Casino without a German licence: the legal position, and why it is paid in crypto

§ 4(4) GlüStV 2021 states a clear prohibition: organising and brokering public games of chance on the internet is forbidden unless expressly permitted. Only offerings holding a permit under the GlüStV 2021 are permitted. A licence from Malta, Gibraltar, Curaçao or Anjouan is not a permit under that treaty.

§ 5 GlüStV 2021 also prohibits advertising for unlicensed gambling. That applies not only to the operator but to anyone advertising on its behalf. Many comparison sites promoting casinos without a German licence therefore move in an area that can be relevant under both supervisory and criminal law.

For the German reader: an operator absent from the whitelist of the Gemeinsame Glücksspielbehörde der Länder (GGL) is not a permitted offering inside Germany. That holds however friendly the site looks, however large the bonus, however fast the promised payout. The legal position is not a matter of taste.

§ 284 StGB is addressed to the organiser. Anyone organising or holding a public game of chance without official permission commits an offence. This is not a regulatory infringement but a crime. It catches the operator, its management and, in certain constellations, intermediaries.

§ 285 StGB is addressed to the player. It makes taking part in an unlicensed public game of chance a criminal offence and provides for imprisonment of up to six months or a fine of up to one hundred and eighty daily units. Only intentional conduct is punishable; someone who does not know the offering is unlicensed is not acting intentionally.

None of that changes the fact that the provision exists and addresses the player, not only the operator. This page states it plainly, without a recommendation either way and without playing it down. Anyone who plays carries a legal risk of their own. Anyone who does not play carries none.

The reason is not enthusiasm for technology but payment processing. Card networks and European payment service providers assign gambling its own merchant category and require proof of a permit for the market where payment is made. Without a German permit an operator cannot produce that proof. § 9(1) sentence 3 no. 4 GlüStV 2021 also lets the supervisory authority extend a prohibition order to parties in the payment chain.

A payment in cryptocurrency passes that point by, because between one wallet and another no institution can check for a permit. The transaction is confirmed by a decentralised network, not a bank. That is why crypto is the obvious payment rail for operators without a German permit – not because they are more modern.

For the player that changes three things: once confirmed, a deposit cannot be recalled, there is no chargeback through the bank, and the exchange rate moves between deposit and withdrawal. A stablecoin removes the third point, not the first two. Anyone depositing in crypto pays without a safety net.

Curaçao is a licensing market, not a promise of consumer protection. The Curaçao Gaming Authority keeps a certificate register at cert.cga.cw. A licence number of the form OGL/YEAR/NNN/NNNN can be looked up there; the register names holder, status and approved domains. Older numbers of the form 8048/JAZ come from the old Antillephone system and are no evidence of a current licence. Two Curaçao registers circulate and contradict each other; only the lookup via cert.cga.cw is binding.

Anjouan is not a state regulator in the classic sense. The Anjouan Offshore Financial Authority, administered by Anjouan Licensing Services Inc., issues numbers of the form ALSI-YEAR-FI2 or -FI3. The licence agents all publish the same list of blocked countries, on which Germany and Austria appear. That list is not on the authority's own site.

More serious still: an investigation by the Australian ABC of 31 December 2025 reports that the central bank of the Comoros calls these licensing bodies fictitious institutions with no physical or legal existence on Comorian territory, and that banking laws of 2013 and 2015 withdrew the authority's recognition. For a German reader: an Anjouan number in the footer is an entry with a private body whose status is disputed at home. It is not consumer protection and not a complaints body.

Four brands that do not list Germany on their blocked-country list – Bitkingz, PlayAmo, Slotum and Winz.io – quote the same licence number ALSI-202508056-FI2. 7Bit Casino and Mirax quote the same Curaçao number OGL/2024/1307/0748. A shared number means one operator sits behind several brand names, and anyone turning from one brand to the next in a dispute faces the same counterparty.

