Curacao vs Anjouan licence

The two regulators' pages do not show one regime asking more of a casino across the board: Curacao publishes more detail on complaints, self-exclusion and terms, and Anjouan more on ownership and bonus disclosure. The biggest difference for a player is the time allowed to complain, which is longer under Curacao's policy, and nothing in either set of rules shows one regime protecting a UK player more.

Operators in both regimes must take part in ADR, and the operator pays for it, not the player. One provider, Cadre, appears on both regulators' lists.

Who stands behind each regulator

The CGA began as the Gaming Control Board, a foundation set up on 19 April 1999 to supervise gaming in and from Curacao, a constituent country of the Kingdom of the Netherlands. When the National Ordinance on Games of Chance (LOK) came into force on 24 December 2024, the board was designated the CGA and became the independent administrative authority for licensing, supervising and enforcing online gaming. A Board of Directors runs it under a Supervisory Board. Political responsibility passed from the Minister of Finance to the Minister of Justice from 19 August 2025. The Supervisory Board resigned in mid-September 2025 and the government began appointing new members. The CGA's stated position is that all licensing and supervisory activities continued uninterrupted.

The Anjouan Gaming Authority administers and supervises Internet Gaming Licences issued under the law of the Autonomous Island of Anjouan, a constituent territory of the Union of the Comoros. It operates under the AOFA. The Anjouan Gaming Board provides supervisory oversight, and Anjouan Licensing Services Inc. is named as the sole authorised administrator of licences and official representative of the Gaming Board. The framework rests on legislation adopted in 2005, including the Anjouan Computer Gaming Licensing Act. Anjouan's pages cite an independent legal opinion, issued on 19 September 2024 and reconfirmed in February 2026 by a law firm regulated in England and Wales and Quebec, Canada, that the AOFA is the lawful gaming regulator and that licences under the 2005 Act are legally valid. That is the Authority's own account of its footing.

The points below are requirements in Curacao's own policies. They are not a ranking: Anjouan's pages set rules of their own, covered in the next section.

Complaint windows and reply times

A player can complain free of charge up to six months after the bet is settled or the incident happened. Anjouan's complaint process gives 14 calendar days for a game outcome dispute and 30 calendar days for an account dispute, such as payments, suspensions or bonuses. Only the registered player can complain.

A Curacao operator must answer within four weeks and may extend that once by another four weeks with prior written notice. Complaints about self-exclusion, cooling-off or the targeting of vulnerable players count as responsible gaming complaints, and operators must use best efforts to settle those within five business days. The player always receives a final decision in writing.

Operators must also keep an official Complaint Submission Form and report their complaints to the CGA on 15 January and 15 June. They must not restrict the player's right to take legal action, except where specific ADR terms were agreed. The ADR step can come with conditions: operators may require ADR before court, make its outcome binding on the player or set a minimum claim value. The CGA does not overturn an operator's or ADR provider's decision unless the complaint was handled inadequately.

Self-exclusion, cooling-off and limits

Operators must offer self-exclusion of 1 year, with options of 3 years, 5 years, 10 years and lifetime, and cooling-off periods of 24-hour, 7-day, 1 month or 3 month length. A player must be able to complete self-exclusion fully online in no more than 15 minutes, without emailing the operator or needing its approval. Once confirmed, it cannot be cancelled before it ends.

Remaining funds, except any frozen under anti-money laundering rules, go back to the original payment method within two business days. The operator must not send promotions or offer free play or bonuses to draw the player back. If a self-excluded person or a minor is found to have gambled anyway, the operator must refund all deposits, again within two business days.

Deposit limits are also required: daily, weekly or monthly, with a lower limit applying at once and a higher one only after a seven-day wait. Players must not be able to deposit or bet until the operator is satisfied they are 18 or older, and age checks should at least include a valid government-issued ID. Advertising must not mislead, encourage excessive gambling or target vulnerable people, and affiliates, influencers and VIP representatives must follow the same framework.

Terms and conditions

The terms guideline (Version 1.0, April 2026) requires terms to be reachable within one click from the homepage, the registration page and the account area. A player must actively accept them at registration, for example with a ticked box; "by using the site you accept" is not enough. Terms must carry the licensee's legal name, registered address, Chamber of Commerce number, licence number, issue date and name as registered with the CGA. They must also say the player agreement is governed by Curacao law, with disputes going to a competent court of Curacao.

On money, terms must state withdrawal conditions, especially identity checks once cumulative deposits and withdrawals pass XCG 4,000 (circa EUR 2,000). At account closure a licensee may refresh KYC but should not ask for more than it asked when the account opened. As a general rule, funds go back only to the account they came from. Terms must set out when winnings may be confiscated or payouts limited or refused, and must include the statement that games are fair and use certified random number generators (RNGs). The guideline enters into force within 6 months after the Version 1.0 release. Sanctions include directives to correct the terms, administrative fines and suspension or revocation of the licence.

