Anjouan offshore licences face growing international scrutiny

At first sight, Anjouan presents itself as an attractive offshore destination for financial and gambling businesses seeking fast market entry and low operating costs. The small island, part of the Union of the Comoros, is frequently marketed online as a jurisdiction offering corporate licences with minimal bureaucracy, low or zero taxation and rapid approval timelines. For some operators, these features appear to offer a convenient alternative to more tightly regulated jurisdictions.

However, behind this outward simplicity lies a licensing structure that has drawn sustained concern from public authorities within the Comoros and increasing attention from regulators abroad. Official statements from Comorian institutions have repeatedly questioned the legal standing of offshore regulators claiming authority in Anjouan. These warnings raise serious doubts about the validity of licences sold under the island’s name and the protections such documents are purported to provide.

This article examines how Anjouan’s offshore licensing ecosystem developed, why it lacks recognised legal authority and how it has become associated with high-risk financial and gambling activities. The focus is on documented regulatory positions and publicly available statements, avoiding speculation or personal allegations.

Anjouan’s political and legal background

Anjouan is one of three islands that form the Union of the Comoros, a sovereign state located off the east coast of Africa. While the islands enjoy a degree of autonomy, authority over monetary policy, banking regulation and international legal recognition rests with federal institutions of the Comorian state.

During the late 1990s, the Comoros experienced a period of political instability. In 1997, Anjouan declared independence from the Union, a move that was not recognised internationally. During this separatist phase, local authorities attempted to establish independent institutions, including bodies presented as offshore financial regulators.

One such body was the Anjouan Offshore Finance Authority, commonly referred to as AOFA. It was created during a time when Anjouan lacked recognised sovereignty and when its legislative acts had no standing beyond the island itself. From its inception, the regulator faced questions about its legitimacy.

Following international mediation, Anjouan rejoined the Union of the Comoros. Subsequent banking and financial legislation enacted at the federal level explicitly removed any remaining authority from offshore bodies established during the separatist period. These laws clarified that licensing of banks, insurers and similar entities fell solely under nationally recognised institutions.

Despite these developments, offshore licensing activities associated with Anjouan did not cease.

Continued use of dissolved regulatory frameworks

Although AOFA was formally stripped of recognition under Comorian law, entities claiming to act under its authority have continued to operate online. Publicly accessible registers list dozens of banks, brokers, insurance firms and gambling operators as “licensed” in Anjouan.

Comorian authorities have addressed this issue on multiple occasions. The Central Bank of the Comoros has issued statements describing certain offshore regulators linked to Anjouan as having no legal or physical existence within the Union. Officials have characterised these structures as fictitious and warned that any licences issued under their name do not carry legal effect.

One central bank official stated in 2020 that these entities “have in reality no physical or legal existence in the territory of the Union of the Comoros” and added that “they operate online via websites to scam people.” This statement reflects an institutional position rather than a judicial finding and serves as a formal warning rather than an accusation against individual license holders.

Despite these warnings, licensing activity has reportedly continued at scale.

A business model built on regulatory ambiguity

The persistence of Anjouan-branded licences appears to be driven by commercial incentives rather than legal recognition. Licensing fees are relatively low compared to established jurisdictions. Approval processes are advertised as taking days rather than months. Ongoing compliance obligations are presented as minimal.

For operators facing rejection or delay elsewhere, such conditions can appear appealing. However, the absence of recognised oversight also means that licence holders may receive no meaningful regulatory supervision, consumer protection requirements or enforcement standards.

From a legal perspective, such licences offer limited value. While they may provide the appearance of regulatory approval, they do not substitute for authorisation in jurisdictions where operators actively target customers. This distinction has become increasingly relevant as national regulators tighten enforcement against unlicensed cross-border activity.

Gambling operators and international exposure

Online gambling platforms have been among the most visible users of Anjouan-linked licences. Several casinos openly display such licences on their websites, presenting them as proof of legitimacy. In practice, this has not prevented enforcement action in countries where those operators lack domestic authorisation.

