Introduction
Online gambling has grown into a worldwide industry, with players and operators operating across borders digitally. Unlike traditional casinos attached to a specific location, an iGaming platform can serve customers in multiple countries, each with its own gambling laws and licensing requirements. Consequently, iGaming operators often require several licences across numerous jurisdictions in order to access their target markets legally.
This multi-jurisdictional licensing landscape offers both opportunities and challenges. A Cyprus-based firm like Michael Chambers & Co. LLC is well placed to understand these complexities. Cyprus, as an EU Member State with a business-friendly environment, makes it a popular hub for international companies while securing licences abroad. Drawing on our experience with iGaming Clients worldwide, this article explores the key trends and challenges in multi-jurisdictional iGaming licensing and how operators and providers can manage their cross-border compliance obligations.
In the early days of the industry, many countries either prohibited online gambling entirely or upheld state-run monopolies, prompting operators to pursue offshore licensing options. Jurisdictions such as Curaçao, Gibraltar, Kahnawake and Anjouan became popular licensing centres, offering relatively simple processes and favourable tax rates. For instance, an Anjouan iGaming licence could cover a wide range of gambling activities and may be obtained within weeks, making it a perfect launching point for start-ups.
As online gambling revenues increased, governments around the world began introducing domestic regulation. Today, there is no universal gambling licence; instead, a patchwork of national and regional laws exists. What is lawful in one jurisdiction may be restricted or banned in another. Notably, countries that once permitted foreign-licensed sites are now increasingly requiring a domestic licence to serve local players. Most European states, for example, have enacted local online gambling frameworks to replace former monopolies. As a result, operators and providers aiming to serve multiple regions might need to secure numerous licences, leading major operators to hold dozens simultaneously across different countries.
This expansion of regulation is a double-edged sword. On the one hand, the broader availability of local licences has opened many new legal markets to access – from newly regulated US states to emerging opportunities in Africa, Asia, and Latin America. On the other hand, meeting the requirements of multiple regulators significantly raises the bar for market entry. The era of operating a worldwide online gambling business from a single permissive licence is fading. Compliance has become a foremost concern for any international operator.
Jurisdiction Strategy
As more jurisdictions issue iGaming licences, operators and providers must adopt a strategic approach to selecting where to apply. Key considerations include cost, processing time, reputation, tax implications and market access. Broadly, licensing jurisdictions fall into the following categories.
Established Tier-1 Regulators: These include jurisdictions with strict standards and high international credibility, such as the United Kingdom (regulated by the UK Gambling Commission). A licence from a Tier-1 authority signals strong player protection and operational integrity, and many major operators ultimately seek them to access regulated markets. However, the application process is lengthy and demanding, requiring extensive disclosures, high fees, and capital requirements, and often covering only a single country.
Offshore and Mid-Tier Jurisdictions: Jurisdictions such as Curaçao, Gibraltar, Kahnawake, and newer entrants such as Anjouan and Nevis. They traditionally offer faster, cost-effective licensing with comparatively lower requirements. Jurisdictions such as Anjouan and Kahnawake have attracted operators due to their business-friendly, low-cost environments. These licences often allow an operator to serve various “grey” markets (countries without their own regulations or that permit foreign licence holders) under one umbrella. The trade-off is that some of these licences carry less weight in strictly regulated environments.
Local National Licences: As more countries pass online gambling laws, operators that want to advertise or operate legally in those markets must obtain a local licence. This category includes individual US state licences (e.g., New Jersey or Pennsylvania for online casinos, with each state regulated separately), as well as licences in markets such as Spain, Italy, Sweden, Germany, South Africa, Australia, and so on. These licences usually restrict operations to that country and impose requirements tailored to local policy goals (for instance, strict player-protection rules or obligations to maintain servers and offices in-country). They are often the most demanding in terms of compliance and ongoing oversight. For operators, however, they provide domestic market legitimacy and customer trust, and help avoid the risk of ISP blocking or legal action that an unlicensed platform might face.
Given this landscape, many iGaming companies adopt a tiered licensing strategy. Frequently, a start-up might begin with an offshore licence (for speed to market and global reach) and later add one or more top-tier or local licences as the business grows. For example, an operator might launch with an Anjouan licence to attract players internationally and prove the concept; then, as regulations tighten or the company seeks investment partners, move into an Isle of Man licence for stronger oversight; and eventually pursue licences in key markets like the UK or certain US states to solidify its presence there.
Another factor to consider is the changing landscape of traditionally “easy” jurisdictions. Regulators that once operated under light-touch regimes are reforming to meet modern standards. Curaçao is a prime example. Known for its lax approach, it introduced comprehensive reforms in 2024–25 that replaced the old master/sub-licence model with direct licensing through a new central authority and implemented stricter checks, including local incorporation, the appointment of compliance officers, and owner vetting. Although the process remains quicker and more affordable than in Europe, it now commands greater credibility due to increased oversight. Essentially, Curaçao is shedding its “rubber stamp” reputation. Operators who previously faced minimal scrutiny now encounter higher compliance costs, and some may struggle to meet the new standards.
