Comoros — Anjouan

No credible market-size or gross gaming revenue estimate was located for the KM-A claimant online-gaming scheme. Growth trajectory is accordingly assessed as closed, a direct consequence of the national gambling prohibition recorded in the GIABA Second Round Mutual Evaluation Report of the Union of the Comoros, rather than an estimate of suppressed or informal demand.

No instrument establishes a licensing pathway for gambling at Union or Anjouan level. Licensing is confirmed as unavailable: the Central Bank of the Comoros states that the Anjouan Offshore Finance Authority has no authority to issue licences and that no online gaming licence has been issued nationally. This closes off the most commonly cited route for compliance teams evaluating an 'Anjouan' credential. The absence is reinforced from the adjacent finance sector: the Central Bank has separately confirmed that no licence has ever been issued for the offshore exercise of banking activities in general, meaning an offshore banking authorisation cannot substitute for, or be read as evidencing, a gambling licence. Taken together, these findings mean there is no licensing authority for an operator to apply to, no application process to follow, and no renewal or revocation framework to plan around, because no licence of either type has ever lawfully issued.

No statutory route exists to lawfully enter the KM-A market for any gambling product. The single pathway that has been marketed to operators — a self-styled 'Anjouan' online gaming licence issued by the Anjouan Offshore Finance Authority — does not constitute a lawful entry route. The Central Bank of the Comoros states plainly that this body has no authority to issue licences and that no online gaming licence has been issued nationally, a confirmed finding as of the regulator's communique of 8 December 2025.

No self-exclusion, deposit-limit, reality-check, or age-verification regime was identified at Union or Anjouan level. This finding reflects an absence inferred from a general search rather than a specific instrument ruling out player-protection measures. In practical terms, an operator or player relying on the claimant 'Anjouan' online gaming scheme would have no recourse to a self-exclusion register, no statutory deposit or loss limit, and no mandated age-verification standard, because no regulator has been identified to design, administer, or enforce such measures for the sector.

No gambling-specific consumer-law framework, alternative-dispute-resolution body, or complaint-escalation path was identified for KM-A, consistent with the absence of any national gambling regulator. This is distinct from the player-protection gap described separately: it concerns general consumer-law application — unfair-terms doctrine, distance-selling rules, cooling-off rights, and refund entitlements — rather than gambling-specific harm mitigation, and no evidence located during this research pass extends general Comorian consumer law to gambling transactions specifically.

No app-store or advertising-platform policy specific to KM-A claimant gaming brands was located during the research pass underlying this baseline. The more significant distribution-risk finding is marketing practice rather than platform policy: the claimant 'Anjouan Offshore Finance Authority' and associated gaming-claimant bodies market the unrecognised 'Anjouan' licence as a trust signal to players and to distribution platforms, notwithstanding the Central Bank of the Comoros's repeated and public disavowal of that credential, most recently in a communique dated 8 December 2025.

The Central Bank of the Comoros issued a public warning communique on 8 December 2025 against entities falsely claiming financial or institutional status linked to the Union of the Comoros, a category that includes the Anjouan-based claimant bodies marketing gambling licences. This communique continues a documented, decade-long pattern rather than opening a new one: the Central Bank has issued disavowal communiques against Anjouan offshore financial claimants in 2014, 2019, 2022, 2023, and 2025, a pattern that has in the past included court actions and an international rogatory commission.

No gambling-specific mutual legal assistance treaty or regulator-to-regulator channel was identified for KM-A. The extraterritorial-risk level is nonetheless assessed as medium, based on a historical analogue rather than a gambling-specific mechanism: the Central Bank of the Comoros has pursued court actions and an international rogatory commission against Anjouan offshore financial claimants in the past, and this precedent plausibly extends to a gaming-branded analogue of the same claimant structure.

The GIABA Second Round Mutual Evaluation Report of the Union of the Comoros, adopted at the May 2024 Plenary, finds that casinos and gambling establishments are nominally designated a Designated Non-Financial Business or Profession category under AML/CFT Law 12-008/AU. The same report records, however, that supervision of this category is not implemented in practice — a formal designation without an operating supervisory structure behind it.

No national technical standards body, approved test lab, or RNG certification regime exists for gambling in KM-A. There is accordingly no certification pathway for gaming software, no server-location rule, and no GLI- or ISO-equivalent conformance standard that a technical-compliance team could certify against, because no regulator has been established to define or administer such a standard.

No reporting, certification, or responsible-gambling operational regime was identified for KM-A at either Union or Anjouan level. This absence reflects the underlying national prohibition rather than a nascent or forthcoming specification: no instrument directly addresses operational obligations for gambling, and no regulator has been identified to administer reporting duties, technical certification, data-retention requirements, or cross-border transfer rules for the sector.

No statutory tax or fee regime exists for gambling in KM-A, because the underlying activity is prohibited nationally. There is accordingly no headline rate, no deduction schedule, and no effective rate for an operator to calculate against, since no lawful gambling activity exists for a tax instrument to attach to.

The Central Bank of the Comoros states that only financial institutions it has duly licensed are authorised to carry out financial or banking activity under a Comorian licence. Payment facilitation for gambling by unrecognised entities, including the claimant 'Anjouan' scheme, therefore operates entirely outside any lawful framework: there is no gambling-specific payment, funding-method, or capital-control instrument that could legitimise it, and the general licensing exclusivity the Central Bank asserts leaves no carve-out for gambling-adjacent payment rails.

No published count of lawfully licensed gambling operators exists for KM-A, a finding directly consistent with the absence of any licensing regime: there is no register against which such a count could be produced. The absence of a licensing authority also means no market-concentration data, no competitive-intensity metric, and no distinction between dominant and marginal operators can be drawn with any lawful basis, since all activity in the sector sits outside the recognised regulatory perimeter.

No consultation or draft legislation was identified for KM-A. The regulatory direction is assessed as static, a conclusion supported by a multi-year pattern of unchanged disavowal communiques issued by the Central Bank of the Comoros in 2014, 2019, 2022, 2023, and 2025, each repeating substantially the same message: claimant financial and institutional bodies linked to the Union of the Comoros, including Anjouan-based gaming claimants, are not recognised.