Africa’s gambling industry is fighting for regulatory credibility. Governments want operators to obtain local licenses, pay taxes, protect consumers and comply with financial regulations. Yet the international offshore gambling market presents a difficult challenge: a license marketed under an African jurisdiction’s name can potentially open doors to operators seeking access to global markets, even the legal authority behind that license is disputed.
The controversy surrounding Anjouan, an island within the Union of the Comoros, raises uncomfortable questions about the commercialization of regulatory identity. Who has the legal authority to issue gambling licenses? Who profits from selling them? And what happens when players, payment providers and business partners rely on a license whose legitimacy is challenged?
Investigation by the Guardian in October 2026 and Australia’s ABC News in December 2025 have brought these questions into sharper focus. Their reporting describes disputed licensing entities, questions over legal authority and a potentially lucrative offshore licensing market. These are serious allegations that require careful examination not assumptions that every operator associated with Anjouan is unlawful.
For Africa, the stakes extend beyond one island. The controversy tests whether the continent can build credible gaming jurisdictions or allow the perception of regulatory weakness to undermine legitimate investment.
The Legal Authority Question
Anjouan’s history is central to understanding the controversy. The island is one of the three main islands constituting the Union of the Comoros, a sovereign state in the Indian Ocean. During a period of separatist rule in the late 1990s and early 200s, an offshore financial licensing structure emerged on the island.
According to ABC News, the Anjouan Offshore Finance Authority (AOFA) continued to appear in the offshore licensing market after Comorian banking legislation passed in 2013 and 2015 removed its recognized regulatory status. The broadcaster also reported that Comorian officials had described certain entities operating under the AOFA name as fictitious or unauthorized.
The issue is not simply whether a website displays a license or cites legislation. It is whether the organization issuing that license has the legal authority to do so.
The 2024 mutual evaluation of the Union of Comoros by the Inter-Governmental Action against Money Laundering in West Africa (GIABA), a Financial Action Task Force -Style regional body, states that gambling is prohibited within the Union under Article 201 and the following provisions of its Penal Code. The assessment also identified deficiencies in aspects of anti-money-laundering supervision.
This creates an important legal question: how do offshore licensing businesses reconcile their claims of regulatory authority with the applicable national legal framework?
The answer requires examination of the legislation, official government notices and relevant court decisions. The existence of an online register or a license certificate cannot, by itself, resolve the question.
A Potentially Lucrative Licensing Economy
The financial incentives are substantial enough to justify closer scrutiny. ABC News reported that Anjouan Licensing Services claimed to have issued more than 1,300 gambling licenses. At an estimated annual price of approximately ₤17,000 per license, the broadcaster calculated potential annual revenue of up ₤22 million. That figure requires careful qualification.
The number of licenses was a claim attributed to the licensing business, while the revenue figure was an estimate based on the reported pricing. Neither should be presented as independently audited revenue or verified profit.
Nevertheless, the reported scale raises significant questions about ownership, financial flows and accountability.
Who receives the fees? Are payments made to companies registered outside the Comoros? What proportion, if any, reaches public authorities? Are there independently audited accounts, identifiable directors and transparent beneficial ownership records?
These are not minor administrative details. In a legitimate regulatory system, licensing fees should sit within a transparent legal and supervisory framework. Applicants should know who regulates them, what obligations they must meet and which authority can suspend or revoke their licenses.
If those fundamentals cannot be established, the commercial value of a license may rest more on its marketing appeal than on demonstrable regulatory protection.
The Player-Protection Test
The most consequential risk falls on consumers who assume that a displayed license offers meaningful recourse. ABC News examined Leon Casino, which displayed an Anjouan license while Australian authorities had identified the operator as operating illegally in that market.
The broadcaster also tested the website’s deposit options and reported that two payment vendors disappeared from the site after questions were sent to them. One of those providers did not respond to the broadcaster’s inquiry. This reporting illustrates the distinction between holding a purported offshore license and being authorized to serve customers in a particular country.
A license issued in one jurisdiction does not automatically authorize gambling in another. Operators may still be subject to local licensing rules, advertising restrictions, consumer-protection requirements and enforcement action.
The consequences can be serious. When disputes arise over withheld winnings, frozen accounts, identity verification or responsible gambling controls, consumers need an identifiable authority with the power to investigate complaints and impose remedies. A logo and license number are not substitutes for an effective complaints process, enforceable consumer rights or independent regulatory supervision.
The Guardian’s October 2026 investigation also examined offshore casinos and their relationship with self-exclusion systems, including GamStop in the United Kingdom. Its reporting raises broader concerns about whether some operators use offshore structures to reach customers who are seeking to restrict their gambling.
The evidence does not establish that every operator displaying an Anjouan license fails to protect consumers. It does, however, justify asking what protection the license actually guarantees and who verifies that those safeguards are being enforced.
The B2B Blind Spot: Who Supplies the Casinos?
The controversy extends beyond consumer-facing gambling websites to the suppliers that power them. In February 2026, Le Monde reported that Relax Gaming, a subsidiary of France’s partly state-owned lottery operator Francaise des Jeux (FDJ) had obtained an Anjouan B2B license to supply gaming software to offshore casinos.
The investigation questioned the legitimacy of the licensing framework and wider ecosystem supported by software suppliers. This raises a difficult question for the international gaming industry: how far should a supplier go in verifying the regulatory status of the operators using its products?
A B2B license does not automatically establish that every casino using a supplier’s software is legally authorized in its target markets. Nor does the reported existence of a disputed license, by itself, establish that a supplier has committed an offence. The commercial issue is diligence. Suppliers, payment processors, banks and affiliates must understand the legal status of their counterparties and assess whether their business relationships expose them to financial, regulatory or reputational risks.
For investors, this matters because regulatory exposure can travel through a business ecosystem. A supplier may not operate the casino itself, yet its software, commercial agreements and distribution arrangements can become part of the security when an offshore market faces questions about legitimacy.
The Anjouan controversy should therefore prompt B2B companies to examine not only where license was obtained but also who issued it, the legal authority behind it and whether the operator is permitted to serve the customer it targets.
What Africa’s Regulators Should Learn
Africa should not allow one disputed offshore licensing framework to define the credibility of its entire gaming industry. The more useful response is to identify the weaknesses that allow regulatory claims to go unverified.
First, regulators should publish searchable registers of authorized operators and suppliers, supported by clear legislation and verifiable license records.
Second, they should make enforcement actions, suspensions and revocations publicly accessible.
Third, regulators should cooperate across borders to investigate unauthorized operators, payment channels and misleading licensing claims.
Fourth, the industry needs stronger due diligence across the supply chain. Gaming studios, platform providers, aggregators and payment processors should verify licensing claims independently rather than relying exclusively on certificates supplied by commercial intermediaries.
Finally, African jurisdictions must demonstrate that regulation is more than a revenue generating exercise. Effective oversight requires competent institutions, transparent ownership checks, anti-money-laundering controls, meaningful player-protection requirements and accessible resolution. These measures are essential to attracting sustainable investment.
Serious operators and institutional investors need predictable laws and credible enforcement. A jurisdiction whose licensing system cannot withstand independent scrutiny risks damaging its own reputation and that of legitimate African markets.
The Anjouan controversy is therefore a test of more than one island’s licensing arrangements. It is a test of whether the global gaming industry is prepared to distinguish genuine regulatory oversight from the appearance of it.
Until that distinction is clear, operators, suppliers, investors and consumers must ask a fundamental question before trusting an offshore license: who stands behind it and what enforceable protection does it actually provide?



