An Anjouan betting license is marketed as a single, all‑in‑one permit for online gambling, tied to Anjouan (Ndzuwani) in the Union of the Comoros and often presented as issued by bodies such as the Anjouan Gaming Board/AOFA. It typically covers both B2C and B2B activities across casino, sports betting, poker, bingo, and even blockchain games, with a remote application process, no local office or resident directors, and quoted timelines of about 4–6 weeks (some claim 10–15 business days). Applicants are asked for standard KYC/KYB, a business plan, AML/KYC and responsible gaming policies, proof of domain, and game/RNG documentation, plus a named compliance officer. Providers promote zero gaming tax on GGR and “no CIT/VAT” for offshore income, but taxes can still arise where you target or have nexus. Operators must geo‑block restricted markets such as the U.S., U.K., France, Germany, Netherlands, Spain, Australia, Comoros, and FATF‑blacklisted countries and follow local laws. Important caveat: public sources note regulatory inconsistencies at the Union level (including FATF references to gambling prohibitions and Central Bank statements questioning AOFA), so enhanced legal due diligence on the license’s legal basis and supervision is essential.
What the Anjouan betting license is (and what it isn’t)
Anjouan offers an internet gaming framework that is often marketed as fast, lightweight, and cost‑effective. In plain English: a single umbrella permission for most online gambling verticals—casino, sports betting, poker, bingo, lotteries, eSports, even “provably fair” and blockchain‑based games—issued under the island’s offshore regime. Many service providers also promote a parallel B2B path so platform vendors and content suppliers can certify themselves as “fit and proper” without running a player‑facing operation.
What it is not: a passport to every market. An anjouan betting license may help you open the doors of payment processors and counterparties, but it does not override domestic laws in countries you target. You’ll still need to geo‑block restricted jurisdictions and comply with local advertising, consumer, and tax rules. If your plan is to market aggressively in the UK, most of the EU, or the US, this license alone won’t cut it.
The fast‑lane pitch vs the legal fine print
You’ll see bold claims: no gaming tax, quick turnarounds (sometimes touted as 4–6 weeks), remote onboarding, and a modern application portal. That’s the sales deck. The fine print is more nuanced. Public sources have flagged legal uncertainty at the Union of the Comoros level (including commentary that the national penal code prohibits gambling) and historic statements by the Central Bank distancing itself from certain “offshore authorities.” While those statements focused on financial licensing—not iGaming—they fuel the ongoing debate about who exactly has the mandate to regulate betting on the island and how that stands under national law.
Operators should treat this as a risk assessment issue, not an internet shouting match. If you proceed, anchor your file with professional opinions from local counsel, verify the issuing authority, and preserve a clear audit trail of the enabling legislation and your license grant. This is how you de‑risk contract disputes, payment provider onboarding, and investor diligence later.
Who should consider Anjouan—and who should not
I see three profiles that fit well. First, startups testing product‑market fit who need a lawful framework quickly, without burning runway on slower, more expensive jurisdictions. Second, established brands launching new verticals or gray‑market skins with careful geo‑controls. Third, B2B vendors who want to supply games or platforms globally and align with a recognized, if lighter, due‑diligence regime.
If you’re courting Tier‑1 banks, listing on a public market, or targeting strictly regulated territories (UK, many EU states, most of North America), you’re better served by Malta, Isle of Man, Alderney, Gibraltar, or domestic licenses. Your cost and timeline jump, but your acceptance by payments, affiliates, and app stores increases as well.
Application anatomy, step by step
Start with corporate housekeeping. You don’t typically need a local Anjouan company or resident director for the license, and the process is often fully remote. That said, you will need a clean corporate stack somewhere, beneficiary disclosure, source‑of‑funds evidence, and board resolutions authorizing the application. Keep your structure simple; payment providers punish complexity.
Your application then bundles personal KYC for directors and shareholders, a business plan with 36‑month forecasts, and policy documents: AML/CFT, KYC, responsible gaming, privacy, and terms for players and affiliates. Add technical exhibits: RNG certificates (if you build your own content), third‑party game provider agreements, domain ownership, hosting/security architecture, and the appointment of a compliance officer. A focused, coherent pack shortens queries and keeps you within the marketed timeframes.
