🏝️Why are gambling start-ups turning to Anjouan for licensing?

📜 Regulatory Foundation and Legal Framework

The Anjouan gaming licence is governed under the laws of the Union of the Comoros, specifically the Anjouan Offshore Finance Authority (AOFA), which acts as the principal regulatory body. The framework was restructured in 2005 and most recently revised in 2023, aiming to meet international compliance standards, particularly concerning anti-money laundering (AML), countering the financing of terrorism (CFT), and responsible gambling.

Anjouan’s legal regime permits licensing for a wide range of activities including sports betting, casino games, lottery, poker, and skill-based games, all under a single B2C or B2B licence. The regulator requires essential internal policies for AML/CFT, Know Your Customer (KYC), and player protection to be embedded within operators’ internal compliance programmes.

Operators must maintain technical servers that allow for periodic audits and data accessibility by the regulator. Although the jurisdiction does not yet have Mutual Evaluation Reports by FATF, Anjouan authorities have actively aligned their practices with standards echoed in FATF Recommendations and EU 5AMLD principles, particularly for operators targeting European markets.

In contrast to jurisdictions that impose burdensome capital requirements and lengthier licensing timelines, Anjouan offers a 2–4 week licensing process, low setup costs, and fewer bureaucratic obstacles. However, compliance obligations remain formally in place to avoid reputational risks and access issues with payment providers.

The licence is issued to international companies, which may be incorporated in Anjouan or other acceptable jurisdictions. Although not white-listed by the UK Gambling Commission or MGA, Anjouan’s licence can act as a strategic intermediary licence to test markets or attract investor attention prior to moving to Tier-1 jurisdictions.

⚖️ Strategic Positioning and Comparative Analysis

Compared to Curacao, Belize, and Kahnawake, the Anjouan licence has recently outpaced several offshore jurisdictions in appeal, particularly due to regulatory modernisation, simplified application procedures, and cost-effectiveness. While Curacao remains the most well-known offshore licence, its reform process under the new LOK law has led to higher barriers for new operators. Belize, although reputable in the past, has become practically inaccessible for new applicants due to a licensing freeze. Kahnawake maintains a good reputation but is geographically restrictive and requires a physical presence.

Anjouan, by contrast, does not impose local staffing requirements or office space, though substance obligations may arise depending on the chosen corporate structure. The licence also includes both B2C and B2B permissions, unlike Curacao where two separate entities are often required.

In terms of cost, Anjouan remains one of the most affordable options globally, with government licensing fees typically under $20,000 annually, including application and first-year maintenance. In addition, its rapid processing time allows start-ups to launch operations quickly and adjust their strategy in real-time with minimal sunk costs.

The transparency of the AOFA has improved significantly, and licensed entities are now published on an official registry. While the jurisdiction is not suitable for operators targeting regulated markets like the UK, Sweden, or the Netherlands, it is functional for acquiring traffic in LATAM, Asia, Africa, and permissive grey jurisdictions within the EU.

💼 Practical Applications and Case Relevance

Numerous gambling start-ups and mid-tier B2B platform providers have used the Anjouan licence as a launchpad while preparing applications in higher-tier jurisdictions. For instance, several Estonian and Cypriot operators with EU corporate structures have opted for Anjouan as a transitional licence to prove concept, attract partners, and demonstrate compliance capacity in fundraising rounds.

Moreover, white-label operators and aggregators increasingly seek Anjouan-licensed providers for business continuity, especially when targeting less regulated markets. Operators in regions like India and LATAM have found payment processing significantly more stable when supported by a recognised offshore licence compared to operating entirely unlicensed.

Recent changes to payment gateway requirements across Europe have also made it increasingly difficult to process funds without a legal licence of any kind. Although Anjouan does not hold EU equivalency, the licence enables operators to open offshore merchant accounts, secure processing partners in crypto and fiat, and provide verifiable evidence of regulated activity to third parties.

While there are inherent limitations - such as the absence of formal treaties with Western regulators - the jurisdiction has proved viable for risk-tolerant projects. For start-ups operating in soft-launch mode or targeting non-restricted regions, Anjouan provides a legally viable and commercially strategic route with acceptable legal risk.

🎯 Conclusion

The Anjouan licence offers an efficient, affordable, and legally structured entry point for gambling start-ups and early-stage operators. While it is not suitable for every business model, it remains a practical solution for market testing, investor engagement, and early revenue generation in non-restricted markets. With clear licensing standards, a developing compliance regime, and increased regulator transparency, it stands as a viable alternative among offshore jurisdictions.

If your gambling venture is considering Anjouan or any other licensing path, our firm provides tailored legal support to evaluate and structure your application. Contact NUR Legal for strategic regulatory assistance, jurisdiction comparison, and full-service licensing support in the gambling and fintech sectors.

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