Legal Gaming: How to Launch a Gambling Project and Avoid Getting Blocked

The last two years have seen regulators worldwide tighten the screws on online gambling. In Europe and the UK, new laws and crackdowns (such as the UK’s Gambling Act 2025 reforms) impose strict affordability checks, advertising curbs and enhanced enforcement powers. Meanwhile Latin American markets are racing to establish legal regimes: Peru, Argentina and Brazil all launched new licensing frameworks in 2024–25 as the regulated market is projected to hit $7.86 billion by 2027. In this climate, any operator without a credible license risks being shut out – by payment processors, affiliates, or even government mandates. This makes “legal gaming” (proper licensing and compliance) absolutely critical for any new gambling venture in 2024–25.

Choosing a Licensing Jurisdiction in 2025

Different jurisdictions offer very different trade-offs. Below is a summary of some popular options (with pros, cons and risk factors):

• Curaçao (Curacao Gaming Authority). One of the longest-standing “.com” licenses, Curaçao remains popular for its relative ease and low cost. Pros: Broad product coverage (one license covers casino games and sports betting), fast processing, global reach, and improved standing – as of Dec 2024 it began operating under a new gaming authority (CGA) with stricter AML rules. In March 2025 Curaçao was removed from the EU’s “gray list” of tax havens, reflecting reforms. Licensees enjoy benefits like “peace of mind” to operate legally, ability to open merchant accounts, and enhanced credibility with partners. Cons/Risks: Curaçao’s license does not allow play from certain regulated countries (notably the UK, Germany, and others) without a local license. Operators must now meet local substance requirements (e.g. local director and staff, AML monitoring). Although still cost-effective, Curaçao’s regime now imposes higher fees and oversight. In short, it’s fast and flexible, but operators must carefully exclude disallowed markets and stay on top of the new Curaçao regulations.

  
  

• Anjouan (Comoros). A newer “master license” from the island of Anjouan (part of the Comoros) is emerging as a low-cost alternative to Curaçao. Pros: Very affordable (~€17,000 application fee), with zero tax on gross gaming revenue. Issuance is fast (often 2–4 weeks with complete paperwork. The Anjouan license covers all gambling activities (casino, sports, crypto) under one certificate and is crypto-friendly. It can be granted as a B2C or B2B license without sub-licenses, simplifying operations. Cons/Risks: It’s still relatively unknown. Its geographic exclusion list is larger (explicitly barring UK, USA, EU major markets, etc.), so it cannot target Western markets. Operators should rigorously verify any Anjouan license with the ALSI regulator (e.g. by contacting the operator directly), since transparency is still improving. In short, Anjouan offers very favorable costs and broad coverage for non-Western markets, but its novelty and limited recognition mean higher perceived risk.

  
  

• Isle of Man (GSC license). The Isle of Man is one of the world’s most trusted iGaming regulators. Pros: It carries top-tier reputation and player trust. The regime is well-regarded for “highest standards of regulation”, so a license signals credibility to players and partners. Corporate tax is 0%, and the regulator is known for cooperative flexibility. It offers a range of license types (casino, sports, software providers, hosting) and an efficient, transparent process. Cons/Risks: The downside is cost: licensing and annual fees are high, and there is a strict capital requirement (typically £100,000 equity). Smaller startups may struggle with these thresholds. Additionally, an Isle of Man license does not automatically allow entry into major markets like the US or Australia - operators targeting those regions would need other licenses. Also, the regulator expects a credible physical or corporate presence, which adds complexity. In summary, the IOM license gives maximum credibility and a tax-efficient base, but at higher setup and maintenance cost.

  
  

• Malta (MGA license). Malta’s Gaming Authority is a gold-standard EU regulator. Pros: A Malta license opens up the entire European market (most EU countries respect the MGA license) and is widely recognized as a mark of trust. It provides strong consumer protections and stable, transparent rules. Licensees benefit from comprehensive regulatory oversight and can use licensed white-label platforms built for MGA standards. Cons/Risks: The process is rigorous and time-consuming. Applicants must staff multiple “Key Officers” (e.g. compliance, AML, risk) and meet capital requirements (e.g. €100k for primary game types). A system audit and on-site compliance review are mandatory before going live, and the entire procedure can easily take 6–12 months. Costs are substantial (application fees, €10–25k license fee per year, plus compliance audits). In short, MGA accreditation grants immediate legitimacy in Europe and is excellent for long-term growth, but requires deep pockets and patience to achieve.