Game testing, suppliers and local presence

B2C licensees must keep an up-to-date operations manual and hand it to the CGA within five working days of a first request. The manual covers a game supplier register, with all third-party game content checked against the official CGA supplier list. It also sets out the operator's maximum payout and withdrawal limits, including any caps per bet, per event or per period, and the technical measures that stop banned persons and self-excluded players from opening or using accounts. It names the Tier-IV certified data centre registered in Curacao and the hosting provider used for critical player records.

The CGA lists certified test labs, among them Gaming Laboratories International (GLI), eCOGRA and BMM Spain Testlabs. A test house needs current accreditation under ISO/IEC 17025 and a signed declaration that it works independently from operators and software suppliers. Being on the list is not an endorsement or guarantee by the CGA. The CGA has no technical standards of its own at present and accepts those of New Jersey, Pennsylvania, Ontario, British Columbia, the United Kingdom and Malta.

Registration for suppliers of critical services and goods must be operational by 24 December 2026. Operators need not meet the local substance obligation under Article 5.12 of the LOK before 1 April 2027.

Crypto controls

Curacao treats crypto as high risk and prefers licensees to deal in fiat-backed regulated stablecoins. Licensees may take crypto only for gambling. They must not act as an exchange, payment services provider or virtual asset service provider, and must tell players they are not responsible for any exchange used to buy or sell crypto. Crypto tied to sanctioned mixers or tumblers is banned.

By default, withdrawals go to the same wallet and in the same asset as the deposit. Wallets must be split between player flow, operations and treasury so that player and company funds do not mix. The bans took immediate effect, and licensees have 12 months (to June 2027) to put in wallet segregation, blockchain analytics, reconciliation, withdrawal whitelisting and audit-ready records.

Published fees

A B2C licence carries a one-off, non-refundable application fee of EUR 4,592. Annual fees are EUR 24,490 (licence fee to the National Treasury) plus EUR 22,960 (supervisory fee to the CGA), EUR 47,450 in total, due by 15 January. B2B licensees pay a EUR 24,490 supervisory fee and no treasury fee.

Unpaid annual fees lead on day 57 to a 21-day suspension and a notice of intention to revoke. On day 71 the licence is revoked, removed from the public licence register and placed on the enforcement register. Anjouan licence fees are also non-refundable, and its fee schedule sits on a separate Fees page.

Enforcement powers

The CGA can issue penalty orders and administrative coercion orders, impose administrative fines, and suspend, revoke or amend licences. Breaches of certain articles are criminal offences that can go to the Public Prosecutor's Office. Offering gaming in or from Curacao without a valid licence is a felony, punishable by up to two years in prison or a fine of NAf 25,000.

Enforcement runs in three phases, from prevention and information through risk-based supervision to corrective measures and sanctions, with a warning or instruction the usual response to a minor breach. The public enforcement register lists only actions that change a licence's status, such as revoked, suspended or not extended. Each entry carries the licence number, licensee, company registration, effective date and status, and no reason.

Anjouan's pages spell out the following points on ownership, bonus disclosure, domain control and enforcement.

Hidden ownership and key people

The Authority reviews the whole corporate chain to identify every beneficial owner and anyone with significant control. Directors, beneficial owners and people in senior management or compliance roles face fitness and propriety checks. Applicants must document the source of funds, and applicants, key persons and beneficial owners are screened against international sanctions lists, politically exposed persons databases and adverse media. No licence is issued while screening leaves concerns unresolved.

Licensees must disclose nominees, trusts or foundations in their shareholding, including arrangements that keep a holding below the 10% notification threshold. The Authority may ask for source of wealth checks on any beneficial owner whatever their stake, including holders of citizenship-by-investment status. B2B licensees must show a clear commercial reason for software, marketing, consultancy and technology contracts. These ownership, dispute resolution and B2B rules apply at once to new applications, and existing licensees must comply by their next renewal at the latest.

Curacao also runs probity checks up to ultimate beneficial owners, so the difference is how explicitly Anjouan names the ways ownership can be hidden.

Bonus terms and advertising

Adherence to the Code of Conduct is a condition of holding a licence. Terms must be clear and in plain language. Pricing, bonus terms, wagering requirements and withdrawal conditions must be shown clearly before a player enters into any transaction.

Advertising must be truthful, not misleading and socially responsible, and claims about winnings, odds or outcomes must be accurate and substantiated. Marketing must not be directed at minors or at people who have self-excluded. Game rules, odds and payout information must be clearly shown, and RNGs must be certified by an approved independent testing facility. Required safer gambling measures include age verification, self-exclusion, deposit and loss limits, and clear information on responsible gaming help.

Domains, seals and statuses

Operators may use only approved operational domains, and every domain change needs the Authority's approval. The official licence seal must link directly to the verification page in the public registry, appear site wide without modification and stay visible to players at all times. It must be removed immediately if the licence is suspended, revoked or expires, and it must not be used on domains or platforms the licence does not cover. Misuse, such as showing it on an unlicensed site or altering its design, can bring legal or regulatory action including suspension or revocation.

