Anjouan and Emerging Offshore Licences: A Due Diligence Framework

Anjouan gambling licences have moved from a low-cost route to market into an open compliance question. An Australian Broadcasting Corporation investigation published on 31 December 2025, followed by warnings from Comoros authorities in January 2026, put the island’s licensing bodies under scrutiny. The dispute is not about lenient rules. It is about who holds licensing authority at all, and how an operator proves that its licence exists.

Why Anjouan Became a Due Diligence Question for Operators

The migration was predictable. When Curaçao replaced its master licence model and raised the cost of entry, operators working to a small first-year budget needed somewhere else to incorporate and go live. Anjouan absorbed much of that demand: annual fees of roughly EUR 17,000, approval in four to six weeks, no tax on gross gaming revenue, and a single permit covering casino, sportsbook, poker and esports. The register maintained by the licence administrator now lists more than 1,300 licences.

What changed in December 2025 was not the price or the paperwork. It was the evidence base. The ABC traced the bodies behind the licences and found no government official associated with them, no published directors, and a legal basis resting on legislation passed by a separatist administration in 2005. Under GICNT-LS licensing requirements, a licence is treated as a verifiable fact rather than a claim on a website footer, and an emerging offshore regime is subject to enhanced scrutiny precisely because that verification is harder.

The Legal Standing of the Anjouan Offshore Finance Authority

The chronology matters more than any single allegation, because it explains why the Union of the Comoros and the island disagree about the same set of documents.

• 1997: Anjouan declared independence from the other Comorian islands. The separatist administration established the Anjouan Offshore Finance Authority (AOFA) as its corporate regulator.
• 2007: the vice-president of the Comoros publicly accused the body of being composed of money laundering operations.
• Shortly afterwards: a World Bank mission reported that the creation of offshore banks in Anjouan was illegal under Comorian law.
• 2013 and 2015: following reunification, banking laws stripped AOFA of its status as a recognised regulator.
• 2023: the Comoros Central Bank described several Anjouan regulators, and the firms selling their licences, as fictitious structures with no physical or legal existence in the territory of the Union.
• May 2023: Anjouan Licensing Services registered two domains on consecutive days, one presenting the Anjouan Gaming Control Board, the other selling gambling licences.

AOFA continues to maintain a public register and, according to the ABC, has added more than 50 banks, insurers, brokers and gambling sites since being formally dissolved. Anyone reading a licence certificate without this history will misread it, which is one reason the regulator and licensing acronyms used in operator documentation deserve to be checked against a statutory source rather than a vendor glossary.

Naming Confusion Across the Bodies That Issue Anjouan Licences

Mature regimes have one named statutory authority, one register and one enforcement record. Anjouan has several overlapping names. AOFA is cited as the source of authority. Anjouan Corporate Services describes itself as its sole authorised agent. Anjouan Licensing Services issues gambling permits through the Anjouan Gaming Control Board and trades publicly as Anjouan Gaming. Advisory material adds a further body, the Anjouan Betting and Gaming Board, to the same chain.

Comorian officials have addressed two of these directly. The secretary general of the Central Bank’s financial intelligence unit told the ABC that Anjouan Corporate Services is operating illegally, and a former attorney-general of the Comoros described Anjouan Licensing Services as an illegal entity. Separately, the mutual evaluation of the Union of the Comoros published in May 2024 has been read by legal commentators as confirming that gambling is prohibited under the Comorian penal code at union level, which would mean the sector has never been assessed for anti-money laundering purposes nationally.

Anjouan Gaming set out its own position in a statement on 10 June 2026. It denied that its licences were ever presented as universal authorisation, accepted that no licensing body can exempt an operator from local law where local authorisation is required, and described its own process as including corporate review, key person assessment, financial vetting, and screening against sanctions lists, politically exposed person databases and adverse media. It objected to commentary that conflates offshore licensing with local market authorisation. Both positions can be recorded side by side in a due diligence file; neither disposes of the other. For comparison against regimes whose statutory basis is settled, the reference table of gambling regulators by country is the more useful starting point.

Six Tests for Assessing an Emerging Offshore Licensing Regime

Due diligence on an offshore gambling licence should not turn on the reputation of the jurisdiction’s name. It should turn on whether the regime produces the six artefacts that make a licence meaningful to a counterparty.

Test	What to establish	Failure signal
Statutory basis	The Act or ordinance in force, its date, and the level of government that passed it	The only cited law predates a constitutional change, or cannot be located in an official gazette
Identity of the supervisor	One named body, with published officers and a physical address	Authority, agent and administrator are separate private companies with no listed directors
Public register	A searchable register on the authority’s own domain, showing legal entity, status and scope	The register sits on a commercial domain, or returns only a certificate image
Complaints and redress	A defined complaints route with an independent stage, and published outcomes	Complaints handling is described in policy but no decisions are published
Enforcement record	Suspensions, revocations and sanctions attributable to named licensees	Fees are collected, but no adverse decision has ever been published
Standing under national law	Confirmation from the sovereign state that the regime is recognised	The national central bank or finance ministry disputes the body’s existence

Two of these carry disproportionate weight. A supervisor that has never suspended a licensee has supplied no evidence of supervision, and a licensing body the sovereign state declines to recognise cannot give a payment partner the comfort it is being asked for. The wider trade-offs between cost, timeline and market access are set out in the comparison of licensing jurisdictions for operators.

