From Malta to Anjouan: The Evolution of International Gaming Regulation since the 1990s

The world of online gaming is barely recognizable today compared to its beginnings in the 1990s. Back then, the primary question was whether an operator could even lawfully take bets online. Today, founders face a jungle of complex requirements: Who controls the company? How are player funds protected? Can the operator prove effective control? Regulation always follows the technology it aims to govern. With the proliferation of smartphones and 24/7 access to gaming, the industry has transformed from a niche market into a massive economic factor.

In the early days, there were few specific rules. Kahnawake introduced its Interactive Gaming Regulations in July 1999, followed by the Isle of Man in 2001 with the Online Gambling Regulation Act. Malta marked a milestone in 2004 as the first EU member state to introduce detailed online gambling regulations. These locations established the so-called gold standard. However, expansion brought closer scrutiny. Banks, payment providers, and software suppliers have become more cautious about who they do business with, as the focus today lies heavily on player protection and Anti-Money Laundering (AML) controls.

Numbers and facts

A look at market volumes illustrates the dimensions. Estimates suggest that global gross gaming revenue (GGR) will reach approximately $115 billion in 2026. This figure results from more customers, more products, and cross-border activities. Interestingly, new niches are also developing. The 2025 report from the European Gaming and Betting Association (EGBA) shows, for example, that esports betting accounts for only 1% of GGR but grew by 16% year-on-year. This explains why regulators now monitor products once considered fringe interests.

The situation in the Caribbean is particularly dynamic. Curacao, long known for its simple master license model, is undergoing a radical shift. The new National Ordinance on Games of Chance (LOK) came into force on December 24, 2024. It requires licensees to have a local legal entity and a direct relationship with the regulator. This tightening was not popular everywhere, as increased costs and bureaucratic hurdles drove some operators away. New players like Anjouan are stepping in. The Anjouan Computer Gaming Licensing Act of 2005 was recently reformed to align with international best practices, attracting operators with quick processes and lower costs.

Background

The history of regulation is not a straight path from chaos to order. Rather, it is an evolution where different states pursue completely different approaches. Costa Rica, for instance, hosts many companies but never introduced a specific licensing system like Malta. Operators there must strictly separate local rules from the laws of their target markets. Nevis also attempted to position itself as a serious hub for ambitious entrepreneurs with its 2025 Online Gaming Ordinance, offering security without the extreme hurdles of established Tier 1 jurisdictions.

Crypto gaming and esports add further layers to the debate. Accepting digital assets requires complex source of funds checks and seamless transaction monitoring.

"We had to ensure integrity in the very beginning. We had to prove ourselves, being the second jurisdiction after Nevada to get gaming, that this was a business as pure as it could be, as clean as it could be." - Linda Kassekert, Chairwoman of the New Jersey Casino Control Commission

This stance from the early days in Atlantic City continues to shape the understanding of modern regulatory authorities worldwide. Anyone building a casino business today must integrate regulation into their business plan before writing the first line of code.

Why it matters for German players

For German players, international developments are interesting but legally only partially relevant, as the State Treaty on Gambling 2021 (GlüStV 2021) draws a clear line. While international hubs like Anjouan or Curacao advertise fast licenses, these offers are illegal for residents in Germany unless a license from the Gemeinsame Glücksspielbehörde der Länder (GGL) is present. The GGL whitelist is the only reliable document to identify legal providers.

Strict limits apply in Germany: a 1 euro stake limit per spin on virtual slots and a cross-operator monthly deposit limit of 1,000 euros, monitored via the LUGAS IT system. These measures serve player protection and addiction prevention. Those playing with providers without a German license forego this protection and risk being unable to sue for winnings, as the contracts may be void. While international evolution shows a trend toward professionalism, national licensing remains the gold standard for the German market.

What it means for GGL-licensed casinos

German operators with a GGL license exist in a constant state of tension. On one hand, they must meet strict German requirements; on the other, they compete globally with providers who often face lower hurdles. International professionalization, such as in Curacao via the LOK law, could weaken the black market in the long run, as reputable payment service providers increasingly withdraw from unregulated or weakly regulated providers. For GGL casinos, this presents an opportunity: as international standards rise, the competitive advantage of offshore platforms through tax evasion or lack of player protection diminishes. Germany's strict rules could eventually prove to be a quality mark, as technical integrity and fund security are highest here.