Typical timeline and sequencing
Most real‑world files run 4–10 weeks from “documents ready” to license issuance, depending on how quickly you answer regulator queries. Parallel‑track your integrations and banking. Incorporate or tidy your holding company in week 1–2. Finalize policy documents in week 2–3. Submit the license pack and field due‑diligence questions in week 3–6. Use weeks 4–8 to complete PSP onboarding, geo‑blocking, and game certifications. Only flip the marketing switch after your responsible gaming and complaints workflows are live.
Compliance requirements that actually matter on day one
Beyond the badge, what keeps you operating is governance. Your AML stack should include sanctions and PEP screening, risk scoring at onboarding, source‑of‑funds triggers on cumulative deposits, and transaction monitoring that flags patterns, not just thresholds. Keep a rapid escalation path to a human analyst and evidence every decision.
Responsible gaming should be visible and hard‑coded. Offer deposit, loss, and time limits, reality checks, time‑outs, and self‑exclusion across all devices. Build affordability and vulnerability logic early; if you only react to chargebacks and regulator complaints, you’re already late. For privacy, maintain a clean data map, reduce retention windows, and log admin access. For fairness, maintain current RNG certificates or signed attestations from your game suppliers plus change‑management controls.
Payment and banking reality check
Expect to start with high‑risk PSPs, EMIs, and crypto on‑/off‑ramps. Tier‑1 acquiring banks rarely underwrite a brand‑new Anjouan B2C. Stack redundancy: at least two card rails, one alternative method (local bank transfers, vouchers), and one crypto channel if your model allows it. Prepare a KYB pack that reads like a prospectus—license, opinions, compliance policies, processing forecasts, fraud controls, and marketing plan. Hold rolling reserves and monitor chargeback ratios weekly. Segregate player balances and operational funds; it’s both good governance and persuasive in PSP underwriting.
Tax, accounting, and where the money really lands
Promoters tout zero gaming tax on GGR, and you’ll often see claims of no corporate tax and no VAT locally. That can be true for offshore income under certain structures, but your tax reality is defined by where your company is resident, where management and control sit, and where your players are. Many countries levy indirect taxes on remote gambling or apply corporate income tax based on effective management. Align early with a cross‑border tax advisor, document board decision‑making, and avoid creating a taxable permanent establishment through on‑the‑ground staff, servers, or marketing agents.
Set up weekly reconciliation between platform data, PSP settlements, and general ledger. Use separate ledgers for player funds, bonuses, and operational cash. If you touch cards, assess PCI DSS scope. If you operate at scale, SOC 2 or ISO 27001 accelerates enterprise deals.
B2B vs B2C under the Anjouan banner
A B2C anjouan betting license is about player safety, fair play, and handling of funds. You’ll be judged on onboarding controls, dispute resolution, and your ability to shut down harm quickly. A B2B license, by contrast, is about supplying safe and tested technology. Expect a heavier emphasis on QA, RNG or game math certification, change control, uptime SLAs, and secure devops.
Contractually, push compliance downstream. If you are B2B, your operators must geo‑block and market lawfully. If you are B2C, your suppliers must notify you of material defects, provide audit logs, and maintain compliant RTP disclosure.
Market access and geo‑restrictions
A license is not a universal key. Sensible operators block high‑risk and strictly regulated countries from day one: the US, UK, much of the EU (including France, Germany, Netherlands, Spain, Austria), Australia, and any FATF‑blacklisted jurisdictions. Use hard geo‑IP blocks, payment filters, and marketing exclusions. Keep a living register of “do not market” countries and align affiliate contracts and CRM segments to it.
Where, then, can you operate? Many international and emerging markets accept offshore operators if you comply with consumer law, ad standards, and payments rules. Your acceptance by payment partners and affiliates will tell you more about practicality than any marketing brochure.
Red flags, myths, and how to avoid being burned
You may encounter multiple “authorities,” “boards,” or “exclusive agents” claiming to be the only authorized gatekeeper. Don’t take branding at face value. Ask for the enabling act or regulation, the current government instrument delegating licensing power, and the official license register. If you can’t verify the chain of authority from the Union to the island regulator, pause.