  
  

• Other jurisdictions: A few other licences may be worth considering on a case-by-case basis. For example, Panama and Antigua & Barbuda have historically issued “.com” licenses, but these are less popular now due to questions about credibility and evolving international standards. Serbia introduced regulated online gambling in 2023, but the €2,500/month license is only valid for Serb-based operations. USA: The U.S. is licensing on a state level (e.g. Kentucky, Virginia), but these are usually for local operators only. Costa Rica technically has no online gambling license (operators register as service providers), which is risky for serious brands. In practice, most international operators choose Curaçao or Malta/IOM as their home base, while using other licenses (UK, Latin American local permits, etc.) to specifically access those markets.

White-Label Gambling Solutions: Fast but with Caveats

A white-label gambling platform lets you rent a ready-made casino or sportsbook under someone else’s license and infrastructure. The provider handles the heavy lifting – software, games, payments, KYC/AML systems, and most compliance – while you supply your brand, marketing and front-end support. As one industry guide explains, a white-label is essentially “a fully managed online gambling platform provided by a third-party company that holds a valid online gambling licence”. The operator runs the site under its own name, but the legal license and tech belong to the provider.

How it works: The provider’s license is the foundation. Under the contract, the provider typically offers:

• A valid gaming license (e.g. from Curaçao, Malta or Isle of Man) for the operator to use;

• The complete platform: game integrations, player account management, payment gateway and fraud/AML tools.

• Technical support and compliance services, so the brand can launch quickly. The operator then focuses on branding, acquiring customers and support. In essence, you gain “all of the benefits of an MGA license – whilst also leveraging the software provider’s own industry expertise” (the MGA source here noting white-label in a Malta context). This makes white-label very attractive for startups or affiliates with limited capital: you don’t pay for your own license or develop your own software, so you get to market in weeks, not months.

Benefits:

• Speed to market: With most backend work done, you can launch in weeks or a few months – much faster than a full license application.

• Lower upfront cost: No large license fee or capital is needed initially – you typically pay a setup fee and/or revenue share to the provider.

• Regulatory “insulation”: Because the provider is the licensee, the operator can focus on marketing and sales. The burden of meeting day-to-day regulatory requirements (reporting, audits) falls to the provider.

• Bundled services: White-label agreements often include support like KYC/AML systems, support staff or tools (for example, some even offer tools for responsible gaming or fraud).

• Ideal for testing: It lets you validate a market or concept without the full investment of a standalone operation. 

Compliance Risks: However, white-label comes with important caveats – increasingly underscored by regulators. By definition, a white-label operator is only as strong as the provider’s license. For example, a Curaçao-licensed white label cannot legally accept players in the UK or Germany (since Curaçao doesn’t cover those markets). This means your jurisdictional reach is tied to the provider’s license. Expanding into a restricted market (like the UK) would require exiting the white-label and re-platforming under an appropriate license.

In practical terms, white-label pitfalls include:

• Jurisdictional limits: You’re blocked from markets the license doesn’t cover (so your growth is constrained).

• Reputation issues: Some partners and affiliates may view white-label brands as higher-risk or less stable compared to fully independent licensees

• Control and scalability: You have limited control over the platform features and tech stack. As you grow, you may outgrow the shared infrastructure; migrating to your own license later incurs costs and delays

• Brand similarity: Multiple white-labels on the same platform may look similar, making differentiation harder

White-label solutions can be very useful for a quick startup, but every operator must plan for compliance. This means thoroughly vetting the provider and understanding exactly which players or regions you are allowed to target. If your business succeeds, you should be ready to invest in a separate turnkey platform or independent license in the long run. As regulators in 2025 demonstrate, simply hiding behind someone else’s license is not a guarantee of safety.

Why a Valid License is Essential (Beyond Just “Being Legal”)

Getting a gambling license is not merely about obeying the law – it’s the key to many other parts of the business:

• Payment Processing: Virtually all banks and payment service providers require a gambling license before opening merchant accounts or facilitating deposits/withdrawals. In Curaçao’s words: having a license “enables you to open a merchant account – most financial institutions won’t let an online casino business open an account without a license.” Without a license, you’ll struggle to get card processors, e-wallet integrations or crypto payment providers to work with you – severely limiting your ability to collect and pay out player funds.

• Traffic and Marketing: Advertising networks, affiliate programs and affiliate marketers typically demand that the casinos they promote are properly licensed. Many traffic sources will block ads for “illegal” or unlicensed gambling sites. White-label aside, even operating from a shady offshore address can trigger ad bans. Having a recognized license (especially from an EU/UK regulator) makes it far easier to run ads on Google, social media or affiliate networks without fear of bans or account shutdowns.

• Partnerships and Software: Top-tier game developers, sportsbook platforms and payment vendors usually only supply licensees. A license signals credibility: for instance, having an MGA or IOM license “makes your casino more appealing for software and payment service providers, many of whom refuse to cooperate with operators who are unlicensed.” In practice, a licensed operator can integrate the latest games, open accounts with leading PSPs and join major gaming networks, whereas an unlicensed brand will be shunned.

