Anjouan Gambling License
cost, requirements & application

€17,828

2-4 Weeks

0%

B2C & B2B

2 domains

FATF

Anjouan License – Key Facts

License TypeB2C and B2B
Issuing AuthorityALSI
Governing LawCGL Act 007 of 2005
Application Fee€17,828 license fee
Annual Renewal€17,828
Tax on GGR0%
License Validity1 year, renewed annually
Typical Timeline2–4 weeks
Eligible ApplicantsAnjouan or recognized offshore operating company

EXECUTIVE SUMMARY

The Anjouan license in ninety seconds

Anjouan issues a single umbrella internet gaming license covering casino, sportsbook, poker, bingo, lottery, fantasy sports and esports under one permit and one annual fee of €17,828. Tax on gross gaming revenue is 0%. There is no local director requirement, no resident Key Person requirement and no physical office requirement — the three obligations that turned the Curaçao LOK transition into a multi-month, €47,450-per-year exercise.

The regime runs under the Computer Gaming Licensing Act 007 of 2005. The Anjouan Offshore Finance Authority (AOFA) owns the AML/CFT perimeter and the prohibited-jurisdictions list. Anjouan Licensing Services Inc. (ALSI) has administered applications, due diligence, issuance and renewals since May 2023. The Anjouan Gaming Board (AGB) sets license conditions, maintains the public register and license validator, and approves the ADR provider list.

Two rules changed the compliance profile since mid-2025 and most operators have not caught up with either. Since July 2025, every B2B supplier serving an Anjouan licensee must hold a full B2B License or an approved B2B License Recognition Certificate — enforced against the operator, not only the supplier. And every licensee must now designate an Authority-approved ADR provider and name it in player-facing Terms and Conditions, with a 30-day internal resolution clock. Both are covered in full below.

Anjouan does not reach the EU or the UK. Nothing offshore does. What it buys is speed, cost and a license in your own corporate name.

WHO WE ARE

We can help you incorporate and obtain the Anjouan Gambling License

COST REGISTER · YEAR 1

What a Anjouan license actually costs in year one

Most Anjouan pages quote “€17,828” and let the reader assume that is the number. It is the government fee and nothing else. Below is the full register, separated into what ALSI charges, what third parties charge, and what we charge.

LINE ITEMYEAR 1YEAR 2 ONWARDPAID TO
Anjouan License Fee (B2B or B2C)€17,828€17,828ALSI
Due diligence & compliance review€1,700 – €3,700Included in renewal reviewALSI
Key Person Authorization€2,000/person€2,000/personALSI
Additional operational domains€500 each€500 eachALSI
Operating company formation & registered agent€3,750€3,750Agent
Policy pack — AML/CFT, KYC, RG, virtual assets, T&CsFixed feeRenewal feeSzilaghi Consulting
ADR provider designation & integrationFixed feePer-case costs borne by operatorApproved ADR provider
RNG / game certification (proprietary content)Per test house quoteRe-certification on changeTest house
Application management & regulatory liaisonFixed feeRenewal feeSzilaghi Consulting
Indicative Year 1€24,200 – €32,000€22,000 – €27,400

Government and third-party costs. Last verified: 11 September 2026.

WHAT THE PUBLISHED TOTALS LEAVE OUT

Two items are missing from almost every Anjouan cost page. Key Person Authorisation is per person, not per license — a three-director structure is €6,000 a year, not €2,000. And the government fee is non-refundable regardless of outcome. A refused application does not return €17,828. That is the entire argument for not filing until the ultimate beneficial owner file is complete, and it is why we do not submit on a client’s behalf until it is.

DUE DILIGENCE SURCHARGES

The €1,700–€3,700 band is not arbitrary. It moves with the ownership chain. A single natural-person shareholder sits at the bottom; a structure involving a trust, a foundation, a nominee arrangement or three or more corporate layers sits at the top, and adds one to two weeks of review. Any nominee, trust or foundation in the shareholding must be disclosed — it is a license condition, not a filing preference, and undisclosed layers surfaced during review are the most reliable way to convert a four-week file into a refusal.

