Anjouan’s casino license originates from the autonomous island of Anjouan, part of the Union of the Comoros, and is marketed as a fast, affordable route into online gaming. It is promoted as a single all‑in‑one authorization covering most egaming verticals—online casinos, sports betting, poker, bingo, lotto, eSports, live dealer, scratch cards, “provably fair” and blockchain games—and certain B2B supply. Applications are typically processed fully remotely, with timelines often quoted at 4–6 weeks end‑to‑end (best case 10–15 business days) and company formation in 1–3 days. Advisors also advertise zero gaming tax on GGR and tax‑neutral IBC structures, though exact fees vary by provider. Operators remain responsible for local laws in each market and commonly geo‑block the United States, United Kingdom, France, Germany, Netherlands, Spain, Australia, Austria, and the Comoros. At the same time, regulator labels and authority claims (AOFA, ABGB/AGA, ALS Inc.) are inconsistent, and the 2024 FATF report states gambling is illegal under the Comorian Penal Code—so this igaming overview offers a clear, lawyer’s review of what the Anjouan license is, where it helps, and the risks to address.
Anjouan casino license: what it is and why the industry is talking about it
If you work in online gaming, you’ve heard the buzz. What is the Anjouan casino license, and why are startups flocking to it? In short, it’s a single, broad license marketed as covering most forms of egaming and igaming. One document for casino, sportsbook, poker, lotto, bingo, and even “provably fair” or blockchain-based games. The promise is speed, low cost, and a remote process. For founders, that sounds like the fast lane.
Anjouan is an autonomous island of the Comoros, and providers describe a modern application flow, remote onboarding, and no gambling tax on GGR. Some agencies say you can use an existing foreign company, avoid local directors, and go live in a matter of weeks. On paper, it’s the dream kick‑off license for early‑stage casinos looking to test product‑market fit.
The legal landscape in and around Comoros
Now for the lawyerly reality check. Public sources note a tension between the island’s licensing practice and national legislation of the Union of the Comoros. The 2024 FATF‑GAFI materials describe gambling as prohibited at the union level. The Central Bank has also issued warnings in the context of offshore financial licensing and the status of island‑level authorities. While those warnings did not target online gambling specifically, they fuel the debate.
This matters for enforceability, bank onboarding, and reputation. Some market actors claim authority names like the Anjouan Offshore Financial Authority and an Anjouan Betting and Gaming Board. Others dispute their standing under union law. The result is a gray zone. Operators can and do obtain an Anjouan license, but you should treat it as a niche offshore approval whose effect is mainly commercial, not a passport into regulated markets.
How operators reconcile the conflict
Most casinos licensed in Anjouan operate only in “gray” markets, block restricted countries, and use strong geoblocking. They frame the license as permission to run online services outside the Comoros, with players in non‑prohibited countries. Even then, risk remains. You still need to comply with each target country’s laws; the license does not override local bans or licensing rules.
What the license typically covers
Service providers promote a “one license covers all” model. That normally includes online casino (RNG and live), sports betting, poker, bingo, lottery, instant win, eSports markets, skill‑chance hybrids, and sometimes crypto‑denominated games. For B2B, suppliers use it to signal testing standards and fair play controls when they sell platforms, content, or risk services to operators.
Read the fine print. Many Anjouan‑licensed casinos publish a restricted‑country list: the USA, the UK, major EU states like France, Germany, the Netherlands, Spain, Australia, and locally prohibited or sanctioned jurisdictions. If you take players from these places, expect PSP pushback or enforcement risk.
Application process overview
The process is marketed as simple: corporate setup, due diligence on owners and managers, AML/CFT materials, and a basic operational pack. You submit a business plan, terms and conditions, responsible gaming policy, KYC procedures, and tech details. Regulators or their agents review beneficial owners, source of funds, sanctions screening, and criminal records.
