A licence purportedly issued in Anjouan may create the appearance of a regulatory framework without constituting a legally valid authorisation.
This issue is particularly significant in the gambling sector. According to an investigation published by Le Monde on 4 February 2026, the Comorian Criminal Code prohibits games of chance throughout the national territory of the Comoros. In this context, a private entity cannot legalise a prohibited activity by issuing a certificate, registering a company in an online register or using regulatory terminology.
The question is therefore not simply whether a company holds a document described as a “licence”. It is first necessary to establish whether the activity is permitted under Comorian law, whether the issuing entity has the legal authority to grant such a licence, and whether the authorisation can be recognised in the countries where the company intends to operate.
Where a licence purports to authorise an activity prohibited in the Comoros, it does not constitute a regulatory passport. On the contrary, it may expose the operator, its directors, investors, service providers and banking partners to significant risks.
SRDB Law Firm assists companies in verifying the legal validity of licences presented as Comorian, identifying the jurisdictions in which their activities may lawfully be conducted, and avoiding commitments based on authorisations that lack genuine legal effect.
An Anjouan Licence Does Not Grant Access to International Markets
Anjouan, one of the islands of the Union of the Comoros, has for several years been promoted as a jurisdiction offering licences in various sectors, including online gambling, financial services, insurance and crypto-assets.
Promoters of these licences often emphasise fast procedures, low costs and a supposedly flexible regulatory framework. Some websites also use institutional terminology, references to Comorian legislation and logos suggesting the existence of a supervisory authority.
This presentation may create a fundamental misunderstanding. A licence issued or offered in Anjouan does not automatically entitle its holder to operate in other countries where it intends to provide services.
Nor can it legalise an activity prohibited within the national territory of the Comoros. The existence of a certificate, licence number or entry in an online register is therefore insufficient to establish the legality of the activity.
The decisive question is whether the issuing authority genuinely possesses the legal power to authorise the activity concerned and whether that authorisation is recognised in the target markets.
Behind the Certificate: Which Authority Actually Has the Power to Issue the Licence?
The Anjouan Offshore Finance Authority, commonly referred to as the AOFA, presents itself as an authority responsible for supervising certain offshore financial activities.
On its website, the AOFA states that its mission is to ensure that all financial operations in Anjouan are conducted responsibly, transparently and in compliance with applicable rules. It claims to implement a comprehensive regulatory framework designed to ensure sound financial governance, protect stakeholders’ interests and promote financial system stability.
However, the AOFA does not possess these responsibilities.
The AOFA also claims to be committed to protecting the financial system against illicit activities, particularly money laundering. Pursuant to the Money Laundering Prevention Act (Government Notice No. 008 of 2005), the Authority claims to ensure that all financial institutions comply with strict anti-money laundering (AML) measures, thereby strengthening the integrity and security of the financial sector.
The Central Bank of the Comoros (BCC) is the official financial regulator of the Union of the Comoros. The BCC and the Comorian federal authorities have described these structures as “fictitious entities”. They have issued statements indicating that the AOFA has “no physical or legal existence” within Comorian territory and operates solely through websites intended to mislead clients.
From the perspective of the Comorian State, this constitutes an impersonation of an official institution and an infringement of its financial sovereignty by private third parties. As early as 2007, Comorian Vice-President Idi Nadhoim accused the AOFA of involvement in money laundering.
It is also noteworthy that the AOFA website uses an international .org domain name (anjouanoffshorefinancialauthority.org), whereas an official government-affiliated website would be expected to use the country’s national .km domain.
The question is therefore twofold: does the entity legally exist, and does it have the statutory authority to issue the licence concerned?
A Licence Cannot Legalise an Activity Prohibited in the Comoros
Gambling and games of chance are prohibited throughout the national territory of the Comoros.
This prohibition is the starting point for any analysis of a licence purportedly issued in Anjouan. A private entity cannot, merely by issuing a certificate, create a right to conduct an activity prohibited by law.
