Everything here is anonymised. The operator, the jurisdiction choices, and the exact timeline have been slightly abstracted to protect client confidentiality. The structure of the problem, the decisions we made, and the outcome are real.
What the operator had when they came to us
The client ran a B2C gambling product — slots and sports betting — with players across three European markets. They had been operating informally for around eighteen months, with volume growing faster than their legal structure. They had no registered entity and no gaming licence. They were not yet illegal in the jurisdictions they were targeting but they were heading there, and they knew it.
Two previous providers had told them to form the company first, let that settle, and then begin the licence application. That sequential approach had cost them four months. Nothing had been filed. What they had at the end of it was a set of preparatory documents, no entity, and no application in progress.
When they came to us they had one clear requirement: speed. They needed to be licensed and operational before the next regulatory cycle closed the informal window they were trading in.
What we found when we looked at the file
The sequential approach was not just slow — it was structurally wrong for their situation. The legal entity and the licence application are not independent steps. The jurisdiction you incorporate in, the shareholding structure you build, and the UBO disclosure you prepare for incorporation are the same documents the licensing regulator reviews. Doing them in sequence means doing them twice: once for the company registry, then again — usually in a revised form — for the regulator.
For this operator, the right structure was a Malta B2B supply arrangement licensing the product, with an MGA B2C Remote Gaming Licence for the operational entity. The opco needed to be a Malta private limited company. The holding could sit elsewhere — in this case, the client had existing BVI structures we could use. None of that required formation to complete before licensing began. It required both to be designed together from the start.
We also found a UBO issue in the existing corporate tree that would have failed the MGA’s fit and proper test at any point in the process. That needed to be restructured before either filing. The previous providers had not spotted it.
What we changed
We redesigned the structure in the first week. The BVI holding was retained and slightly amended. A new Malta opco was incorporated, with share classes and director appointments designed to satisfy MGA’s fit and proper requirements from day one. The UBO issue was resolved through a reorganisation of the holding layer before any filing went to any regulator.
We filed the Malta incorporation and opened the MGA pre-application engagement in the same week. There is no regulatory requirement to have the company fully incorporated before engaging the MGA on a pre-submission basis — the application itself requires it, but the early engagement does not. We used that window to get the regulator’s initial read on the file before the opco was registered.
How the engagement ran
The timeline from first call to licence approval looked like this:
- Week 1: Scoping call and structural review. UBO issue identified and flagged.
- Week 2–3: Holding restructure completed. Malta opco incorporation filed. MGA pre-application engagement opened.
- Week 5: Malta opco registration confirmed. MGA pre-submission meeting completed; initial feedback positive.
- Week 8: Full MGA licence application submitted with complete AML/KYC framework, responsible gambling policies, and technical audit documentation.
- Week 14: MGA queries responded to. Second-round information request submitted.
- Week 26: MGA B2C Remote Gaming Licence issued. Operator went live the following week.
Seven months from first call to live. The previous four months of sequential work had produced nothing that carried forward into this process — the structural decisions had to be remade from the beginning.
Throughout, we dealt with the MGA directly. The client did not communicate with the regulator. We managed the information requests, attended the meetings, and prepared every response. The client stayed focused on their product and their player acquisition pipeline.
What the outcome meant in practice
The operator is now live under MGA licence. They have a clean corporate structure that will support future expansion — including additional EU market registrations if they pursue them. The UBO issue is resolved. The banking introduction followed the licence, as it normally does for MGA-licensed operators: with a clean file and a licensed entity, the account process was straightforward.
The lesson from this case is not that parallel filing is always faster. It is that the sequencing question — which step comes first — has a correct answer that depends on the regulator, the jurisdiction, and the operator’s specific structure. Getting that wrong at the start is expensive. Getting it right means the steps reinforce each other rather than blocking each other.
In a similar position?
If you are an operator with a live product and no legal structure — or one where formation and licensing have stalled — book a call. We will tell you what the right sequencing looks like for your specific situation.