2026-01-06

The Anjouan Gambling License Scandal and a Clash of Regulatory Regimes

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At the end of December 2025, a high-profile article was published by Canada’s public broadcaster, focusing on gambling licenses issued in the jurisdiction of Anjouan, which is part of the Union of the Comoros.

Formally, the article centered on the claim that online casinos licensed in Anjouan were servicing Australian players without holding an Australian national license, using electronic wallets, including MiFinity.

However, upon closer examination, it becomes clear that Australia is merely a pretext, not the core of the investigation. The real focus of the publication is an attempt to challenge the legal validity of the Anjouan license itself.

The Core Thesis of the Publication

When reduced to its conceptual core, the article advances the following claim:

Anjouan licenses are fictitious, and operators purchasing them are effectively paying for a legally void document.

Moreover, the article asserts that even central authorities of the Union of the Comoros allegedly consider these licenses illegitimate.

Historical Background: Separatism and Legal Discontinuity

The first evidentiary pillar of the article refers to the period of separatist governance in Anjouan.

from 2005 to 2008, the island was governed by a separatist administration;
during this period, local regulations were enacted;
in 2008, the island was reintegrated under central authority;
some decisions from that period were later annulled.

This narrative is used to argue that the legal foundation of Anjouan’s offshore sector is inherently illegitimate.

The Agency-Based Licensing Model

The second major argument concerns a model in which a private company, registered in the United Kingdom, acts as an agent of the Anjouan authorities and issues licenses to operators.

The article points to:

weak legal disclosure;
rudimentary infrastructure;
similarities to a “master license” structure.

This construction is presented as further evidence of the alleged fictitious nature of the licensing regime.

Documents Used to Support the Allegations

In practice, the evidentiary base of the article relies on just two sources:

a World Bank / IMF report from 2010 on the AML/CFT framework;
a letter from the Central Bank of the Comoros dated 2022.

Both documents are outdated and do not directly address gambling licenses.

Findings from the IMF Report (2010)

The report documents the development of Anjouan’s offshore sector from the late 1990s, with peak activity between 2003 and 2008.

The key conclusion of the report (paragraph 44) states:

The legal framework that allowed the creation of offshore companies remains in force, and non-financial companies created during that period retain legal validity, as no actions were taken to invalidate them.

Nota Bene. In the context of this conclusion, it is noteworthy that the internet domain anjouangov.com, explicitly mentioned in paragraph 44 of the IMF report as the official website created by the island's authorities, continued to exist until recently. In order to draw additional attention to this issue and maintain public debate about its legal status, this domain was purchased by the author of this report.

The Central Bank’s Position (2022)

The Central Bank’s letter addresses the illegal activities of offshore banks and fictitious financial institutions.

Crucially:

The document relates exclusively to financial licenses and contains no direct conclusions regarding the legality of gambling activity.

Federal Structure and Political Reality

The Union of the Comoros is a decentralized state with strong federal characteristics.

Anjouan has historically held substantial parliamentary representation, making the dismantling of local regimes politically and technically complex.

Even with political will, fully dismantling Anjouan’s offshore infrastructure is extremely difficult in practice.

Where the Real Conflict Line Lies

The conflict becomes explicit where a central regulatory authority exists.

where a Central Bank exists → active resistance;
where no sector-specific authority exists (gambling) → legal grey zone.

This explains why pressure is concentrated on the financial sector, while gambling remains in a space of legal ambiguity rather than explicit prohibition.

Anjouan Offshore Finance Authority as the Primary Target

The main focus of the attack is the Anjouan Offshore Finance Authority — a body acting as an agent for offshore company registration and license issuance, including gambling licenses.

This organization:

maintains a public presence at international conferences;
works directly with operators;
is not a clandestine entity.

Its public visibility makes it a convenient and vulnerable target.

Why the Scandal Emerged Now

The broader context of recent years is decisive:

the Curaçao licensing reform has stalled since 2023;
temporary licenses are extended repeatedly;
promised transparency has not been achieved;
banks have increased scrutiny and expressed concern.

Against the weakening of one regime, Anjouan emerged as an alternative center of gravity, and its rapid strengthening triggered a counterreaction.

Why the Australian Angle Appears Artificial

Violations of Australian gambling law have occurred for decades — with and without licenses, across multiple jurisdictions.

Australia is not the primary beneficiary of weakening Anjouan. The main interests lie with Curaçao and, indirectly, Malta.

Conclusion

The recent publication appears less as a legal investigation and more as an element of information warfare between offshore regulatory regimes.

The documents on which it relies:

are not new;
do not directly concern gambling licenses;
allow for alternative interpretations.

This does not mean that the Anjouan license is beyond reproach. It means that the legal reality is far more complex than the media narrative suggests.

Let's Discuss Dialogue

If you have additional information on this issue, specialize in Anjouan legislation, or would like to discuss these conclusions, you are welcome to contact me directly.

You can reach me by email at: [email protected]. We can arrange an interview or a deeper professional discussion.