Three distinct elements must be considered: first, the possible existence of a commercial or administrative document; second, the legal competence of the entity that issued it; and third, the lawfulness of the activity it purports to authorise.
Even where a licence bears a number, an expiry date, a seal or a reference to Comorian legislation, it cannot have a legal effect that overrides the legislation governing the activity. If the activity is prohibited, the document cannot make it lawful.
A licence issued without a valid legal basis therefore provides no regulatory protection. On the contrary, it may give a company a false sense of security and delay the identification of risks.
B2B Licences Do Not Eliminate Legal Risk
The distinction between business-to-consumer (B2C) and business-to-business (B2B) activities is frequently invoked to justify the use of licences issued in Anjouan.
A B2C operator offers gambling services directly to players. A B2B provider, by contrast, supplies software, content, platforms, technical services or solutions to gambling operators.
This distinction may be relevant, but it does not mean that all B2B activities are automatically authorised.
The Le Monde investigation reports that Relax Gaming, a subsidiary of the FDJ Group, allegedly obtained a so-called B2B licence in Anjouan on 14 November 2025 to supply slot machine, bingo and table games to casino operators registered in Anjouan.
According to statements reported in the article, FDJ describes Relax Gaming as a service provider operating exclusively between businesses, rather than an operator offering gambling services directly to the general public.
This situation illustrates the difficulty of assessing the legal risks faced by B2B providers. Their legal classification depends on the company’s actual role, contractual arrangements, services provided, clients involved, target jurisdictions and degree of participation in gambling operations.
A provider described as purely technical may, in practice, contribute to the design, provision or commercialisation of gambling services. It must therefore verify that its involvement does not facilitate a prohibited or unauthorised activity.
Online Gambling, Financial Services and Crypto-Assets: The Sectors Most Exposed to Questionable Licences
The risks are not limited to online casino operators.
Offshore structures may also offer licences in the financial services, insurance, payments or crypto-asset sectors. In each of these areas, the existence of a certificate or an entry in a register is insufficient to demonstrate that a company holds a recognised regulatory authorisation.
Regulated activities are generally subject to strict requirements concerning capital, corporate governance, management, internal procedures, customer protection, management of funds and supervision by a competent authority.
A company relying on a licence that lacks legal effect may therefore face blocking measures, sanctions, banking difficulties and disputes with clients or business partners.
Operators, Suppliers, Investors and Banks: Who Bears the Risk When a Licence Is Invalid?
A company may face legal exposure even if it does not directly operate an online casino.
A software supplier may be associated with an unauthorised gambling operation. A payment service provider may encounter difficulties processing financial transactions. A bank may refuse to open an account or maintain a banking relationship. An investor may face a loss in the value of its investment or reputational damage.
Commercial partners may also be affected by an invalid or unrecognised licence. Contracts entered into with the operator may become difficult to perform, particularly where the licence constitutes an essential condition of the transaction.
The questions to be examined include the following: does the operator hold valid authorisation in each target country? Is the issuing authority legally competent? Have the beneficial owners been identified? Are payments processed through regulated financial institutions? Do the contracts clearly allocate responsibilities? Are termination and indemnification mechanisms provided for in the event that the licence is withdrawn or invalidated?
A Licence That Is Difficult to Verify Is a Warning Sign
Opaque offshore structures, complex corporate chains, international financial flows lacking a clear economic rationale and difficulties identifying beneficial owners are significant risk factors.
A licence that is difficult to verify does not, in itself, constitute evidence of an offence. However, it should be treated as a warning sign when combined with other factors, such as the absence of a verifiable address, uncertainty surrounding the identity of directors, payments routed through multiple jurisdictions or the lack of independent official documentation.
Companies must be able to demonstrate the due diligence conducted both before entering into and throughout the business relationship. In particular, they should document the identity of their partners, the origin and destination of funds, the ownership structure and the economic rationale of the transaction.
