iGaming & betting · Banking & EMI
An Anjouan licence, processing only where it may legally trade
A Costa Rica incorporated operator holding an Anjouan gaming licence had grown quickly, and its payment stack had broken twice in twelve months. Two processors terminated the account inside a year, each time without a clear reason given beyond risk. The operator assumed it was being de-risked for the category and came to us expecting to be told the licence was the problem.
It was not the licence. Traffic was the problem, and nobody had checked it against what the licence actually permitted.
What was actually brokenBoth terminations were licence-scope failures, not risk-scoring failures. An Anjouan licence authorises a defined set of markets. The operator's checkout was accepting players from jurisdictions well outside that set, and each processor eventually reconciled settlement geography against the licence and closed the account. A third processor would have done the same.
The Costa Rica company was also doing double duty as both the licensed operating entity and the payments counterparty. Every application therefore presented one entity carrying gaming risk, settlement risk and merchant risk at once, which reads worse to an underwriter than the business actually was.
The route we placedJurisdiction and structure type only. We never name the institutions involved.
- 1
We mapped licence scope against twelve months of actual traffic before approaching a single institution, then geo-restricted the checkout to the jurisdictions the Anjouan licence genuinely permits. Fixing this first is what made every later application survivable.
- 2
We placed operating and settlement accounts with European EMIs whose stated appetite covers licensed gaming, and added a Canadian MSB-registered rail for the North American-facing flows the licence does allow, so the two flows sit on separate infrastructure.
- 3
We structured a separate payment agent entity so the operating company is no longer also the payments counterparty, which let each application be underwritten on one risk profile rather than three stacked together.
From repeat terminations to a stack matched to what the licence actually permits.
Week 1
Licence scope vs traffic
Reconciled twelve months of settlement geography against the Anjouan licence and identified the markets driving the terminations.
Week 2
Checkout geo-restricted
Restricted acceptance to permitted jurisdictions, so the file presented a compliant footprint rather than one that would fail reconciliation later.
Weeks 3-4
Banking placed
European EMI operating and settlement accounts approved, plus a Canadian MSB rail for permitted North American flows.
Weeks 4-5
Payment agent live
Payment agent entity structured and live, separating the payments counterparty from the licensed operating company.
- Prior position
- 2 processor terminations in 12 months
- Time to full stack
- 4-5 weeks
- Structure
- EU EMI, Canadian MSB rail, payment agent
- Root cause
- Licence scope vs traffic, fixed before applying
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