Timelines range from three to eight weeks if your documents are clean. Some advisors quote 10–15 business days after submission. Expect faster corporate formation, slower compliance checks. The process is usually remote, with no local office or resident director requirements. Costs are lower than tier‑1 hubs, but plan for ongoing compliance work.
Documents you will be asked for
- Passport copies and proof of address for UBOs and directors
- Bank and professional references, plus a CV for gaming‑relevant roles
- Source‑of‑funds declaration and transactional history
- Business plan, game catalogue, software/RNG certificates, and domain proof
- AML/KYC/Responsible Gaming policies and appointment of a compliance officer
Compliance expectations after approval
Approval is not a shield against poor practices. You will need working AML/CFT controls, transaction monitoring, sanctions screening, and record‑keeping. Expect to maintain policies, train staff, and log responsible gambling interventions. Third‑party audits or RNG certifications may be requested. Notify the authority of changes to control, directors, domains, or payment flows.
Many promoters highlight “no gaming tax” and low or zero corporate tax for offshore income. Even if that is available locally, your tax position is determined by substance and where you actually manage the business. If management sits in the EU or UK, you may create a taxable permanent establishment. Plan for VAT on B2C where applicable, and for corporate residence rules in your team’s home countries.
Banking, payments, and PSP reality check
Here’s the part founders underestimate. Card acquirers treat offshore and gray‑market gambling as ultra‑high risk. An Anjouan license may not open mainstream acquiring. You will often start with alternative payment methods, niche acquirers, or crypto processors. These partners want proof of geoblocking, KYC, chargeback control, and fair T&Cs.
You can improve acceptance with clean UBO profiles, independent game testing, a robust chargeback plan, and transparent complaint handling. Build a compliant data stack (device fingerprinting, velocity checks) and a clear refund and bonus‑abuse policy. Expect rolling reserves and higher MDRs at the start.
Jurisdictional reach and geoblocking
Anjouan does not give you rights inside markets that require their own licenses. You must comply with each target country’s rules. That means blocking prohibited GEOs, filtering local languages and currencies, tailoring bonus marketing disclosures, and limiting affiliates. Regulators look at where you market, not where you are incorporated.
Good practice includes GEO IP blocking plus payment blocking, app store distribution controls, and funnel‑level disclosures. If local law bans online gambling or demands a local license, do not take players there. When in doubt, get a local counsel memo for each priority market.
Risk review: player perception and dispute resolution
Player reviews are mixed. Some praise fast onboarding. Others complain about weak dispute resolution or slow responses from certain “authorities.” If the regulator does not actively mediate, the onus is on you to show fairness. Publish your RTP audits, withdrawal SLAs, and escalation paths. Use a recognized ADR body even if not required. Segregate player funds where possible and say so.
Trust is earned with transparent limits, quick KYC, and consistent withdrawal behavior. If you rely on a young regulator for credibility, double down on self‑regulation. Clear terms around bonus wagering, max bets, and restricted games will save you chargebacks and bad press.
Structuring your business with an Anjouan license
Many igaming groups separate IP, operations, and processing. One company holds the license and player contracts. Another holds platform IP. A third manages PSP contracts and risk. This helps isolate liabilities and streamline a future migration to a tier‑1 jurisdiction. It also helps with commercial negotiations, since suppliers and acquirers like clean counterparties.
Add a data‑protection layer early. If you touch EU residents, GDPR applies, even with offshore hosting. Use reputable hosting, WAF and DDoS protection, and keep a tested incident response plan. For affiliates, implement approval workflows, UTM discipline, and geo‑restricted creatives.
Cost drivers you should budget for
License fees are the easy part. The ongoing costs make or break you. Budget for AML staff, external audits, RNG and live studio certifications, platform licensing, CRM tooling, fraud prevention, and responsible gaming tech. Add rolling reserves at PSPs, legal opinions for key markets, and a proper financial reporting stack.
Most startups underestimate the cash needed for withdrawals in bonus‑heavy campaigns. Set a treasury policy. Maintain buffers, segment VIP payouts, and implement tiered withdrawal limits that comply with fair‑play rules in your chosen markets.
