Did North American Regulation Change the Offshore Casino? Anjouan, Ontario and the New Geography of Online Gambling
Something interesting is happening in offshore gambling.
Anjouan has been developing its licensing framework, including requirements involving beneficial ownership, alternative dispute resolution and B2B commercial relationships.
That’s interesting on its own.
But I think there is a much bigger question hiding underneath it:
Did offshore gambling regulation change because the international gambling market changed around it?
More specifically:
What happened to the traditional offshore casino model when jurisdictions such as Ontario and individual U.S. states increasingly insisted that gambling regulation follows the player?
That takes us down a much more interesting rabbit hole.
The Old Idea Was Relatively Simple
For years, the international online gambling model could appear remarkably straightforward from the consumer’s perspective.
A company incorporated somewhere.
It obtained a gambling licence somewhere.
It launched a website.
And players from numerous countries could potentially reach it.
Obviously, the legal reality was always more complicated than that.
But the internet created something national gambling legislation had never really been designed for:
a gambling business without meaningful geographical borders.
A casino could be incorporated in one country, licensed in another, host technology somewhere else, process payments elsewhere again and accept customers thousands of kilometres away.
Then governments started catching up.
Increasingly, the important regulatory question became not:
Where is the casino licensed?
But:
Where is the player?
That distinction changes almost everything.
Europe Was Already Moving in This Direction
It is easy to talk about a “European gambling market,” but there isn’t one universal European gambling licence.
Gambling regulation remains largely national. An authorization obtained in one European jurisdiction does not simply provide automatic authorization throughout Europe.
Great Britain provides a particularly clear example of the point-of-consumption approach.
The UK Gambling Commission states that regardless of where a business is based in the world, it needs a licence if it provides remote gambling facilities to consumers in Great Britain.
So an operator can be incorporated and licensed elsewhere and still require British authorization to serve British consumers.
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The Gambling Commission makes the same point in its remote casino licensing information.
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That represents an important shift in thinking.
The location of the gambling company matters.
But increasingly:
the location of the consumer matters too.
And Then Came Ontario
Ontario is especially fascinating because we have a very clear before-and-after date.
April 4, 2022.
That was the day Ontario launched its regulated private iGaming market.
Ontario described the launch as bringing the province’s internet gambling market out from under its previous grey-market situation.
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The Ontario system also makes an important distinction that consumers sometimes miss.
Having a gambling licence somewhere else does not make a website part of Ontario’s regulated iGaming market.
Private operators entering Ontario’s market must register with the Alcohol and Gaming Commission of Ontario (AGCO) and execute an operating agreement with iGaming Ontario (iGO).
Ontario said exactly that when announcing the market’s launch.
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And Ontario’s market performance reporting specifically describes the regulated market as operators offering games pursuant to operating agreements with iGaming Ontario.
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This is where I need to make my usual Ontario clarification.
An Anjouan Licence Is Not an Ontario Registration
Neither is a Curaçao licence.
Neither is a Malta licence.
Neither is any other foreign gambling licence.
A statement in a website footer saying that a casino is licensed somewhere overseas tells you something about its regulatory status under that jurisdiction.
It does not establish that the casino participates in Ontario’s regulated iGaming market.
Those are two completely different things.
If you’re physically located in Ontario and want to determine whether a gambling website participates in Ontario’s regulated system, Ontario’s own regulatory information is the relevant place to check.
That distinction matters.
A lot.
The United States Makes Geography Even More Complicated
Then there is the United States.
The American regulatory landscape is even more geographically fragmented.
Online gambling authorization largely operates at the state level.
That means there isn’t simply one American online casino market.
There are individual state markets, each operating according to its applicable legislation and regulatory framework.
An operator’s authorization in one state doesn’t automatically authorize that operator in another.
Now imagine operating an international gambling business.
You no longer have one question:
Are we licensed?
You potentially have many.
Are we authorized in Ontario?
Great Britain?
Germany?
The Netherlands?
New Jersey?
Michigan?
Pennsylvania?
And so on.
The answer can legitimately change depending upon where the person holding the phone happens to be standing.
Which Makes Me Wonder About the Offshore Industry Itself
This is where I’m going to play devil’s advocate.
When we encounter increasingly complicated corporate structures behind offshore casinos, it is tempting to immediately interpret that complexity as suspicious.
Sometimes complexity deserves scrutiny.
But there’s another possible explanation that shouldn’t be ignored.
Maybe international gambling businesses became structurally more complicated because gambling regulation became geographically more complicated.
Think about what a modern international gambling business potentially needs to accommodate.
An Ontario-regulated operation has one regulatory framework.
A U.S. state-regulated operation may have another.
A British operation has another.
Individual European countries can impose different requirements.
And offshore markets continue to exist alongside all of them.
Suddenly, putting everything under one company, one website and one operational structure might not make much sense at all.
