This is a guest contribution by Lionel Iruk. An i‐gaming, international wealth management, M&A, principal attorney and manager at Empire Legal. If you would like to submit a contribution please contact Bill Beatty for submission details. Thank you.
In the second of a two part series, Lionel Iruk of Empire Legal discusses various banking destinations for online casinos. If you missed part one, read here.
A. Banking Destinations for online casinos
Gibraltar is considered as one of the most important global financial services destination. It boasts of an extremely stable economy and is largely insulated from global financial upheavals. Gibraltar is also one of the few destinations in Europe which has a regulated online casino licensing system.
The Licensing Authority in Gibraltar is headed by the Gambling Commissioner and a number of online casinos are licensed to the jurisdiction. Gibraltar licenses are highly respected and can be used to access customers from across Europe.
According to the Licensing Authority in Gibraltar, “No bank account or credit card merchant account, nor the receipt, processing, holding and clearance of customer funds and credit card transactions, shall be maintained by the licensee in a jurisdiction other than Gibraltar, or in a Gibraltar licensed institution without the prior approval of the Licensing Authority.”
Further, accounts have to be maintained as per applicable laws. This basically means that banks in Gibraltar provide banking services to online casinos as permitted by the Licensing authority.
The major advantage with Gibraltar as a destination for licensing your online casino and ultimately opening a bank account to operate the casino from the destination is that it has representations from some of the most renowned banks in the world. Further, it would also allow transactions in Euro and GBP which are preferred currencies for global transactions.
On the other hand, Gibraltar also has a very low gaming tax rate 1% of the turnover up to £42,500,000 of annual turnover with the gaming tax capped at 425,000 per annum, with a minimum annual tax payable of £85,000. This makes it an ideal destination for entrepreneurs who are looking to target the European market.
As a well regulated European economy, most payment gateway service providers will be willing to link with bank accounts based in Gibraltar and this would allow you to provide a large number of payment options. The Jyske Bank in Gibraltar is a preferred banking partner but has high minimum funding requirements of over $ 100,000.
Overall, Gibraltar is highly recommended as a banking destination, but obtaining banking services may not be possible without a local online gaming license.
b) Isle of Man
The Isle of Man is one of the crown dependencies of the United Kingdom. It has a separate currency called the Manx Pound which is fixed at par with the British Pound. Hence, both the economies are strongly integrated. On the other hand, Isle of Man has a strongly developed local software industry and has also promoted the growth of a healthy online gaming industry.
The Gambling industry in Isle of Man is regulated by the Gambling Supervision Commission which aims to make Isle of Man one of the preferred online gaming hubs with a range of support services to aid the industry.
Owing to the support of the local government authorities for online gaming and the close relation of the island with the British Banking industry, the banks in Isle of Man provide online banking services to the online gaming sector.
Entrepreneurs who are willing to take advantage of Isle of Man as a gaming destination are at most times encouraged to take a local egaming license and shift the business there. The island boasts of excellent IT infrastructure, friendly regulations, support services and a very low tax rate between 0.1 to 1.5%. The island also operates a special start-up promotion scheme called “Where you can” to promote the businesses. On the other hand, the island is a white listed jurisdiction under the OECD and also provides a number of EU specific exemptions.
Although, there are many famous banks located on the island, the Standard Bank is considered as a preferred banking option by many businesses.
Most payment gateway service providers would be more than willing to link their gateways to an Isle of Man bank account and most currencies from across the world can be accepted. On the other hand, not all banks in the country would allow opening of accounts for gaming companies which are not licensed in the islands. As such, obtaining a local license is highly recommended.
c) Alderney Islands
The Alderney islands are a part of the British Channel islands. They are not a part of the United Kingdom or the European Union, but are considered to be one the prominent off shore financial centres of the world.
The Alderney Islands also are a prominent gaming destination whose attraction has grown over the years primarily owing to the promotion of gaming and associated services by the Local government. The government has encouraged the development of ancillary services to promote the gaming industry and banking and payment gateway services are included among them.
The gaming and support services in the islands are regulated by the Alderney Gambling Control Commission which has tried to build the best infrastructure. For entrepreneurs who wish to take advantage of Alderney as a gaming destination, it provides a number of types of licenses starting from temporary license to long term licenses.
Banks in Alderney are generally welcome to accepting Egaming accounts particularly if the company has a local Egaming license. The banking institutions in the country have excellent standards and as an international financial services destination, the financial institutions in the country have excellent links with banks across the globe. Among the banks located in Alderney islands, Lloyds is famous for its high standard of services across the globe.
The banks would however insist on production of all relevant documents for the KYC requirements and may decline transactions from high risk destinations. To ensure that you are able to access the excellent business services in Alderney, you are recommended to obtain your egaming license from the local regulator.
d) Antigua and Barbuda
Idyllic tourist destinations, Antigua and Barbuda are considered as one of the most beautiful island nations of the world. But there is more than it meets the eye. Antigua and Barbuda are also a prominent global financial services destination.
The Banking Sector in Antigua and Barbuda is regulated by the Financial Services Regulatory Commission (FSRC), Antigua & Barbuda. In addition to other financial services the FSRC also regulates banking and gaming.
