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Comoros Online Gambling Regulation, Licensing & Tax Regime

Sub-national unit

KM-A is closed: gambling is prohibited nationally and any 'Anjouan' gaming licence is unrecognised by the Union of the Comoros.

13 closed · 7 not yet assessed → 20 classes
Regulator: None recognised by Union of the Comoros (Self-styled Anjouan Gaming … · Collected 1 Nov 2026 · Published 4 Nov 2026 · Changed 1 Nov 2026 PDF Sign in for PDF Compare
Regulatory DimensionComoros Standing Position
JurisdictionComoros (KM-A)
Primary Gambling RegulatorNone recognised by Union of the Comoros (Self-styled Anjouan Gaming Board unrecognised)
Product Access Summary13 closed · 7 not yet assessed
Permitted (Open) VerticalsNone recorded as open
Prohibited (Closed) VerticalsCasino, Poker, Bingo, Lottery, Sports betting, Esports betting, Fantasy sports, Skill games, Sweepstakes, Software / B2B, Affiliate marketing, Payments for gambling, Crypto gambling
Primary Instruments ReferencedBCC-COMMUNIQUE-2025-12-08-WEB; BCC-COMMUNIQUE-2025-12-08-PDF
Verification & CurrencyAI research, not expert reviewed · Published 4 Nov 2026 (collected 1 Nov 2026)

Can we offer our product?

Every product class, in fixed taxonomy order. The band is what you can do; where the recorded legal status says something the band does not, it is shown beside the product.

Player products

  • CasinoProhibited
    Closed
  • PokerProhibited
    Closed
  • BingoProhibited
    Closed
  • LotteryProhibited
    Closed
  • Sports bettingProhibited
    Closed
  • Other event betting
    Not yet assessed
  • Horse and greyhound racing betting
    Not yet assessed
  • Esports bettingProhibited
    Closed
  • Exchange betting
    Not yet assessed
  • Pool betting
    Not yet assessed
  • Virtual event betting
    Not yet assessed
  • Fantasy sportsProhibited
    Closed
  • Skill gamesProhibited
    Closed
  • Prediction markets
    Not yet assessed
  • SweepstakesProhibited
    Closed
  • Free play
    Not yet assessed

Supply roles

  • Software / B2BProhibited
    Closed
  • Affiliate marketingProhibited
    Closed
  • Payments for gamblingProhibited
    Closed

Settlement rail

  • Crypto gamblingProhibited
    Closed

No class-level certainty grade is recorded for this jurisdiction yet; confidence is carried per section below.

Board briefing

KM-A (Anjouan) baseline established: gambling remains nationally prohibited and no 'Anjouan' licence is recognised by the Union of the Comoros.

What has changed

  • BCC's 8 December 2025 communique disavows the Anjouan Offshore Finance Authority and Anjouan Corporate Services, confirming no online gaming licence has been issued nationally, consistent with the GIABA May 2024 MER's finding that gambling is prohibited in the Union of the Comoros.

What to do now

  • Treat any 'Anjouan' gaming licence as a contested, unrecognised credential; apply enhanced due diligence to any counterparty, payment rail, or corporate agent with an Anjouan nexus; do not rely on claimant domains for tier classification or compliance sign-off.

What to watch

  • Any future Union-level gambling statute or BCC guidance that formally addresses online gaming (none currently exists); continued BCC communique cadence (2014, 2019, 2022, 2023, 2025 pattern) signalling ongoing claimant activity.

11 answers, each dated and graded

The weather grades favourability for an operator, not legality: legality is the product table above. The left rule is our confidence: solid confirmed, dashed probable, dotted uncertain.

01 · What kind of market is this?

