Comoros gaming license
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The Comoros gambling license, most commonly issued out of Anjouan, is marketed as a universal online gaming authorization that can cover casino, sportsbook, bingo, and lottery under one license. It allows multiple brands and URLs, servers hosted anywhere, and is usually tied to an IBC, with a 1‑year term and annual renewal. Application timelines are often quoted at 2–4 weeks after complete filing, though a realistic end‑to‑end path with KYC and PSP onboarding can run closer to two months. The price is a fixed annual fee (the official tariff is not publicly posted), and extra URLs may attract additional charges; advisors often highlight 0% GGR tax and no VAT on foreign income for IBCs. Note the risk signals: FATF’s 2024 report states gambling is prohibited under the Comorian Penal Code, and Central Bank statements have questioned island‑level “offshore” regulators, which can make banking and vendor onboarding harder. Expect AML/CFT controls, responsible gaming, reporting to the Comoros Finance Commission, and geoblocking of restricted markets such as the USA, UK, France, Germany, Netherlands, Spain, Australia, and the Comoros.
Who is the regulator?
Most conditions mirror standard responsible gambling and AML expectations:
- Appoint a compliance officer and a Money Laundering Reporting Officer (MLRO).
- Maintain written AML/KYC, player due diligence, recordkeeping, and suspicious activity procedures; no cash transactions on player accounts.
- Responsible gaming framework to identify and assist at‑risk players; age verification; sober advertising that does not bring the Union into disrepute.
- Notify the authority of serious incidents within 48 hours and of beneficial ownership changes of 3%+ within seven days.
- Submit periodic reports and maintain financial ratios the authority prescribes.
- Keep abreast of prohibited jurisdictions and avoid offering gaming where it constitutes a crime for you or the player.
In other words, even a “light” license expects real compliance infrastructure, not just a badge on your footer.
Let’s talk price. The headline price is not the whole price. Market quotes in 2025 vary by agent and scope, but these are realistic bands for planning:
- Company incorporation (IBC) in Anjouan or elsewhere in Comoros: USD 2,000–5,000.
- Initial gaming license fee: USD 15,000–30,000.
- Annual renewal fee: USD 10,000–25,000.
- Compliance manuals, RG, AML/KYC, policies and onboarding: USD 5,000–15,000 initial.
- Independent testing/certification (RNG, security): USD 5,000–30,000 depending on stack.
- Payments stack (PSP, crypto on/off‑ramps, banking KYC): USD 5,000–20,000 initial, then monthly fees.
- Ongoing compliance (MLRO, reporting, monitoring): USD 2,000–6,000 per month if outsourced.
Timelines are marketed at 3–8 weeks from a clean file to issuance, but the clock stops if due diligence documents are incomplete, your tech stack needs work, or a PSP declines you and you must re‑route payments.
A note on taxes: you will see claims of 0% tax on GGR. Treat that as a marketing headline, not a tax opinion. Corporate tax depends on where your company is resident for tax purposes, where value is created, and where players sit. BEPS rules, MLI, and local nexus laws can attach tax outside of Comoros even if the local corporate law says otherwise. Model your tax globally.
Step-by-step: how operators actually get licensed
Company formation
You begin by incorporating an IBC. Anjouan typically permits remote management and a local registered agent. Nominees may be allowed, but you will still disclose the UBO to the regulator. Keep share capital and director data consistent across all filings—banks and PSPs will check.
Documentation and due diligence
Prepare KYC packs for all directors, shareholders, and UBOs: notarized passports, proof of address, CVs, police clearance, source of funds/wealth. On the technical side, line up your platform description, RNG or game certifications, T&Cs, privacy policy, AML/KYC, RG policy, and your risk matrix for geoblocking.
Application filing through an agent
Most filings go through an “authorized agent.” They package your application, liaise with the board/authority, and coordinate additional questions. Ask for a copy of what is submitted and written confirmation of receipt by the authority. Keep your communications in writing.
Post-approval tasks
Issuance usually comes with corporate papers (incorporation, good standing), and operational policies. You then complete PSP onboarding, maybe appoint a payment agent, connect your cashier, and go live in beta. Expect to file first reports within your first quarter and to respond quickly to any compliance queries.
AML/KYC and the MLRO function
Your MLRO must be senior and independent enough to say “no.” Implement tiered KYC, ongoing monitoring, sanctions screening, and a SAR/STR process. Document everything. Even if the regulator’s template is light, align with FATF and common EU/UK standards—this is what PSPs and counterparties expect.
