Anjouan Gaming License Restricted Countries
None of the published lists we reviewed can be treated as the current restricted-country list for every Anjouan licensee. The official Anjouan website says Anjouan law places no territorial restrictions on licences. It also requires licensees to follow the law of each market they serve. Two of the guides reviewed below still publish fixed exclusion lists. In practice, check your licence conditions, each target market’s law, applicable sanctions, and supplier and payment restrictions together. A country missing from an online list is not automatically an allowed market.
Why do Anjouan restricted-country lists disagree?
The lists disagree because the sources describe different things, and none reconciles the rules licence by licence. Two secondary guides publish a standard exclusion list. The official website describes what Anjouan law itself restricts.
Source reviewed | What it says or shows | What it tells you |
|---|---|---|
Describes licences as having no territorial restriction under Anjouan law; preserves local-law obligations | This is the current published general position, not permission from a destination country | |
Allows individual conditions and requires compliance with applicable laws | The actual licence and its amendments still need checking | |
Follows the official no-territorial-restrictions wording | A secondary account supports that reading; it is not the legal instrument | |
Presents excluded markets and geoblocking requirements | A conflicting secondary account exists; do not adopt its list as universal | |
Uses restricted-market lists and an allowed-list approach | Useful questions to ask; confirm the answers with the authority |
None of this proves that restrictions in older licences or certificates no longer apply, or that every existing licence carries the same conditions. No source reviewed gives a universal effective date, a notice replacing the old lists, or a licence-by-licence reconciliation.
What should you ask the authority?
Ask whether the current general statement applies to your licence number and whether any territorial conditions remain attached to it. Also ask which document takes precedence if an older certificate or condition conflicts with the website. Get a dated answer that names the conditions that apply.
Keep the answer with the licence file. A sales agent's assurance that “the country is not on the list” does not close the question.
What remains uncertain about the licensing legal basis?
The Anjouan website describes an offshore licensing regime, while an international assessment reports a national gambling ban in Comoros. A lawyer needs to reconcile the two, and a public-register entry cannot do that alone.
The 2024 GIABA/FATF mutual evaluation of Comoros, Recommendation 28, criterion 28.1, reports that Comoros prohibits gambling on its territory. It cites Article 201 et seq. of its Penal Code. The Anjouan website bases its licences on the 2001 Constitution of the Comoros and four Anjouan statutes from 2005. It also cites an independent legal opinion dated 19 September 2024 and reconfirmed in February 2026.
The two statements come from different institutions and dates, and they cover different territory. Without legal analysis, neither shows that every offshore approval is invalid, or that the national ban does not matter. Before you rely on the approval, get a legal opinion on the issuer's authority, the offshore activity and the instruments that currently apply. This question is separate from whether a destination market allows you in.
How should you assess a target country?
Check each Anjouan target market against four separate gates: licence scope, destination law, sanctions and financial crime, and commercial permissions. This is an internal checklist, not an official Anjouan classification.
Gate | Question | Evidence needed | Decision if unresolved |
|---|---|---|---|
Licence scope | Does this licence and its conditions permit the proposed activity and domain? | Issued instrument, amendments and authority clarification | Hold the proposed launch |
Destination law | Can this entity offer this product to these customers and advertise through these channels? | Country-specific legal analysis and any required local authorisation | Hold or exclude, as advised |
Sanctions and financial crime | Which legal prohibitions and risk controls apply to this business and transaction? | Applicable sanctions analysis and AML risk assessment | Escalate; apply legally required restrictions |
Commercial permissions | Will the PSP, bank, game supplier and platform support the market? | Written contractual scope and provider approval | Do not route unsupported activity |
A licence is one input to this assessment. A provider can set narrower restrictions, and a market may still require local authorisation where Anjouan imposes none.
Treat FATF risk lists and sanctions regimes separately. Do not copy a label such as “FATF sanctioned countries” into your policy without naming the obligations that actually apply to your entity.
