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 Offshore Financial Authority (AOFA), 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 to issue and the same again each year, which is closer to a third of Curaçao’s recurring B2C cost than to the quarter often claimed, a fast one to two month timeline, minimal substance requirements and no gaming tax. B2C and B2B are separate categories, not one licence covering both.

Anjouan licensing volume grew quickly through 2024 and 2025, concentrated in crypto-payment operators and smaller books serving emerging markets where a Tier 1 signal is not what wins customers. We do not publish a licensee count: the Authority does not publish one, and the figures in circulation trace to industry estimates we cannot check against the register.

There is no restricted-country list, and that is the important detail

The single most important thing about market access under an Anjouan licence is that the Authority does not decide it for you. Its published position is that licences contain no territorial restrictions under Anjouan law, that an Anjouan licence does not override local prohibitions or regulatory requirements, and that operators remain solely responsible for geo-blocking, market access controls and local compliance.

Read that carefully, because it is the opposite of reassuring. A blacklist would at least tell you where the edges are. Instead the licence is silent on geography and every boundary comes from somewhere else: the conditions attached to your own licence, the gambling law of each market you target, sanctions and financial-crime exposure, and the risk appetite of the banks, payment providers and suppliers you depend on. Markets that license gambling locally, which includes the United States, the United Kingdom, France, Germany, the Netherlands, Spain, Australia and Austria, are closed to you as an Anjouan licensee because their law requires their licence. That is a conclusion from their law, not from a list Anjouan hands out.

Which markets those are, and why each is closed, is worth being precise about, because none of it comes from Anjouan.

The United States licenses gambling federally and state by state. The United Kingdom requires a Gambling Commission licence for anyone serving British customers. France requires authorisation from the Autorité Nationale des Jeux, Germany from the Gemeinsame Glücksspielbehörde der Länder, the Netherlands from the Kansspelautoriteit and Spain from the Dirección General de Ordenación del Juego. Australia’s Interactive Gambling Act restricts the offering, and Austria runs a monopoly framework. Between them those markets are most of the regulated iGaming world.

Sanctions and financial-crime exposure narrow the map further, independently of gambling law and regardless of any licence.

The liability point follows from the same logic. An Anjouan licence permits the activity from Anjouan’s perspective, so serving a prohibited market is not a breach of Anjouan law. It is exposure under the other country’s law, which is where enforcement actually lands: payment-provider cooperation, site blocking, personal liability for executives, asset forfeiture. The licence you hold offers nothing against any of it.

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.

Advisers report that for most Anjouan operators crypto-payment rails end up as the primary payment infrastructure, which we carry as reported rather than measured. 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 costs EUR 17,828 to issue and EUR 17,828 in each following year, with EUR 500 for every additional domain on a B2C licence. 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 markets that do not license gambling locally (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. One caution for anyone running a supplier arm alongside the casino: B2C and B2B are separate categories in Anjouan at EUR 17,828 each, exactly as in post-LOK Curaçao, so that footprint costs two licences in either jurisdiction.

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

Advisers describe Anjouan as a staging post rather than a destination, with operators moving on once revenue justifies a heavier licence: Curaçao for crypto-focused operations, the Isle of Man or Malta for a Tier 1 signal and broader market access. We have seen no published data on how long operators actually stay, so we are not going to print a figure for it.

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 suit early-stage operations. Past that point the payment-processing and reputational ceiling is what usually forces the upgrade, rather than the licence fee.