Can Operators Still Rely on an Anjouan Licence? The Central Bank Warning, Registry Numbers and Alternatives

Anjouan is part of the Union of the Comoros. For operators holding or considering an Anjouan gambling licence, the issue now extends beyond application costs, processing times and certificate verification. They must consider how an express rejection at national level could affect their operating arrangements.

Our assessment is that this is a significant risk signal warranting renewed due diligence and contingency planning. The public evidence does not establish that courts have revoked every individual licence. Equally, the absence of a judgment is no assurance that a licence is legally sound or commercially usable.

What did the central bank actually warn about?

The notice signed by the Central Bank of the Comoros (BCC) on 8 December 2025 is not limited to offshore banking. It expressly includes online gambling and sports betting, stating that these activities are not authorised within the national territory and that no corresponding licences have been issued. It characterises conducting the listed activities under purported Comorian authorisations not issued by the BCC as fraudulent and warns of possible legal proceedings.[1]

This is the central bank’s official position, not market speculation. It is not an identified judgment revoking a particular licence, but it directly challenges the claimed basis of authorisation. Our research did not identify a judicial decision that conclusively resolves the division of authority between the island and the national government and removes this conflict.

Anjouan Gaming, meanwhile, claims authority under island legislation dating from 2005 and cites a private legal opinion in support of legality. That is the licensing system’s own position, not an independent judicial finding.[2] Neither side’s account, taken alone, resolves the substantive conflict.

On 19 October, the Guardian reported government plans for legal action and requests for UK assistance.[3]

How many licence holders are listed?

Our page-by-page review of Anjouan Gaming’s public register on 28 October 2026, at 13:29 Taiwan time, captured 1,251 licence records, with 1,251 distinct licence numbers and 1,250 distinct company names.[4] These figures describe the register. They do not represent 1,251 independently verified lawful operators, nor a count of websites or players.

All records displayed “Valid”, yet 68 carried expiry dates before the review date and another 22 showed expiry on that date. This discrepancy means the total cannot simply be described as the number of currently valid licences. Nor does the date discrepancy alone prove that the operators were acting unlawfully. Renewal and record-update status require case-specific verification. The register also warns that periodic updates may lag behind changes.[9]

The register demonstrates substantial use of the licensing system. It does not settle questions about licensing authority or access to a target market. Widespread adoption is not evidence that all legal and commercial risks have been resolved.

Four questions that require separate answers

First, does the national government recognise the claimed authorisation? This depends on the respective powers of the island and national authorities and the applicable law. A certificate or online verification result cannot answer it. Second, is the operator still complying with the licensing system’s own conditions, including renewal, anti-money laundering, responsible gambling and dispute-handling obligations? Uncertainty over the first question does not make the second disappear.

Third, is the service permitted where its players are located? An offshore licence is not a worldwide passport. For example, serving consumers in Great Britain through remote gambling requires operators to address local licensing requirements even if they are based overseas.[5] Fourth, will banks, payment service providers, game suppliers and other counterparties accept the operating structure? Their risk policies and contractual terms create a separate set of requirements.

A licence appearing in a register, an issuer describing it as valid, and an operator being able to serve customers and receive payments reliably in a particular country are three different propositions.

How could these issues translate into operating costs?

Operational consequences need not wait for a court ruling. Counterparties may request further documentation, reassess the basis of authorisation, restrict services or revise arrangements under their contracts. These are plausible risk scenarios, not findings that widespread payment suspensions, account closures or licence revocations have occurred.

Broad assurances of complete legality in contracts or on websites may also create risks if they exceed the actual scope of authorisation. Renewal spending should be considered alongside the timetable for contingency arrangements. Complaints and alternative dispute resolution (ADR) procedures still need to be handled as agreed, but those processes do not replace market authorisation or resolve the underlying authority dispute.

Operators should identify which payment arrangements, game content and technical services depend on the existing licence, then review contractual provisions on regulatory changes, termination, notice and data migration. They should also preserve records of player balances, unresolved complaints and transactions, and assess obligations that would continue during a service interruption. Changing licences does not mean leaving existing responsibilities behind.

For existing operators, our preferred sequence is to map these dependencies, obtain counterparties’ requirements in writing and then develop a workable alternative. New entrants should clarify their target markets and key counterparties’ acceptance criteria before investing in websites, payment integrations and marketing. This gives a more realistic picture of total cost than application fees alone.

Which alternatives merit consideration?

The choice should start with player markets, products and operational capabilities, rather than a search for another inexpensive certificate. The following routes merit further assessment. None is necessarily suitable for a particular operator, and obtaining a licence does not guarantee access to a bank account or payment services.

Route	What to assess	Key requirements
Curaçao	A CGA licence under the current LOK framework	Local company and management arrangements; not the former sublicensing model.[6]
Malta	An MGA B2C remote gaming licence	An EU/EEA entity, ongoing compliance and operational-substance costs. The fixed annual fee is not the total cost.[7]
Isle of Man	A route for operators able to establish a real operational presence	Local company, directors and operational management arrangements, rather than a certificate change alone.[8]
Target-market licensing	Operators with a defined core market that justifies long-term investment	Requirements depend on country, product and customers. In Great Britain, being established overseas does not remove local licensing requirements.[5]

The useful decision now is not to declare all Anjouan licences invalid or entirely unproblematic. It is to examine the legal basis, target markets, counterparty acceptance and transition costs separately. Whether an operator can maintain a verifiable, sustainable business is the question that should guide its licensing choice.