One example is Leon Casino, which prominently references its Anjouan licence. In early 2025, Australian authorities identified Leon as operating illegally in Australia. The platform does not hold an Australian gambling licence and offers products prohibited under Australian law, including online slot machines, blackjack and in-play sports betting.

Despite this, Leon has engaged in marketing activities that included sponsorships and influencer promotions linked to Australia. There is no indication that sponsored individuals were aware of the platform’s regulatory status at the time. Nevertheless, the case illustrates how Anjouan-branded licences can be used to create a veneer of legitimacy without providing actual legal clearance.

Even after regulatory warnings, Leon reportedly continued to make Australian-specific payment options available. This highlights a broader issue: an Anjouan licence does not appear to impose meaningful restrictions on where or how operators solicit customers.

Payment processing and oversight concerns

The acceptance of payments is a critical operational aspect for online casinos. In jurisdictions with effective regulation, payment service providers are subject to oversight and must comply with strict anti-money laundering and consumer protection rules.

In contrast, operators licensed under Anjouan-associated frameworks have been observed offering a wide range of payment methods with limited transparency. These have included credit cards, instant payment systems and cryptocurrencies.

In one documented test, payment providers disappeared from a casino website shortly after questions were raised about compliance. While this does not constitute proof of wrongdoing, it does suggest an absence of stable regulatory expectations or enforcement mechanisms.

Such patterns reinforce concerns that Anjouan licences do not impose consistent operational standards on licensees.

The structure behind Anjouan licensing services

Questions also surround the entities that market and sell Anjouan licences. The primary intermediary historically linked to AOFA is Anjouan Corporate Services. This company presents itself as the sole authorised agent for obtaining offshore licences tied to Anjouan.

However, publicly available information about its governance is limited. Its website lists no directors, board members or physical address. Contact details are minimal and include misspellings that would be unusual for a government-affiliated institution.

The Central Bank of the Comoros has stated that Anjouan Corporate Services is operating illegally. This assessment reflects the bank’s position that no such licensing authority exists under Comorian law.

Social media activity connected to the firm has been attributed to individuals describing themselves as consultants. Communications originate from outside the Comoros, further complicating claims of local regulatory authority.

Historical links and continuity of operations

Historical records indicate that individuals connected to Anjouan Corporate Services have been involved in similar offshore structures for many years. A 2007 speech by a Comorian vice-president referenced a British national in connection with offshore entities linked to Anjouan.

Corporate records in the United Kingdom show that this individual was associated with companies later described by Comorian authorities as fictitious. Over time, younger family members and associates appear to have taken on visible roles within the industry.

Attendance at international gambling conferences by representatives linked to Anjouan licensing services suggests continued efforts to promote the jurisdiction to global operators. Such events provide marketing opportunities but do not confer legal recognition.

None of the individuals or companies contacted in relation to these structures provided substantive responses to questions regarding their authority or compliance with Comorian law.

Expansion into gambling specific licensing

In 2023, a new entity emerged under the name Anjouan Licensing Services. Around the same time, websites appeared promoting an Anjouan Gaming Control Board and offering gambling licences.

These sites claimed that more than 1,300 licences had been issued, with annual fees reported at approximately €17,000 per licence. If accurate, this would imply annual revenues in the tens of millions of euros.

As with earlier structures, these claims rely on oversight from AOFA. A former attorney-general of the Comoros has publicly stated that Anjouan Licensing Services is also an illegal entity. The company provides no information about its ownership or management.

Domain registration records indicate that the websites were registered by a Costa Rica-based firm specialising in offshore corporate services.

The role of international consultants

Fast Offshore, previously known as Overseas Business Services Ltd, is a consultancy that assists companies in obtaining gambling licences in various jurisdictions. It is run by a Canadian national and has actively promoted Anjouan as a cost-effective licensing destination.