As one of the first nations in the world to provide online gaming licenses, Anitgua and Barbuda has a detailed licensing regime for the sector and ancillary services. The gaming services sector in the islands is supported by the International Banking Industry in Antigua and Barbuda which functions under the International Banking Act.
The support for international banking through specialised legislation has enabled the islands to develop a globally competitive international banking industry which now attracts clients from across the globe. The North International Bank and The Global Bank of Commerce located in Antigua are famous for their business friendly services.
Egaming operators from across the world can approach the International Banks in Antigua and Barbuda for opening their accounts. With flexibility to operate in multiple currencies and experience in the gaming sectors, banks in Antigua and Barbuda can be an ideal choice for any egaming entrepreneur.
A Central American country, Belize is more famous for its jungles and tourist resorts. However, owing to the government’s efforts to promote the services sector, it has now also emerged as a favoured destination for banks which provide services to global clients.
Banking in Belize is regulated by the Central Bank of Belize. The country has an extremely open economy which has encouraged entrepreneurs to use it as a financial services destination.
Banking in Belize has now acquired global popularity owing to the licensing of International Banks in Belize who cater to a global audience. The banks are well versed with global customer service standards and can provide customised services to customers.
The Atlantic International Bank and The Heritage International Bank in Belize stand out for their exceptional service and low deposit requirements making them suitable for new businesses.
Egaming companies can approach the banks in Belize for opening their accounts in case they desire customised service with generally flexible documentation requirements.
A Caribbean Island, St. Lucia is famous for the international banking industry. Considered as a relatively cost effective alternative to more expensive destinations such as the Bahamas and Antigua, St. Lucia also provides excellent International Banking Services.
Banking in St. Lucia is controlled by the Financial Services Regulatory Authority (FSRA). Under the supervision of the regulator and through friendly legislations of the Government, an excellent International Banking industry has developed on the island. Owing to the relatively less knowledge about the country, banks in the country can provide you with personalised service. The Bank of St. Lucia International is a commonly preferred entity for entities opening their accounts in the country.
For any egaming operator, St. Lucia can be a preferred banking destination owing to the cheap cost, personalised services and excellent location. Opening an account costs around $2000 for the initial process with yearly service charges depending on the value of the transactions.
g) Vincent and the Grenadines
Located between the US Coast and the Caribbean islands, St. Vincent and the Grenadines are located between two global financial service hotspots. However, owing to the support of the Government and an active regulator, the islands have themselves emerged as an important financial services destination.
Banking in St. Vincent and the Grenadines is regulated by the Financial Services Authority. The authority has played a proactive role in promoting the islands. It maintains a transparent licensing procedure for international banks which has attracted a number of prominent international banks to establish base in the country.
Egaming operators wishing to open an account can visit any of the licensed banks, a list of which is provided on the website of the regulator. The level of service provided by the banks is normally excellent and multilingual executives are common. Remote opening is sometimes possible, but extremely rare. The Loyal Bank and the Euro Pacific Bank are normally cited by customers in the islands for their very high standard of service.
A new entrant to the financial services industry, Vanuatu has carved a niche for itself particularly among European and Asian clients. The tiny island plays host to a number of world class international banks which attract global clients.
Banking in Vanuatu is regulated by the Vanuatu Financial Services Commission. The commission has aided the growth of a number of international banks which now cater to a global clientele. Among the banks, the ANZ Bank (Vanuatu) Limited is known for its exceptional service and global recognition.
Egaming operators can approach the international banking companies for opening their accounts and to take advantage of their excellent and relatively low cost services. Most of the banks provide multi currency services and specialised business banking facilities.
A member of the European Union, a highly developed economy and a country with one of the highest standard of living in the world, Malta is often forgotten as one of the premier global financial services destinations which provides ready access to the European market.
Malta has a very developed financial services industry and also a very well regulated egaming licensing mechanism. Over the years, a Maltese Egaming license has evolved to be one of the most sought after gaming license respected across the world.
The popularity of the gaming sector has also led to the development of a banking industry which is well aware of the financial needs of the gaming sector. As the banks are located in Europe, you secure a number of business benefits. However, on the flip side it also limits your access to funds and brings with it strict scrutiny.
Overall, in case you are able to obtain a Maltese gaming license, you will be able to open an account in a Maltese bank to conduct your business and receive funds from across the world. Without a local license, opening an account can be a critical problem.
The charges of opening and operation are high at around $2000 for staring up. There are other charges depending on the amount of transactions and special facilities required. The Mediterranean Bank and Bank of Valleta both have moderate deposit requirements and service charges and are normally preferred by foreign customers.
Although of late not much positive news has come from the region, Lebanon stands as a rare oasis of peace and development in the Middle Eastern region. Contrary to public perception, Lebanon and particularly Beirut has a number of important international business hubs which cater to clients from both Africa and the Middle East. The city also maintains close relations to many European Business hubs.
Lebanon has a unique banking secrecy law and a friendly business environment. More than 70 (Seventy) banks are located in Lebanon, particularly around Beirut which attract international clients. Among the most famous are Bank of Beirut and Lebanon and Gulf Bank which are recognised for extremely business friendly banking process.
