Anjouan licence pitched as entry ticket to European PSPs, says NuxGame exchange

FinTelegram reviewed a cached email thread dated 28 September 2026 in which a NuxGame executive told a prospective client that an Anjouan gambling licence was the minimum requirement to work with conventional European payment service providers. The exchange, attributed to Bar Konson and saved in PDF exports, states that a Costa Rica–registered gambling company could not connect bank accounts or traditional PSPs without that offshore licence and that crypto would otherwise be the only feasible route. The thread ends with the parties agreeing to a call; it does not document any completed PSP onboarding or a named merchant account.

What the correspondence shows about the Anjouan licence and European PSP access

The supplied email chain presents an Anjouan licence as a gating condition within the specific sales discussion documented by FinTelegram. Konson, identified in the signatures as NuxGame's Chief Business Development Officer, told the correspondent that traditional payment rails and bank accounts “cannot be connected with a Costa Rica registration,” and that an Anjouan licence was the minimum requirement to work with traditional European PSPs in the scenario he described. The thread contains no named PSP, no approved merchant account, no market-by-market legal assessment and no evidence that any particular European PSP had accepted or onboarded the operator.

The correspondence therefore supports two limited conclusions: first, that NuxGame staff presented an Anjouan licence as a threshold in a sales conversation; second, that the representation stopped short of establishing a completed payment integration or market permission. It does not establish a universal legal rule that Costa Rica companies may only use crypto or that European PSPs as a class accept Anjouan-licensed merchants.

Country permission remains distinct from payment onboarding

The exchange highlights a common compliance fault line: payment acceptance is separate from gambling permission in the customer's country. The European Commission notes that online gambling lacks a single EU sectoral framework and that national systems differ. The Dutch Gambling Authority (Kansspelautoriteit) provides a concrete example: offering online gambling in the Netherlands requires a licence under Article 31a of the Dutch Gambling Act. An offshore licence from Anjouan therefore does not, by itself, confer lawful permission to offer online gambling in the Netherlands or any other EU member state.

Payment providers' published policies make this distinction explicit. Adyen's eligibility rules, cited in FinTelegram's review as a public policy example, say acceptance decisions reflect applicable laws, payment‑partner requirements, risk and the business model and that acceptance should not be read as an opinion on legality. FinTelegram's correspondence does not name Adyen as a partner to NuxGame; it uses Adyen only to illustrate why a PSP's acceptance is not a substitute for national gambling permission.

What the thread leaves unresolved about onboarding and ownership checks

The correspondent asked if an Anjouan arrangement could avoid supplying personal ID or a passport. Konson replied that an authorised representative could be appointed, but he also asked whose name the existing Costa Rica company was registered under and requested the owner’s full compliance documents. He described engaging a representative directly as a costly alternative. Those qualifications matter: the exchange does not substantiate anonymous onboarding, nor does it explain how the ultimate beneficial owner would be identified or whether the registered owner and the person exercising control are the same.

For EU obliged entities, Article 13 of Directive (EU) 2015/849 requires identification and verification of the customer, identification and reasonable verification of the beneficial owner, and checks on the identity and authority of someone acting for the customer. Appointing a representative does not replace those obligations.

The missing links between licence, merchant account and payment rails

FinTelegram's payment-route investigations focus on the cashier and the payment flows players see: gateway domains, payment‑initiation providers and displayed recipients. This correspondence concerns an earlier stage: how an operator is presented to the payment network during onboarding. The thread does not connect NuxGame to any specific gateway domain or merchant previously reported by FinTelegram. It also fails to supply the concrete items a PSP typically requires:

• the identity of the contractual merchant and its controlling persons

• the merchant account provider or acquirer that would sign the contract

• the approved payment‑gateway domains and cashier integration

• a market-by-market list of permitted countries and products

Because those items are absent, the documents do not answer whether onboarding assesses the operator's live website and controlling persons or merely the existence of a company plus an offshore licence.

Questions FinTelegram put to NuxGame and what operators should watch

FinTelegram identified several clarifications it seeks from NuxGame: whether the statements reflect partnerships NuxGame directly controls, which PSPs (if any) accept Anjouan operators and under what contractual conditions, how country-specific gambling permissions are assessed during onboarding, and what ownership disclosure the proposed representative arrangement would require. The supplied exchange establishes neither completed onboarding nor regulatory breach; it documents a sales-stage representation and a request for owner compliance files.

For operators and payments teams evaluating similar routes, the exchange underlines practical due diligence points: confirm named PSPs and acquirers, require written evidence of merchant accounts and permitted domains, and secure a market-by-market compliance opinion rather than relying on an offshore licence alone. Vendors and PSPs will typically require documentary proof of ownership and beneficial ownership before opening a merchant relationship.

How to share additional evidence

FinTelegram invited recipients with first‑hand information about offshore casino onboarding, Anjouan‑related payment arrangements or merchant due diligence to share contracts, onboarding requirements or correspondence confidentially via Whistle42. The outlet checked public sources on 4 October 2026, including the European Commission guidance on online gambling, the Dutch Gambling Authority’s rules and Adyen’s eligibility policy, and cited Article 13 of Directive (EU) 2015/849 (consolidated text) for AML customer‑identification standards.

For payments teams and compliance officers, the practical headline is simple: an offshore licence can be presented as an onboarding condition, but it does not replace the merchant‑level checks, acquirer approvals or national gambling permissions that determine whether European customers can legally be served. Treat any sales‑stage claim about PSP access as a starting point for documentary verification.