With an operator holding a German permit, several protective systems apply that a casino without a German licence lacks. OASIS is the central exclusion register through which a self-exclusion is enforced across all operators. The GGL's limit file caps monthly deposits. The complaints routes are clear: for problems, the Gemeinsame Glücksspielbehörde der Länder is responsible.

The cross-operator deposit limit is €1,000 per calendar month under § 6c(1) sentence 3 GlüStV 2021. It sums all deposits across all operators permitted in Germany, not per account. On application it can rise to €10,000 a month if economic capacity is proven and no indications of gambling addiction or of a risk of it exist. An operator may grant a limit between €10,001 and €30,000 to at most 1% of its active players.

All of that falls away as soon as you play with an operator without a German permit. There is no OASIS connection, no central limit file, no supervisory authority to step in when a payout fails to arrive. The operator can set its own rules, but it is obliged to no one in Germany to enforce them.

The main promise of operators without a German licence is access to games a nationally permitted operator may not offer: classic table games such as roulette and blackjack fall under § 22c GlüStV 2021 and are a matter for the federal states. Only virtual slot machine games under § 22a and online poker under § 22b can be permitted nationwide. An operator without a German permit can offer live roulette and live blackjack without minding these boundaries.

For that the player pays a price the marketing rarely names. There is no independent arbitration body, no binding behavioural monitoring under § 6i GlüStV 2021 and no limit file. Anyone who does not receive a payout cannot go to the GGL; only the civil courts remain, against a company often seated in a jurisdiction where enforcement is practically difficult.

On top comes the crypto payment itself: network fees are paid by the sender, not the operator. On a small withdrawal the fee can make up a noticeable share. How an operator accounts for it stands in its payment terms – not in its marketing copy. The supposed promise of freedom is therefore above all a waiver of protection.

The first step is always the GGL whitelist. Under § 9(8) GlüStV 2021 the Gemeinsame Glücksspielbehörde der Länder publishes an official list of organisers and intermediaries holding a permit under the GlüStV 2021. The list stands at gluecksspiel-behoerde.de and is the only binding place to check a German permit. An operator not on it has no German permit – regardless of what the footer says.

For a Curaçao licence, open cert.cga.cw and enter the licence number. The register names holder, status and approved domains. Compare them with the operator's footer. If holder or domain differs, or the status is not active, the licence statement is worthless. Older numbers of the form 8048/JAZ are no evidence of a current licence.

For an Anjouan number there is no comparable public register. You can cross-check it only with the licence agents, not with an independent authority. Note the agents' identical country lists: if Germany is on them, then by the operator's own account it should not target the German market. The Curaçao Gaming Authority's register is more reliable, but it too does not replace a German permit.

This page is an analysis, not play experience. Nothing was played, deposited or tested. The review consists of reading the operators' terms and the registers they invoke. No sentence here claims an offering without a German permit is legal in Germany. No sentence recommends playing there. No sentence plays down the risk.

The list below this text is not an editorial ranking; the order comes from a disclosed formula. The calculation runs against a fixed denominator of 10 points, across six components: licence and entry in the licensor's register (2.5), a published country list (1.5), clarity of the verification rule in the operator's own terms (2.0), the number of cryptocurrencies named (1.5), reach measured by the number of blocked countries (1.5) and whether verification already happens at sign-up (1.0). A seventh component – the number of game studios – is provided for in the weighting but currently not awarded, because only a small minority of brands publish the figure; it counts in neither numerator nor denominator. The denominator is deliberately fixed: a component an operator does not document costs points instead of dropping out of the calculation – otherwise ignorance would be rewarded. A brand documenting fewer than three components, or with no verifiable licence statement, gets no mark rather than a bad one. A licence revoked or deleted in the register means the brand is not listed at all. The purchased position of Vave bypasses this formula rather than running through it. The full calculation stands on the Rating method page.

This page draws its lines clearly: a mechanism that can be recalculated, or a register entry, is no guarantee of solvency, willingness to pay, or a German permit. Those are separate questions. Anyone who understands that can judge the statements in operators' footers for themselves.