Why casino license is important? (Interview)
Conversation with Frank Schuengel. He is an eGaming Licensing Specialist at the MannBenham Fiduciaries Limited corporate service provider company.
Conversation with Frank Schuengel. He is an eGaming Licensing Specialist at the MannBenham Fiduciaries Limited corporate service provider company.
Date: July 15, 2023
Date: July 15, 2023
Location: iGB L!VE London 2025
Frank Schuengel is part of the Isle of Man-based law firm and corporate service provider MannBenham. Specializing in iGaming licensing, MannBenham has carved a niche in this sector and has been instrumental in providing licenses for various casino operators.
According to Schuengel, casinos require licenses primarily for two reasons:
Schuengel explains that casino licenses can typically be found in two types:
For players looking to gamble on a new site, Schuengel advises checking whether the casino is licensed. This can be verified by scrolling to the bottom of the casino's home page.
Situated in the Irish Sea, between Ireland and Scotland, the Isle of Man is a small crown dependency known for its gaming regulations. With its own government, Tynwald, the longest continuously running government in the world, it provides a favourable and stable business environment for gaming companies. MannBenham has been a part of the gambling licensing in the Isle of Man for over 20 years.
Schuengel outlines numerous reasons why the Isle of Man is a business-friendly place. For digital companies, including gaming, finance, and even crypto companies, the benefits are vast. With high quality of life, safety, tranquility, and a business-friendly atmosphere with no corporation tax and 0% capital gains tax, the Isle of Man presents a compelling case for businesses.
Moreover, the Isle of Man is distinguished by its responsive local government and the accessibility of its regulatory body. This, coupled with segregated player fund accounts, assures that players' money is safe, making it a preferred choice for both players and operators.
From a player's perspective, Schuengel insists that the Isle of Man license should be at the top of the trust list. It guarantees the legitimacy of the company, the source of its money, and the absence of any crime involvement. For operators, this translates into more respect and trust from the players.
The Isle of Man government charges a £5000 application fee, which is due upon application submission. Once the license is granted, operators are charged £36000 per year. In addition, there's a gaming levy between 1.5% and 0.1% depending on volume, based on GGR.
"It's very, very competitive with other jurisdictions and that's on the fee side."
Delays often occur during the due diligence process, where the authorities must familiarise themselves with the operator's entire group.
"If you want to get an Isle of Man license, by all means pick up the phone to us. I can get that four to six months. The delays always come into due diligence."
The Isle of Man Gambling Supervision Commission implements a number of measures to ensure that games are fair and that players are safe.
For instance, any games used must be under the Isle of Man license, and every game on a casino's website must be certified by an approved testing house.
"Only games that are certified by reputable testing house can actually be offered."
Additionally, strict responsible gambling policies are in place. The government mandates tools for self-exclusion and limits, and even maintains a central register for problem gamblers.
"There's no messing around with this. So they are very, very strict on the responsible gambling side. It has to be there and it makes sense. We want a sustainable industry. We want people to have fun."
Schuengel foresees a lot of lower-tier operators moving to the Isle of Man due to increasing industry regulation. This includes areas like anti-money laundering, banking, payment providers, and KYC procedures.
"We're adopting to crypto for example. We were one of the first to give you a proper Tier 1 crypto license. Which is the same license that for fiat. We're now moving into all the other digital spaces."
One area that Schuengel is keen to explore more is player feedback. He is interested in knowing more about what players value and how they perceive the industry.
"I'd love to hear more from players actually. Just general conversation and networking and seeing what do the players think of our industry?"
Frank Schuengel shared insights on a new licensing jurisdiction called Nevis. While not yet a true Tier 1 jurisdiction, Nevis offers a middle ground between the highly respected but stringent licenses (like Malta or Isle of Man) and easier-to-get ones (like Curaçao or Anjouan).
"There has always been a space in the middle, and I think that is where I see Nevis."
Nevis positions itself as a flexible option with promising potential, driven by experienced people behind the framework. Still, Schuengel points out that it has yet to earn the same trust from bankers and lawyers as the top-tier jurisdictions.
Located in the Caribbean, Nevis operates separately from St. Kitts. While beautiful and appealing as a location, it's unlikely to become a full-fledged business hub. Instead, operators tend to use Nevis (or similar pre-regulated jurisdictions) for licensing while running support operations elsewhere.
Popular outsourcing destinations include the Philippines, where operators can legally base their customer service teams thanks to business process outsourcing permits.
Schuengel believes most pre-regulated markets will eventually implement local licenses, driven by governments seeking tax revenue. This trend is already squeezing out grey-market B2C operations, particularly from reputable jurisdictions like the Isle of Man.
"The number of countries that a Tier 1 license is comfortable you targeting is getting smaller and smaller."
As a result, B2B licensing continues to grow while B2C models decline unless fully compliant. Schuengel also mentions the fringe of unlicensed operators persists but continues to shrink.
A new regulatory trend is the licensing of affiliates. Schuengel notes that jurisdictions like the Philippines are beginning to accredit suppliers and potentially marketers. The goal: disrupt the flow of money to illegal operators by holding suppliers accountable.
"They're not going to do it by domain blocking. They're going to go after your money streams."
This may expand across more jurisdictions as governments aim to protect local frameworks through licensing not just of operators, but of affiliates and suppliers as well.
When asked about the easiest and most effective Tier 1 license today, Schuengel didn’t single one out as "easy," noting they all involve six-figure investments and similar effort. However, he sees promise in:
In 2025, Schuengel sees a narrowing window for grey-market operations. Operators must choose between the legitimate, regulated path or risk being blacklisted.
"You have to decide: do you want to dance in the light or dance in the shadows?"
He emphasizes that operators dabbling in unlicensed markets may face difficulties gaining approval later. Regulators are unlikely to welcome companies that previously skirted rules.