What should your country approval record contain?
The approval record should cover a market, a product and a legal entity. A sportsbook, a casino, an advertising campaign and a B2B supply deal can each need a different analysis.
Record field | Required detail |
|---|---|
Market and customer class | Country or subnational territory, location/residency rules and exclusions |
Product and channel | Casino, sports betting or supply service; website, app and marketing channels |
Operating entity and domain | Exact licence holder and proposed approved hostname |
Legal basis | Counsel's conclusion, date and scope; local permit where required |
Licence conditions | Relevant condition or written clarification |
Provider coverage | PSP, bank and game-provider permissions |
Controls | Registration, access, payment and marketing restrictions |
Decision owner | Named internal approver and next review trigger |
Use approved within stated scope, excluded, or pending review as internal statuses. The regulator does not issue these labels. Do not turn “pending” into approval because a launch deadline is close.
Three market decisions worked through
The four gates reject the GB proposal below. The supplier and licence-condition cases end in a narrower scope or a hold. The first example rests on a published UKGC rule; the other two are hypothetical.
Great Britain: an Anjouan licence alone is insufficient for remote B2C supply
The UK Gambling Commission's remote-licensing guidance requires the relevant UKGC licence to offer remote gambling to consumers in Great Britain, even from overseas. An Anjouan-only casino proposal therefore fails the local-authorisation gate. This example covers Great Britain only. Do not extend it to every UK territory or every B2B activity without analysis.
Record field | Decision record |
|---|---|
Proposed activity | Remote casino offered to consumers in Great Britain |
Approval held in this example | Anjouan only; no relevant UKGC operating licence |
Controlling evidence | UKGC remote-licensing guidance |
Gate result | Local operating-authorisation requirement not met |
Launch decision | Do not launch this proposed GB service on the Anjouan licence alone |
Reopening condition | Appropriate local authorisation and the remaining licence, provider and compliance checks |
A provider excludes a country that counsel otherwise qualifies
Assume counsel has cleared a defined casino product and customer group, but the game supplier's contract excludes that country. The commercial gate fails for that supplier's games. Remove those games from that market or agree a contract change with the supplier. A legal opinion does not amend a supply agreement.
A licence condition conflicts with the general website
Assume an issued condition excludes Market X, while a newer general webpage says Anjouan law imposes no territorial restrictions. Keep Market X pending until the issuer confirms which instrument applies. A general webpage does not prove that your individual condition has changed.
For a managed brand, also identify the operator and approved domain through the white-label responsibility checklist.
How should approved restrictions be implemented?
Turn each approved market decision into controls for access, onboarding, payments and marketing, then test them. A country spreadsheet does little if the platform applies different rules.
Align player terms, registration fields and location checks with the approved market definition.
Reconcile country controls across the platform, payment flow and game suppliers.
Set procedures for conflicting location data and attempts to bypass controls.
Restrict affiliate and advertising activity to the approved scope.
Test blocked and permitted journeys before release and after material changes.
Keep decision records, test results, exceptions and a named escalation owner.
Counsel and the compliance team must decide how to treat existing accounts and player funds. A new market restriction is no reason to improvise a withdrawal policy.
For evidence that the licence itself matches the company and domain, follow the Anjouan licence check workflow.
When should the country assessment be refreshed?
Refresh an Anjouan country assessment when a relevant rule, licence condition, supplier contract, payment route or business model changes. Also review it on a fixed schedule, more often for higher-risk markets.
A new domain, game vertical or payment method can change the assessment even if the country stays the same. If you are weighing another jurisdiction, compare the Anjouan versus Curaçao decision factors. A different licence does not remove the destination-law question.
Discuss your target-market evidence with MGL
Bring your intended countries, products, operating entity, domains and payment model, then discuss your market plan with MGL. Ask us which questions need regulator confirmation and which need local counsel. For the application itself and company setup, see MGL’s Anjouan gaming licensing support.
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