Two more myths: that an anjouan license immunizes you from foreign enforcement (it doesn’t) and that it guarantees Tier‑1 banking (it won’t). Also watch for “too fast to be true” application timelines that gloss over due diligence. The quickest path is still the path with clean documents, transparent ownership, and robust policies.
Player protection and dispute resolution signals
Regulators in light‑touch jurisdictions tend not to act as hands‑on ombudsmen. Earn trust yourself. Publish clear RTPs, T&Cs in plain English, and house rules that don’t weaponize bonus clauses. Offer a two‑tier complaint path: internal review with a 72‑hour SLA, then an independent ADR or mediation partner. Keep player funds segregated and disclose your method. These signals reduce churn, chargebacks, and forum drama—priceless for a young brand.
Cost drivers you can control
Most promoters highlight the headline license fee, but your real spend hides elsewhere. Compliance architecture (KYC tools, sanctions screening, monitoring), content (game providers and platform fees), payments (reserves, rolling fees, fraud tools), and security (WAF/CDN, DDoS, logging) dominate year one. Keep external counsel close for marketing reviews; one sloppy affiliate campaign can cost more than your entire license. Build for renewals: regulators like tidy reporting, and PSPs love clean MI packs.
A pragmatic go‑live checklist
- Geo‑blocking configured, tested, and tied to payment routing and CRM.
- AML/KYC live with sanctions/PEP, risk scoring, and documented escalations.
- Responsible gaming controls enforced across web and app; self‑exclusion honored globally.
- RNG certificates and supplier attestations current; change control documented.
- Complaints and ADR workflow in place; response templates pre‑approved by counsel.
- PSP stack diversified; reserves modeled; chargeback playbooks trained.
- Player funds segregation mechanism implemented and reconciled.
- Privacy notices, cookie banners, and data retention schedules deployed.
- Affiliate contracts aligned to geo rules, brand guidelines, and bonus terms.
- Board minutes, policies, and license documents compiled for audits and banking reviews.
A quick comparison to set expectations
| Factor | Anjouan | Curaçao (new model) | Malta |
|---|---|---|---|
| Speed to license | Fast (weeks if docs are clean) | Moderate (months) | Slow‑moderate (months) |
| Cost | Low‑moderate | Moderate | High |
| Market acceptance | Mixed; stronger in emerging markets | Improving | Strong in regulated markets |
| Banking/PSPs | High‑risk EMIs/PSPs first | Mid‑tier improving | Tier‑1 possible |
| Oversight depth | Light to mid | Mid | Heavy |
| Best fit | MVPs, expansions, B2B | Growth‑stage B2C/B2B | Mature B2C in regulated markets |
The table is not a value judgment; it’s a mapping tool. Choose the jurisdiction that matches your markets, capital, and brand ambitions—not the one with the shiniest brochure.
