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The Pre-Regulated Playing Field: An In-Depth Look at Anjouan’s Online Gambling Jurisdiction in 2024

We delve into existing and emerging grey market licensing jurisdictions to compare what they offer to the online gambling industry. This week, we turn our focus to Anjouan.

The Pre-Regulated Playing Field: An In-Depth Look at Anjouan’s Online Gambling Jurisdiction in 2024

We explore various jurisdictions from Curacao to Kahnawake and Tobique, presenting essential facts and analyzing the pros and cons of each based on our extensive expertise, industry feedback, and decades of experience. This installment examines one of the newer players vying for business: Anjouan.


What & Where is Anjouan?

Anjouan is an autonomous volcanic island in the southwestern Indian Ocean, situated off the east coast of Africa between Mozambique and Madagascar. As one of the three main islands comprising the country of Comoros, it has a population of around 360,000, mostly residing in the capital city of Mutsamudu.


The current egaming legislation is called the Computer Gaming Licensing Act 007 of 2005. Although the jurisdiction has been established for some time, it has only recently been heavily marketed, particularly in response to changes in Curacao.


What Licenses Does Anjouan Offer?

Anjouan offers a “comprehensive” license covering B2C and B2B operations, as well as various verticals including casino, sports betting, poker, and lottery. White labeling is permitted, but sub-licensing is not. The jurisdiction mandates local data replication as part of the license fee. A Key Person, akin to the Designated Official in the Isle of Man, is included in the licensing process, with the option to add additional Key Persons at a cost, as well as additional URLs (only two website addresses are included per license).


Applicants must undergo a reasonably strict due diligence process, pass a compliance check, and provide various policies demonstrating adherence to regulations. While not as stringent as some other jurisdictions, the licensing due diligence requirements are sufficiently rigorous to ensure only suitable applicants are approved.


Cost & Taxes

The total cost of obtaining a license, including initial setup fees and required ISP service for compliance backups, is EUR 17,000 ($18,500). Additional Key Persons can be added for EUR 2,000 ($2,150) each. Notably, there is no gaming tax.


Targeted Countries

Anjouan currently restricts or prohibits several territories, requiring that they must be GEO IP blocked. These include Australia, Austria, Comoros, France, Germany, Netherlands, Spain, United Kingdom, USA, all FATF blacklisted countries, and any other jurisdictions deemed prohibited by the Anjouan Gaming Board and Offshore Financial Authority.


Licensees must conduct due diligence before accepting and registering players from any territory to ensure compliance with local laws. This guidance aligns with practices in other jurisdictions.


Processing Time

The processing time for obtaining an Anjouan online gambling license is currently two to three weeks, making it one of the quickest licenses to obtain. With additional time for preparing the required paperwork, the entire process can feasibly be completed in as little as two to three months.

Cyprus Gaming License


Company Presence

The Anjouan regulator does not require the gaming company to be based on the island. Businesses can choose a company in other jurisdictions to apply for the license. There is an option to register an Anjouan International Business Corporation on the island as part of the licensing process, currently priced at around $4,000. Local data backup is required but included in the license fee.


Travel Requirements

There is no requirement for license applicants to travel to Anjouan, as licenses are administered off-island.


Banking and Payment Services

Generally, banking and payment services are accessible. Anjouan is viewed similarly to the old Curacao, meaning companies can engage with certain PSPs and banks. However, in some cases, it might be necessary to engage with payment partners through a separate entity, depending on where the licensed company is based. This process will be familiar to those who have held a Curacao license in the past.


Acceptance by Suppliers and Third Parties

Anjouan licenses are generally accepted by many software suppliers to satisfy compliance requirements. However, acceptance varies from company to company, so it is recommended to verify before applying for an Anjouan license. Given the recent popularity of the license and minimal negative feedback, it appears to be on par with Curacao from previous years.


Pros and Cons Summary

Anjouan is positioning itself as the new Curacao, offering quick and convenient licenses at a reasonable cost. Although the gaming legislation has been in place since 2005, Anjouan is relatively new to the grey market licensing scene. Its popularity has surged following changes in other jurisdictions like Curacao, and its future growth remains to be seen.


The quick turnaround time and relatively low cost are appealing to companies, particularly smaller operators and startups. However, the underlying legislation may seem lightweight compared to other jurisdictions, potentially causing concerns for compliance departments.

Global compliance requirements are becoming increasingly stringent, often driven more by banks and payment providers than gaming regulators. Currently, obtaining payments with an Anjouan license seems feasible, making it an attractive and cost-effective option. However, its long-term credibility and suitability in the market are yet to be determined, especially as other jurisdictions enter the game.



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