Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.
Board Briefing
Standing brief, pending expert review.
Comoros is governed by a blanket gambling-prohibition regime under Law No. 20-038/AU of 29 December 2020 (the Penal Code), article 201 et seq., which prohibits casinos and gambling establishments outright. The same provision prohibits lotteries and all games of chance. This characterisation is drawn from GIABA's Mutual Evaluation Report of the Comoros, adopted in May 2024, which assessed the country's measures against money laundering and terrorist financing and in doing so treated the gambling prohibition as settled. No licensed gambling sector of any kind exists in the jurisdiction. The most recent development is dated 8 December 2025, when the Central Bank of the Comoros publicly disclaimed entities claiming, without authorisation, to be an organisation or financial institution linked to the Union of the Comoros, a disclaimer that extends to island-level claimant gaming-licensing bodies on Anjouan and Mwali/Moheli.
Summary
Market Opportunity
Market opportunity in Comoros is negligible. No gross-gaming-revenue estimate, market-size figure, or growth data exists for the jurisdiction, consistent with the market-size-band field resolving to negligible. The blanket statutory prohibition of casinos, gambling establishments, lotteries and games of chance under the Penal Code, Law No. 20-038/AU article 201 et seq., removes the underlying commercial activity from which an addressable market could be measured, and the Central Bank's 8 December 2025 disclaimer of island-level claimant licensing bodies removes even the appearance of a tolerated grey-market pathway through an offshore island licence.
A historical FATF/APG typology record of three operating casinos in Comoros sits in unresolved tension with this characterisation and is the only data point suggesting any prior commercial activity, but it has not been reconciled against the current prohibition and cannot be read as evidence of a present addressable opportunity.
Licensing & Regulation
No licence types, issuing authority, or application pathway exist for gambling in Comoros. The licensing-pathway-exists field for the jurisdiction resolves to false, reflecting the absence of any statutory mechanism by which an operator could apply for, hold, or renew a gambling licence. The controlling instrument is the Penal Code itself (Law No. 20-038/AU of 29 December 2020, article 201 et seq.), which prohibits casinos and gambling establishments outright and separately prohibits lotteries and all games of chance. No agrement — the licence instrument used for financial activity in Comoros — has ever been issued for the offshore exercise of banking, finance-company or financial-establishment activity tied to any Comorian island, a disclaimer that reaches beyond banking into the claimant gaming-licensing space addressed by the Central Bank's December 2025 communique. There is accordingly no B2B or B2C licensing requirement, renewal process, or suspension or revocation mechanism distinct from general criminal enforcement.
Regulated Activity Classes
All 20 canonical activity classes are shown for every jurisdiction so the grid is directly comparable. 13 carry an assessed status here. Where a class has no statutory activity-class assessment of its own, the status shown is the product-coverage position for that jurisdiction and is marked via product coverage — it describes whether the product can lawfully be offered, not that the regulator operates a separate licence class for it. Not yet assessed describes the state of our coverage and is not a statement that the activity is unregulated.
Player products
Supply roles
Settlement rails
Standing brief, pending expert review.
Casino, betting, lottery, payments-for-gambling and affiliate-marketing activity classes are each classified as prohibited in Comoros, across both online and land-based or retail channels. Casino activity is prohibited across online and land-based channels; betting is prohibited across online and mobile channels; lottery products are prohibited across online and retail channels. Payments supporting gambling activity are prohibited, a position supported jointly by the Penal Code's blanket prohibition and the Central Bank's December 2025 disclaimer of island-level claimant licensing bodies. Affiliate marketing of gambling is treated as falling under the same prohibition, inferred from the absence of any statutory carve-out for promotional activity rather than from direct statutory text. A historical FATF/APG typology report records three operating casinos in Comoros, a figure in direct tension with the current prohibition characterisation; this discrepancy remains unresolved and is carried as a contested data point rather than suppressed.
Entry Pathways
No licence types, B2B licensing pathway, or entry route of any kind exists for gambling in Comoros. The licensing-pathway-exists field resolves to false, reflecting the Penal Code's blanket prohibition of casinos, gambling establishments, lotteries and games of chance, which leaves no statutory basis for an application process, local-entity requirement, or capital threshold to attach to.
No agrement has ever been issued for the offshore exercise of banking, finance-company or financial-establishment activity tied to any Comorian island, and the Central Bank's December 2025 communique disclaims island-level claimant bodies — the Anjouan Offshore Finance Authority and the Mwali International Services Authority — as sources of lawful licensing. Neither claimant body is recognised as a Comorian government licensing authority for any purpose, gaming included. There is accordingly no lawful route into the Comorian market for any gambling product, whether through a national licence or an island-level claimant instrument.
Player Protection
No self-exclusion scheme, deposit-limit regime, reality-check requirement, or age-verification standard exists for gambling in Comoros, consistent with the player-protection-regime-exists field resolving to false: no licensed gambling sector exists for such a regime to attach to. There is accordingly no marketing-to-vulnerable-persons restriction, no age-restricted marketing rule, and no KYC or identity-verification duty specific to gambling in the jurisdiction, because the entire sector is prohibited rather than regulated with harm-mitigation obligations layered on top.
