What an Anjouan licence offers for European casino payments
Exchange dated 28 Sept 2026 links the licence to attempts to reach European PSPs
Key Takeaways
- In an exchange dated 28 September 2026, Bar Konson of NuxGame presented the Anjouan licence as the minimum requirement to seek European PSPs.
- The documentation reviewed by FinTelegram names no PSPs, shows no completed onboarding and lists no approved European markets.
- Konson said a Costa Rica-registered company could not connect traditional bank accounts or PSPs in the proposed configuration and that cryptocurrency would be the only feasible alternative.
- Appointing an authorised representative does not relieve European obliged entities from customer identification and verification duties under article 13 of Directive (EU) 2015/849.
A NuxGame executive presented the licencia de Anjouan as the minimum requirement to access traditional payment routes serving European customers in a conversation dated 28 September 2026. The message chain, reviewed by FinTelegram, attributes the replies to Bar Konson, identified in signatures as Chief Business Development Officer of NuxGame; the correspondence does not name specific PSPs nor document a completed onboarding.
What NuxGame said about the Anjouan licence and access to PSPs
The exchange reproduces an explicit question: which payment providers, acquirers or open banking partners would accept a gaming company registered in Costa Rica that serves European markets. The reply attributed to Bar Konson states that bank accounts and traditional payment providers cannot be connected to a Costa Rica company in the proposed setup, and that cryptocurrency would be the only feasible option in that scenario.
Next, Konson frames the licencia de Anjouan as the minimum threshold to try to work with traditional PSPs oriented to Europe. FinTelegram reviewed PDF exports of the conversation and notes that this condition appears in the commercial discussion, but the thread does not document approval by any PSP, nor an activated merchant account, nor specific European markets authorised.
What the correspondence establishes and what remains to be shown
The evidence presented allows outlining several claims and gaps:
The correspondence describes that with a company in Costa Rica connection to conventional payments is restricted in the proposal.
An Anjouan licence is presented as a condition to attempt access to European PSPs.
There is no PSP named in the documentation, no formal acceptance and no country-by-country legal coverage analysis.
The interlocutor is asked for the complete compliance documents of the Costa Rica company owner; the thread does not show a promise of anonymous onboarding.
The table accompanying the original piece summarises by stages what is established and what remains open: structure in Costa Rica, Anjouan requirement, coverage for European customers and the role of the authorised representative.
Why an offshore licence does not equal permission to operate in each European country
The European Commission reminds that online gambling lacks a single sector-wide regime in the EU and that authorisations operate at national level. The concrete example comes from the Dutch Gambling Authority (Kansspelautoriteit): offering online gambling in the Netherlands requires a licence under article 31a of the Dutch Gambling Act. An Anjouan licence alone does not grant legal permission to operate in markets such as the Netherlands.
Payment acceptance policies illustrate the separation between being accepted by a PSP and having permission to offer gambling in a market. Adyen, cited in the public documentation reviewed by FinTelegram as an example policy, requires that eligibility considers applicable laws, partners’ requirements, risk and business model, and makes clear that acceptance by a provider should not be read as an opinion on the legality of the service. FinTelegram does not state that Adyen is a partner of NuxGame; Adyen is invoked only as a public reference.
Authorised representative, KYC and obliged entities’ duties
In the conversation the interlocutor asks whether the Anjouan setup can avoid submitting identity or passport documents. Konson suggests that an authorised representative could be appointed, but asks under which name the company is registered in Costa Rica and requests the full compliance documents of the current owner. He also mentions that engaging a representative directly would be an expensive alternative.
That nuance is key: the correspondence does not promise anonymous onboarding. In addition, Directive (EU) 2015/849, consolidated and cited in the documentation, requires in its article 13 to identify and verify the customer, to reasonably identify and verify the beneficial owner and to check the identity and authority of anyone acting on behalf of the customer. Naming a representative does not replace those obligations for entities subject to European regulation.
Where this fits in the payments chain and what remains to be connected
FinTelegram’s investigations into payment routes typically focus on what appears when a player reaches checkout: gateway domains, payment initiation providers and receivers shown to the user. The correspondence with NuxGame addresses an earlier stage: the operator’s presentation to the payments ecosystem and the conditions for a PSP to examine its application.
What the documents do not provide is the link between the licence and specific payment rails: there are no approved domains, no contractual provider, no permitted markets and no clear responsibility for ongoing checks. The FinTelegram piece poses open questions: does onboarding evaluate the casino’s live website, the controlling persons and target markets, or is the mere existence of a company and an offshore licence enough?
Open questions addressed to NuxGame and a call to provide information
FinTelegram requests clarification on whether Bar Konson’s statements describe NuxGame’s real partners, which PSPs would consider operators with an Anjouan licence and under what conditions, how country-by-country permissions are reviewed and what ownership disclosure the authorised representative proposal requires.
FinTelegram invites confidential sharing of contracts, onboarding requirements or relevant correspondence via Whistle42. Public sources consulted on 4 October 2026 include the European Commission, the Dutch Gambling Authority, Adyen’s public eligibility policy and Directive (EU) 2015/849 (article 13).
"An Anjouan licence was presented in the discussion as the minimum requirement to work with traditional PSPs in Europe," according to documents reviewed by FinTelegram, which do not show formal approvals or named PSPs. — FinTelegram
For providers and compliance teams reading this: the discussion highlights an operational distinction between being approved by a payment provider and having permission to offer gambling products in a national market. For questions about [payments](/payments) and [regulation](/regulation), consult our sections on payments and regulation.
Frequently Asked Questions
What did the correspondence show about the Anjouan licence?
The correspondence dated 28 September 2026 presented the Anjouan licence as the minimum requirement to try to work with traditional PSPs serving European customers; the reviewed PDFs attribute answers to Bar Konson, Chief Business Development Officer of NuxGame, and do not document any PSP approval.
Does an Anjouan licence mean you can legally operate in European countries?
No. The European Commission and national examples such as the Dutch Gambling Authority show that gambling authorisations are national; an Anjouan licence alone does not grant legal permission to operate in markets like the Netherlands, which require a licence under article 31a of the Dutch Gambling Act.
Was anonymous onboarding promised in the conversation?
No. Konson asked for the name under which the Costa Rica company is registered and requested the owner’s full compliance documents; he also said hiring a direct representative would be costly, indicating that an anonymous process was not offered.
Does acceptance by a PSP equal an opinion on the legality of the service?
No. Public provider policies, including the Adyen eligibility policy cited as an example, state that acceptance by a provider should not be interpreted as a view on legality and that eligibility depends on applicable law, partner requirements and risk.
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About the author
Isabela Fuentes
Payments Correspondent
Isabela Fuentes covers payments and fintech in the gambling industry — processor and PSP deals, payment-method launches, crypto rails, and the compliance shifts that decide what players can pay with at the cashier. She opens with the deal or launch, names the companies and methods precisely, and translates the jargon into what operators and players gain or lose. From PIX and open banking to stablecoin settlement, Isabela Fuentes follows the money moving the sector.
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