Explosion in offshore licence providers is a key enabler of illegal betting networks

Why illegal sports betting operators bother with offshore gambling licences is not immediately clear, as those licences are, by and large, worthless. Obtaining one such licence in territories like Curaçao, Nevis, or Anjouan does not grant any legal right to operate in other jurisdictions, no more than having a handgun licence in Texas allows its holder to carry a pistol in the streets of London. 

Moreover, most offshore licences do not even permit their holders to do business in the territory that issued them: the Comoros, which Anjouan is part of, prohibits online gambling for local residents and makes it a condition for its licensees to geo-block their websites in the jurisdiction. However, worthless or not, illegal operators do have their reasons for acquiring them.

One of them is to reassure customers that their operation is legitimate and has gone through some kind of due diligence process, that it is "regulated" and, therefore, that bets placed on their platforms - and winnings - are safe.

But while some of these licences do provide a modest degree of protection (in Curaçao, for example, where there have been a handful of cases of gamblers mounting successful challenges against operators in court), in the overwhelming majority of cases, customers are helpless if and when they've been defrauded, which is often. 

Licenses provide an illusion of safety and access to banks

What matters to illegal operators is to provide an illusion of safety and legitimacy, not just to their customers but also to their service providers, including their bankers.

Access to the global banking system is paramount. Even now that illegal betting operators are pivoting to cryptocurrency as a favoured means of payment, the money must be able to flow through the system. 

A problem here is that electronic payment service providers must abide by anti-money laundering regulations. Offshore gambling licences, whilst of no value in real terms, can be used to assuage the concerns of these service providers, (some) banks included; by giving them at least the option of claiming "plausible deniability" should a problem arise with their client. Any licence is better than no licence at all.

Offshore licence providers themselves adopt a similar strategy of "plausible deniability". Over the past few years, Anjouan has become a destination of choice for hundreds of illegal operators, including some of the most prominent brands in the industry, such as Burnley sponsor BK8 and PSG and Barcelona betting partner 1XBet.

Anjouan has therefore attracted greater scrutiny, and not of a positive kind for the most part, with accusations of being little else than a purveyor of blank cheques for the darker side of the gambling business. 

The jurisdiction's "regulator", Anjouan Gaming, has responded by issuing a Summary of Core Regulatory Obligations in January 2026, which Play the Game has seen, which appears to place much stricter controls on its licensees. 

However, multiple industry sources have told Play the Game that there were no signs - as yet - of any subsequent enforcement of those measures; and how could there be, when this would mean auditing a huge number of entities, most of which are headquartered in tax havens, and Anjouan Gaming, which only employs a handful of staff, does not have the capacity to do so? 

But the twin illusions of transparency and legitimacy must be upheld. 

Scandals and new laws have closed down three licensing hubs

Until very recently, Curaçao, the Philippines and the Isle of Man were key offshore licensing hubs, the three destinations of choice for illegal Asian-facing betting operators in particular. 

It has only taken a couple of years for the map to be redrawn almost entirely. 

The Isle of Man, shaken by the King Gaming scandal, which revealed how a group of Chinese criminals had abused the island's licensing system to conduct fraudulent business, feared it could be classified as a high-risk jurisdiction by international bodies and institutions, including MONEYVAL.

MONEYVAL is a permanent monitoring body set up by the Council of Europe with the task of assessing compliance with the principal international standards to counter money laundering and the financing of terrorism.

Such a classification would have had catastrophic consequences for the banking and services sectors, which constitute the core of the economy of the autonomous British Crown Possession. 

Manx police carried out some spectacular, well-publicised raids, whilst the island's Gaming Board revoked a number of licences obtained by dubious operators. Others, including illegal casinos 188bet (Bayern Munich's Asian gambling partner) and W88 (AFC Sunderland's shirt sponsor), jumped before they were likely to be pushed. No illegal operator would now think of the island as a safe base to operate from any longer.

The Philippines went further. The proliferation of POGOs (licensed offshore gaming operators) since the mid-2010s led to a massive influx of Chinese illegal immigrants to staff the myriad companies which opened offices in the capital Manilla. It is estimated that up to 150,000 of them had flocked to the business quarters of Pasay and Makati, where some of them were subjected to appalling abuse, enslavement, torture and even murder. 

