13/09/25
Selecting the optimal jurisdiction for iGaming or crypto licensing is a strategic decision. It affects regulatory compliance, operational flexibility, tax obligations, and market credibility — critical factors for operators planning cross-border activities.
📜 Legal Framework and Official Standards
The Tobique Gaming Commission (TGC) was established under the Tobique Gaming Act 2023, a statute of the Tobique First Nation in New Brunswick, Canada. The Act comes into force by proclamation on dates appointed by the Chief and Council. Implementing regulatory codes - the General Code of Practice and the Remote Gambling AML Code of Practice - were enacted on 5 April 2024.¹
The General Code of Practice requires licensees to:
• Implement responsible gaming tools such as self-exclusion and deposit limits.
• Prevent access by minors and vulnerable persons.
• Provide transparent terms and effective dispute-resolution mechanisms.
The Remote Gambling AML Code of Practice obliges operators to:
• Conduct KYC checks on all players.
• Apply enhanced due diligence for high-risk jurisdictions.
• Block access and transactions from FATF-blacklisted or sanctioned states, and other banned jurisdictions listed by the Commission.
License instruments specify the duration of validity. The Act allows temporary licenses of up to six months while applications are processed, but the length of a full license is set by the Commission on a case-by-case basis.
⚖️ Regulatory Position and Market Comparison
Compared with established jurisdictions such as Malta, the Isle of Man or Curaçao, Tobique’s framework is relatively new. This means enforcement practice is still developing, yet its rules are modern, reflecting current international standards for AML/CTF and consumer protection.
Industry commentators note that licensing can be relatively fast where applications are complete, but the Commission does not publish a guaranteed timetable. Timelines remain case-specific.
From a financial perspective, Tobique appears to follow an annual fee model rather than a revenue-based gaming tax. Several industry advisory firms state that gambling revenue earned under a Tobique license is not subject to local corporate income tax, though this is commercial guidance rather than a statutory exemption. Operators must seek tax advice in their incorporation or operating jurisdictions.
Restrictions apply to certain territories - including the USA, UK, and some Canadian provinces - where operators must apply geo-blocking. This narrows potential market reach compared with broader licenses, but aligns with compliance requirements.
🌍 Practical Applicability and Case Examples
The Tobique framework is designed to support remote operations. There is no blanket statutory requirement for a local office or servers in Tobique, though license conditions may impose specific requirements. Many operators currently run remotely under this regime.
For example, an online casino operator targeting European or Asian markets (excluding restricted states) may find Tobique beneficial because:
• Licenses are issued under a clear statutory framework of Indigenous law.
• Fees replace turnover-based gaming taxes.
• Remote operations are permissible, reducing infrastructure costs.
Similarly, B2B game providers may apply for licenses if their games are certified, beneficial owners pass due diligence checks, and AML requirements are observed.
Risks remain: the enforcement record is still young, so the predictability of audits and sanctions is untested. Holding a Tobique license does not guarantee acceptance in every market; some jurisdictions require domestic authorisations regardless.
✅ Conclusion
The Tobique Gaming License, established under the Tobique Gaming Act 2023 and strengthened by its April 2024 Codes, provides a modern legal structure for remote gaming. It imposes strong AML/CTF and player-protection obligations while offering operators flexibility and a fee-based model.
Yet, caution is essential: the regime is new, enforcement practice is still evolving, and restrictions on certain markets apply. Operators must also assess local tax and regulatory obligations in their target jurisdictions.
If your business is considering obtaining a Tobique Gaming License, NUR Legal can assist with application preparation, compliance advisory, and cross-border risk assessment. Contact our team to explore whether this jurisdiction is the right fit for your gaming operations.
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Emil Korpinen