Offshore gambling licences: Curaçao, Kahnawake, Anjouan

Key facts (as of 29 October 2026)

• Curaçao: the National Ordinance on Games of Chance (LOK) took effect on 24 December 2024 and made the Curaçao Gaming Authority (CGA) the direct licensing and supervisory body for online gaming, replacing the master and sub-licence system (European Gaming; CGA).
• Curaçao crypto guideline (June 2026): crypto may be accepted only as payment for gambling. Sanctioned wallets and mixers were banned immediately; player funds must sit in segregated wallets; withdrawals should normally go back to the same wallet and asset. Policies were due by September 2026, risk assessments by December 2026 and full technical controls by June 2027 (European Gaming, 30 June 2026; CGA guideline).
• Kahnawake: the Kahnawà:ke Gaming Commission (KGC) issues Client Provider Authorizations (CPAs) under its Regulations concerning Interactive Gaming, first made on 8 July 1999 and last amended on 25 March 2026. A CPA application costs US$35,000 including the first-year fee, rising to US$40,000 for applications submitted on or after 1 January 2027. The annual fee stays at US$20,000 (KGC notice, 13 August 2026).
• Anjouan: the government of the Union of the Comoros has told UK authorities that a licensing regime run in Anjouan's name is unauthorised. A Banque Centrale des Comores spokesperson called it illegal. The Anjouan register lists nearly 1,500 licence holders (iGaming House and GCA News, reporting a Guardian investigation of 19 October 2026).

At a glance

Curaçao

Under the LOK the CGA licenses operators directly. Existing licensees received provisional licences, which were extended to 24 December 2025. Applicants need a Curaçao company with a resident managing director, and the CGA reviews applications in two phases of eight weeks each, extendable by four weeks (see Gambling regulators and payments).

The June 2026 crypto guideline

Source: European Gaming, 30 June 2026, summarising the CGA guideline; CGA crypto policy guideline (June 2026).

The guideline also points licensees to FATF Recommendation 16, the Travel Rule, for transfers between regulated entities.

NoteThe CGA publishes its licence fees separately. We could not open the fee schedule this pass, so no Curaçao fee figures are given here.

Kahnawake

The KGC licenses interactive gaming from the Mohawk Territory of Kahnawà:ke. Its main operator authorisation is the Client Provider Authorization. The regulations limit a player to one player account per website operated by an authorised client provider.

Fees from the KGC advisory notice of 13 August 2026:

Complete applications submitted before 1 January 2027 are assessed under the old schedule.

Anjouan

Anjouan is an autonomous island of the Union of the Comoros. A licensing operation using its name has issued gambling licences to a large number of operators, many of them specialising in crypto gambling (GCA News, citing the Guardian).

WarningThe 2022 and December 2025 warnings concerned banking and financial licences. The October 2026 statements, as reported, address the gambling licences directly. Both reports are secondary sources quoting the Guardian. Treat an Anjouan licence as unverified authorisation until the position is settled, and check the latest statements from the Comorian authorities.

How a payments partner might read these licences

flowchart TD
    A[Operator shows an offshore licence] --> B{Which issuer?}
    B -- Curacao CGA --> C[Check licence on CGA register and crypto policy status]
    B -- Kahnawake KGC --> D[Check CPA on KGC permit holder list]
    B -- Anjouan --> E[National authorities dispute the regime]
    C --> F{Serving countries with their own licensing?}
    D --> F
    E --> G[Enhanced due diligence or decline]
    F -- Yes --> H[Local licence also needed]
    F -- No --> I[Proceed with standard high-risk onboarding]

A simplification for orientation, not advice.

Timeline

Q/A

Does a Curaçao licence allow an operator to run a crypto exchange for players?

No. Under the June 2026 guideline crypto may be accepted only as payment for gambling. Licensees may not act as an exchange, PSP or VASP, or convert or hold crypto for players outside gambling transactions.

Why does the CGA prefer stablecoins?

It treats crypto as high risk and tells licensees to favour fiat-backed regulated stablecoins, which reduce price risk on player balances and are easier to reconcile.

Is Kahnawake getting more expensive?

Yes, for new applicants and renewals from 1 January 2027: a CPA application rises from US$35,000 to US$40,000 and a five-year renewal from US$5,000 to US$40,000 (including the annual fee). The annual fee itself is unchanged.

Should a PSP treat an Anjouan licence as valid?

The Comoros government and central bank have, as reported, called the regime unauthorised and illegal. That is a strong reason for enhanced due diligence at the very least.

Sources

• European Gaming, "Curaçao's crypto guideline: what the CGA now requires of licensees" (30 June 2026): https://europeangaming.eu/portal/latest-news/2026/06/30/208477/curacaos-crypto-guideline-what-the-cga-now-requires-of-licensees/
• Curaçao Gaming Authority, crypto policy guideline (June 2026): https://gamingcontrol.spin-cdn.com/media/online_gaming_policies_and_guidelines/20261012_crypto_policy_guideline_jun_2026.pdf
• Curaçao Gaming Authority, online gaming policies and guidelines: https://www.cga.cw/regulation/online-gaming
• Government of Curaçao, CGA press release (14 October 2025): https://gobiernu.cw/wp-content/uploads/2025/10/CGA-Press-Release-14-oktober-2025-Final-Dutch-Eng-Pap.pdf
• Finzil, iGaming payment challenges (18 October 2026; secondary): https://finzil.com/blog/igaming-payment-challenges
• Kahnawà:ke Gaming Commission, increase of fees (13 August 2026): https://gamingcommission.ca/increase-of-fees/
• Kahnawà:ke Gaming Commission, Regulations concerning Interactive Gaming (25 March 2026): https://gamingcommission.ca/wp-content/uploads/2026/03/Regulations-concerning-Interactive-Gaming_March-25-2026-2.pdf
• iGaming House, "Comoros denounces Anjouan gambling 'licences' and seeks UK assistance" (19 October 2026; secondary): https://igaminghouse.net/en/news/licensing/articles/comoros-denounces-anjouan-gambling-licences-and-seeks-uk-assistance
• GCA News, "Anjouan gambling licensing faces questions over regulatory authority" (October 2026; secondary): https://gcauthority.com/news/anjouan-gambling-licensing-faces-questions-over-regulatory-authority/