The practical player-protection question for an operator considering Comoros is a market-access question: the Penal Code's blanket prohibition of casinos, gambling establishments, lotteries and games of chance removes the premise on which a player-protection regime would otherwise be built.
Consumer Protection
No general consumer-law framework, consumer regulator, or alternative-dispute-resolution body specific to Comoros was identified. This reflects an absence of retrievable material on general consumer-protection law rather than a confirmed legal position on unfair-terms doctrine, distance-selling rules, cooling-off rights, or complaints handling, and is logged as a research gap distinct from the player-protection question.
Because no licensed gambling sector exists in Comoros in the first place, the practical relevance of a general consumer-law overlay is limited to any residual consumer transactions conducted through claimant island-level entities such as the Anjouan Offshore Finance Authority or the Mwali International Services Authority, neither of which is recognised as a Comorian government licensing authority and neither of which carries any protection under Union of Comoros law for a counterparty relying on it.
Distribution & Platform Rules
No platform-specific regulatory instrument — no app-store ruling, no ISP-blocking order, no search-engine de-listing requirement, and no affiliate-marketing-platform restriction — specific to Comoros was identified. Restrictions in this area are inferred from the blanket statutory prohibition of casinos, gambling establishments, lotteries and games of chance under the Penal Code rather than directly evidenced by a dedicated distribution-platform instrument.
Affiliate marketing of gambling is treated as falling under the same general prohibition, absent any statutory carve-out for promotional activity, which is the closest the record comes to a platform- or marketing-adjacent rule; no payment-provider platform restriction specific to gambling distribution was separately identified beyond the general payments posture.
Enforcement
Enforcement rests on general criminal law rather than a sector-specific regulator. Criminal prosecution under the Penal Code, Law No. 20-038/AU article 201 et seq., is the enforcement mechanism available against gambling activity; the maximum sanction is not specified in the available characterisation of the Penal Code.
No named enforcement event against a gambling operator appears in the record. The most significant development is the Central Bank's 8 December 2025 communique, which publicly disclaimed entities claiming, without authorisation, to be an organisation or financial institution linked to the Union of the Comoros; under this disclaimer, operators relying on an Anjouan- or Mwali-issued offshore gaming licence carry no protection under Union of Comoros law.
Extraterritorial risk from this posture is assessed as medium, reflecting the Central Bank's active disclaimer practice in the absence of any evidence of formal cross-border enforcement cooperation specific to gambling. A historical FATF/APG typology report recording three operating casinos in Comoros sits in unresolved tension with the current prohibition characterisation and bears on how confidently the practical enforcement picture can be read.
Extraterritorial Reach
The Central Bank of the Comoros' 8 December 2025 communique disclaims entities claiming, without authorisation, to be an organisation or financial institution linked to the Union of the Comoros, a disclaimer that under the regulator's own terms covers island-level claimant gaming-licensing bodies on Anjouan, Mwali/Moheli and Grande Comore.
Neither the Anjouan Offshore Finance Authority nor the Mwali International Services Authority is recognised as a Comorian government licensing authority for any purpose, and operators relying on either carry no protection under Union of Comoros law. Extraterritorial risk is assessed as medium, reflecting the Central Bank's active public disclaimer practice against offshore island claimants in the absence of any evidence of formal cross-border enforcement cooperation specific to gambling.
Sub-jurisdictions
Regulatory reach of this parent jurisdiction into 2 member territories.
AML / CFT
GIABA's Mutual Evaluation Report of the Comoros, adopted in May 2024, assesses the country's measures against money laundering and terrorist financing and in doing so characterises the gambling prohibition as settled fact. The same evaluation records that the Central Bank, the Ministry of Finance and the Financial Intelligence Unit convened on emerging money-laundering and terrorist-financing threats, including the misuse of the Comorian IBAN by offshore companies — a general financial-integrity vulnerability rather than a gambling-sector-specific one.
No designated-reporting-entity status for the gambling sector under AML legislation was identified, consistent with the absence of any licensed gambling sector for such a designation to attach to. The practical AML/CFT burden for an operator considering Comoros is the underlying criminal exposure of operating a prohibited activity at all, layered onto a general financial system already flagged for offshore-company IBAN misuse.
Data Protection
Data protection obligations are not covered in this report. They are not specific to gambling licensing: the controller and processor duties that apply to a licensee are the same ones that apply to any business handling personal data in this jurisdiction, so this report links to the specialist source rather than restating it. Gambling-specific privacy duties -- player data retention, age and identity verification, marketing consent -- are covered in the player protection and operational obligations sections above.
