Most gambling operators first hear one figure when they look at an Anjouan gaming license: 17.000 Euro. That amount is correct, but it covers only part of the real cost. Operators also face recurring fees, payment costs and limits on the markets they can enter. In our earlier article Anjouan Gambling License: How does it work? we explained what the license is and how the application process works.
This article looks at the issue from another angle. We examine what operators actually pay after adding recurring fees and payment costs. We also look at restricted markets, the parties behind the license and the risks when problems arise. The advertised price alone gives an incomplete picture.
What does an Anjouan gaming license actually cost?
The headline number. The published application fee is 17.000 Euros. The regulator lists this amount, as do many licensing consultancies. However, operators should view it as an entry cost rather than the full operating budget.
The real first-year invoice. After approval, several additional costs follow:
- License application: 17.000 Euros
- Initial compliance and due diligence review: 1.700 Euros
- Annual key-person authorization: 2.000 Euros
- Each additional domain: 500 Euros
- Complex corporate structure surcharge: 250 to 500 Euros
- B2B supplier license, for software and platform providers, required since July 2025: 9.500 Euros per year
These charges bring the realistic first-year cost for a standard B2C operator to around 21.000 to 22.000 Euros. That figure applies before the operator processes a single payment. A second domain, a more complex holding structure or a B2B software layer can quickly push the total above 30.000 Euros.
What happens after year one. The operator must renew the license every year. The annual fee also remains substantial:
| Year | Cost item | Approximate amount |
|---|---|---|
| Year 1 | Application + compliance review + key-person fee | 20.700 Euros |
| Year 2 | Renewal + key-person fee | 15.300 to 17.000 Euros |
| Year 3 | Renewal + key-person fee | 15.300 to 17.000 Euros |
| 3-year total | Excluding domains, structure surcharges and B2B fees | ≈ 51.300 to 54.700 Euros |
Over three years, the direct licensing costs remain significant. Curacao’s B2C fee increased to around 47.450 Euros per year after the licensing reform of 24 December 2024. A comparison based only on licensing fees, however, does not account for the wider regulatory and operational risks discussed below.
The cost the fee schedule does not show you
Higher payment processing costs
Payment processing: the real line item. An Anjouan license does not provide access to the same payment infrastructure as Malta, Curacao or the Netherlands. Stripe and PayPal will not process this business. Major card acquirers such as Worldpay, Adyen and Checkout.com also stay away. Most EU and UK-regulated payment providers take the same approach.
That leaves operators with specialist offshore processors and, increasingly, crypto rails. These options cost much more. Specialist offshore processors typically charge 8 to 12 percent per transaction. Operators in a Tier 1 jurisdiction may pay roughly 2 to 3 percent instead. At meaningful transaction volumes, this difference can become the largest recurring cost. It can easily exceed the annual license fee.
Limited access to banking
Banking: when no one will hold your account. Very few banks will directly open an account for an Anjouan gambling company. Caribbean correspondent banks have gradually reduced their exposure to the sector. European banks that once accepted more offshore gambling clients have also become more selective.
Some operators therefore use several companies and multiple banking relationships to keep funds moving. This structure creates extra legal and administrative costs. Those expenses come on top of the higher payment processing fees.
A decision that appears to cost 17.000 Euros can therefore affect the operator’s entire payment and banking structure. Those consequences continue for as long as the operator uses the license.
Behind the license: who is actually selling it?
The organizations involved
A gambling license also carries the reputation of the organization that issues it. For that reason, operators should understand who manages the Anjouan system. Anjouan Licensing Services Inc. (ALSI) processes applications and was established in May 2023. The older Anjouan Offshore Finance Authority (AOFA) directs applicants to a “sole authorised” agent, Anjouan Corporate Services. Operators use that agent to purchase the license. Neither organization publishes its directors or board members on its own website.
What the ABC News investigation found
An ABC News investigation published in December 2025 examined the people connected with these organizations. It found domain records showing that Fast Offshore registered the websites of Anjouan Licensing Services in May 2023. Fast Offshore is a Costa Rican consultancy run by Canadian Ron Mendelson.
Mendelson has also published articles that promote the same license his company helps clients obtain in “just days.” The investigation also examined Anjouan Corporate Services. It identified Ronnie Dvorkin, a British national in his late seventies. A Comoros vice-president had already raised his historical connection in 2007.
The investigation also named Adam Dvorkin, Elliot Sorsky and Toby Sorsky. They represented the entity at an industry conference in Dubai in 2025. None of these facts proves wrongdoing by itself. However, they provide more context than the neutral government-agency image often associated with the license. Operators should understand that structure before entering into a contract with either party.
The cost of the markets you cannot enter
Markets named by the regulator
The Anjouan Gaming Control Board lists several markets that license holders may not serve. Each market has its own licensing regime. The board also accepts that an Anjouan license cannot replace local authorization in these jurisdictions:
- United States (UIGEA, Wire Act)
- United Kingdom (UK Gambling Commission)
- France (ANJ)
- Germany (GGL)
- Netherlands (Kansspelautoriteit)
- Spain (DGOJ)
- Australia (Interactive Gambling Act 2001)
- Austria (federal gambling monopoly framework)
The list is not exhaustive
This list does not show every country where the license lacks legal validity. It only names several large markets with active enforcement. Operators should not assume that countries outside the list automatically permit Anjouan-licensed gambling.
An Anjouan license has no legal standing in any jurisdiction outside Anjouan itself. Other countries may have their own gambling laws and regulators. Those authorities can treat an Anjouan-licensed operator as unlicensed and illegal when it serves local residents. This can happen even when the country does not appear in the list above.