• Brand Credibility: Players prefer (and trust) licensed casinos. A license means you’ve passed a regulator’s vetting – in Curaçao’s words, it “grants the casino a significant amount of legitimacy in players’ eyes.” Especially in regulated markets, showing a license badge (or listing on a regulator’s website) is a basic trust signal.

In short, a license is foundational for operations, payments, marketing and reputation. As one Curaçao guide puts it, licensure gives operators “peace of mind that they can do business without having to worry about legal repercussions”. Conversely, we’ve seen in practice at Lex Legas that operators without credible licensing often end up blacklisted by banks, have affiliate campaigns paused, or face enforcement actions – all of which choke off traffic and revenue.

Lex Legas Insights: Structuring, Compliance and Best Practices

Drawing on years of experience advising gaming clients, Lex Legas emphasizes proactivity and structure in launching a gambling project:

• Jurisdiction Selection & Corporate Structure: We guide clients in choosing the jurisdiction that best fits their target markets and budget. For example, our attorneys can help incorporate a holding company in Curaçao or set up an MGA-licensed operating company in Malta, ensuring the corporate setup satisfies local substance rules. This often involves coordinating with local law firms and accountants to establish a compliant entity with the required local directors or offices.

• License Application Preparation: Applying for a license requires extensive documentation (CVs, banking references, proofs of funds, business plans, system audits, etc.). We assist in gathering and organizing everything the regulator will demand – from drafting company bylaws and AML policies to scheduling the mandatory system audit (as with Malta). In Curaçao or Anjouan applications, for instance, we prepare the detailed personal due diligence packages needed to satisfy KYC checks. 

• Compliance Program Setup: Obtaining a license is just the start. To retain it, operators need robust AML/CFT and responsible gambling frameworks. Lex Legas advises on building these programs (e.g. customer risk profiling, transaction monitoring, self-exclusion procedures), tailored to each jurisdiction’s rules. We also conduct mock audits and ongoing reviews so that by the time regulators knock, the client is ready.

• Banking & PSP Introductions: We leverage our network of payment specialists to help clients open merchant accounts and crypto wallets under their license. Having legal support for due diligence often reassures banks, helping to unlock banking and payment options that would otherwise be closed to an unlicensed operator.

• Regulatory Updates & Licensing Strategy: Because the rules keep changing, we keep clients informed of the latest developments. For example, when the UK introduced new affordability checks and advertising restrictions, we advised how to adapt UK-facing operations accordingly. Similarly, we monitor EU directives or Latin American licensing rollouts so clients can apply to new markets (Peru and Chile are great examples of emerging regulated markets in 2024–25).

In all these steps, our goal is to make compliance an enabler, not an afterthought. By structuring the project properly from day one, we help operators avoid the dreaded scenario of an abrupt block or fine later on.

Actionable Tips: As a practical checklist when launching a gambling project, remember:

• Choose Your Jurisdiction Wisely: Map out which countries you want to target and pick licenses accordingly. For example, use MGA/IOM if EU markets matter; Curaçao/Anjouan for broader international play; local licenses for specific national markets (e.g. a UK license if aiming at Britain).

• Do Your Due Diligence: If going the white-label route, vet the provider rigorously. Confirm their license is valid, ask for proof of regulatory registrations, and verify they actually have AML procedures in place. 

• Budget for Full Compliance: Even a fast license requires prep. Allocate time and money for AML consultants, audits and the regulator’s fees. For instance, anticipate a 6–12 month timeline for an MGA license, and have the capital ready.

• Prepare KYC/AML from Day One: Implement strong customer identity and transaction monitoring procedures before launch. This not only keeps you legal but prevents regulators from treating you like the “bad actors” they’re going after.

• Plan for the Long Term: If you start on white label to test waters, plan an exit strategy to a standalone license as you grow. Consider a turnkey platform as an intermediate step: it lets you own your license while still outsourcing tech. Either way, early planning saves headache later. 

• Keep Learning the Rules: Regulations evolve. Bookmark regulator websites (UKGC, MGA, etc.), attend industry webinars, and adjust your compliance as laws change. For example, new UK advertising restrictions in 2025 or MiCA rules for crypto gaming may require tweaks.

• Work with Experienced Advisors: Specialized gambling lawyers (like Lex Legas) can identify pitfalls that general counsel might miss. Use experts for tasks like filling out applications, translating documents for the regulator, and interpreting subtle regulatory language.

Launching a gambling project in 2025 means balancing opportunity with caution. By selecting the right license, building a solid compliance foundation, and staying informed of regulatory trends, you can open doors instead of hitting roadblocks. At Lex Legas, we combine our legal expertise with hands-on industry knowledge to guide operators through every step – from initial structuring to ongoing compliance support – so you can grow your brand safely and confidently.