Responsible gaming and player protection
Age checks, self‑exclusion, deposit limits, and cool‑off periods are standard. Publish clear T&Cs and bonus rules. Keep an internal log of disputes and resolutions and a path to escalate to the regulator. If you can plug into third‑party RG tools or provide links to support organizations, do it.
Technology, testing, and data security
Have your RNG or game math certified by a recognized lab. Apply ISO‑style security controls: access logging, encryption in transit and at rest, backup/restore drills, and vulnerability management. If you process crypto, implement blockchain analytics and on‑chain risk scoring.
Market access, payments, and geoblocking
A Comoros/Anjouan license does not open every door. Tier‑1 regulated markets (UK, most of EU, some LatAm) will reject it, and some PSPs will not touch it. Many operators rely on a mix of mid‑tier PSPs, crypto rails, and regional aggregators. Build your geoblocking list conservatively and keep it updated—advertised exclusions often include the USA, France, Germany, Netherlands, Spain, the UK, and, notably, the Comoros itself.
On banking, assume heightened KYC and periodic reviews. Keep financial statements tidy, reconcile player funds, and avoid cash or P2P transfers. If you pitch Web3‑only, remember on/off‑ramp compliance is still in scope.
| Jurisdiction | Typical time to license | Cost profile | Regulatory perception | Market access |
|---|---|---|---|---|
| Anjouan (Comoros) | 3–8 weeks | Low initial, low annual | Mixed, scrutinized | Broad gray markets; limited Tier‑1 |
| Curaçao (new regime) | 3–6 months | Moderate | Improving, still mid‑tier | Better PSP access than Anjouan |
| Isle of Man | 4–8 months | High | Strong, bank‑friendly | Good access, not EU |
| Malta (MGA) | 6–12 months | High | Gold standard | Strong access across many markets |
You will find posts alleging that Anjouan licensing is a “scam,” alongside claims of unresponsive dispute handling and weak enforcement. You will also find operators who have had a decent, quiet run. Both realities exist. Here is how to de‑risk:
- Verify the license on an official, current register—do not rely on screenshots.
- Demand the legal basis for the authority’s powers and the text of the applicable act.
- Check whether the union‑level position could override island practice; factor this into banking and M&A risk.
- Vet your agent: ask for references, engagement terms, and escrow for government fees.
- Test PSP appetite before you file; do not assume the license will open doors.
- Build an adult‑level complaints process; if the regulator does not mediate effectively, your brand must.
If anything changes in beneficial ownership or a serious incident occurs, notify the authority fast—most conditions require seven days for ownership changes and within 48 hours for incidents. Keep a paper trail.
Comoros (Anjouan) can suit founders who need speed to market, plan to operate in unregulated or lightly regulated geographies, and are comfortable with a lean compliance stack that still meets global AML/RG norms. The price is attractive, the licensing path is straightforward, and the ability to run multiple brands from a single license is a commercial plus.
It is not ideal for operators seeking deep PSP access in the EU/UK, premium game suppliers with strict vendor policies, or a regulatory badge that carries automatic credibility with banks and investors. If your strategy involves enterprise partnerships, app store distribution, or regulated market entry, you are better off spending more time and money on Curaçao’s new regime, the Isle of Man, or Malta—and using a Comoros vehicle, if at all, only as a short bridge with a clear exit plan.
- Confirm the regulator’s authority, the act in force, and the live status of the license register.
- Map your target countries and verify the legality of remote gaming and promotions there.
- Get written PSP term sheets contingent on a Comoros license; line up at least two.
- Lock in your AML/KYC, RG, and incident response mechanics; appoint a named MLRO.
- Budget the full cost of ownership, not just the headline license price.
- Decide now whether Comoros is your destination or your stepping stone—and plan the upgrade path accordingly.