| Aspect | Summary | Operator takeaways | Risks and notes |
|---|---|---|---|
| What the Anjouan betting license is | A remote online gaming authorization marketed by Anjouan (island in the Union of the Comoros) for B2C and B2B iGaming. Often promoted as fast, affordable, and broad in scope. | Useful as an entry-level license for online casino, sports betting, poker, bingo, lotto, eSports, scratch cards, and provably fair/blockchain-based games under a single license. | Recognition varies. Some partners will accept it; others will not. Always verify acceptance with PSPs, banks, and affiliates before launch. |
| Jurisdiction and location | Anjouan (Ndzuwani) is one of the Comoros islands in the Indian Ocean. | You can apply remotely without a local office or local directors. | National rules and island frameworks can conflict. See “Legal basis and controversy.” |
| Regulator and administrators (claimed) | Marketed bodies include Anjouan Licensing Services Inc. (exclusive administrator), Anjouan Offshore Financial Authority (AOFA), Anjouan Gaming Board/Anjouan Betting and Gaming Board, and “Gaming Control Anjouan.” Some sites name Anjouan Corporate Services as an “authorized agent.” | Engage only with verifiable officials or vetted intermediaries. Request proof of mandate, sample license, and an independent legal opinion. | The Central Bank of the Comoros has publicly disavowed AOFA in finance contexts. This undermines trust. Names and websites may change. Do enhanced due diligence. |
| Legal basis and controversy | Service providers present a modernized online gambling regime for Anjouan. However, the 2024 FATF Mutual Evaluation for Comoros notes gambling is prohibited in the Comorian Penal Code at national level. The Central Bank has denied offshore licensing powers for similar island bodies. | Obtain a written legal memo on operability and enforceability. Treat the license as a commercial risk instrument, not a passport into regulated markets. | Expect scrutiny from counterparties. Perceived conflict between national law and island practice creates legal uncertainty and reputational risk. |
| License types | B2C license for operators; B2B license for suppliers/platforms. | Choose B2C if you take bets or handle player funds; B2B if you supply software, games, or platforms. | Some partners will still ask for stronger EU/UK licenses for B2B integrations. |
| Scope of activities | Single license marketed to cover most iGaming: casino (RNG and live), sports betting (pre-match/live/virtual), poker, bingo, lotto, eSports, scratch cards, “provably fair” and crypto games. | Good for diverse catalogs without multiple permits. | Confirm whether specific verticals (e.g., live dealer, jackpots, crypto) need extra testing or conditions. |
| Geographic reach | Promoted as “global.” You must still comply with each target country’s laws. Commonly cited blocked markets: Australia, Austria, Comoros, France, Germany, Netherlands, Spain, the UK, the USA, and FATF‑blacklisted countries. | Implement GEO‑IP blocking and market-by-market legal checks. Keep a documented restricted list. | Operating into restricted markets can trigger seizures, fines, PSP cut-offs, and domain blocks. |
| Taxes | Marketed benefits include 0% gaming tax on GGR, no corporate income tax, and no VAT at the jurisdiction level. | Plan tax residency and management location carefully. Consider transfer pricing and CFC rules. | You may still owe tax where you are managed, have staff, servers, customers, or marketing activity. Get tax advice. |
| Company setup | No need for a local entity; many providers accept foreign companies to hold the license. | Align corporate structure with banking, PSPs, and IP. Keep UBO information clean and current. | Some counterparties prefer the license holder and the merchant of record to be the same entity. |
| Application model | Heavily marketed as a streamlined, digital-first process with simple forms and guided onboarding. | Prepare a complete, neat package to avoid queries. | “Too easy” can be a red flag to banks and PSPs. Strong internal controls help. |
| Timelines (marketed) | Claims range from 10–15 business days to 4–6 weeks, 6–7 weeks, and up to 2–3 months depending on documents and checks. | Budget 4–8 weeks in practice if your documents are ready and clean. | Delays happen if due diligence triggers extra questions or if policies are weak. |
| Key personal KYC | Passport (notarized), proof of address (≤3 months), bank reference (≥2 years), professional reference (lawyer/accountant), CV, declaration of source of funds, sanctions and criminal checks. | Gather and certify early. Consistency across all documents is crucial. | Any adverse media, sanctions, or inconsistent funds trail may cause refusal. |
| Business documentation | Business plan (markets, product, 3‑year projections, structure), software description, supplier agreements, RNG/test reports, domain proof, policies: AML/CFT, KYC, Responsible Gambling, T&Cs, appointment of a compliance officer. | Use proven templates but customize to your model. Map player journeys to controls. | Missing or generic policies are a common reason for queries or refusal. |
