Anjouan Gambling Licensing Faces Questions Over Regulatory Authority

International Investigations Raise Questions Over Anjouan Gambling Licensing

On 19 October 2026, The Guardian published an investigation into an offshore gambling licensing network operating under the name of Anjouan, an autonomous island within the Union of the Comoros.

The investigation examined the activities of companies and intermediaries linked to the issuance of offshore gambling licences, alongside statements from Comorian authorities challenging the legitimacy of certain organisations claiming regulatory powers.

According to The Guardian, the public register of the Anjouan Gaming Authority lists nearly 1,500 gaming licence holders, many of them specialising in crypto gambling.

The newspaper reported that a spokesperson for the Central Bank of the Comoros described the licensing regime as illegal activity by persons abusing the name of the Comoros to gain an appearance of legitimacy, and as a serious concern for the country’s efforts to strengthen its safeguards against money laundering and terrorist financing.

The Guardian also reported that Comorian authorities were preparing judicial action and had sought international cooperation, including assistance from British government and law enforcement agencies.

The investigation followed earlier reporting into Anjouan's offshore licensing arrangements.

On 31 December 2025, Australia's ABC News published an investigation questioning the legal standing of organisations issuing financial and gambling licences under Anjouan's name.

On 4 February 2026, France's Le Monde, in collaboration with CasinoZorgplicht.nl, examined the Anjouan B2B gaming licence held by a major software supplier.

Although the investigations focused on different aspects of the offshore gambling industry, they raised overlapping questions about the legal foundations of Anjouan's licensing arrangements, the organisations administering them and the extent of regulatory oversight.

The Central Bank of the Comoros Issues an Official Warning

An important development was the official warning issued by the Central Bank of the Comoros on 8 December 2025.

In its statement, the Central Bank identified several entities, including the Anjouan Offshore Finance Authority (AOFA), also referred to as the Anjouan Offshore Financial Authority, and Anjouan Corporate Services, which it said were not recognised by the Union of the Comoros and lacked legal authorisation to issue financial or banking licences.

The Central Bank also stated that certain activities were not authorised within the national territory and that no corresponding licences had been issued. The activities specifically identified included those described as Online Betting, Gaming, Gambling Licenses. The Central Bank added that any claim to carry on these activities under a Comorian licence not issued by it is fraudulent and exposes those concerned to prosecution.

The statement warned individuals, businesses and financial institutions about the risks of dealing with the entities concerned or relying on licences issued under their authority.

The Central Bank further indicated that it intended to pursue appropriate legal procedures against the entities involved, in accordance with the applicable legislation.

However, an important legal distinction must be maintained.

The Central Bank’s direct supervisory competence concerns banking and financial activities, although its communiqué expressly lists online gambling licences among the activities for which, it states, no licence has been issued in the Comoros. The communiqué is an official warning rather than a judicial determination, and it does not, by itself, constitute a court finding invalidating every offshore gambling licence issued under Anjouan’s licensing framework.

Nevertheless, the warning represents a formal challenge by a national authority to the legal standing of organisations associated with Anjouan's offshore licensing arrangements.

What Is the Legal Basis for Anjouan Gambling Licences?

Anjouan's offshore gambling licensing model is primarily directed at international operators providing online gaming services outside the Comoros.

Under such arrangements, the operating company is typically incorporated elsewhere. The Guardian noted that Anjouan's public licensing register lists company names, including entities incorporated in Panama, Belize and Costa Rica, but does not, by itself, identify the individuals who ultimately own or control them. Incorporation outside Anjouan does not, in itself, establish that a licensing arrangement is unlawful.

The central legal issue is therefore not where the operator is incorporated, or whether gambling is permitted for local residents, but whether the organisation issuing the international licence has the necessary legal authority to do so.

According to the legal framework published by Anjouan Gaming, its licensing system is based on legislation adopted by the Autonomous Island of Anjouan in 2005.

The principal instruments cited by the organisation include the Anjouan Computer Gaming Licensing Act 2005 and the Anjouan Offshore Finance Authority Act 2005.

Anjouan Gaming identifies AOFA as the competent authority for offshore financial and gaming activities. It also states that Anjouan Licensing Services Inc. serves as the sole authorised licence administrator for the Anjouan Gaming Board.