| Aspect | What it covers | Official/claimed rules | Practical implications | Price and cost notes |
|---|---|---|---|---|
| Regulator and legal basis | Who issues and supervises a Comoros online gambling license | Two parallel narratives exist: (1) Comoros Finance Commission (CFC) under the Betting and Gaming Act and CFC Act No. 17-008/AU (2017) is cited in some materials; (2) On Anjouan (Ndzuwani), the Anjouan Betting and Gaming Board (ABGB) and/or Anjouan Offshore Finance Authority (AOFA) are promoted as the bodies issuing the gaming license, sometimes via “Anjouan Licensing Services Inc.” and “Anjouan Corporate Services” as agent. | Expect fragmented administration and branding. Always request the current enabling act, the regulator’s appointment instrument, and contact details of the issuing authority for direct verification. | Government fee is described as a fixed annual fee, but not publicly standardized. Expect an “official fee” plus an agent/administration fee. |
| Legality in the Union of the Comoros | Statutory backdrop and national policy | FATF’s 2024 Mutual Evaluation notes gambling is prohibited by the Comorian Penal Code, and the Central Bank of the Comoros has disavowed AOFA in offshore contexts. Yet Anjouan-facing sites promote licensing under local island law. | There is a legal tension between national law and certain island-level practices. Treat licenses as potentially vulnerable to policy shifts and banking scrutiny. Build contingency plans. | Legal uncertainty increases compliance and banking costs. Price in extra legal opinions and due diligence. |
| Who can apply | Eligible applicant | “Online betting and gaming licenses are issued only to Comoros companies.” Anjouan marketing sometimes claims non-local entities can apply through a local agent; nominee directors are acceptable. | Plan to incorporate a local company (typically an IBC) to align with the “Comoros company” requirement. Nominees may be used but raise enhanced KYC/UBO scrutiny with banks/PSPs. | Company formation and nominee services add setup and annual maintenance fees. |
| Company type and structure | Corporate form, directors, ownership | International Business Company (IBC) commonly used. At least one director/UBO; no residency requirement stated. Some providers claim minimum share capital of USD 250,000—this is not consistently documented by authorities. | Confirm capital rules in writing with the regulator/agent. Keep simple share structure and clear UBO disclosure to pass due diligence. | Capitalization (if required) ties up funds. Registered office/agent and annual IBC fees apply. |
| Scope of license | Covered gambling activities | Computer/Internet gaming, sportsbook (including horse/greyhound), casino, lottery, bingo; one license can cover many online gambling types, brands, and URLs. | Good fit for multi-brand strategies. You can add additional domains/brands beneath the same license, typically via notifications and fees. | Base fee plus per-URL or per-brand add-on fees are common. Budget for future brand expansions. |
| Territory and infrastructure | Hosting, banks, geography | Server may be located anywhere in the world. Profits may be cleared through any bank. | Choose hosting in a reputable data center for uptime and third-party testing. Banking is the pinch point—expect enhanced checks from correspondent banks. | Add costs for Tier-1 hosting, DDoS, CDN, and banking compliance packages. |
| Validity and renewal | Term and renewal duties | License validity is one year with annual renewal. | Track renewal windows and submit updated policies, reports, and fee payments on time to avoid lapses. | Annual government fee + agent renewal fee. Late renewal may incur penalties. |
| AML/KYC and cash rules | Financial crime controls | Strict AML/KYC controls mandated by the CFC/ABGB: cash must not be used in any transaction involving a player account; appoint an MLRO; staff training; identify suspicious transactions; maintain records; report to the authority. | Implement robust onboarding (KYC/age), transaction monitoring, and SAR/STR workflows. Document policies and staff training logs. | Ongoing costs for KYC vendors, AML monitoring tools, audits, and MLRO/compliance staff. |
| Player protection and advertising | Safer gambling, marketing | Identify at-risk players and provide information/support; prohibit underage gambling; advertising must not bring the Union of the Comoros into disrepute. | Build RG tools: limits, self-exclusion, timeouts, and links to support bodies. Vet creatives and affiliates for compliance. | Allocate budget to RG tooling, hotline links, and compliance review of marketing and affiliates. |
| Reporting and notifications | Ongoing regulator engagement | Submit reports at intervals/formats set by the regulator; satisfy financial ratio requirements; notify material changes; attend meetings on notice (≈7 days). | Establish a recurring reporting calendar. Maintain MI packs (KPIs, RG stats, complaints, tech incidents, financials). | Internal reporting effort + potential external compliance consultancy. |
| Ownership and control changes | Shareholding changes and events | Notify changes when any person reaches 3%+ beneficial holding within 7 days; notify any termination of gambling licenses elsewhere; notify serious incidents within 48 hours. | Keep legal and company secretarial teams aligned. Build incident response with a 48-hour reporting SLA. | Secretarial costs for filings and legal drafting; incident forensics and legal counsel when issues arise. |