Verifying a Gambling Licence Against the Issuing Body’s Register

To verify a gambling licence against the issuing body’s register, work through a fixed sequence and record the result. The following steps apply to any remote gambling regime and take under an hour.

1. Locate the register on the supervisory body’s own domain. If the only route to it is through a licence seal on the operator’s site, treat the seal as unverified.
2. Search by legal entity name rather than by brand. One corporate entity frequently operates a dozen domains, and only the entity is licensed.
3. Read the status field and the expiry date. Anything other than an active status means the operator is not currently authorised, whatever the footer says.
4. Confirm the scope covers the products actually offered. Casino, sportsbook, live dealer and lottery are not always covered by a single permit.
5. Check the seal resolves to the register record. Curaçao licensees carry digital seals linked to the public database, and the Curaçao Gaming Authority published a warning in February 2026 about a site displaying a counterfeit one.
6. Cross-check the entity against the corporate registry of its jurisdiction of incorporation, and reconcile the ultimate beneficial owners with what the operator has declared.
7. Record the date of the check and retain a copy of the register entry. An undated verification is worth nothing to an auditor twelve months later.

Market Access and Enforcement Risk in Target Jurisdictions

An offshore licence authorises nothing in a market that licenses locally, and this is where the practical damage occurs. The Australian Communications and Media Authority requested that internet service providers block eight gambling sites on 14 February 2025 for breaching the Interactive Gambling Act 2001, among them Leon, a brand that displays an Anjouan licence and had continued to accept Australian sign-ups. Anjouan gambling licences come with a restricted territory list that typically excludes Australia, the United Kingdom, France, Germany, the Netherlands, Spain, the United States and the Comoros itself, but that list is a contractual undertaking rather than a technical control.

The gap between the undertaking and the traffic is visible in the market. A number of sites marketing themselves to British players as alternatives to the national self-exclusion scheme operate under Anjouan permits, which is a direct compliance problem for any affiliate or supplier in the chain. Operators serving Australia face a settled enforcement pattern rather than a novel risk, as ACMA enforcement practice has produced blocking requests on a rolling basis since 2019.

Payment Partnerships Are Where Offshore Licence Risk Becomes Concrete

Acceptance of a gambling licence by payment providers is the test that actually constrains a business, and it is applied privately, without appeal and usually without notice.

• Acquirer and PSP onboarding. Payment partners run their own jurisdiction lists. A licence that fails their test is not debated, it is declined at underwriting.
• Sudden withdrawal of methods. During the ABC investigation, two payment vendors disappeared from an Anjouan-licensed casino’s cashier within hours of the journalist putting questions to them.
• Correspondent banking for the corporate entity. The holding company still needs an account, and the bank will read the same central bank statements the operator hopes nobody reads.
• Supplier distribution terms. Game studios restrict where their content may be served, and a contested licence complicates the warranty an operator gives on market access.
• Crypto rails as substitution. Moving volume to cryptocurrency does not remove the obligation. Travel rule data still has to move with the transfer, and the AML controls on crypto payments are the area auditors probe first when fiat rails have been withdrawn.
• Concentration and exit. If one provider carries most of the deposit volume, losing it stops the business. Model the migration before signing, not after the decline.

Comparing the Anjouan and Curaçao Licence Regimes

A comparison of the Anjouan and Curaçao licence regimes is the one most operators actually run, since the realistic alternative to an island permit is the post-reform Caribbean framework rather than Malta. The two have diverged since December 2024.

Attribute	Anjouan	Curaçao
Legal basis	Island legislation of 2005, contested at union level	National Ordinance on Games of Chance (LOK), in force 24 December 2024
Issuing body	AOFA, through private administrators trading as Anjouan Gaming	Curaçao Gaming Authority, sole issuer
Intermediaries	Licences sold through agents and administrators	Master and sub-licence model abolished, legacy sub-licences expired in January 2025
Register	Maintained by the licence administrator	Public register on the authority’s domain, with digital seals linked to records
Local substance	Not required in practice	Physical presence required from 1 January 2026
Indicative annual cost	Around EUR 17,000	Materially higher, with B2C fees in the tens of thousands of euros
Open question	Whether the issuing bodies are recognised by the sovereign state	Supervisory capacity and consistency of enforcement

The table sets out what enhanced scrutiny has to establish in each case. The analysis of Curaçao after the LOK reform sets out why a reformed regime still attracts additional checks.

What GICNT-LS Requires of Operators Holding Emerging Offshore Licences

Jurisdictions running emerging offshore licensing regimes are not excluded from certification. They are assessed against a heavier evidential burden under GICNT-LS, which is reviewed annually rather than on a fixed multi-year cycle.

• A dated verification of the licence against the issuing body’s register, retained in the compliance file and repeated at each review.
• Documented identification of the supervisory body, its statutory basis and its standing under the law of the sovereign state.
• Evidence of geo-blocking, in effect and tested, for every market that requires local authorisation.
• A complaints procedure with an independent stage, provided by the operator where the licensing regime supplies none.
• Payment and supplier arrangements mapped, with the licence-dependency of each relationship identified.
• No representation, in marketing or in terms, that certification substitutes for a licence. The boundary is set out in how certification differs from licensing.