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Since Curaçao's LOK rewired offshore licensing in December 2024, Anjouan has become the permit of choice for low cost operators. Here is how suppliers, affiliates and payment companies check what they are contracting with, and what the data says about the operators behind those licences.
Key takeaways
- Register First: An Anjouan licence is issued under AOFA, supervised by the ABGB and administered by ALSI since May 2023, and should be confirmed with the administrator rather than read off a footer
- Disputed Status: The central bank of the Comoros does not recognise AOFA licences and the 2024 FATF evaluation records gambling as prohibited under the federal penal code
- Responsible Gambling Gap: None of the 77 Anjouan licensees reviewed by Gamblers Connect reach the Great or Exceptional RGI tier, against 17 of 22 UKGC licensees
- Second Licence Test: Operators serious about regulated markets pair the offshore permit with a UKGC, MGA, CGA or Kahnawake licence, and that pairing is the strongest signal in the file
Why offshore gambling licence checks moved up the B2B agenda
An offshore gambling licence used to be a footer detail that partners glanced at once. Curaçao's new gambling law, the Curaçao LOK, took force on 24 December 2024 and replaced the master licence and sub licence model that had run since 1993 with direct supervision by the Curaçao Gaming Authority. Hundreds of operators that had lived under sub licences faced new applications, new fees and new scrutiny, and a share of them looked for an alternative. Anjouan, an autonomous island in the Union of the Comoros, offered one: a single permit covering casino, sports betting, poker and crypto denominated wagering, processed in three to four weeks, at a fraction of the cost of a tier one licence.
That shift matters well beyond the operators themselves. Game studios decide which brands may carry their content and in which markets. Affiliates inherit the regulatory exposure of the programmes they promote. Payment companies onboard merchants whose licence class decides what acquiring banks will accept. For all of them, a counterparty's licence is no longer a footer detail. It is the first page of the due diligence file.
What an Anjouan gambling licence actually is
The issuing chain: AOFA, ABGB and ALSI
An AOFA licence, as the Anjouan gambling licence is formally known, is issued under the Anjouan Offshore Financial Authority (AOFA), the offshore financial regulator of the island. Gaming licensing is supervised by the Anjouan Betting and Gaming Board (ABGB), established by Anjouan's Computer Gaming Licensing Act 007 of 2005, and administered operationally by Anjouan Licensing Services Inc. (ALSI), set up in May 2023 as the sole authorised licence administrator. A genuine licence therefore names a company incorporated in Anjouan, carries a reference that ALSI can confirm, and shows a validity window, because licences run for one year and renew annually, with the renewal application due at least 60 days before expiry.
Term, renewal and cost
Cost is the commercial reason the licence exists. According to the fee schedule recorded by Gamblers Connect, an independent B2B iGaming media platform, the initial application package is about EUR 18,000, including the Key Person authorisation and the first year of the Licence Management Platform. Annual renewal is about EUR 13,300 plus EUR 828 for the platform, company registration in Anjouan about USD 3,900, and preparation of the compliance package about USD 3,000. ALSI has updated the schedule since the 2023 relaunch, so partners should ask for the current figures rather than rely on a licensing agent's brochure.
What the licence covers
One permit covers online casino, including live dealer, sports betting and exchanges, online poker, bingo and lottery style products, and cryptocurrency deposits, withdrawals and wagering. That breadth is attractive to crypto focused operators and is also why an Anjouan licence tells a partner little about product quality on its own: the same certificate sits above a disciplined operator and an opportunistic one.
The legal status every partner should read before signing
The framework operates in a disputed legal space, and the dispute is documented. The Banque Centrale des Comores, the federal central bank, has stated publicly that no offshore financial licences, including those issued by AOFA, are recognised under national law, on the basis that only the central bank can license financial institutions in the Union of the Comoros. The 2024 FATF mutual evaluation of the Comoros records that gambling is prohibited under the Comorian Penal Code, and on that basis FATF conducted no assessment of the gambling sector at all.
Anjouan's answer rests on its status as an autonomous island under the federal constitution and on the continued enforceability of its 2005 Act within the island. The two positions have not been reconciled. The Comoros was not on the FATF list of jurisdictions under increased monitoring as of 13 June 2025, but that reflects the national AML regime overall and does nothing to validate the offshore licences. For a partner, the practical reading is simple: a legitimate permit on the island's own terms, a disputed one at federal level, and a licence class that regulators in target markets treat as unlicensed for market access purposes.