As Curaçao tightens its regulations, many operators are examining other offshore options. One beneficiary is Anjouan, a jurisdiction in the Comoros whose gambling licence, once obscure, has gained popularity as a quick, cost-effective alternative with widespread acceptance. Other jurisdictions, such as, Kahnawake, and Panama, are also promoting themselves as reliable, business-friendly licensing centres in the post-Curaçao landscape.
Compliance Challenges
Obtaining a licence is only the first step; maintaining compliance with each jurisdiction’s ongoing requirements is an even more challenging task when operating internationally. Compounding this challenge, many jurisdictions now require even B2B gaming suppliers (platform providers, aggregators and software vendors) to hold their own licences, extending regulatory oversight beyond the operators and adding to the industry’s compliance burden. Each jurisdiction imposes its own laws, reporting rules and compliance standards, which may conflict with those of other regulators.
Anti-Money Laundering (AML) and Know Your Customer (KYC): All reputable regulators require measures to prevent money laundering and terrorist financing, but the specifics differ. European jurisdictions follow EU AML directives—for example, verifying player identity once certain deposit thresholds are reached and promptly reporting suspicious transactions—while others may set different thresholds or approaches. Some regulators demand extensive source-of-funds checks for high-value players, and the definition of a “VIP” or high-risk customer can vary. A multi-licensed operator needs a strong AML programme that meets the strictest standards across all its licences to avoid breaches. Staying up to date with evolving AML laws (such as the EU’s 6th AML Directive) is vital across every market served.
Player Protection and Responsible Gambling: Protecting players is a universal regulatory aim, but it is enforced through a variety of rules. For example, the UK and many EU countries require operators to provide tools like self-exclusion programmes, deposit or loss limits, and periodic reality-check notifications. Some jurisdictions mandate participation in a central self-exclusion registry (e.g. the UK’s GAMSTOP or Italy’s system), which necessitates integration with those databases. Other regions have more flexible requirements or concentrate on different aspects of consumer protection, such as strict limits on advertising to minors or restrictions on bonus offers. An operator must customise its platform settings and responsible gaming features for each licence – for instance, enforcing Sweden’s deposit caps, while allowing different parameters for Curaçao-licensed players.
Technical Standards and Audits: Most licensing authorities impose technical standards on gaming software and systems. This usually includes certification of the random number generator (RNG) by approved testing laboratories, regular IT security audits, and the segregation of player funds into designated accounts. Some regulators – for instance, in Malta or the Isle of Man – require an annual system audit and compliance report. Conversely, others demand real-time access to data or periodic transaction reports for oversight. Multi-jurisdictional operators must invest in IT infrastructure and processes that meet all these standards – sometimes by maintaining separate technical environments or by implementing reporting modules for different regulators.
Advertising, Marketing and Data Protection: Advertising and marketing regulations also differ significantly across jurisdictions — for example, some countries ban or restrict bonus offers and gambling adverts on certain media. Data protection presents an additional layer: an operator serving EU customers must adhere to the GDPR when managing personal data, regardless of where its licence is issued.
Managing these diverse obligations remains a significant operational challenge. Many gaming companies establish large compliance teams or hire external consultants and law firms in each jurisdiction. The cost of compliance (and the risk of fines or licence suspension for non-compliance) has become a key factor in deciding where to operate. Sometimes, if a market’s compliance burden exceeds its revenue potential, operators may choose not to enter that market.
From the perspective of a Cyprus-based firm coordinating multi-jurisdictional compliance, we often serve as a central hub for Clients – liaising with local counsel and authorities across various countries, maintaining a calendar of filing deadlines (licence renewals, audits, tax reports, etc.), and standardising policies to meet the strictest requirements across various jurisdictions. By creating a unified compliance framework tailored to each jurisdiction, operators can better manage complexity. Technology is also crucial: modern compliance software can automate identity verification across databases, monitor transactions for suspicious patterns in line with each regulator’s thresholds, and generate the required reports for each jurisdiction with a single click. Embracing such tools has become essential in the multi-license environment.
It is also worth noting that regulators are increasingly cooperating. Authorities share information and coordinate on issues like match-fixing, AML efforts, and player self-exclusion. This means a severe compliance failure in one jurisdiction can quickly affect others. A company’s reputation must therefore be maintained consistently across all areas. On the positive side, a strong compliance record in one region can facilitate new licence applications – regulators feel more confident in applicants with a history of responsible operation under other licences.