In certain regulated sectors, a high-risk business relationship may also trigger enhanced due diligence requirements, the refusal of transactions or the termination of the commercial relationship.
When the Appearance of Regulatory Compliance Conceals Broader Risks
Regulatory terminology, institutional logos, references to foreign legislation and the existence of a public register may create the impression that an activity is subject to genuine regulatory oversight.
However, such appearances cannot replace independent legal verification. A company must be able to establish who actually supervises the activity, who holds the funds, who is responsible for compliance and which authority can intervene in the event of a breach.
Where clear answers to these questions are unavailable, the commercial decision should be suspended pending further due diligence.
A licence offered by an entity whose legal status is uncertain may also be viewed unfavourably by banks, investors and commercial partners. The issue therefore extends beyond the risk of sanctions. It also concerns the company’s ability to open bank accounts, obtain financing, secure insurance and maintain sustainable business relationships.
Before Paying for a Licence, Verify These Essential Elements
Before purchasing or using a licence presented as originating from Anjouan, a company should verify the legal existence of the issuing authority, the legislation granting it its powers, the precise scope of the licence, the authorised activities, the territories covered and the renewal conditions.
It should also identify all parties involved, verify beneficial ownership, analyse financial flows, review contractual arrangements and determine whether the target countries recognise the licence concerned.
These checks should be conducted before payment for the licence, not after operations have commenced. A company that discovers too late that its authorisation is not recognised may already have incurred substantial expenditure, entered into contracts, recruited employees, opened bank accounts and exposed its brand to reputational risks.
The analysis should also address the practical consequences of a disputed licence. In particular, companies should anticipate the risk of website blocking, bank account closures, payment suspensions, contractual termination, investment refusals or difficulties responding to requests from supervisory authorities.
A Disputed Licence Can Disrupt Payments and Undermine Contracts
The validity of a licence should not be assessed in isolation from the broader business and contractual structure.
Contracts entered into with operators, intermediaries, technology suppliers or payment service providers should clearly define each party’s responsibilities. They should also address the consequences of the withdrawal, suspension or challenge of the licence.
Appropriate contractual safeguards may be required, including representations and warranties concerning the validity of authorisations, cooperation obligations, audit rights, termination mechanisms and indemnification clauses.
Such contractual protection does not replace prior due diligence, but it may reduce the company’s exposure if the regulatory situation develops unfavourably.
SRDB Law Firm Assists Companies Before They Make Commitments
SRDB Law Firm advises companies considering the acquisition of licences presented as legally valid, such as those offered in Anjouan, or contemplating business relationships with operators relying on such licences.
The firm can conduct independent verification of the issuing authority, assess the validity and scope of the licence, identify the jurisdictions in which the activity may lawfully be conducted, examine the B2C or B2B nature of the project, assess payment-related and anti-money laundering risks, and review contracts entered into with operators or intermediaries.
SRDB Law Firm can also prepare a country-by-country risk assessment and provide operational recommendations based on three possible scenarios. The transaction may proceed where sufficient legal safeguards are in place. It may be restructured to mitigate identified risks. Alternatively, it may need to be abandoned where the licence or proposed arrangement lacks a sufficiently sound legal basis.
The firm’s assistance may be provided before purchasing a licence, signing an agreement with an operator, raising capital, undertaking an acquisition, entering into a technology partnership or opening a bank account.
The objective is to prevent companies from relying solely on the appearance of a certificate, an online register or an intermediary’s commercial representations without first verifying the actual legal validity of the authorisation.
For any questions regarding the validity of an Anjouan licence or the legal and regulatory risks associated with your business activities, please contact our team at contact-comoros@srdb-lawfirm.com
Sources:
Central Bank of the Comoros – Official Statement: Statement on Illegal Offshore Banking Activities
Press article: Le Monde – 4 February 2026