| Technology and certification | Platform, RNG, security | System supplier must be “fit and proper.” Many sources cite RNG/game fairness certification (e.g., iTech Labs/eCOGRA) and data protection controls. | Obtain independent testing certificates for RNG/games. Apply ISO 27001-style controls or equivalent security baselines. | Certification fees per game/RNG; periodic re-testing; security tooling and audits. |
| Payments and crypto | PSPs, banking, digital assets | Non-cash only. Some providers claim crypto is allowed with transaction monitoring. | Offer fiat via vetted PSPs and, if using crypto, deploy chain analytics and enhanced AML. Prepare for provider- and market-specific restrictions. | PSP setup fees, rolling reserves, FX/processing costs; blockchain analytics subscriptions if using crypto. |
| Restricted markets | Where you cannot operate | Operators commonly exclude: USA, UK, EU states like Germany/Netherlands/Spain/Austria, Australia, France, and the Comoros. Lists vary by PSPs and law; you must avoid jurisdictions where play is illegal. | Maintain a dynamic geo-block and compliance matrix. Track evolving local laws to avoid criminal exposure. | Geo-IP, legal monitoring subscriptions, and ongoing counsel increase operating costs. |
| Dispute resolution and register | Player complaints and license lookup | “Gaming Control Anjouan” sites claim a dispute process and a public License Register listing licensees/URLs/status. | If you rely on that register, verify it matches your license and domains. Publish clear complaint paths and ADR links to boost trust. | Minimal direct cost; invest in transparent complaints handling to reduce chargebacks and disputes. |
| Controversies and risk signals | Credibility, banking, player sentiment | Central Bank warnings about AOFA in offshore contexts; FATF note on national prohibition; mixed player reviews about Anjouan enforcement responsiveness. | Expect enhanced scrutiny from banks, PSPs, affiliates, and B2B suppliers. Mitigate with strong compliance evidence and alternative licensing roadmap if scaling. | Additional legal opinions, reputational management, and possibly parallel licensing in a second jurisdiction. |
| Application steps | From zero to license | 1) Incorporate a Comoros entity (typically IBC) and appoint registered agent; 2) Prepare documents: KYC for UBOs/directors, police clearance, corporate docs, business plan, policies (T&Cs, KYC/AML/RG), supplier contracts, tech architecture, domain list; 3) Submit via authorized agent; 4) Due diligence and clarifications; 5) Pay fees; 6) License issued; 7) Go-live and ongoing reporting. | Work with a reputable local agent. Keep responses fast and complete to avoid delays. | Professional fees for incorporation, document prep, translations, and agent handling. |
| Timeline | How long it takes | Market claims range from 2–4 weeks to ≈2 months, depending on completeness and regulator workload. | Build a conservative plan: 6–8 weeks from kick-off to go-live if documents and platform are ready. | Time-to-market affects burn rate; budget for bridging costs and pre-revenue period. |
| Taxes | Corporate and GGR posture | IBCs are often marketed as tax-exempt on foreign income; some sources claim 0% GGR, no VAT, no income tax. Local implementation and your home-country tax rules still apply. | Obtain written tax confirmations locally and align with international tax, CFC, and economic substance rules. | Tax advice and potential substance costs (staff, office) if required by your group tax planning. |
| Price structure (no official tariff published) | How “price” is built in practice | Components typically include: 1) Government application/issuance fee; 2) Annual government license fee (fixed); 3) Agent/administration fee (setup + annual); 4) Per-URL/brand additions; 5) IBC setup and annual maintenance; 6) Testing/certification; 7) AML/KYC vendors; 8) Insurance (optional); 9) Legal and tax opinions. | Ask for an itemized quotation separating government fees from agent fees. Negotiate multi-URL packages and renewal discounts. | Expect meaningful upfront plus recurring annual spend; final “price” varies by agent bundle and your tech stack. |
| Deliverables at issuance | What you receive | License certificate; certificate of incorporation/incumbency; tax exemption note (if applicable); certificate of good standing; share certificate; M&A; approved T&Cs and KYC/AML policies; government notice. | Keep certified copies ready for banks, PSPs, game providers, and affiliate networks. | Notary/apostille and courier costs for certified sets. |
| Operations and maintenance | Keeping the license in good standing | Maintain AML/KYC/RG programs; file periodic reports; update the regulator on material changes; meet financial ratio requirements; attend meetings if called; renew annually. | Create a compliance calendar and appoint a Compliance Officer and MLRO with clear reporting lines. | Ongoing compliance headcount or outsourced compliance retainer. |
| Fit-for-purpose use cases | When this license is used | Startups or emerging brands targeting non-restricted markets; crypto-friendly casinos; multi-brand rollouts needing fast entry. | Pair with strong internal compliance and careful market selection to mitigate banking and reputational friction. | Budget for parallel licensing later if scaling into stricter markets. |
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