| Compliance standards | AML/CFT controls, KYC risk tiers, affordability where needed, responsible gambling tools, fair play/testing, anti‑fraud, data security, transaction monitoring, dispute handling. | Build a control matrix. Document procedures and evidence logs. Train staff. | Weak compliance attracts PSP rejections and complaints escalation. |
| Crypto and “provably fair” | Marketed as acceptable under the single license if controls are in place. | Add blockchain risk policies, wallet screening, and on/off‑ramp KYC. | Some PSPs and ad networks restrict crypto gaming even if licensed. |
| Player protection and complaints | Marketing claims include formal dispute resolution. Independent reviews report slow or absent responses and weak oversight. | Publish a clear complaints process and response times. Consider an external ADR. | Poor dispute handling leads to reputational damage, chargebacks, and affiliate warnings. |
| Renewal | Marketed as a simple annual renewal, typically within about one month if compliant and fees are paid. | Track renewal deadlines, keep policies and ownership data current. | Non‑compliance or late fees can stall renewal and disrupt PSPs. |
| Fees and costs | Widely described as “accessible,” with clear, upfront pricing by service providers; lower setup and maintenance than EU regulators. | Get a written cost breakdown: license, renewal, testing, compliance, corporate, and PSP onboarding. | Very low fee offers or “guaranteed approval” are red flags. Validate inclusions and timelines. |
| Banking and payments | Acceptance varies by bank/PSP. High‑risk providers may onboard if controls are strong and markets are compliant. | Pre‑negotiate with 2–3 PSPs. Provide complete KYC, GEO‑blocking proof, and policies. | PSPs may drop merchants for complaints spikes or market breaches regardless of license. |
| Marketing and affiliates | Some networks accept Anjouan; premium networks may require MGA/UKGC or equivalent. | Maintain clear T&Cs, bonus rules, and ad compliance. Monitor affiliates. | Misleading ads or bonus abuse can trigger fines and partner bans. |
| Pros (operator view) | Fast time‑to‑market, single broad license, remote onboarding, lower cost, flexible corporate setup. | Good for testing MVPs, raising early revenue, or B2B credentials. | Plan an upgrade path to stricter licenses if targeting Tier‑1 markets. |
| Cons (operator view) | Legal uncertainty at the national level, mixed reputation, variable acceptance by PSPs and partners, potential weak enforcement. | Use it as a stepping stone, not a final destination for strict markets. | Expect enhanced due diligence from serious partners and app stores. |
| Who it suits | Startups validating product/markets, emerging‑market operators, B2B suppliers needing a formal licensing status. | Keep a tight restricted‑markets list and robust controls from day one. | Avoid targeting jurisdictions that require local licensing or explicit authorization. |
| Who should avoid | Brands focused on the UK, EU‑regulated states, USA, or other strict regimes. | If Tier‑1 access is essential, pursue local licenses (e.g., MGA, UKGC, state licenses). | Operating without the right local license risks criminal and regulatory action. |
| Operating without a license | Expect fines, seizure orders, civil/criminal action, site blocks, PSP blacklisting. | Keep at least one valid license plus legal opinions for each market. | Unlicensed activity can contaminate banking and ad accounts for years. |
| Practical compliance checklist | Legal opinions per target market; GEO‑IP blocking; age/ID checks; AML/KYC and RG policies live; fair‑play testing; clear bonus and withdrawal rules; SLAs for complaints; incident logs; staff training; restricted markets list; PSP A/B redundancy. | Demonstrate controls to PSPs and partners with screenshots, logs, and policy excerpts. | Keep evidence packs ready for audits and partner reviews. |
| Red flags to watch | “Guaranteed approval,” claims of banking rights via AOFA, offers to access restricted markets, no due diligence, no testing, refusal to name the actual issuing authority. | Walk away if you see these signs. | Regulatory names and websites can change; verify mandates directly and document it. |
| Typical timeline plan | Week 1–2: corporate setup and KYC. Week 2–4: policies, testing, application. Week 4–8: regulator review and queries. Week 6–10: issuance, PSP onboarding, soft launch. | Build a parallel PSP/KYC onboarding path to save time. | Add buffer for enhanced checks and policy rewrites. |
| Documentation quality tips | Keep documents recent, notarized where required, and consistent across names, addresses, and dates. | Use a single data room for regulators, banks, and PSPs. | Inconsistencies trigger delays and extra scrutiny. |
| Bottom line | Anjouan betting license can speed launch and reduce costs, but it carries legal and reputational uncertainty. | Validate authority, secure PSP acceptance, and comply with each target market. | Treat it as a stepping stone and manage risk with strong compliance and clear market boundaries. |