Comoros Gambling — Overview

Unfavourable

The Union of the Comoros maintains a national prohibition on casinos and gambling establishments, confirmed by the FATF/GIABA Mutual Evaluation Report of May 2024, while a separate and unrecognised island-level licensing apparatus operating under the Anjouan Gaming, Anjouan Offshore Finance Authorit…

Full analysis · 131 words

The Union of the Comoros maintains a national prohibition on casinos and gambling establishments, confirmed by the FATF/GIABA Mutual Evaluation Report of May 2024, while a separate and unrecognised island-level licensing apparatus operating under the Anjouan Gaming, Anjouan Offshore Finance Authority, and Anjouan Corporate Services names continues to market itself abroad. The Union government and the Central Bank of the Comoros, exercising exclusive constitutional competence over financial and gaming legislation under Article 9 of the Union Constitution and Organic Law No. 05-003/AU, have disavowed that apparatus as carrying no legal standing. As at late October 2026 the government has escalated from disavowal to seeking cooperation from UK police and financial-intelligence bodies, and is reported to be preparing domestic legal action, marking a materially more active posture than the earlier communiqué-level position.

  • National prohibition of gambling confirmed by GIABA MER (May 2024)
  • Central Bank disavowal of the Anjouan Offshore Finance Authority and related claimant bodies (8 Dec 2025)
  • No designated supervisory authority for the casino/gambling DNFBP category in practice
  • Historical pattern of BCC legal action and international rogatory commission against Anjouan offshore financial claimants
Confirmed · AI-generated · Read full analysis & tables →
Unfavourable

Legislative competence over banking, financial, and gaming matters is reserved exclusively to the Union government and the Central Bank of the Comoros under Article 9 of the Union Constitution and Organic Law No. 05-003/AU. Anjouan island-level bodies, including the self-styled Anjouan Offshore Fina…

Full analysis · 134 words

Legislative competence over banking, financial, and gaming matters is reserved exclusively to the Union government and the Central Bank of the Comoros under Article 9 of the Union Constitution and Organic Law No. 05-003/AU. Anjouan island-level bodies, including the self-styled Anjouan Offshore Finance Authority and Anjouan Corporate Services, have no constitutional competence to create financial or gaming law or to issue a nationally recognised gambling licence. The Central Bank's communiqué of 8 December 2025 stated plainly that no online betting or gaming licence had been issued in the Comoros, directly disavowing the bodies marketing Anjouan-branded licences. This constitutional allocation of competence is the legal basis for the government's position that the Anjouan licensing chain was never capable of lawful existence, a position reinforced by the escalation toward active cross-border enforcement-seeking reported since October 2026.

Confirmed · AI-generated · Read full analysis & tables →
08 · What must the platform meet?

Comoros Gambling — Technical compliance

Unfavourable

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 cert…

Full analysis · 123 words

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. This is distinct from the general offshore-banking website actions the Central Bank of the Comoros has historically pursued against Anjouan financial claimants, which address financial-licensing status rather than technical gaming-system standards. No gambling-specific ISP or DNS interdiction was evidenced in the research reviewed. An operator citing technical certification under the claimant 'Anjouan' licensing scheme would be citing a certification with no corresponding national technical authority behind it.

Probable · AI-generated · Read full analysis & tables →
09 · Can we ship through apps and platforms?

Comoros Gambling — Distribution and platforms

Unfavourable

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 a…

Full analysis · 115 words

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. A distribution platform or affiliate network relying on the 'Anjouan' credential as evidence of regulatory legitimacy is relying on a credential the issuing jurisdiction's own central bank has stated carries no authority to issue licences.

Uncertain · AI-generated · Read full analysis & tables →
10 · How hard does the regulator enforce?

Comoros Gambling — Enforcement

Unfavourable

Enforcement posture has escalated materially. The Union government is reported, as at 19 October 2026, to be seeking cooperation from UK police and financial-intelligence bodies regarding the Anjouan gambling-licensing network, and to be preparing domestic legal action, naming British nationals, tho…

Full analysis · 137 words

Enforcement posture has escalated materially. The Union government is reported, as at 19 October 2026, to be seeking cooperation from UK police and financial-intelligence bodies regarding the Anjouan gambling-licensing network, and to be preparing domestic legal action, naming British nationals, though no Comoros court filing has yet been located to evidence that action. This follows the Central Bank's earlier communiqué of 8 December 2025 disavowing the unrecognised Anjouan Offshore Finance Authority and Anjouan Corporate Services. Independently, Sweden's Spelinspektionen issued an immediate prohibition order on 28 October 2026 against Immortal Snail LLC, operator of duel.com, an Anjouan-licensed platform, for targeting Swedish consumers without a licence recognised there. Together these developments show enforcement risk broadening from a single disavowing statement to concurrent multi-jurisdictional action, with the Comoros dispute and foreign regulatory enforcement now proceeding on separate but reinforcing tracks.

