Belize

Land-based growth is similarly constrained by a historically small and fixed pool of licensed premises — an undated notice recorded only five licensed casinos in the country — while the lottery segment has moved toward direct state administration following the 2023 revocation of the prior private concessionaire's exclusive licence. Taken together, the absence of a located market-size estimate, the closed online channel, and the concentrated land-based base point to a small, structurally constrained opportunity rather than an unquantified but potentially large one.

The lottery pathway runs through the Lotteries Committee under the Lotteries Control Act, Cap 151, which issues commercial lottery licences at a tiered statutory fee. The online gaming pathway, by contrast, is closed: a government notice dated 9 June 2025 declares a moratorium on new online gaming licensing and states that no online gaming companies are currently licensed in Belize. For technology and platform suppliers seeking a business-to-business route rather than a direct operating licence, no such licence class has been identified in the Gaming Control Act, the Lotteries Control Act, or the sections of Act No. 3 of 2026 reviewed, leaving that pathway unresolved rather than confirmed open or closed.

On the online side, enforcement posture has been communicated through public notice rather than individual proceedings: an 18 February 2022 Gaming Control Board notice stated that one named operator held a valid Belize online licence while treating other claimed licensees as invalid, and a 9 June 2025 government notice superseded that position, declaring a moratorium on new online licensing and stating that no online gaming companies are currently licensed in Belize, with any claim to the contrary characterised as illegal.

The two notices are internally inconsistent across time, and the operative enforcement theory targets the false assertion of current licensure itself rather than gambling activity as such. The practical revocation risk for a licensed entrant centres on material breach of licence conditions, as demonstrated by the Brads Gaming Group case, and on any public claim of online licensure that the current moratorium notice would characterise as illegal.

This represents the government disclaiming offshore assertions of licensure in public notice form rather than through a formal state-to-state cooperation mechanism or a documented correspondent-banking disruption; no such formal cross-border enforcement instrument has been located. The notice sits in tension with an earlier 18 February 2022 Gaming Control Board notice, which had stated that one named operator held a valid Belize licence while treating other claimed licensees as invalid, meaning the government's own public position on offshore licence claims has shifted materially between 2022 and 2025. An entrant or a counterparty relying on a Belize-issued online licence should treat the 2025 position as the current and superseding one.

No explicit suspicious-transaction or currency-transaction reporting threshold specific to the gambling sector has been located, and no FATF or CFATF mutual-evaluation finding specific to Belize gaming has been located either. This leaves the practical AML/CFT burden for an entrant genuinely uncertain: a licensee should expect to be treated as a reporting entity by cross-reference, but cannot currently point to a confirmed threshold, a gambling-specific guidance note, or a mutual-evaluation rating to calibrate the scale of that obligation.

The absence of a published threshold or evaluation finding is a gap in the available record rather than a confirmed absence of obligation, and an entrant should treat the cross-referenced designation as the operative baseline until a threshold or sector-specific guidance is located.

On compliance, Cap 152 cross-refers to the Money Laundering and Terrorism (Prevention) Act in its definitions, supporting a probable designation of gaming licensees as reporting entities, though no explicit reporting threshold has been located. No operational-obligation, responsible-gambling, or technical-certification instrument specific to Belize gaming licensees has been located, so beyond the lottery fee schedule and the general AML cross-reference, an entrant cannot currently point to a published compliance cost schedule.

The lottery segment has consolidated rather than diversified: following the 2023 revocation of Brads Gaming Group Ltd's exclusive licence for material and substantial breaches, lottery administration passed to the state-owned Belize Government Lotteries Limited, replacing a private concessionaire with direct state administration. Taken together, these signals describe a small, concentrated land-based market anchored around a historically fixed pool of licensed premises and a now state-run lottery, with the online segment foreclosed entirely by the standing 2025 moratorium rather than competitive at all.

Section 62 of the Act deems licences issued under the predecessor statutes to continue once the new Act takes effect. No commencement date for the Act has been located, which means the reform remains enacted but not yet in force, and the legacy regulatory bodies continue to operate under Cap 152 and Cap 151 in the interim. The Act's 2025 Bill precursor had already proposed the Commission and Board-of-Directors structure before assent. Until a commencement order is located, the practical regulatory position for an entrant is the legacy one, not the one described by the new Act's text.