In November 2024, President Marcos issued a decree which outlawed all offshore operators and revoked the licences they'd been given by the Filipino gaming authority PAGCOR. The decree went into force on 1 January 2026. Some business-to-business companies still operate from Manila, which remains a popular venue for gambling industry conferences to this day, but the POGOs have by and large gone - and so have their licences.

Curaçao's case is more ambiguous. A series of gambling-linked scandals implicating top officials of its Gambling Control Board and politicians left the local authorities and the Kingdom of the Netherlands, of which the island is an autonomous territory, with no choice but to review the entire offshore licensing system.  This system enabled four master licensees to sell sub-licences to illegal operators with minimal oversight from the official regulator. 

Unsurprisingly, Curaçao attracted some of the most controversial operators around, including current sponsors of Everton FC and Leicester City FC, Stake.com and BC.Game.

A new law (known as "LOK", for Landsverordening op de Kansspelen, "national gambling ordinance") abolished the old master licence system altogether. At first, these changes triggered an exodus of sub-licensees, more often than not to Anjouan, but the flight appears to have ceased and even to have been reversed in the past half year. 

Nevertheless, the climate of uncertainty provided an opening for new, more accommodating licensing jurisdictions, which took full advantage of the situation.

Report documents explosion in offshore entities 

As documented by investigative journalist Steve Menary and professor Marko Begović in their 2025 report for Bristol University, 'Mapping the Offshore Gambling Regulators', there has been an explosion in the number of "offshore entities claiming to be gambling regulators" in the recent past. 

Those entities, which are domiciled (at least on paper) in the most unexpected of locations, offer similar services to what the Isle of Man, Curaçao and the Philippines long provided to illegal platforms. 

There are some surprising names in the list alongside established powerhouses of the gaming industry like Malta. Miniscule jurisdictions with zero previous presence in the gaming market, such as the Northern Mariana Islands, Palau and Equatorial Guinea, are now part of a total of more than twenty jurisdictions issuing offshore gaming licences worldwide.

Why choose such locations? The first reason is cost: the more exotic the location, the cheaper it'll be to get a licence there. Offshore licences typically cost a fraction of what would be charged by licensing authorities elsewhere.

Anjouan offers particularly attractive rates of under 20,000 euros for the initial application,  and licensees pay 0% in VAT and 0% tax on their gross gaming revenue (GGR), whereas holders of a Danish licence would be expected to pay a 28% tax on their GGR on top of their registration costs and their annual licence fees.

A "nominee shareholder" and a "nominee director" ("straw men" in all but name) can also be provided by Anjouan licence providers for an additional 10,000 euros, enabling the actual owners of the operator to remain anonymous.

Part of the trick consists in fooling customers, banking service providers and genuine regulators into believing that the "offshore entities claiming to be gambling regulators" are official, government-backed bodies similar to, say, the MDJS in Morocco or the ANJ in France, authorities which enjoy independence but remain part of their country's administrative network. 

This is easily done. The entities in question will call themselves "Gaming Board",  "Gambling Commission" and suchlike, and add the name of the offshore jurisdiction to complete the illusion, but, in reality, as Play the Game has found out from multiple sources in the gaming industry, the licence providers are private concerns run by individuals with no actual connection to the local authorities. 

A striking example of the laissez-faire which is exploited by offshore licence providers is the already-mentioned Anjouan, where no fewer than three competing "licensing authorities" have claimed to be "based" on the island, Anjouan Licensing Services Inc, Gaming Control Anjouan and Anjouan Corporate Services ltd. 

If finding out who exactly is in charge of what can be a challenge, Anjouan Licensing Services Inc. appears to have secured a quasi-monopoly in the jurisdiction. Details as to who is in charge of those companies can be just as sketchy as the information available about their clients.

Play the Game made random checks on the 1,000+ companies, which according to Mendelsson, have acquired offshore licences in Anjouan over the past three years. It is a list that keeps growing: There were fewer than 500 licensees in 2025, the 1,000 mark was passed in the autumn of 2025, and the number has surpassed 1,300 as of February 2026.

Barely any of these checks yielded results, as if these companies didn't exist at all; and when successful, invariably led to shell companies located in tax havens and jurisdictions where business information is kept strictly confidential. It was impossible to find any record of their ultimate beneficial owners. 

That, of course, is part of the appeal of Anjouan and other offshore jurisdictions to illegal operators.