Jurisdictions We Cover
The regulator and the law Gaming in Poland is governed by the Gambling Act of 19 November 2009 (Ustawa o grach hazardowych), as amended. The Minister of Finance is the supervisory and licensing authority, with enforcement carried out by the national fiscal administration (KAS). The Ministry also
maintains a public register of prohibited gambling domains and supports payment-blocking
against unlicensed sites.
Whats permitted
• Online: Most online gambling falls under a state monopoly operated by the state-owned
company Totalizator Sportowy (whose online casino is Total Casino). The only forms
private operators may offer online — under a licence — are mutual (sports) betting and
promotional lotteries. Online casino, poker, bingo and slot-type games are reserved for the
monopoly.
• Land-based: Private entities may operate casinos under a concession and betting under
a licence. Slot machines outside casinos fall under the state monopoly.
• Betting licences are granted by the Minister of Finance, typically for a six-year term, and
a limited number of operators hold them.
How we help
• Assess whether a planned product is permitted, monopoly-reserved, or prohibited
• Apply for betting and promotional-lottery licences and manage Ministry correspondence
• Build AML, data and player-protection compliance to Polish standards
• Advise foreign operators on lawful market access and the limits of cross-border supply into
Poland
• Respond to enforcement, domain-blocking and classification issues
The regulator and the law
Gaming in Malta is regulated by the Malta Gaming Authority (MGA) under the Gaming Act,
substantially overhauled in 2018. As an EU member state, Malta combines a robust regulatory
framework with the reputational weight of an EU licence.
Whats permitted
The MGA issues two principal licence categories:
• B2C — Gaming Service Licence, for operators offering games directly to players.
• B2B — Critical Gaming Supply Licence, for suppliers of essential gaming software and
systems.
Each covers up to four game types — Type 1 (RNG/casino games), Type 2 (fixed-odds betting),
Type 3 (peer-to-peer, e.g. poker and betting exchanges) and Type 4 (controlled skill games).
Licences are issued for a ten-year term.
How we help
• Advise on the right licence category and game types for your model
• Prepare and manage the full MGA application, including policies and documentation
• Coordinate corporate setup, share-capital and key-function requirements
• Maintain ongoing compliance: reporting, audits, responsible gaming and AML
• Support B2B suppliers on Critical Gaming Supply licensing and operator contracts
The regulator and the law
Curaçao gaming is now governed by the National Ordinance on Games of Chance — the LOK
(Landsverordening op de Kansspelen) — passed in December 2024 and in force since 24
December 2024. The Curaçao Gaming Authority (CGA) is the sole licensing authority, having
replaced the former system in which four private master licensees issued sub-licences with
limited oversight.
What changed under the LOK
• A single government regulator (the CGA) now issues licences directly — the master/sub-
licence model is abolished.
• Licensing runs in two phases: Phase 1 assesses the integrity and financial standing of
UBOs and key persons; Phase 2 verifies technical, operational and legal compliance.
Each phase runs roughly eight weeks, with possible extension, and a provisional licence
may be issued during Phase 2.
• B2C and B2B licences are available, with applications handled through a new online
portal.
• The transitional "Orange Seal" for former sub-licensees was phased out on 15 October
2025 — only the "Green Seal" of a full CGA licence is now valid.
• Mandatory AML rules and alternative dispute resolution (ADR) apply to all licensees, with
local staffing and physical-presence obligations phasing in toward the end of the decade.
How we help
• Advise new applicants through both phases of the LOK process and CGA correspondence
• Support former sub-licensees transitioning to direct CGA licences
• Build the AML, ADR and player-protection frameworks the LOK requires
• Plan for upcoming local-presence and staffing obligations
• Assess how a Curaçao licence fits a wider multi-market strategy
Every market has its own rules
There’s no single international gaming licence — and no one-size-fits-all jurisdiction. The right choice depends on your products, target markets, ownership structure and appetite for compliance. We help operators pick a primary jurisdiction, build a compliant base, and expand in a planned sequence.