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Potential for proprietary licensing

1) Starting point: Nevis has already launched an adjustable mode

In 2025, Nevis Island adopted and enacted Nevis Online Gaming Ordinance, 2025, creating the Nevis Online Gaming Authority (NOGA), a regulator that licenses and supervises online operators. According to the Nevis administration, ordinance is valid from May 1, 2025 and is focused on attracting international operators to the "white" legal framework.

What is already there: the official portal NevisGaming. com (NOGA) with materials on procedures, technical and operational requirements for license applicants.


2) Why the federation has a chance to scale the regime

Diversification of the economy. Licensing and related services (lawyers, auditors, hosting, payment gateways) form the export of services and fees from licenses/supervision. At the Nevis level, this is the explicitly stated goal of reform.

Regulatory "showcase." The shift from "grey" practices to a public register of licences and AML/CFT requirements reduces risk and increases predictability for banks/providers.

Payment/digitalization infrastructure. ECCB's experience with DCash and regional fintech initiatives confirm the course towards digital dresses (although DCash is not a method for iGaming, the vector itself is important).


3) Attention points: AML/CFT and reputation

St. Kitts and Nevis undergoes regular FATF/CFATF assessments: the key to success is to show compliance with the FATF Recommendations and the enforceability of measures (KYC, transaction monitoring, sanctions compliance). This is critical for bank correspondent relations and acceptance of payments by operators.

Risk factors that industry media and consulting firms write about: historical criticism of "offshoring," the need to provide real, not declarative, supervision (departures, audits, sanctions). What NOGA was created for.


4) What the "federal" expansion (beyond Nevis) can give

Pros:
  • A single showcase for operators. The general procedure or mutual recognition of licenses makes it easier to choose jurisdiction.
  • Stability for payment partners. The wider the coverage of rules within the federation, the easier it is for banks and providers to assess risk.
  • Synergy with offline tourism. The online + offline framework will allow connecting resorts and online brands in marketing (responsibly and with restrictions).
Downsides/risks:
  • Regulator capacity. Personnel, IT systems, an inspection and mutual assistance mechanism with law enforcement agencies will be required.
  • Consumer protection circuit. ADR/Ombudsman and complaint procedures, including cross-border cases, will have to be formalized.
  • External perception. Start errors (weak KYC, paper checks) will quickly undermine trust.

5) Roadmap for 12-24 months

1. Complete the secondary and publicity of the registries.

Nevis has already published the ordinance and NOGA materials; the next step is regularly updated public lists of licenses, types of licenses, supervision statistics.

2. Synchronize standards with FATF/CFATF.

Tie license requirements to specific FATF items (beneficiaries, TRM, sanctions, PEP, record keeping) and publicly show how this is built into oversight.

3. Build Consumer Loop (ADR).

Establish an independent dispute resolution mechanism, oblige operators to indicate ADRs on the site and in T&C; publish aggregated complaint/decision metrics.

4. Payment ecosystem.

Memoranda with banks and providers (cards/e-wallets/crypto-gateways) on the list of permissible practices, reporting and triggers of enhanced monitoring.

5. Mutual recognition/harmonization in the federation.

Options:
  • "Federal Minimum Standards" + Island Licenses (Nevis, then St. Kitts), or "SKN Single License" with an operating back office on Nevis.

6. Communication and marketing of jurisdiction.

Operator White Paper: License Categories, Review SLAs, Fees, Supervision Cases. The emphasis is on transparency, not on the "cheapest license."


6) Economic effect assessment (qualitative)

Revenue from fees and supervision. One-time fees for submission/issuance + annual fees.

Income taxes/VAT-like charges (depending on the model).

Service multiplier. Law firms, hosting providers, KYC services, audits - jobs and export of services (similar to how Nevis is already positioning itself).


7) Realistic constraints

Market size and talent pool. A small jurisdiction cannot "digest" dozens of large groups without the phase growth of institutions.

Global trends. Tighter requirements in the EU/UK/US mean increased attention to risk outsourcing - mature RegTech will be needed.

ECCB digital pilots. Although DCash is a retail project and not about iGaming, the pause/restart story shows that the introduction of new fintech initiatives takes time.


Saint Kitts and Nevis has already made a key move through NOGA and Nevis Online Gaming Ordinance (2025). With careful harmonization of FATF standards, the launch of consumer protection (ADR) and the public register of licenses, the federation is able to turn the "island" initiative into a recognizable regulated jurisdiction of the Caribbean. The most important conditions for success are transparency, staff capacity of supervision and partnership with payment providers.


Sources

Nevis Online Gaming Ordinance, 2025 (official PDF).

Nevis Island Administration: News about the introduction of ordinance into force and licensing purposes through NOGA.

NevisGaming. com (NOGA official website): mission, licensing process, those/operational requirements.

FATF/CFATF: AML/CFT Mutual Assessment Materials for St. Kitts and Nevis (Gain Requirements and Priorities Context).

ECCB/DCash (the context of the region's digital payment initiatives).

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