Migration strategy: from Anjouan to tier‑1 licenses
For many casinos, Anjouan is a test bed. If KPIs look good, you can pursue Malta, Isle of Man, or other mature regimes. That path needs early planning. You will need stronger player fund segregation, enhanced affordability checks, expanded KYC/EDD, and technical certifications under ISO/GLI standards. Your content catalogue may need re‑approval. Your team will need on‑shore presence.
Treat your Anjouan phase as a compliance beta. Document everything, centralize logs, and maintain a change register. When you apply for a tier‑1 license, that governance history is gold.
Red flags and how to vet service providers
“Official” and “exclusive” claims are common in this corner of the market. Verify authority names against government gazettes, current legislation, and union‑level notices. Ask for a license template, conditions, and a verifiable registry entry. Check whether player complaints are logged publicly and how disputes are resolved.
Avoid anyone promising instant bank accounts, guaranteed card acquiring, or zero compliance. Use staged payments or escrow tied to milestones. Get independent legal opinions on Comoros law and on the authority’s standing. Speak to PSPs before you commit, so you know whether your target payment stack will accept Anjouan‑licensed casinos.
Quick review: who Anjouan is for
Anjouan fits lean teams that want to launch an online gaming MVP in gray markets with controlled risk, and who understand the limitations. It can work for B2B suppliers that need a light licensing signal while they build references. It is not a passport for regulated Europe or North America, nor a magic key to card acquiring. Think of it as a stepping stone, not a destination.
If you approach it with clear eyes—tight geoblocking, strong AML, honest marketing, solid player care—you can learn fast and scale responsibly. If you treat it as a shortcut, the market will close doors on you just as quickly.
Side‑by‑side overview with common alternatives
The table below is a snapshot, not legal advice. Markets change. Always verify current rules before you decide.
| Feature | Anjouan (Comoros) | Curaçao (new regime) | Malta (MGA) |
|---|---|---|---|
| Typical processing time | 3–8 weeks (varies) | 2–4 months | 6–12+ months |
| Scope | Single online license, broad categories | B2C/B2B framework | Multiple license types |
| Local presence | Commonly marketed as not required | Local presence evolving | Local presence required |
| Gaming tax on GGR | Marketed as 0% | Low single‑digit models | Progressive rates |
| PSP acceptance | Limited, niche/high‑risk | Moderate, improving | Strong (if compliant) |
| Market access | Gray markets only | Gray to semi‑regulated | Regulated EU and beyond |
Practical checklist for a credible launch
- Map markets with legal opinions and block prohibited GEOs at IP and payment layers.
- Build AML/CFT that mirrors FATF standards: KYC, EDD, monitoring, and sanctions screening.
- Publish clear T&Cs, bonus rules, withdrawal SLAs, and a formal complaints and ADR route.
- Secure RNG and live game certifications from recognized labs; publish summaries.
- Pre‑board PSPs and APMs; expect reserves; monitor chargebacks daily.
- Separate funds operationally; aim for escalating segregation as you scale.
- Keep a migration plan to a tier‑1 license. Your future self will thank you.
Final review for founders in igaming and egaming
Anjouan offers speed and affordability, with a license structure that covers many casino verticals under one roof. The trade‑off is legal uncertainty at the union level, mixed player‑protection reviews, and tougher banking. If you pair the license with serious compliance and careful market selection, it can be a useful early chapter in your online gambling story. If you need blue‑chip credibility on day one, pick a different jurisdiction—and budget accordingly.