Enter the Corporate Onion
A modern international gambling operation can potentially involve:
Brand
↓
Trademark owner
↓
B2C operator
↓
Platform provider
↓
B2B technology provider
↓
Game aggregator
↓
Individual game studios
↓
Payment infrastructure
↓
Marketing providers
↓
Affiliate networks
↓
Corporate service providers
That can look extraordinarily complicated when you’re trying to research it from the outside.
But complexity alone doesn’t establish wrongdoing.
There can be completely legitimate reasons to separate intellectual property, technology, marketing, payments and regulated gambling operations.
In fact, increasingly jurisdiction-specific regulation may create very good reasons for doing exactly that.
The problem is that it changes the investigative question.
“Who Owns This Casino?” May No Longer Be Enough
That used to be my favourite question.
I’m increasingly convinced it isn’t the best one.
The better questions are:
Who legally operates this particular website?
Who ultimately owns or controls that operator?
Who owns the brand and intellectual property?
Who supplies the gambling platform?
Who provides or aggregates the games?
Who handles payments?
Who performs customer acquisition and marketing?
Which entities contract with each other?
Which entity is licensed in which jurisdiction?
And perhaps most importantly:
Which of those relationships changes when the player’s location changes?
That last question could tell us an enormous amount about how modern international gambling actually works.
Which Brings Us Back to Anjouan
This is why developments in Anjouan become much more interesting.
If a regulator wants to understand a modern online gambling operation, simply knowing the name of the company holding the consumer-facing licence may no longer be enough.
It also needs to understand ownership and control, technology, B2B relationships and the infrastructure surrounding the operator.
Anjouan’s licensing materials increasingly speak the language of:
beneficial ownership
B2C and B2B licensing
corporate structures
commercial relationships
alternative dispute resolution
ongoing supervision
licence verification
Those are meaningful areas of regulation.
Anjouan’s current licensing information can be found directly here:
Its licence conditions are here:
Its public licence register is here:
Its licence verification system is here:
And its regulatory notices and updates are here:
Is Anjouan Getting Standards?
It certainly appears to be developing a more detailed regulatory framework.
And credit where credit is due.
Beneficial ownership transparency is useful.
Understanding B2B relationships is useful.
Alternative dispute resolution is useful.
Corporate disclosure is useful.
Independent licence verification is useful.
Ongoing supervision is useful.
But there is an important distinction between regulatory architecture and regulatory effectiveness.
The real test comes afterward.
How thoroughly are beneficial owners verified?
How closely are B2B relationships examined?
What happens when an operator doesn’t comply?
Are consumer complaints meaningfully resolved?
Are suspensions and revocations used when appropriate?
Are enforcement outcomes sufficiently transparent for consumers and other regulators to understand them?
Those aren’t criticisms unique to Anjouan.
They are questions we should ask of every gambling regulator.
A regulatory framework ultimately proves itself through implementation.
But Ontario Creates an Awkward Question: Who Should Have Known Better?
This is where Ontario makes the story considerably more complicated.
Because Ontario didn’t simply regulate casino operators.
It built a regulatory ecosystem involving operators, gaming-related suppliers, technology providers and independent testing laboratories.
And many companies participating in that ecosystem are sophisticated international gambling businesses.
They understand geolocation.
They understand regulated versus unregulated markets.
They understand licensing.
They understand game certification.
They understand supplier contracts.
They understand jurisdictional restrictions.
They understand that a product approved for one market isn’t automatically approved for another.
In fact, Ontario’s regulatory framework requires operators to provide the AGCO with an up-to-date list of the suppliers supporting their Ontario gaming sites, including suppliers within their own corporate structures and third-party suppliers.
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The AGCO’s standards also place obligations directly on registered gaming-related suppliers.
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And Ontario requires applicable gaming technology to be certified against Ontario’s standards before deployment in the regulated market.
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So there is an interesting question that deserves to be asked without presuming the answer.
If a sophisticated international supplier participates in Ontario’s regulated market, how much responsibility should it bear for knowing where else its products are being supplied?
That question becomes especially interesting when the same supplier’s games can also be found on offshore websites accessible from Ontario.
There are several possible layers.
The offshore operator knows where it accepts registrations and wagers.
The platform provider may know which domains and operators use its infrastructure.
The aggregator may know where particular game libraries are being distributed.
The game studio knows its contractual counterparties, although it may not necessarily control every downstream deployment.
The payment provider has its own view of transactions and merchants.
And the regulated supplier may simultaneously have obligations arising from participation in regulated markets.
Exactly how much visibility and control each participant possesses will depend on its contracts, technology and position in the supply chain.
That is why simply saying:
“The casino was offshore”
doesn’t necessarily end the regulatory conversation.
Ontario Has Already Demonstrated That Point
Ontario’s regulatory model isn’t confined to looking at the website taking the wager.
The AGCO regulates gaming-related suppliers as well as operators and explicitly states that it monitors both for compliance with Ontario’s regulatory obligations.
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That changes the question from:
Was this offshore casino licensed in Ontario?