Articles authored by its principal highlight the speed and affordability of Anjouan licences. While these pieces are framed as industry commentary, they also function as marketing material for consultancy services.

The consultancy’s involvement in registering Anjouan-related domains suggests a close working relationship with the licensing ecosystem. Public interactions between Fast Offshore and representatives of Anjouan Corporate Services further indicate industry alignment.

Neither the consultancy nor its principal responded to requests for comment regarding the legal status of Anjouan licences.

Regulatory risk for operators and consumers

From a legal standpoint, the use of Anjouan-issued licences presents clear risks. Operators may mistakenly believe that such licences offer protection against enforcement action. In reality, national regulators assess legality based on domestic law, not offshore branding.

Consumers face risks as well. In the absence of a recognised regulator, dispute resolution mechanisms are unclear. There is no evidence of enforceable consumer protection standards or compensation schemes tied to Anjouan licences.

For financial institutions and payment providers, association with unrecognised licensing regimes may create compliance exposure under international anti-money laundering frameworks.

Anjouan’s reputational impact

The continued marketing of licences under Anjouan’s name has reputational consequences for the island and for the Union of the Comoros as a whole. While federal authorities have repeatedly disavowed these activities, the persistence of online licensing creates confusion among international audiences.

This disconnect highlights the limits of enforcement when digital operations are conducted entirely offshore. It also underscores the importance of clear international communication by recognised authorities.

Conclusion

The Anjouan offshore licensing phenomenon illustrates how regulatory ambiguity can be systematically exploited without delivering the legal certainty that operators and consumers alike may assume exists. While the island is repeatedly marketed as a permissive and efficient jurisdiction, the underlying framework has been explicitly rejected by the very sovereign state to which Anjouan belongs. This disconnect between marketing claims and legal reality creates a structural risk that cannot be resolved through branding, website disclosures or intermediary assurances. In practical terms, licences issued under Anjouan-linked entities function more as commercial products than as instruments of recognised regulatory authority.

From a governance perspective, the situation underscores the limitations of offshore models that operate without internationally acknowledged oversight. The absence of transparent institutional structures, identifiable officials and enforceable compliance mechanisms leaves significant gaps in accountability. These gaps affect not only regulators attempting to enforce domestic law but also businesses that may underestimate their exposure and consumers who may overestimate the protections available to them. The repeated public warnings issued by Comorian authorities serve as a formal record that these risks are known, articulated and unresolved.

As regulatory cooperation increases across jurisdictions, the reliance on unrecognised offshore licences is likely to become increasingly untenable. Operators seeking long-term market access and legal stability will face growing pressure to align with fully recognised regulatory regimes. In this context, Anjouan’s offshore licensing model stands as a cautionary example of how perceived regulatory shortcuts can ultimately undermine credibility, compliance and trust on a global scale.

FAQs

What is Anjouan’s role within the Union of the Comoros?
Anjouan is a semi-autonomous island within the Union of the Comoros but does not have authority over national banking or gambling regulation.

Are Anjouan offshore licences legally recognised?
Comorian authorities have stated that offshore regulators linked to Anjouan lack legal standing under national law.

Why do operators seek Anjouan licences?
Operators are often attracted by low fees, fast approval and minimal compliance requirements.

Do Anjouan licences protect operators from enforcement?
No. National regulators enforce domestic laws regardless of offshore licences.

Are gambling licences from Anjouan valid internationally?
They are not recognised by most national regulators and do not replace local authorisation.

What risks do consumers face?
Consumers may lack access to dispute resolution, regulatory oversight and compensation mechanisms.

Who issues Anjouan licences?
Licences are marketed by private companies claiming authority from dissolved regulatory bodies.

Has the Comoros Central Bank commented on this?
Yes. The central bank has warned that certain Anjouan regulators are fictitious entities.

Are payment providers affected?
Payment providers working with unrecognised operators may face compliance and regulatory risks.

Is the situation likely to change?
Increased international scrutiny may limit the practical use of Anjouan-branded licences over time.