Banks in Lebanon are willing to accept clients from across the globe and the existence of bank secrecy laws mean that your private data is not available for scrutiny. The banks however prefer introduction to clients to ensure their trustworthiness. There is no need for any local license and international clients are accepted by almost all banks.
Morocco located in North Africa is a famous international tourist destination famous for its climate and unique cuisine. However, since the late 1980’s, Morocco has slowly transformed into a business destination with many prominent company establishing their headquarters in the country particularly in Tangiers.
Although, it may come as a surprise to many, Morocco although it is an Islamic country has well developed Casino industry which has primarily been built to cater to the needs of the tourists who visit the country. Famous casinos are located in iconic properties in Morocco and hosts international gaming tournaments including the Marrakech Poker open.
The banking industry in Morocco is quite old and has originated from the French Banking system. The country has a lot of French influence and the language itself is extremely popular among a section of the population.
The prominent banks in the country are located in and around the cities of Casablanca, Marrakech and Tangiers. Among the banks which can be recommended for Foreign clients in Morocco are Banque Populaire du Maroc and BMCE Bank. The costs of the account opening process may vary on the complexity of proceedings and the value of transaction. However, it is generally close to Euro 400 plus taxes for around Euro 10000 in capital. Fees may be charged extra depending on the complexity of the transactions.
The last destination which we cover in this report is a small island nation off the coast of Africa which has been able to carve out a unique place for itself as a global offshore financial services destination. Although not very rich in natural resources, the economy of the island is extremely stable which has enabled it to attract global investments.
Banking in Seychelles is generally divided into separate corporate and personal banking services. Although the same bank might together offer the two different kinds of accounts, but the minimum balance and documentation requirements for the different kinds of accounts may vary.
Generally, the minimum amount which has to be deposited while opening a corporate account in a bank is close to EUR 100,000 although special exemptions may be made. Fees and transaction charges may be payable depending on the type of services sought from the bank. The Mauritius Commercial Bank (Seychelles) is a preferred banking organisation in the country.
The banks may seek documents like proof of identity and licenses for the business from which funds will be sourced. The account opening process is relatively simple and if all documentation is in order, accounts are opened within a week.
B. Essential notes for a Casino Banking account
We assume that by now you have had a fair idea of the countries where you can seek to open the bank account for your online casino business. However, to succeed in the account opening process and ensure that you have a stable business relationship with the bank, it is essential that you pay attention to the following issues:
a) Obtain a license for your business
No matter which jurisdiction you choose, if you have a license for your online gaming business from any jurisdiction it provides an added degree of authenticity to your business and makes the entire account opening process much easier and simpler. Obtaining a license may initially be a little costly, but in the long run, the benefits outweigh the cost. If the process seems complicated for your taste, we at Empire Legal provide special egaming licensing services which cover any budget, any type of game and any need.
b) Ensure documentation is in order
Like any other business, it is essential that you go the extra mile to ensure that all your documents like company incorporation certificate, share certificates, licenses are in order and that you have obtained certified copies of the documents from the authorities. These documents are essential for opening your account and to start your business.
c) Get a popular payment gateway
Payment gateways serve as the intermediary between the payment page of your casino and the bank where the funds will ultimately be transferred. As such, it plays a crucial link in ensuring that you receive your funds and can access them when you need.
Select a payment gateway which supports integration with the bank where you maintain your account. Consult the payment gateway beforehand about their choice and also inform your bank about the regular transfer of funds with the payment gateway. Select a gateway which has multiple payment options. It is preferred if the gateway could decline payments coming from IP addresses of restricted jurisdictions.
d) Block restricted jurisdictions
There are a few jurisdictions in the world which do not allow their residents to visit offshore online gaming sites. The government of these countries come down heavily on websites which the citizens access. As a precaution, try to ensure that the IP addresses coming from such jurisdictions are blocked. Also, ensure that customers read and accept a disclaimer stating that they are not from such jurisdictions.
Accessing customers from certain restricted jurisdictions might mean that the banks would no longer be willing to deal with your funds owing to the very high compliance requirements in case of dealings with such jurisdictions.
e) Backup Backup Backup
This point is self explanatory. Maintain a back up of every tiny piece of data and use professional help if required.
f) Contact experts at the drop of a hat
Banking and IT services are normally handled by experts. It is preferred that you contact experts such as those from Empire Legal to help you select the ideal banking destination and ensure that you are able to access the best services. The information available is immense and it is not normally possible to read and process such specialised information within a short period time.
Now, you are ready to ensure a home for your funds. Happy Entrepreneurship!!
Lionel Iruk, is an i‐gaming, international wealth management, M&A, principal attorney and manager at Empire Legal, and frequent legal contributor to CalvinAyre.com . He has been involved in international Business, Real estate, asset development, and iGaming projects throughout the Continental United States, Europe and South East Asia since 2008. His practice focuses on citizenship and residency planning, licensing, tax management, international wealth management, corporate structures, international business compliance, immigration law, E-Sports Law, Financial Technology/ Bitcoin Law, iGaming, and issues affecting non-profit organizations and charitable foundations.