What 77 reviewed Anjouan operators show
Gamblers Connect reviews operators by licence and scores each one on a 12 criteria Responsible Gambling Index covering policy, account history access, reality checks, self exclusion, underage prevention, ethical marketing, deposit, wagering, session and loss limits, self assessment and a budget calculator. As of November 2026 its directory held 77 Anjouan licensed operators, 77 of them running casino, 74 live dealer tables, 53 poker and 10 a sportsbook.
None of the 77 reached the Great or Exceptional tier. Thirty four scored Average, 33 Concern and 10 Poor. Among the 22 UK Gambling Commission licensees in the same directory, 17 scored Great or Exceptional; among 36 Malta Gaming Authority licensees, 25 did; among 175 Curaçao licensees, six. The licence does not cause that gap, but it predicts it, which is why the certificate should start the due diligence rather than end it. The Anjouan licensed casino reviews record, for each operator, the licence, the legal entity, secondary licences, AML programme, beneficial ownership transparency and dispute history, and negative findings are published rather than quietly dropped.
A six step gambling licence due diligence routine
1. Confirm the entity and the licence with the administrator
Match the legal entity in the contract to the entity on the licence, and confirm the licence with ALSI rather than with the operator. Brands change companies; licences do not travel with them.
2. Check the validity window
Record the issue and expiry dates. A licence inside its final 60 days with no renewal filed is a licence that may lapse mid contract.
3. Ask for the compliance evidence
The operating conditions give a partner something concrete to request: an Anjouan registered company, a Key Person who has passed ALSI's fitness and propriety review, a documented AML and CFT programme, KYC at registration and for material transactions, a live connection to the Licence Management Platform for reporting, and responsible gambling tooling at operator level. A certificate alone says nothing about whether any of it runs.
4. Look for a second licence
Operators with ambitions in regulated markets pair the offshore permit with a recognised one, most often the UKGC, the MGA, the Curaçao Gaming Authority, the Kahnawake Gaming Commission or Panama's JCJ. That pairing says more about the business than the Anjouan paper does.
5. Read the dispute and enforcement history
Complaint volumes, unresolved disputes and payment delays reported by customers and partners are the earliest signal of trouble, and they rarely appear on the operator's own site.
6. Price the licence class into the contract
Shorter payment terms, reserves or rolling settlement, audit rights and termination triggers tied to licence status are standard responses to a disputed permit, and they cost nothing to include at signature.
What happens next
Curaçao's transition is still under way and Anjouan's intake continues, so the population of operators holding only an offshore permit is growing rather than shrinking. Partners that verify once at onboarding and never again will be caught out by lapsed renewals and entity changes. An annual re check against the administrator, the operating conditions and the operator's own disclosures is the minimum, and the licence class belongs in every risk committee paper that mentions the counterparty.
Frequently asked questions
Is an Anjouan gambling licence legal?
It is a legitimate permit under Anjouan's Computer Gaming Licensing Act 007 of 2005, administered by ALSI since May 2023. At federal level the Comoros central bank does not recognise offshore licences and the Comorian Penal Code prohibits gambling, so partners treat it as a disputed offshore permit rather than a recognised one.
How much does an Anjouan licence cost?
According to the fee schedule recorded by Gamblers Connect, the initial package is about EUR 18,000, renewal about EUR 13,300 plus EUR 828 for the licence management platform, with company registration about USD 3,900 and document preparation about USD 3,000. ALSI has updated the schedule since 2023, so current figures should be confirmed directly.
What should a supplier check before contracting with an offshore licensee?
The legal entity against the licence, the validity window, evidence that the AML, KYC and responsible gambling conditions actually run, any second licence held, and the operator's dispute history. Of 77 Anjouan licensees reviewed by Gamblers Connect, 43 score Concern or Poor on responsible gambling, so the certificate alone is not enough.
Sources
- Anjouan Licensed Casino Reviews, licence framework, fees and legal status disclosure. Gamblers Connect, November 2026. https://gamblersconnect.com/casinos/anjouan/
- Curaçao Licensed Casino Reviews, LOK 2024 framework in force 24 December 2024. Gamblers Connect, November 2026. https://gamblersconnect.com/casinos/curacao/
- Responsible Gambling Index methodology, 12 criteria and five tiers. Gamblers Connect, 2026. https://gamblersconnect.com/responsible-gambling-index/
- Mutual Evaluation Report of the Union of the Comoros, 2024. FATF GAFI, 2024. https://www.fatf-gafi.org/
- Anjouan Computer Gaming Licensing Act 007 of 2005 and ALSI operating conditions, as recorded in the Gamblers Connect licence reference. Anjouan Betting and Gaming Board, 2005 and 2023.
Data in this article comes from the Gamblers Connect casino directory and demo catalogue as dated above and may be cited with attribution to Gamblers Connect.
- B.E. Delmer, Gambling911.com