Technical Compliance
No RNG certification regime, approved testing laboratories, game-approval process, or technical-standards body exists for gambling in Comoros; the technical-standards-body-exists field resolves to false. The prohibition is enforced through general criminal law under the Penal Code, Law No. 20-038/AU article 201 et seq., rather than through a technical-compliance apparatus of the kind found in regulated markets, meaning there is no server-location rule, no GLI- or ISO-equivalent conformance standard, and no certification cost or lift for an operator to budget for.
This is a direct consequence of the absence of any licence against which a technical standard could be imposed, rather than a gap within an otherwise-operating technical-compliance regime.
Operational Obligations
No reporting obligation, technical-certification requirement, or responsible-gambling operational requirement exists for gambling in Comoros, consistent with the operational-obligations-exist field resolving to false: no licensing instrument creates any such obligation. There is equally no data-retention duty or cross-border data-transfer requirement specific to gambling, because no licensed sector exists for one to attach to.
The one general compliance signal of note is not gambling-specific: GIABA's May 2024 evaluation records that the Central Bank, the Ministry of Finance and the Financial Intelligence Unit convened on emerging money-laundering and terrorist-financing threats, including the misuse of the Comorian IBAN by offshore companies, a vulnerability relevant to any payment rail touching the jurisdiction rather than a gambling-sector reporting-entity designation.
Cost to Operate
There is no headline tax rate, fee schedule, or cost-to-operate basis to model for Comoros: the tax-fee-schedule-exists field resolves to false, a position inferred directly from the absence of any licence to which a fee or tax could attach. The same absence of a licensing apparatus means there is no technical-standards body, no RNG certification regime, and no approved-testing-laboratory framework against which an operator would need to certify, and no player-protection regime requiring compliance infrastructure such as self-exclusion or deposit-limit tooling.
Because no licence exists, none of the analytical cost or compliance-lift measures that would ordinarily describe an operator's cost base in a regulated market have any basis to attach to in Comoros; the cost of operating here is instead the criminal exposure described under enforcement.
Payments & Money Flow
No gambling-specific payment rule exists in Comoros. The only payments-adjacent instrument located is general rather than gambling-specific: the Central Bank's regulatory-texts index confirms no agrement has ever been issued for the offshore exercise of banking, finance-company or financial-establishment activity tied to any Comorian island, and the Central Bank's 8 December 2025 communique separately disclaims entities claiming, without authorisation, to be an organisation or financial institution linked to the Union of the Comoros.
Payments that support gambling activity are themselves classified as prohibited, a position supported jointly by this disclaimer and by the Penal Code's blanket prohibition of the underlying activity. There is no permitted-method list, withdrawal-obligation framework, or cross-border capital-control regime specific to gambling for an operator to navigate, because the activity itself has no lawful basis from which such rules could be built.
Competitive Landscape
No licensed-operator count, market-concentration figure, or unlicensed-market-share estimate exists for Comoros, reflecting the complete absence of any regulator register to query rather than a resolved figure of zero or low concentration. This is logged as a structural research gap: there is no licensing regime in Comoros for a register of licensed operators to exist in the first place.
The competitive dynamic that does exist is defined negatively by the jurisdiction's posture — the Penal Code's blanket prohibition of casinos, gambling establishments, lotteries and games of chance, and the Central Bank's active December 2025 disclaimer of island-level claimant licensing bodies on Anjouan and Mwali/Moheli — rather than by any measurable operator presence or market share.
Reform Horizon
No active consultation, draft legislation, or political commitment toward liberalising or regulating gambling exists in Comoros; the reform pipeline is assessed as having no live stage, and the regulatory direction remains static. The controlling position remains the Penal Code's blanket prohibition of casinos, gambling establishments, lotteries and games of chance, confirmed via GIABA's May 2024 Mutual Evaluation Report.
The most recent instrument of any kind touching the gambling-adjacent space is the Central Bank's 8 December 2025 communique disclaiming island-level claimant licensing bodies, which is a financial-integrity measure rather than a step toward liberalisation or regulation of gambling itself. Nothing in the record locates a date on which this position would change.
Trust & verification
Provenance of this record.
Architecture patterns
6 patternsRed Flags
3 flags · 1 criticalWhat changed this cycle
Standing brief, pending expert review.
Comoros is governed by a blanket gambling-prohibition regime under Law No. 20-038/AU of 29 December 2020 (the Penal Code), article 201 et seq., which prohibits casinos and gambling establishments outright. The same provision prohibits lotteries and all games of chance. This characterisation is drawn from GIABA's Mutual Evaluation Report of the Comoros, adopted in May 2024, which assessed the country's measures against money laundering and terrorist financing and in doing so treated the gambling prohibition as settled. No licensed gambling sector of any kind exists in the jurisdiction. The most recent development is dated 8 December 2025, when the Central Bank of the Comoros publicly disclaimed entities claiming, without authorisation, to be an organisation or financial institution linked to the Union of the Comoros, a disclaimer that extends to island-level claimant gaming-licensing bodies on Anjouan and Mwali/Moheli.