Confirmed · AI-generated · 3 enforcement events · Read full analysis & tables →
Evidential record & source register 1 enforcement · 5 red flags · 9 sources · Expand full record

Enforcement record

What the regulator has actually done, newest first. 1 recorded event.

  1. 8 Dec 2025
    Banque Centrale des Comores · Entities claiming unrecognised financial/institutional status linked to the Union of the Comoros, including Anjouan-based claimant bodies
    Confirmed
    Sources

What gets operators fined

5 red flags (3 high, 1 medium) and 3 controls that address them.

  • high
    Payment processor or bank onboarding a counterparty citing a KM-A gaming licence as compliance basis
    No designated national reporting-entity regime for gambling exists in practice; GIABA MER flags weak DNFBP supervision nationally.
    Sources
  • high
    Counterparty relies on a claimant domain as proof of good standing
    Claimant domains are excluded from T1/T2 tiering; no official Anjouan gaming instrument text has been located despite repeated search.
    Sources
  • high
    Use of Anjouan-registered entities for payment rails
    Historical pattern of BCC legal action and international rogatory commissions against Anjouan offshore financial entities signals elevated correspondent-banking and sanctions-screening risk.
    Sources
  • medium
    Player disputes arising from an operator licensed only by the unrecognised Anjouan bodies
    No national ADR, regulator, or enforcement body exists to hear player complaints against a Comoros-nexus operator; redress is effectively unavailable.
    Sources
  • critical
    Operator or supplier claims to hold an 'Anjouan' gaming licence from the Anjouan Offshore Finance Authority or 'Anjouan Gaming' board
    The Union of the Comoros' central bank states these bodies are not recognised and have no authority to issue licences; treating the claim as a credential exposes counterparties to misrepresentation and AML/reputational liability.
    Sources

Controls

  • 001
    Licence-claim verification protocol
    Verify any 'Anjouan' gaming licence claim against the BCC's published disavowal communique before onboarding.
    Sources
  • 002
    Correspondent-banking enhanced due diligence trigger
    Apply enhanced due diligence to any payment rail touching an Anjouan-registered corporate or financial services agent.
    Sources
  • 003
    DNFBP-gap compensating control
    Given unimplemented national DNFBP supervision of casinos/gambling, apply the counterparty's home/host regulator AML programme as the controlling framework rather than relying on any Comoros-nexus registration.
    Sources

Worked scenarios

5 entry scenarios, each with the move we would make.

A PSP is asked to onboard an online casino operator presenting an 'Anjouan Gaming' licence citing the Betting and Gaming Act 2005.

The BCC's 8 December 2025 communique states that such bodies are not recognised in the Union of the Comoros and have no authority to issue licences; no online gaming licence has been issued nationally.

Do this: Decline to treat the licence as a valid regulatory credential; apply unlicensed/high-risk onboarding controls or decline the relationship.

Sources

A law firm is asked whether a B2B software supplier can lawfully supply platform technology to an 'Anjouan'-licensed operator.

No statutory B2B licensing pathway exists in the Union of the Comoros; gambling is prohibited nationally per GIABA MER (May 2024).

Do this: Advise the client that no lawful B2B licensing pathway exists and that supply would carry AML/reputational exposure.

Sources

An affiliate marketer is asked to promote an operator's 'Anjouan licence' as a trust signal.

GIABA MER confirms national gambling prohibition; BCC communique confirms the claimed licensor has no authority to issue licences.

