curacao Regulatory Changes
The transition from the NOOGH legislation to the LOK framework brings about fundamental changes in Curacao’s regulatory approach. One significant shift is the requirement for B2C businesses to obtain a license for companies that interact directly with players, control player funds, or manage player data. Additionally, B2B licenses are mandatory only if a company establishes itself in Curacao.
Anjouan Regulatory Framework
Anjouan’s regulatory framework is designed to accommodate the unique needs of crypto iGaming operators. The jurisdiction’s openness to partnerships with banks and payment providers demonstrates a flexible approach that aligns with the dynamic nature of the crypto space.
Comparative Analysis of Processing Time
Curacao Processing Time
With the ongoing changes in Curacao’s licensing framework, processing times may experience fluctuations. The transition to the LOK framework and the increased regulatory scrutiny may potentially extend the time required for license approvals and renewals.
Anjouan Processing Time
Anjouan stands out for its quick and efficient processing times, a crucial factor for operators looking to establish a presence in the crypto iGaming sector swiftly. The streamlined procedures contribute to the jurisdiction’s appeal as a time-effective licensing destination.
Comparative Analysis of Legitimacy and Recognition:
Curacao Legitimacy and Recognition
Curacao has traditionally enjoyed recognition and legitimacy in the iGaming industry. However, the recent changes in the regulatory framework and the uncertainties associated with the transition to the LOK law introduce an element of ambiguity regarding the jurisdiction’s standing.
Anjouan Legitimacy and Recognition
Anjouan, while relatively newer to the scene, has made strides in garnering legitimacy and recognition. The jurisdiction’s commitment to transparent and legitimate licensing processes has contributed to its acceptance within the crypto iGaming industry.
Comparative Analysis of Partnerships
Curacao Partnerships
The partnerships landscape in Curacao remains stable, but the increased regulatory requirements may impact the ease with which operators can form partnerships, especially in the crypto iGaming space.
Anjouan Partnerships
Anjouan’s openness to partnerships with banks and payment providers is a notable advantage. The flexibility in forming partnerships facilitates smoother transactions, a crucial aspect for crypto iGaming operators.
Conclusion
As the crypto iGaming landscape evolves in 2024, operators face a critical decision in selecting the right jurisdiction for their licenses. While Curacao undergoes regulatory shifts, Anjouan stands out as a promising alternative, offering a cost-effective, crypto-friendly, and agile licensing process. The choice ultimately depends on an operator’s priorities, risk tolerance, and strategic vision for navigating the complex and dynamic world of crypto iGaming. In this comparison, we have explored the changing landscape, costs, regulatory frameworks, processing times, legitimacy, and partnerships associated with both jurisdictions. Operators must thoroughly assess the pros and cons of each jurisdiction to make an informed choice aligned with their business objectives and the unique demands of the crypto iGaming industry in 2024. As the industry continues to mature, the decision-makers must stay vigilant, adaptive, and well-informed to thrive in this rapidly evolving space.