Enforcement: How hard does the regulator enforce?

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.