Do this: Do not represent the licence as a lawful credential; flag as a false-credential-marketing red flag.

Sources

A compliance team is screening a corporate structure that lists an Anjouan-registered 'Corporate Services' agent as registered agent for an online gambling brand.

Historical pattern of BCC action against offshore corporate/financial service providers on Anjouan, including court actions and an international rogatory commission.

Do this: Treat as elevated correspondent-banking/sanctions-screening risk and escalate for enhanced due diligence.

Sources

A player disputes a withheld withdrawal from an operator claiming an Anjouan gaming licence and seeks regulatory recourse.

No national gambling regulator or ADR body exists; GIABA MER confirms gambling is prohibited nationally, meaning no state apparatus oversees such disputes.

Do this: Advise the player that no national redress mechanism exists and that the operator's claimed licence carries no recognised regulatory backing.

Sources

What we looked for and could not find

Confirmed absence is a finding of its own. These are the questions we searched and could not answer from a citable source, with the searches we ran. Never behind the paywall.

Market opportunity. no credible market-size or GGR estimate published for the KM-A claimant online-gaming scheme.
  • searched: Anjouan online gambling market size estimate
  • searched: Comoros gambling GGR estimate
  • searched: offshore Anjouan gaming revenue report
  • checked: fatf-gafi.org
Competitive landscape. no published count of operators claiming an Anjouan gaming licence, nor market-concentration data.
  • searched: Anjouan Gaming licensees list
  • searched: Anjouan Offshore Finance Authority licence register
  • searched: number of Anjouan gaming licensees
  • checked: banque-comores.km
Cost to operate. no statutory fee schedule or tax basis exists for a prohibited activity; no Betting and Gaming Act 2005 text was located.
  • searched: Anjouan gaming licence fee schedule
  • searched: Anjouan Betting and Gaming Act 2005 text
  • searched: Comoros gambling tax law
  • checked: banque-comores.km
Operational obligations. no reporting, certification, or RG-operational regime identified.
  • searched: Anjouan gaming regulator reporting obligations
  • searched: Anjouan Gaming board compliance requirements
  • searched: Comoros gambling operator reporting law
  • checked: banque-comores.km
Player protection. no self-exclusion, deposit-limit, reality-check, or age-verification regime identified.
  • searched: Anjouan self-exclusion register gambling
  • searched: Comoros gambling age verification law
  • searched: Anjouan Gaming responsible gambling rules
  • checked: banque-comores.km
Technical compliance. no technical standards body, test lab, or RNG certification regime identified; no evidence of gambling-specific ISP/DNS interdiction.
  • searched: Anjouan Gaming technical standards RNG testing
  • searched: Comoros gambling ISP blocking
  • searched: Anjouan gaming board approved test lab
  • checked: banque-comores.km
Distribution platform rules. no app-store or ad-platform policy specific to KM-A claimant gaming brands located.
  • searched: Anjouan gambling app store policy
  • searched: Google Play Anjouan gaming apps restriction
  • searched: Anjouan gaming affiliate rules
  • checked: banque-comores.km
Data protection. no dedicated Comorian data-protection statute or supervisory authority identified.
  • searched: Comoros data protection law
  • searched: Union of Comoros personal data law 2024
  • searched: Anjouan data protection authority
  • checked: banque-comores.km
Consumer protection. no gambling-specific consumer-law framework, ADR body, or complaint-escalation path identified.
  • searched: Comoros consumer protection law gambling
  • searched: Anjouan gaming dispute resolution
  • searched: Comoros consumer regulator gambling complaints
  • checked: banque-comores.km
Aml cft regime. reporting threshold and practical implementation of the DNFBP designation for casinos/gambling remain unclear beyond the GIABA MER's general finding of non-implementation.
  • searched: Comoros Law 12-008 AML DNFBP threshold
  • searched: Comoros FIU gambling reporting threshold
  • searched: GIABA Comoros casino supervision
  • checked: fatf-gafi.org

Source register

Every source on a four-step tier scale. A claim is never shown at a stronger tier than the source it cites.