The register uses four statuses. Active means the licence is valid and the holder is in good standing. Suspended means a temporary suspension during which the holder may not operate. Revoked means permanent withdrawal for serious breach, persistent non-compliance or where a fix is not achievable. Expired means the validity period ended without renewal, whether the holder did not renew or the Authority chose not to. Only an Active licence authorises licensed gaming.

Complaint steps and ADR providers

Complaints go to the operator first, through the complaint function in its interactive site seal, and other channels may be refused. Operators must investigate and answer within 30 calendar days, after which the player may escalate to an approved ADR provider. Licensees must name their approved provider, with contact details, in their player-facing terms. The approved providers are EGIS ADR, Axion ADR, iGaming ADR and CADRE B.V.

Providers will not take a complaint where the operator's internal process was not followed, and may refuse one that is frivolous or already before another ADR provider or a court. EGIS-ADR and CADRE may refuse complaints made more than 12 months after the operator said it could not resolve the matter. Either party can appeal an EGIS-ADR decision within seven days of notification, and CADRE decisions bind operator and player unless agreed otherwise beforehand. Complaints and ADR communications must be in English, although CADRE accepts complaints in the player's native language and iGamingADR arranges translation where needed.

Players should not contact the Authority to resolve a dispute, and it will not discuss individual complaints. Anyone who believes an operator is not meeting its obligations can still report it, and a report that points to a breach may feed supervision.

Enforcement notices and supervision

Revocation is the Authority's most severe measure. Grounds include fraud, dishonesty or material misrepresentation, and conviction of the holder or a key person for a relevant offence. A revoked holder's associated URLs are also blocked from any other licence. Enforcement entries carry a stated ground. Knifex Ltd was revoked on 9 June 2026 for fraud, and Amor 25 Limited on 10 July 2026 for illegal sublicensing.

Suspension grounds include failing to keep adequate financial resources or player fund segregation, and not paying regulatory fees in time. A suspended licence can be reinstated once the holder has fixed them. Mucho Gaming Limited, a B2B holder, was suspended on 8 September 2026 for violating licence conditions and failing to take part in ADR.

After licensing, supervision is risk-based and proportionate. Licensees file compliance reports at set intervals covering anti-money laundering controls, responsible gaming and financial performance, and a notice of 10 March 2026 set the deadline for Q1 2026 reports at 30 April 2026. The Authority may run targeted reviews where there are signs of non-compliance, and can order corrective action within a deadline, with formal enforcement if it is not met.

A casino licensed abroad is never a way around a self-exclusion. Under Curacao's rules a self-exclusion covers that operator's own domains, and the player is encouraged to self-exclude from other gambling sites too. Anyone who needs support can start with responsible gambling.

On access, an Anjouan licence does not override local prohibitions or regulatory requirements. Operators alone are responsible for geo-blocking, market access controls and local compliance, and complaints from players in excluded territories fall outside regulatory review.

A Curacao licensee must show the licence holder's name and registered address, its official licence number, a statement that the CGA oversees its operations, its CGA digital seal and links to support such as GamCare, Gamblers Anonymous and GambleAware in the site footer. Take the number to the registry. Register overviews do not guarantee that a licence is currently valid, because status can change, and no rights can be derived from them. Entries can also confuse: some print no status, some past their end date still read Assessment in progress, and one licence number, OGL/2024/1397/0784, is listed against two companies, Grrr Tech B.V. and Olympus Holdings N.V. The CGA's old online gaming portal will not return to service, a decision dated 7 October 2026. Existing licences stay valid, the digital seal is affected and an alternative is promised.

An Anjouan certificate carries a unique licence number and a QR code that links to the verification page. That page shows the licensee name, licence number, status, approved operational domains and validity period. A certificate that cannot be verified through the register should not be relied on, because paper or digital copies may be outdated or altered. Register data is updated periodically, so for a time-sensitive check the Authority should be contacted directly. A register entry confirms licensing status only and is not an endorsement.

The steps for reading an entry are in how to check a casino licence, and fake and cloned casino licences covers licences that do not check out. For the comparison with Britain's regulator, see UKGC vs Curacao licence and non-UKGC casinos explained. Each regime has its own page, and so does the list of casinos that hold it:

• Curacao gaming licence explained
• Anjouan gaming licence explained
• Curacao licensed casinos
• Anjouan licensed casinos

When a regulator changes a rule, or a fact on this page turns out to be wrong, our team reads the regulator's own page or register again and corrects the page. Tell us what you found at info@biglicence.co.uk. That is the only address for corrections.

• Big Licence team checks of the licences we cover
• cga.cw Used for the Curacao Gaming Authority's own pages and register.
• spin-cdn.com Used for complaints.
• anjouangaming.com Used for Anjouan Gaming's own pages and public register.