Anjouan pushes back on offshore licence criticism

• Anjouan Gaming has issued a public statement drawing a distinction between its licensing framework and the conduct of individual operators.
• The statement comes amid ongoing industry debate about black market, grey market and offshore gambling.
• A 2024 FATF report finding that gambling is prohibited under Comorian law remains unaddressed by the authority.

Anjouan Gaming has issued a public defence of its internet gaming licence framework, pushing back against what it describes as commentary that conflates offshore licensing with local market authorisation.

The statement, published on LinkedIn on 10 June, does not name specific examples of the commentary it addresses. Anjouan is, however, frequently referenced in industry discussions about black market and offshore gambling, including by international regulators and operators in licensed markets.

One recent example is the controversy over Relax Gaming, the B2B subsidiary of FDJ United, which obtained an Anjouan licence in November 2025, prompting criticism from industry observers and a front-page investigation by French newspaper Le Monde.

Operator vs framework

Anjouan Gaming’s statement draws a clear line between the legal basis on which a licence is issued and the compliance obligations of individual operators. The authority says its framework covers AML and KYC requirements, responsible gambling obligations, technical standards, complaint handling and domain approvals, and that enforcement powers including licence suspension and revocation are available.

The post identifies several issues it says critics have conflated: the administrative basis of the licence, its scope, ongoing obligations on licensees, a specific operator’s compliance status, and the responsibility of each operator to comply with local law in every market where they operate.

Anjouan Gaming said:

“An Anjouan Internet Gaming Licence is not, and has never been presented as, a universal authorization to operate in every country in the world. No licensing authority can exempt an operator from local law in jurisdictions where local authorization is required.”

Legal questions persist

The statement is unlikely to resolve the central legal question surrounding the jurisdiction. A 2024 report by the Financial Action Task Force stated that gambling is prohibited under the Comorian Penal Code, listing it among activities not permitted by law. The FATF consequently did not conduct any AML/CFT assessment specific to the gambling sector.

The Central Bank of the Comoros has also repeatedly stated that it does not recognise the Anjouan Offshore Financial Authority, which issues gambling licences, and has warned against what it describes as unauthorised offshore activity.

Anjouan has been among the beneficiaries of regulatory upheaval elsewhere. Its rise as a licensing hub has been accelerated by uncertainty stemming from Curaçao’s overhaul and pressure on Malta from EU member states seeking to restrict operators from targeting their citizens without local licences.

As of July 2025, Anjouan Gaming requires all B2B providers working with its licensed operators to hold either a local B2B licence or an approved B2B Licence Recognition Certificate, at an annual fee of €9,500.

What it means

Anjouan Gaming says it welcomes comparative analysis and constructive criticism, and that its framework is designed to be practical, transparent and commercially accessible.

It points to its due diligence requirements, including corporate reviews, key person assessments, financial vetting, and screening against sanctions lists, PEP databases and adverse media, and directs stakeholders to its public register and official channels for licence verification.

The authority says it considers unhelpful any commentary that treats operator misconduct as evidence against an entire licensing framework. That position will face continued pressure as regulators in major markets scrutinise the supply chains of operators holding offshore licences alongside Tier 1 authorisations.

For B2B suppliers and operators weighing entry into the jurisdiction, the statement reinforces one core point: the licence creates obligations, but market-by-market legal exposure remains entirely with the licensee.