| Aspect | Details |
|---|---|
| What is the Anjouan casino license (overview) | An online egaming/iGaming authorization issued on the autonomous island of Anjouan (island of the Union of the Comoros) that operators use to offer gambling with casino, sportsbook, poker, bingo, lotto, and related online gaming services. A single license is often marketed as covering most game types. |
| Where is Anjouan | Anjouan (Ndzuwani) is an autonomous island of the Comoros, in the Indian Ocean between Madagascar and mainland Africa. |
| Who issues the license (governance) | Marketed issuers and bodies include: Anjouan Licensing Services Inc. (claims official authority/sole administrator), the Anjouan Offshore Financial Authority (AOFA), the Anjouan Betting and Gaming Board/Anjouan Gaming Authority (ABGB/AGA), and Anjouan Corporate Services (claims “only authorized agent” and keeps a register). Multiple, competing “official” claims exist. |
| Legal status in Comoros (controversies) | Public commentary cites the 2024 FATF Mutual Evaluation Report stating gambling is prohibited under the Comorian Penal Code. The Central Bank of the Comoros has publicly disavowed island‑level offshore financial licensing (including AOFA) in the finance context. While that warning did not target egaming specifically, it raises questions about the legal foundation of island-issued licenses within the national framework. Conduct independent legal review in‑country. |
| License types (B2C and B2B) | B2C: online casinos, sportsbooks, poker rooms, bingo/lotto, live dealer, eSports, “provably fair” and blockchain-based games (as claimed by promoters). B2B: platforms, software, content suppliers, payment/orchestration providers serving licensed operators. One “all-in-one” license is often advertised as covering both broad categories; confirm scope in your approval letter. |
| Activities covered | Commonly promoted coverage: online casino (slots, tables, live), sports betting (pre-match/live/virtual), poker, bingo, lotto, scratch, eSports, RNG and peer-to-peer games, and game suppliers/developers. Validate permitted verticals and hosting rules in your license conditions. |
| Corporate setup | Frequently marketed as: no need to incorporate in Anjouan, no local director, no office, fully remote onboarding. Alternatively, some providers recommend an Anjouan or other IBC as the licensee. Clarify entity requirements with the issuing office you engage. |
| Eligibility (people) | Directors, shareholders, UBOs: over 18, clean criminal record, not on sanctions lists, good business reputation, verifiable source of funds/wealth. Expect KYC for each controller. |
| Key applicant documents | Notarized passport, proof of address (≤3 months), bank letter or statement (often asking for 2+ years relationship), CV, professional reference (lawyer/accountant), source-of-funds declaration. Corporate KYC if applying via a company. |
| Operational documentation | Business plan (target markets, products, 3‑year projections), game/software description and supplier contracts, RNG or game certifications (if proprietary), domain ownership proof, AML/CFT policy, KYC/age verification, Responsible Gaming policy, player T&Cs, appointment of a compliance/AML officer. |
| Application process (steps) | Typical sequence: 1) Preparation & entity setup (if needed) and KYC file. 2) Application package compilation. 3) Due diligence by authority. 4) Conditional approval and fee payment. 5) License issuance and go‑live checks (GEO‑blocking, policies, payment rails). |
| Timelines (as marketed) | Claims vary by provider: 10–15 business days at the fastest, more commonly 4–6 weeks, 3–4 weeks in some promos, and up to 2–3 months end‑to‑end including prep. Add time for assembling documents and platform readiness. |
| Fees (indicative) | Marketed as “accessible/competitive,” with lower setup and renewal costs than many European regimes. Budget also for compliance build‑out, audits, platform, hosting, payments, and annual professional support. Request a written cost schedule (application, license, renewal, fit & proper checks, changes, and audits). |
| Taxes (promoted positions) | Frequently advertised as: no gaming tax on GGR, no corporate income tax, and no VAT for offshore income (e.g., via IBC structures). Reality depends on your corporate structure, place of effective management, and customer locations. You may still owe taxes in operating/management jurisdictions. Get tax opinions before launch. |