Strategic Planning
Strategic planning is essential before expanding into multiple jurisdictions. An operator should thoroughly map out its current and future target markets and formulate a licensing plan aligned with its growth strategy.
- Target Markets: Which countries or regions are priority markets now or on the horizon?
- Scope vs. Depth: Does the business model rely on broad international reach (implying an initial broad licence) or on deep focus in a few specific markets (implying prioritising those local licences early)?
- Costs and Taxation: What are the compliance costs, tax obligations, and other regulatory requirements in each target jurisdiction?
- Operational Capacity: Do available resources align with each jurisdiction’s requirements?
For example, a B2C online casino targeting players in South and Southeast Asia – regions where regulation is often unclear – might begin with a broad offshore licence such as that offered by Anjouan. In contrast, a sportsbook aiming at Europe will likely need to obtain a licence in each major country it wants to operate in, given Europe’s strict enforcement against unlicensed operators. Sometimes a hybrid approach works best: obtaining one broad licence to cover as many regions as possible, while simultaneously applying for a few key national licences where the market potential justifies the effort.
This is where engaging expert legal and consulting advisers proves valuable. Navigating regulatory nuances is not just a legal task but also a business challenge – it involves understanding the gambling ecosystem in each region, mastering application procedures (which are often highly bureaucratic), and considering political or cultural factors that influence regulation. Experienced advisers can offer invaluable insights. For example, “If you want to get a licence in Country X eventually, note that you must have a local company and staff in place for six months before you apply.” Such foresight helps prevent costly mistakes – like pursuing an unviable licence or launching in a country only to be shut down for non-compliance.
At Michael Chambers & Co. LLC, we often coordinate multi-jurisdictional licensing projects for Clients. We collaborate closely with legal professionals and regulatory contacts in relevant jurisdictions, prepare documentation to meet diverse requirements, and guide Clients through thorough due diligence, such as background checks on owners and key personnel, which are standard in most licensing regimes. By ensuring each application is complete and consistent, we help present the strongest possible case to each regulator—reducing approval times and minimising follow-up queries. We also advise on corporate structuring to support the licensing strategy, whether by establishing subsidiaries in each target country or by using holding companies in strategic locations, such as Cyprus, to separate assets and intellectual property from the licensed operating entities.
Another key aspect is staying ahead of regulatory changes. Gambling laws worldwide are constantly evolving. New regulations are being introduced in previously open markets, such as parts of Latin America, Africa, and Asia, and established markets are frequently updating their frameworks. For example, the UK’s recent gambling review introduces stricter affordability checks and stake limits for online gaming; Germany’s Interstate Treaty 2021 established a new central regulator with tighter controls; and even traditionally lenient jurisdictions like Curaçao have overhauled their systems. A law firm with an international outlook consistently monitors such developments. We regularly provide Clients with “regulatory radar” reports highlighting upcoming changes, allowing operators to adapt proactively—whether by applying for a new licence in time or by adjusting internal policies to meet new regulations.
In summary, approaching multi-jurisdictional licensing without a plan is a recipe for trouble. However, with careful planning and expert guidance, regulatory complexity can become a competitive advantage. Companies that successfully navigate licensing across multiple regions secure first-mover advantages in newly regulated markets, gain greater customer trust (as players feel safer on well-regulated platforms), and ultimately build more sustainable businesses. Yes, the compliance costs are higher, but so are the rewards of legally and transparently reaching a broader customer base.
Conclusion
The iGaming industry is gradually transitioning from a “Wild West” period to a more mature, highly regulated sector spanning numerous jurisdictions. For operators, this involves managing a variety of licences and regulations — from offshore jurisdictions that provide broad international licences to major markets like those in the EU, each with its own strict regime. It’s a demanding environment, but one that also encourages higher standards and long-term stability within the industry. Companies investing in a comprehensive multi-jurisdictional licensing strategy today are positioning themselves for future global expansion. They are additionally building goodwill with regulators and players by demonstrating a commitment to adhering to the rules wherever they operate.
From our vantage point in Cyprus, we regularly work with international and offshore companies attracted by the country’s EU status and business-friendly environment. This has provided us with extensive experience collaborating with regulators across multiple jurisdictions. Despite differences in legal systems, we consistently see that strong governance, transparency, and regulatory compliance are key to meeting cross-border expectations.
In an increasingly interconnected regulatory landscape, cooperation and adaptability are key. Both operators and providers must be ready to update their practices and obtain new licences as laws evolve. Those who remain agile and informed will find that regulatory compliance is not just a cost centre, but a cornerstone of their brand’s credibility and longevity. With proper guidance and commitment, navigating multi-jurisdictional licensing is not a hurdle but a pathway to global success. A strong legal partner like Michael Chambers & Co. LLC can support this journey, helping businesses achieve full compliance and laying the legal groundwork for sustained growth.