Master Licenses and Sublicenses in Gambling

What a master license and a sublicense are

A master license is a gambling license granted by a jurisdiction to a single company, and that company then rents out the right to operate under it. Each brand that rents that right holds a sublicense. The brand never deals with the government directly; its legal relationship is with the master licensee. If you have a dispute, the entity that is supposed to be accountable is the sublicense holder, and above it the master licensee, not necessarily the regulator.

This structure is not unique to online gambling. Macau's land-based casino market works on a similar layered idea: the government granted concessions to a small number of companies, and some of those concessionaires in turn brought in sub-concessionaires, such as Venetian Macao SA, MGM Grand Paradise SA and Melco Resorts (Macao) SA, operating alongside the original concessionaires SJM, Wynn Resorts (Macao) SA and Galaxy Casino SA¹. The difference is that Macau's sub-concessionaires are giant, named casino companies, while an offshore sublicense holder can be a shell company you have never heard of.

You can see the master-sublicense wording in the terms of real sites. LuckyTaj states it is licensed by the Curaçao government and operates under the master license of Gaming Service Provider N.V.³. GCWIN99 says it is licensed by the Government of Curaçao and operates under the master license of Gaming Services Provider N.V.⁴. Glory Casino's page simply lists "Curacao Master Gaming License"⁹. ACR Poker's terms say your license to play the games is governed under the laws of Curaçao and the sublicense granted thereunder to International Processing Services S.A.².

Contrast this with a direct license. Under the British system, for example, the regulator tells players to check that the gambling business itself holds a British Gambling Commission license before transferring money into an account¹⁰. There is no middleman: the company you pay is the company the regulator licenses. That is the practical difference between a sublicense and a direct license, and it is the single most useful thing to understand about offshore gambling licensing.

How the Curaçao system works: master licensees and their operators

Curaçao built its online gambling industry on the master license model. A handful of master licensees, private companies holding a master license from the Curaçao government, each sponsored large numbers of sublicense holders. Every casino brand you have seen citing "Curaçao license" was, in most cases, a sublicense holder under one of these master licensees.

The names that appear in operators' fine print show how the layers stack up:

The system has also gone through a rebranding that makes it harder to follow. Depending on when a site was licensed and who wrote its footer, the same Curaçao framework appears under several names: Bitcasino's terms say it operates under a Curaçao gaming license issued by the CGA, the Curaçao Gaming Authority¹³, while Bitcasino's own about page says it is officially recognized by Curaçao eGaming⁵. Casino Khajana's terms say it is regulated and authorized by the Curacao Gaming Control Board (GCB)¹⁴. Shuffle says it holds a license from the Curaçao Gaming Control Board¹⁵. Khelo24-betin cites license number CUR-365/JAZ¹⁶. Some of these are the old master-license era names, some are the newer national regulator, and some sites mix them freely.

For you as a player, the practical consequence is that a bare "8048/JAZ" or "Curaçao licensed" claim in a footer tells you very little. Guidance on verifying licenses is blunt about this: ignore generic "8048/JAZ" claims unless you can match the company, domain and activity in the public register¹⁷. A sublicense number means a private company vouched for the operator, and that company may have hundreds of other brands under the same master license. Our pages on how to check a gambling license and how to verify a Curacao gambling license walk through the steps, and what replaced the Curacao master license explains the reform.

The Curaçao Gaming Authority portal breach

The CGA disclosed the security incident in a public statement, saying the access had been contained and the source identified, while a forensic investigation continued¹⁸. The breach mattered well beyond IT security: the portal held the ownership and application files for the companies behind hundreds of gambling sites, and those files became the raw material for everything that followed.

Casino Secrets leak: what the ownership data showed

This is the ownership question that matters to players. When a site's terms name a sublicense holder like International Processing Services S.A. or Ragnarok Corporation N.V.², that is a company. The leak showed who stands behind those companies, and it showed that the structure had kept that information effectively invisible to players and, in many cases, thinly reviewed by the licensing side.

Licenses granted despite unanswered ownership questions

In other words, the files show cases where the licensing review raised questions about who an applicant's beneficial owners were and where their money came from, and the license was granted anyway while those questions remained open. For a player, this is the sharpest practical finding of the leak: a Curaçao license sticker on a site has not always meant that the regulator had finished, or even insisted on finishing, its homework about who runs the company holding your deposit.