| Compliance obligations | AML/CFT framework aligned with risk-based KYC, player due diligence, sanctions screening, record‑keeping, suspicious activity reporting, responsible gambling, self-exclusion, fair gaming controls, vendor due diligence, third‑party audits (when requested), incident reporting, and timely disclosure of changes (e.g., UBO within 7 days). No cash acceptance; maintain financial ratios if imposed. |
| Geo reach and blocking | Marketed as allowing international operations, subject to local laws of target countries. Commonly listed restricted/prohibited markets: Australia, Austria, Comoros, France, Germany, Netherlands, Spain, the UK, the USA, and FATF‑blacklisted countries. Enforce GEO‑IP and payment blocking and follow national rules where players are located. |
| Banking and payments | Acceptance by banks/PSPs varies. Some acquirers treat Anjouan‑licensed casinos as higher risk, leading to onboarding friction, higher MDRs, rolling reserves, or crypto‑only phases. Mitigations: clean KYC, strong RG/AML stack, reputable suppliers, transparent T&Cs, and proactive dispute handling. |
| Player protection and disputes (review) | Third‑party feedback online reports uneven oversight and slow/absent responses to player complaints; some public threads mention non‑payment disputes and limited regulator engagement. Operators should implement robust internal ADR/ODR, publish clear payout rules, and use independent dispute channels to build trust. Players should proceed cautiously. |
| Advantages (operator view) | Fast time‑to‑market, cost‑effective entry, single license for multiple verticals, remote application, flexible corporate arrangements, and marketing utility in many gray markets. Useful for MVP validation in igaming/egaming. |
| Limitations and risks | Legal uncertainty within the Union of the Comoros, fragmented “authority” claims, uneven acceptance by payment providers and affiliates, limited access to tightly regulated markets, potential reputational drag versus Malta/Isle of Man/Gibraltar, and possible policy changes. |
| Comparison (at a glance) | Curacao: widely known, modernized regime; moderate recognition; quicker than Tier‑1 EU. Malta (MGA): strong credibility, higher cost, intensive compliance, better banking. Isle of Man/Gibraltar: high trust, strong supervision, higher cost and substance. Anjouan: fastest/lowest cost image but with legal/recognition questions. |
| Renewal and reporting | Annual renewal with fee payment; marketed as light-touch and completed within about a month if compliant. Maintain periodic reports, update ownership/management changes promptly, and keep AML/RG programs current. |
| Suitability (who uses it) | Startups and early‑stage casinos/sportsbooks testing product‑market fit; B2B platform or content providers seeking an initial regulatory wrapper; operators targeting gray markets with careful geo‑blocking. Not ideal for access to the most regulated “white” markets. |
| Practical compliance checklist | Appoint MLRO/compliance officer; finalize AML/KYC/RG/T&Cs; integrate KYB/KYC and age checks; implement sanctions/PEP screening; RNG/game certs or reputable suppliers; clear bonus/payout logic; risk register and incident playbooks; GEO/IP and payment blocking; data protection and cybersecurity controls; independent ADR. |
| Time‑to‑market playbook | Day 0–3: Intake, KYC list, entity plan. Week 1–2: Corporate setup, documents, policies, supplier contracts. Week 3–6: Submission, DD, conditional approval. Week 6–8+: License issue, PSP onboarding, soft launch with controlled limits and monitoring. Adjust for slower cases (up to 2–3 months). |
| Frequently asked questions | Can I operate in multiple countries? Yes, but you must comply with each country’s gambling laws; some require local licenses. Is a local office required? Commonly marketed as not required. Consequences of operating without a valid license? Fines, shutdowns, and PSP blacklisting. How fast is renewal? Often cited as ≈1 month if compliant. |
| Due diligence tips (with in‑practice review) | Get a written confirmation of the exact issuing authority and legal basis; verify your license on an official register; obtain local Comoros legal counsel’s memo; secure banking/PSP pathways before committing; define restricted GEOs; capture tax advice for management and player locations; plan an exit/migration path to a higher‑recognition license if scaling. |
| Bottom line (balanced review) | The Anjouan casino license is marketed as a quick, low‑cost on‑ramp for online gaming. It can help startups validate their model in selected markets. However, conflicting governance signals and mixed player‑protection reviews mean higher legal and reputational risk. Treat it as a stepping stone, not a final destination, and reinforce compliance beyond the bare minimum. |