Anjouan Gambling Licence — Restricted Countries and Payment Realities 2026

Why Anjouan exists as an iGaming jurisdiction

Anjouan is one of three autonomous islands within the Union of the Comoros — a small archipelago nation in the Indian Ocean between Madagascar and Mozambique. Its gambling regime rests on two 2005 statutes: the Computer Gaming Licensing Act 007 of 2005, which established the Anjouan Betting & Gaming Board (ABGB), and the Money Laundering (Prevention) Act 008 of 2005, which sets the AML baseline. The Anjouan Offshore Finance Authority (AOFA) provides financial oversight, and Anjouan Licensing Services Inc. (ALSI) administers the regime. For nearly two decades, licensing volume was minimal.

Curaçao’s LOK reform changed everything. The LOK was adopted in 2023 and came into force on 24 December 2024, raising Curaçao’s substance bar and pushing its recurring cost to roughly EUR 47,450 a year for a B2C licence. Operators displaced by the increase needed an alternative, and Anjouan was positioned: ~EUR 17,828 application plus ~EUR 15,000 annual renewal (about a third of Curaçao’s recurring B2C cost), a fast 1-2 month timeline, minimal substance requirements, 0% taxes, and one licence covering both B2C and B2B activity.

Anjouan licensing volume grew rapidly through 2024 and 2025. Estimates from industry sources put the active Anjouan licensee count above 500 by mid-2026 — concentrated in crypto-payment iGaming and smaller operators serving emerging markets where Tier 1 reputation isn’t a requirement.

The restricted-country list — the most important detail

The single most important detail about an Anjouan licence is the restricted-country list. Anjouan licensees are prohibited from offering services to customers in a set of restricted jurisdictions. The list changes periodically — operators should verify the current list with the ABGB before targeting any specific customer geography.

The restricted jurisdictions:

• United States — federal law (UIGEA, Wire Act) plus state-by-state gambling regulation
• United Kingdom — UK Gambling Act 2005 requires UKGC licence for any operator serving UK customers
• France — ANJ (Autorité Nationale des Jeux) licensing requirement
• Germany — Gemeinsame Glücksspielbehörde der Länder (GGL) licensing requirement
• Netherlands — KSA (Kansspelautoriteit) licensing requirement
• Spain — DGOJ (Dirección General de Ordenación del Juego) licensing requirement
• Australia — Interactive Gambling Act 2001
• Austria — federal gambling-monopoly framework
• Comoros itself — the licence is offshore-only; no domestic offering
• FATF-blacklisted countries — excluded across the board

The list captures the bulk of regulated iGaming markets globally. Anjouan licensees can legitimately serve customers in unregulated emerging markets and a handful of regulated markets without local licensing requirements — but the addressable customer geography is materially narrower than operators sometimes assume.

Operators serving customers in restricted countries face two separate liability layers. The ABGB licence itself permits the activity from Anjouan’s perspective, so the operator isn’t violating Anjouan law. But the customer’s home-country law typically prohibits unlicensed gambling-service provision, exposing the operator to enforcement under that country’s laws — payment-processor cooperation requirements, ISP-blocking, criminal liability for executives, asset forfeiture.

Payment processing — even harder than Curaçao

The practical limitation that surprises Anjouan operators most is payment-processor acceptance. Even more restrictively than Curaçao, almost no tier-1 payment processors will serve Anjouan licensees.

Stripe — blacklisted. PayPal — blacklisted. Major Visa/MasterCard direct acquirers (Worldpay, Adyen, Checkout.com) — blacklisted. Most EU and UK processors — blacklisted.

Specialist offshore-friendly processors will sometimes serve Anjouan operators but at materially higher merchant fees: 8-12% per transaction versus 2-3% for Tier 1 jurisdiction-licensed operators. At realistic transaction volumes, this fee differential becomes the largest operating-cost line item — substantially exceeding the licence-fee savings.

Banking access is similarly restrictive. EU banks generally refuse Anjouan iGaming business accounts. UK banks restrictive. Most Caribbean correspondent banking now excludes Anjouan iGaming. The viable banking arrangements run through specialist providers: Bank Frick (Liechtenstein, but increasingly selective on Anjouan), Caribbean specialist providers, and a handful of Asian institutions willing to serve Anjouan licensees subject to enhanced due diligence.

For most Anjouan operators in practice, crypto-payment rails are the primary payment infrastructure. The licence works for crypto-deposit operators serving non-restricted markets. For fiat-payment operators, the banking and processor friction often makes Anjouan economics worse than the headline cost differential suggests.

When Anjouan makes sense

Despite the limitations, Anjouan has a real commercial use case in specific operator profiles.

Early-stage operators testing markets — operators in the first 6-12 months who want regulated status at minimal cost while validating product-market fit. Anjouan provides legal cover for operations into non-restricted markets at roughly EUR 15,000 a year after the first-year outlay of about EUR 33,000. Operators typically migrate to Curaçao or Tier 1 jurisdictions once revenue justifies the higher cost.

Crypto-payment operators serving emerging markets — operators whose customer base is concentrated in non-restricted emerging markets (parts of LATAM, Southeast Asia, Africa, parts of Eastern Europe) where Tier 1 reputational signal doesn’t drive customer acquisition. For crypto-deposit operators, the banking limitations matter less because crypto-payment rails are the primary infrastructure.

Existing operators with marginal volumes in non-restricted markets — operators with established business serving non-restricted markets where the simple Anjouan compliance overhead is preferable to Tier 1 substance investment. The single B2C+B2B licence also suits operators running a supplier arm alongside the casino, since post-LOK Curaçao would require two separate licences for the same footprint.

The use case Anjouan doesn’t serve: operators wanting EU customer access, UK customer access, US customer access, tier-1 payment-processor acceptance, institutional-grade reputational signal for fundraising, or B2B-supplier relationships with major iGaming platforms (most of whom require Tier 1 jurisdiction operating partners).

Migration path — from Anjouan to better licensing

The realistic Anjouan timeline for most operators is 18-36 months. Operators use Anjouan to establish operations and validate market fit, then migrate to a more substantive licence: Curaçao for crypto-focused operations, IoM or Malta for operators wanting Tier 1 reputation and broader market access.

The migration is not trivial. Tier 1 jurisdictions don’t accept Anjouan as prior-licence credit — applicants effectively start fresh on substance and reputational evaluation. Operators should plan the migration 6-9 months ahead of the target jurisdiction’s review timeline, with substance investment and key-person appointments completed in parallel with the application.

For operators choosing Anjouan in 2026, treat it as a transitional jurisdiction rather than a destination. The cost economics work for 12-24 months of early-stage operations. Beyond that, the payment-processing and reputational ceiling typically forces an upgrade.