We at Advennt gave an overview of the Tobique licensing jurisdiction in June 2024 with reference to an earlier study on unregulated markets and .com licensing hubs.
The well documented problems facing some of those more established licensing hubs has created an opportunity for younger players in the market such as Tobique to establish themselves as serious competitors in the market. Tobique has a rapidly growing licensee base attracted by its maturing, stable and transparent licence regime in the context of other competing licensing hubs, such as Curacao, Anjouan and Isle of Man.
Tobique
Given that the first license (to an underlying company of SoftSwiss) was granted only 18 months ago, Tobique has built itself into a market name in a short period of time. Tobique now has a significant number of both game providers and top tier payment solution providers accepting Tobique. Licensees are listed on the Tobique Gaming Commission site, where currently there are now 103 License holders.
The pipeline of ongoing applications is very strong. Almost all game providers are represented in active Tobique licensed sites. Inevitably the more B2C licensees that are present in a jurisdiction, the more attractive it becomes for third-party vendors such as payment processors, game providers and banks to supply to them.
One of the reasons for the rapid growth is no doubt due to a robust regulatory framework. The same law firm that drafted the Kahnawake legislation (Lazarus Legal in Canada) also assisted with creating the Tobique legislation in conjunction with an EU based firm that ensured that the legislation evolved from the best practices enshrined across various jurisdictions, promoting both excellence and familiarity.
Tobique is accepted by a number of UK and European Electronic Money Institutions and payment systems, including Interac in Canada. Tobique partnered with DLAG to provide the front facing part of the business, dealing with applications and general issues. General feedback for DLAG is extremely positive, with applicants praising the speed of response, transparency and professionalism of the team. Tobique also retained a specialist compliance company, LI Compliance, to handle the AML, KYC and monitoring issues for the Tobique portfolio. By retaining dedicated resources with strength in depth, Tobique is able to promote certainty and deal with applications quickly without sacrificing quality.
The majority of the largest gaming software aggregators are now onboarding Tobique and recommending the jurisdiction to their clients. As above, the feedback from them is that the service levels provided by DLAG are exceptional. This compares to the current troubled situation in Curacao and the many months it can take to get a licence elsewhere in a jurisdiction with comparable regulatory and compliance standards to Tobique. All questions posed to Tobique via DLAG are answered within 24 hours, where DLAG pride themselves on being unbureaucratic and available to discuss queries at any time and to adhere to their own licence application timeframes, as quoted since go live in April 2024.
Tobique also has a robust crypto payments regime, which adheres to strict money laundering KYC requirements whilst aligning with international standards such as Markets in Crypto Asset Regulation (MiCA), the Travel Rule requirement and generally FATF Recommendations and Guidance. Its crypto payment regulations set out guidelines as well as requirements to enable operators to comply and mitigate risks, including use of regulated virtual assets service providers (VASPs) to carry some of the compliance burden.
Finally Tobique is the forerunner when it comes to social and skill gaming verticals, which are outside the definition of gambling. The benefit of a proportionate, lighter touch licence regime for these non-gambling operators, helping them gain credibility, trust and standing when it comes to dealing with their suppliers (especially on the payment side) and customers.
Other market leaders
Curacao, Anjouan and the Isle of Man have had a difficult year in comparison to Tobique.
Curacao has struggled to meet the demand of moving sub-licensee operators (possibly exceeding 1,000) under its old master licence regime, to a direct licence regime. Delays and uncertainties generated by the implementation of its new gambling laws (LOK) has led to a significant exodus to other competing jurisdictions such as Anjouan and Tobique. The recent departure of the Curacao Gaming Board’s Supervisory Board and its Finance Minister only increases uncertainty for operators in a difficult market.
Anjouan has to a certain extent benefitted from Curacao’s downturn but still lacks transparency in terms of clear transparent regulation and operating codes, instead relying on outdated and vague legislation. Without high standards of licensing, compliance and supervision the jurisdiction may be considered too light touch to suit the risk appetite of tier one software and payment suppliers.
In May 2025 the Isle of Man Government published a National Risk Appetite Statement (“NRAS”) to enhance the Island’s risk mitigation framework within the eGaming sector and related industries. The NRAS was developed in response to emerging risks presented by an increasingly complex criminal landscape in East and Southeast Asia, which includes the exploitation of casinos and eGaming platforms. In parallel there has been a general tightening in regulatory supervision over the past 5 years resulting in many large fines and other enforcements as well as licence surrenders. As a result, the number of online licensees has declined from 148 in 2020 to 63 in October 2025. This is unlikely to change, especially in light of the Moneyval evaluation into its AML regime next year.