Daw Global Weekly Company Brief : W/C 24 August 2026

This week's Company Brief focuses on the following three topics, which I have outlined below for ease of reference:

▸ Nevis Online Gaming Authority (NOGA)
▸ Rolling Reserves And The Cash Flow Effect
▸ Group Structures And Intercompany Flows

Nevis Online Gaming Authority (NOGA)

Insights by Paul Hill – Sales Director & iGaming Strategist

A strategic partnership has been entered into with the Nevis Online Gaming Authority (NOGA), and it is worth setting this out in both directions, because the benefit is reciprocal.

NOGA was established under the Nevis Online Gaming Ordinance 2025 and regulates iGaming operators licensed from the island of Nevis, within the Federation of Saint Kitts and Nevis. Both consumer-facing and business-facing licences are issued, cryptocurrency activity is permitted, approval runs to between 30 and 60 days, and foreign income is taxed at 0%.

The relationship makes sense for a specific reason, which is that the regime is newly established and growing quickly but is not yet a licence the vast majority of financial institutions are familiar with.

Our Compliance team has reviewed the framework in detail and is comfortable supporting operators licensed under it, whether they hold a consumer-facing or a business-facing licence.

Licensees gain access to our multi-currency banking and wider financial ecosystem, covering the full fiat and cryptocurrency requirement rather than part of it. That runs from incoming funds from players and operators through to settlement into the bank account held in the name of the licensed entity.

New and existing clients gain direct access in return. Operators expanding across markets hold licences in more than one jurisdiction, and this gives them a further option, either as an addition to an existing structure or as a new licence altogether.

Rolling Reserves And The Cash Flow Effect

Insights by Martin Van Lessen – Strategic Director

When a customer pays an operator by card, the payment is not final. For a period afterwards, that customer can ask their own banking provider to reverse it, and the financial institution can take those funds back out of the operator's bank account.

That reversal is a chargeback. A refund is the same movement made voluntarily by the operator instead.

Reversals can arrive months after the operator has already been paid, which leaves the Payment Service Provider (PSP) carrying the exposure. Its protection is to hold back a slice of every payment it processes and release it later, once the window for disputes has closed. That retained portion is the rolling reserve.

The arithmetic is what catches operators out. A reserve of 10% held for 180 days does not mean 10% of one month's takings is withheld.

It means 10% of every month's takings is withheld on a rolling basis, so an operator trading steadily has around six months of that 10% sitting with the PSP at any given moment. On a growing book, the amount held grows faster than the business does.

Reducing a reserve is a matter of evidence rather than negotiation. Trading history, a low dispute rate sustained over time, audited accounts and a licence the provider recognises will all move it.

Knowing how much is held and when it releases is the difference between forecasting and guessing.

Group Structures And Intercompany Flows

Insights by Rafa Menzel – Senior Account Executive

Very few operators sit within a single legal entity. The licence is typically held by one company, financial-related operations sit with another, and marketing, technology and intellectual property often sit elsewhere again, frequently in different jurisdictions for sound operational and regulatory reasons.

Funds therefore move between related entities as a matter of routine. Management fees, licence fees, intercompany loans and cost recharges all pass across the group.

Every one of those transfers is a payment between connected parties, and connected-party payments attract more scrutiny than any other category of transaction on a bank account because, at a glance, they carry the same characteristics as layering.

Documentation is what separates a routine intercompany transfer from a flagged one. A written agreement between the two entities, a payment narrative that matches the agreement, and amounts consistent with what that agreement provides for will clear without difficulty.

The failure that causes real disruption is a mismatch between the group structure chart submitted at onboarding and the entities actually transacting.

An entity that appears in the payment flow but not on the chart will stop the payment and reopen the file.

Keeping the chart current and notifying changes when a new entity is added, rather than when it starts paying, is the whole of the solution.