The Corporate Structure Behind an Anjouan Gaming Licence (2026)

Most operators think an Anjouan gaming licence is a single thing you buy. It isn’t — it’s the top layer of a small stack of companies, and the licence is worthless if the structure underneath it can’t contract, bank or take payments. The question that actually decides whether you launch is which entity holds what, and where each one sits.

In our practice the answer is consistent: the applicant company is incorporated in Costa Rica, the Anjouan licence is issued to it and sits on top, and — where your payment model needs it — a separate payment-agent company in Cyprus handles the fiat rails. This is the definitive breakdown of how that structure works, who holds each piece, what the nominee and UBO options really change, and why it survives bank and PSP underwriting when a naked offshore shell does not.

The three-entity structure at a glance

Anjouan is unusual among offshore regimes in that it demands no physical presence — no local office, no resident director, no on-island server. That single fact is what makes the structure below possible: because the island requires nothing locally, you’re free to put the operating company wherever it does the most work. The result is a lean stack of one or two companies plus the licence, not a tangle of shells.

Read top to bottom, that’s the whole thing. The licence doesn’t own anything and doesn’t sign anything — it’s an attribute of the Costa Rica company. The Cyprus agent, when present, is a payments convenience layer, not a second licensee. Everything commercial flows through the operating company in the middle. For the full fee and legitimacy picture behind the permit itself, our Anjouan gaming licence guide covers the licence layer in detail; this article is about the companies around it.

Why the applicant company sits in Costa Rica

Anjouan permits an applicant to be an Anjouan IBC or a compliant non-resident company — it does not force local incorporation. So the real decision is where to put the entity that will actually run the business, and Costa Rica has become the default for reasons that are entirely practical rather than clever.

It’s fast and inexpensive to form, and it carries no gaming tax on income earned from international operations — which pairs cleanly with Anjouan’s 0% tax on gross gaming revenue. Just as importantly, it’s a jurisdiction the supply side already knows: game studios, aggregators, platform providers and payment partners onboard Costa Rica operating companies as a matter of routine. That familiarity is worth more than it sounds, because every counterparty you deal with is underwriting your company, not your licence.

This pairing isn’t theoretical. When we last analysed the public Anjouan register, 191 of roughly 1,400 licence holders traced back to a single Costa Rica corporate identifier — a strong signal that Anjouan-on-Costa-Rica is the established structure, not an edge case. Operators coming across from other regimes recognise the shape immediately; it’s the same backbone we use for Curaçao-to-Anjouan migrations, just without the local-substance overhead Curaçao demands.

The Cyprus payment agent: who needs it, and why

Here’s the friction that catches most new operators: many card acquirers, PSPs and e-money institutions will not contract or settle with an offshore company. Their own risk and correspondent-banking rules push them toward an EU-based counterparty. That’s the gap the Cyprus payment agent fills.

The Cyprus company is a separate legal entity that sits between the operator and the fiat rails. It’s the name on the PSP agreement and the entity player card payments settle into, before funds move on to the operating company under an intercompany arrangement. It holds no gaming licence — it isn’t a second operator — and within the EU’s PSD2 framework it acts as a payment-facing contracting party, not a regulated payment institution in its own right. What it buys you is acceptance: an EU counterparty that card schemes and acquirers are comfortable underwriting.

You do not always need it. A crypto-first casino that runs deposits and withdrawals on-chain can often launch on the Costa Rica company and an EMI account alone — the Cyprus layer only earns its keep once fiat card processing enters the mix. We scope it to your real payment model rather than adding it by reflex; the mechanics of that decision are laid out in our Anjouan payments guide, and the crypto-only path in the Anjouan crypto payments breakdown.

Who holds what: shareholders, UBOs and nominees

Ownership runs through the Costa Rica company. Shares in that operating entity are held by you — directly, through a holding company, or through nominees — and it is that entity, as licensee, that the ABGB scrutinises. The Anjouan due-diligence process reaches through the corporate layer to every shareholder, director and ultimate beneficial owner: passports, proof of address, source-of-funds evidence and clean-record checks are mandatory for each of them. That is a fixed requirement, covered in full in our Anjouan licence requirements guide.

This is where operators most often misread the structure, so it’s worth being blunt. Nominees change public visibility, not regulatory disclosure. A nominee director or shareholder means your name need not appear on the public corporate record — a legitimate privacy and administration choice used across the industry. It does not hide the real UBO from the regulator or the bank, and it must never be sold as if it does. The ABGB always sees the true beneficial owner, and so, under their own KYC, does any EMI you open an account with. Used honestly, nominees keep your name off a public filing while every regulated party who needs the truth still gets it.

Why this structure is bankable

The whole point of building it this way is to survive underwriting — because in this industry, banking, not the licence, is what stalls launches. Gambling is a high-risk category everywhere, and offshore gambling doubly so, which is why you will never bank a gaming operation through Wise, Stripe or PayPal: mainstream processors prohibit the category outright. The realistic path is an EMI or specialist neobank that knowingly serves high-risk merchants, plus, where fiat cards are involved, the Cyprus payment agent as the acquirer’s EU counterparty.

What makes this stack bankable is that every layer gives the underwriter something concrete to approve. There’s a real operating company with substance and a paper trail, a verifiable Anjouan licence they can look up on the public register, and — for the fiat rails — a recognisable EU entity to contract with. That’s the opposite of a bare offshore shell, which is exactly the profile that gets declined. If you want to understand the failure mode this avoids, our guide on why high-risk banking fails walks through the common rejections, and the gaming company bank account guide covers what a compliant application looks like.

None of this is about hiding money or gaming the rules. It’s the reverse: a structure legible enough that a regulator, a bank and an acquirer can each underwrite the part they care about. Get the entities right up front — Costa Rica operating company, Anjouan licence on top, Cyprus payment agent where the fiat rails demand it — and the licence you paid €17,828 for actually turns into a business that can take deposits. Get it wrong and you own a certificate that no bank will touch.

If you’re structuring a new Anjouan operation or untangling one that’s stalled at the banking stage, we set the whole stack up end to end and match it to your real payment model. See the Anjouan gaming licence service, compare the numbers in our Anjouan licence cost breakdown, or book a free consultation and we’ll map the right structure to the markets you actually plan to serve.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.