CGA's response to the leaked documents

The CGA said the leaked extracts do not show the full picture of any single application, and that its process stands¹⁹. Whether that reassures you is your call; the practical takeaway is unchanged either way. The ownership data is now public, the portal was breached through a fictitious company, and the licensing records themselves show open questions at the moment of approval.

Operators licensed by the CGA: TrustDice.win and me88

Under the newer Curaçao framework, some operators cite a direct license from the Curaçao Gaming Authority rather than a sublicense under a private master licensee.

TrustDice.win, a casino aimed at bitcoin and ethereum players²⁰, states in its terms that it is licensed and regulated by the Curaçao Gaming Authority (CGA), with license number OGL/2024/664/0280, issued on July 16, 2024²¹. Its terms also point players to independent help organizations including Gamblers Anonymous, GamCare and Gambling Therapy²¹. me88 states it is licensed by the Curaçao Gaming Authority and markets itself as a certified and officially licensed platform²².

Other operators citing the CGA include Cloudbet with license number OGL/2024/328/0599¹², Bitcasino¹³, 7Bit Casino, which advertises over 10,000 games under the Curaçao Gaming Authority license, and Mega Dice¹⁶. Note the OGL prefix on the newer numbers: it marks the post-reform direct licenses, as opposed to the old JAZ-style master and sublicense numbers. Our page on how to read a gambling license number breaks the formats down.

Moving to Anjouan: why some operators switch licenses

Anjouan, an island in the Comoros, has become the main destination for operators leaving Curaçao. Unlike the old Curaçao model, Anjouan issues internet gaming licenses directly to the operating company, and it runs a public validation page where a specific domain and license number can be checked. CoinPoker's license, for example, appears on the Anjouan register as License No. ALSI-202412004-FI1, held by Precise Interactive Inc., with operating status VALID as of September 26, 2026⁷.

Operators now citing Anjouan include Rainbet, whose terms say it is licensed in Anjouan for the provision of online games of chance²³; CoinPoker, whose terms say it is authorized to operate remote gambling services pursuant to a valid gaming license issued by the Anjouan Gaming licensing authority²⁴; Lucky Block, citing licensure by the Offshore Finance Authority of the State of Anjouan²⁵; and Phenom Poker, licensed for real-money internet-based interactive poker services²⁶.

Two practical points about Anjouan are worth knowing. First, Anjouan licenses carry excluded territories: the CoinPoker license lists Australia, Comoros, France, Netherlands, Spain, United Kingdom and USA, plus all FATF-blacklisted and sanctioned jurisdictions⁷. Second, the Anjouan Gaming Authority does not provide direct support services to players; it requires licensed operators to signpost independent support resources instead²⁷. So an Anjouan license is real and checkable, but it is not a regulator that will take your call. Our pages on the Anjouan Gaming Authority, how to verify an Anjouan gaming license and Anjouan vs Curacao licenses go deeper.

The switch also reflects where players actually are. The vast majority of operators catering to Thai players hold licenses issued in other jurisdictions, led by Curaçao²⁸, and that pattern holds across much of Asia. Offshore licenses, whether master-sublicense or direct, do not make a site legal in your country; they only describe where the company is registered. Whether you may play is a separate question, and in much of Asia the practical risk of playing on an offshore-licensed site is that it operates in a legal gray zone with no local recourse.

A quick check before you deposit

Given everything above, here is a short routine before you put money on any offshore-licensed site:

• Find the license claim in the site's terms, not just the footer logo, and note the exact company name, domain and license number¹⁷.
• Match that number and company in the regulator's public register or validation page, the way CoinPoker's ALSI-202412004-FI1 can be validated on Anjouan's register⁷. Ignore generic "8048/JAZ" claims you cannot match¹⁷.
• Work out whether the site holds a direct license or a sublicense under a master licensee. If it is a sublicense, the private master licensee, not a regulator, is your first port of call in a dispute³.
• Check the excluded territories list on the license if one is published, since Anjouan licenses name them explicitly⁷.
• Remember that a license sticker does not tell you who owns the company. The Casino Secrets leak showed ownership can sit behind shell layers that only a leak exposed⁶.
• If a regulator like the UK Gambling Commission matters to you, its guidance is to check the business holds its license before transferring money¹⁰.

For the wider picture, see gambling regulators and licenses in Asia, types of gambling licenses, public gambling license registers, fake gambling license claims and the risks of playing on unlicensed sites.