The list therefore works better as an overview of markets with a high enforcement risk. It does not define where an Anjouan license becomes legally valid.
Enforcement in regulated markets
The risk of enforcement is not theoretical. The Dutch Kansspelautoriteit publishes periodic updates on its enforcement against illegal gambling offers and maintains public sanction decisions. Several decisions have involved operators using offshore Comoros licensing.
The UK Gambling Commission takes the same general position. Its guidance on unlicensed gambling provision explains that an offshore license creates no right to serve consumers in a regulated market. That principle applies whether the offshore regulator lists the country or not. Every inaccessible market can therefore represent lost revenue that does not appear in a simple fee comparison.
The Leon Casino example
The ABC News investigation provides a practical example. Leon Casino displays an Anjouan license. Australian regulators nevertheless identified it as an illegal operation in early 2025. The casino had targeted Australian consumers through UFC sponsorships and influencer promotions.
Australia’s Interactive Gambling Act 2001 prohibits this type of offer. After ABC journalists asked questions, two payment providers disappeared from Leon Casino’s website. MiFinity was one of them. The case shows how enforcement can create several costs at once. An operator may lose access to a market, face public naming and need new payment providers. The public record can also remain long after the casino brand itself disappears.
The legitimacy question behind the license
Recognition within Comoros
The issue goes beyond the amount an operator pays for the license. It also raises questions about regulatory risk. The same ABC News investigation examined whether institutions in Comoros recognize the organizations issuing these licenses.
The investigation reported repeated rejection from national institutions. The Comoros Central Bank described the organizations behind Anjouan’s offshore licensing as “fictitious structures” with “no physical or legal existence.” A former Comoros attorney-general called Anjouan Licensing Services “an illegal entity.”
Comoros also introduced banking legislation in 2013 and 2015. Those laws removed the Anjouan Offshore Finance Authority’s recognized regulatory status. The investigation further cited a World Bank mission. That mission found that creating offshore banks in Anjouan had been illegal under Comoros law from the start.
The size of the licensing business
The investigation also estimated the scale of the operation. Anjouan Licensing Services says it has issued more than 1.300 gambling licenses. At roughly 17.000 Euros per license each year, this could produce annual revenue of up to 22 million Euros.
That revenue goes to a licensing structure that the national government does not recognize as a regulator. Operators should therefore consider what the word “license” means in this context. Here, a private administrator sells the product. That does not automatically provide the level of regulatory supervision that EU operators or players may expect from a license shown in a website footer.
The regulator’s response
Anjouan Gaming has rejected this interpretation. Responding to international criticism through Focus Gaming News in June 2026, the regulator stated that “an Anjouan Internet Gaming Licence is not, and has never been presented as, a universal authorisation to operate in every country.”
The regulator also pointed to AML and KYC checks, technical testing, responsible gambling protocols and sanctions screening. It presented these measures as evidence of an operational compliance system. However, the dispute over whether Comoros itself recognizes the licensing authority remains a matter of public record. That issue directly affects the regulatory risk associated with the license.
What happens if it goes wrong
Payment and banking disruption
License comparisons often stop with the published fees. With Anjouan, later problems can cost more than the license itself. These risks may only appear after an operator has committed to the structure.
A payment processor can end the relationship with little notice. Its compliance team may decide that the license creates too much risk. The operator then needs to rebuild its payment system quickly, often on less favorable terms.
A bank can take similar action and close an account. This can temporarily freeze working capital during transfers. Regulators can also publicly list a brand when traffic reaches restricted markets. Affiliates or gaps in geo-targeting can cause that traffic. Leon Casino provides a practical example of this risk.
Limited options in a dispute
There is also a structural issue. Critics argue that the licensing bodies operate in a legal grey area within Comoros. That can limit an operator’s options when a dispute with the licensor arises.
Such disputes could involve renewal terms, higher fees or sudden changes to requirements. Operators with Malta or Curacao licenses can use established administrative and judicial procedures. An Anjouan operator has a different position. Critics of the regulator argue that its own national government does not fully recognize its authority.
Anjouan gaming license cost: what to think?
The 17.000 Euros headline price should not determine the decision. The wider costs and regulatory risks are more important. Operators should consider several questions before relying on this license:
- Do you plan to serve any market that requires its own license, such as the EU, UK, US or Australia? If yes, an Anjouan license adds nothing there and the cost of eventually re-licensing should be budgeted from day one.
- Have you priced payment processing at 8 to 12 percent, not 2 to 3 percent, into your unit economics?
- Do you have a banking relationship lined up, or a credible plan for one, given how few institutions accept this license directly?
- Are you comfortable that the entity issuing your license is not recognised as a regulator by its own national government, and that you have limited recourse if a dispute arises?
- Is your business model genuinely offshore-only, with no ambition to raise institutional capital, list publicly, or integrate Tier 1 payment providers later?
The direct licensing fee is therefore only one part of the financial exposure. Operators must also account for payment processing charges, banking restrictions and markets that remain closed. Enforcement in regulated jurisdictions can create additional financial and reputational consequences. Changing the regulatory structure later may introduce further costs.
These issues become particularly relevant because an Anjouan license has no legal standing outside Anjouan itself. At the same time, questions remain about recognition of the licensing authority within Comoros. For operators assessing the total cost, these regulatory and structural risks should form part of the calculation rather than being treated as secondary considerations.
Want to know more about gambling licenses in other jurisdictions? Read our blog about the Curacao gambling license, where we cover the application process and the risks for consumers, or go back to Anjouan Gambling License: How does it work? for the full application procedure.