The organisation maintains that its licensing framework remains legally valid under Anjouan and Union of the Comoros law.

It further refers to an independent legal opinion dated 19 September 2024, reportedly reconfirmed in February 2026, supporting the lawful status of AOFA and the validity of Internet Gaming Licences issued under the 2005 legislation.

However, the full text of that opinion and the legal reasoning supporting its conclusions were not independently available for examination among the public materials reviewed by GCA.

As a result, a significant distinction remains between the legal authority claimed by Anjouan's licensing organisations and the position expressed by Comorian national authorities.

Determining the legal standing of the offshore gambling licensing framework would require examination of the continuing validity of the relevant 2005 legislation, the constitutional division of powers between the Union and the autonomous island, and the legal status of the organisations responsible for administering licences.

Why Regulatory Uncertainty Matters for Operators and B2B Suppliers

For international iGaming businesses, a gambling licence is not merely an administrative document. It can form an important part of the operator's wider legal, commercial and compliance framework. An analyst at Eilers & Krejcik Gaming told The Guardian that such a licence gives players a degree of reassurance and makes banks, payment providers and other commercial partners more comfortable doing business with licensees.

Banks, payment service providers (PSPs), gaming software suppliers, platform providers and other counterparties may consider an operator's licensing arrangements when conducting KYB checks, AML/CFT due diligence and regulatory risk assessments.

Where the legal authority of a licensing body is publicly challenged by national authorities, businesses relying on that licence may face additional scrutiny concerning the legal certainty of the underlying framework.

This question is particularly relevant to B2B suppliers providing gaming content, technology or platform services to operators holding Anjouan licences.

Such suppliers may need to assess not only whether their counterparties hold licences, but also whether those licences are issued under a legally established and enforceable regulatory framework.

Two separate legal questions must nevertheless be distinguished.

The first concerns the authority of the offshore licensing body and the validity of the licence it issues.

The second concerns whether a licensed operator is permitted to provide gambling services to customers in a particular destination market. The second question is governed by the law of each destination market and applies to licences of every jurisdiction: no licence by itself carries a right to serve players where local law requires separate authorisation or prohibits the activity.

Anjouan Gaming itself acknowledges this distinction. Its published regulatory position states that licence holders remain responsible for complying with the laws of the jurisdictions in which they operate, including market access restrictions and geo-blocking requirements.

The current questions surrounding Anjouan therefore concern the legal foundations of its specific licensing arrangements rather than the legitimacy of international gambling licensing as a business model.

Potential Legal Implications

According to The Guardian's investigation of 19 October 2026, Comorian authorities were preparing judicial action in connection with allegedly unauthorised licensing activities.

If formal proceedings are initiated, their implications for the international iGaming industry will depend on the scope of the claims, the jurisdiction of the relevant court and the legal findings ultimately reached.

Such proceedings could address the activities of particular intermediaries, the authority of specific licensing organisations or potentially broader questions concerning the legal foundations of Anjouan's offshore licensing framework.

These outcomes should not be treated as interchangeable.

A finding concerning the conduct of an individual intermediary would not necessarily determine the legal status of the entire licensing system. Equally, an adverse determination concerning the authority of a licensing body could raise wider questions about licences issued under its name.

As of 23 October 2026, GCA has not identified a verified final court ruling declaring Anjouan's entire gambling licensing framework invalid.

The available official statements and international investigations therefore establish the existence of a significant dispute concerning regulatory authority, rather than a conclusive judicial determination of the status of every licence issued under the framework.

Our Take

The questions surrounding Anjouan's gambling licensing arrangements extend beyond the activities of individual offshore intermediaries.

Official warnings from Comorian authorities and investigations by international media have brought renewed attention to a more fundamental issue: the legal basis and regulatory authority of the organisations issuing international gambling licences under Anjouan's name.

Although the validity of the licensing framework has not been conclusively determined by a verified final court ruling, the apparent divergence between the positions of national authorities and Anjouan's licensing organisations creates material regulatory uncertainty.

For international operators, B2B suppliers and payment partners, such uncertainty represents a regulatory and commercial risk that warrants consideration independently of the jurisdiction's commercial attractiveness.

The central question facing Anjouan's gambling licensing framework is not whether its licences are commercially attractive, but whether the issuing authorities can demonstrate a clear, legally established and continuing basis for their regulatory powers.