Obviously, an offshore licence itself doesn’t provide Ontario authorization.
The more interesting question becomes:
What responsibilities do companies participating in Ontario’s regulated ecosystem have when their products or services also appear elsewhere?
And that brings us straight back to the evolution of offshore corporate structures.
Because once suppliers participate simultaneously in regulated and offshore markets, separation becomes extremely important.
Separate entities.
Separate contracts.
Separate domains.
Separate platforms.
Separate licences.
Separate game catalogues.
Separate geographic permissions.
Separate compliance controls.
That separation may be entirely legitimate and, in many circumstances, necessary.
But effective separation has to exist operationally, not merely on a corporate diagram.
If a business says Market A and Market B are separate, the interesting regulatory question is whether its technology, contractual controls and distribution practices actually maintain that separation.
That is where Ontario becomes particularly fascinating.
The province launched its regulated private iGaming market in 2022.
It didn’t invent international gambling.
It entered an industry that was already global.
And many of the businesses entering Ontario already possessed years of experience operating across multiple jurisdictions.
So perhaps Ontario didn’t merely change where casinos could legally advertise and take bets.
Perhaps it also forced the international gambling supply chain to become much more precise about which company supplies what, to whom, through which platform, on which domain, and in which jurisdiction.
And that leads to a question I think is considerably more important than simply asking who owns an offshore casino:
Who knew where the product was going?
Because in a modern gambling ecosystem, the casino at the end of the chain may be only the most visible participant.
The regulatory story may increasingly lie upstream.
But Maybe This Story Is Bigger Than Anjouan
This is the part I’m most interested in.
Maybe we’re watching two evolutions meet.
For decades, offshore gambling developed around the internet’s ability to transcend geography.
Governments increasingly responded by making geography matter again.
Great Britain: Are you providing gambling to British consumers?
European jurisdictions: Are you offering gambling within our national market?
Ontario: Are you registered and operating within Ontario’s regulated system?
United States: What state is the player physically located in, and what does that state’s regulatory framework permit?
Meanwhile, offshore jurisdictions have had to evolve in a world where their licensees may exist alongside businesses participating in those highly regulated markets.
That creates an enormous compliance puzzle.
And perhaps it helps explain why the international gambling industry of 2026 looks structurally different from the offshore gambling industry of ten or fifteen years ago.
So Here’s the Question I’m waiting for Ontario to answer.
Not:
Are complicated corporate structures evidence that casinos are hiding something?
That’s too simplistic.
And not:
Does an Anjouan licence make a casino regulated in Ontario?
Absolutely not.
The much more interesting question is:
Did the expansion of point-of-consumption gambling regulation force the offshore casino industry to evolve?
Did Ontario’s regulated market matter?
Did expanding U.S. state regulation matter?
Did increasingly nationalized European regulation matter?
Did supplier compliance obligations matter?
Did geolocation become more sophisticated?
Did international gambling groups begin separating brands, operating entities, intellectual property, technology, payments and B2B services more deliberately as a result?
And if they did:
Can we actually see that evolution in the corporate record?
Because Ontario gives us a particularly useful line in the sand:
April 4, 2022.
Look at international casino structures before that date.
Then look at them afterward.
Look at corporate entities.
Look at trademarks.
Look at domains.
Look at licences.
Look at B2B providers.
Look at payment companies.
Look at supplier relationships.
Then compare what changed.
That could tell us whether we’re simply looking at increasingly complicated offshore casinos…
or witnessing the creation of an entirely different international gambling architecture.
One Last Ontario Reminder 😇
I can be genuinely encouraged by Anjouan strengthening its regulatory framework while simultaneously saying this:
Anjouan licensing and Ontario regulation are not interchangeable.
Ontario has its regulatory system.
Anjouan has its regulatory system.
Great Britain has its regulatory system.
The United States has state-based regulatory systems.
European jurisdictions maintain their respective frameworks.
A licence can help answer:
“Which authority licenses this operation?”
It doesn’t necessarily answer:
“In which jurisdictions is this operation authorized to offer gambling?”
Those are increasingly two very different questions.
And perhaps understanding that distinction is the key to understanding where international online gambling is heading next.
The internet made gambling global.
Regulators made location matter again.
Now the corporate structures sitting between those two realities may be changing with them.
And that is something worth watching.
Sources and Further Reading
Anjouan Gaming, Licensing
Anjouan Gaming, Licence Conditions
Anjouan Gaming, Public Licence Register
Anjouan Gaming, Verify a Licence
Anjouan Gaming, Regulatory Notices and Updates
iGaming Ontario, Ontario’s New iGaming Market Is Live, April 4, 2022
iGaming Ontario, Ontario’s New iGaming Market to Launch April 4, 2022
iGaming Ontario, Market Performance Reports
UK Gambling Commission, Remote Gambling
UK Gambling Commission, Remote Casino Operating Licence
European Commission, Online Gambling
European Commission, Gambling Case Law