REGULATORY FRAMEWORK

AOFA, ALSI and the Computer Gaming Licensing Act 007 of 2005

Three bodies perform distinct functions, and operators routinely file into the wrong one. AOFA is the parent financial services authority: AML/CFT supervision, the prohibited-jurisdictions list, and the framework within which gaming licenses sit. ALSI is the administrator — applications, due diligence, issuance, renewals. Your dossier goes to ALSI. The Anjouan Gaming Board sets license conditions, runs the public register and license validator, and approves the ADR provider list.

The statutory basis is the Computer Gaming Licensing Act 007 of 2005, and the license itself is a single instrument rather than a set of vertical permissions. One license, one fee, every vertical.

LICENSE CLASS 1

B2C Operator License

€17,828 issuance · €17,828 annual renewal. Authorizes online casino, sportsbook, poker, bingo, lottery, fantasy sports and esports under one permit. Licensed activity may take place only on domains approved by the Authority; additional operational domains are €500 each and must be approved before use. The licensee’s registered corporate name, license number, approved domains, status and contact details appear on the public license validator.

LICENSE CLASS 2

B2B Supplier License

€17,828 issuance · €17,828 annual renewal — the same schedule as B2C. For platform, software, aggregation and technical service suppliers to licensed B2C operators. Suppliers already licensed in a recognized jurisdiction — Malta, Isle of Man, Curaçao, Romania Class 2 — may instead take the lighter B2B License Recognition Certificate at approximately €9,500 per year, which recognizes the existing license and applies Anjouan-specific conditions on top.

Both classes are valid for one year, renew on the anniversary of issuance, and are published in NOGA’s public registry — the verification point your payment partners and B2B counterparties will actually check.

Full B2B LicenseB2B Recognition Certificate
Annual cost€17,828~€9,500
SuitsNo existing gaming license, or Anjouan as primary supplier authorizationAlready licensed in a recognized jurisdiction
AssessmentFull licensing assessmentRecognition plus Anjouan conditions
StandingStandalone Anjouan supplier licenseRecognition of a license held elsewhere

Core ongoing obligations

  • Use only Authority-approved domains for licensed activity, and file additions, changes and removals before use
  • Maintain accurate representation of license status on all player-facing platforms
  • Hold Key Person Authorisation for every individual in a designated role, renewed annually
  • Maintain beneficial ownership records, including nominees, trusts and foundations, available to the Authority on request
  • Notify the Authority of material changes to the licensed operation
  • Designate an Authority-approved ADR provider and name it in player-facing Terms and Conditions
  • Enforce geo-blocking technically against the prohibited markets list, and monitor AOFA additions to it
  • Hold gaming and transaction data accessible to the Authority on demand, with a mirrored data set to the specification in your issued conditions
  • B2B only: demonstrate commercial rationale for operator contracts and disclose significant cross-border financial flows, including virtual asset settlements

THE JULY 2025 B2B RULE

Since July 2025, every B2B supplier serving an Anjouan-licensed operator must hold a full B2B License or an approved Recognition Certificate. That captures game studios and content providers, platform and turnkey providers, aggregators, RNG and testing vendors, payment service providers and compliance technology suppliers.

The exposure runs to the operator. Contracting an unauthorised supplier is an operator-side condition breach. Before signing a content, platform or payment agreement, request the counterparty’s Anjouan authorisation reference and verify it on the public register. This belongs in procurement, not in legal review after the fact.

THE ADR RULE

Every licensee must designate at least one Authority-approved ADR provider and publish its name and contact details in player-facing Terms and Conditions. Four providers are currently approved: EGIS ADR, Axion ADR, iGaming ADR and CADRE B.V.

You have 30 days to resolve a complaint internally. After that the player may escalate, and you bear the cost of the proceedings. Most providers decline complaints filed more than 12 months after your final response. Three build items before launch: the ADR clause in your T&Cs, a 30-day complaint clock with an audit trail in your support system, and final-response letters that state the escalation route and the 12-month limit.

LICENSING PROCESS

Application to registry listing in four phases

Total: 2–4 weeks for a complete, well-prepared dossier. Incomplete UBO documentation is the number-one cause of delay. Six weeks where the ownership chain runs through trusts, foundations or three or more corporate layers.

Week 1

Phase 1 — Structuring & document preparation

Jurisdictional fit confirmed. Operating entity incorporated. Ownership chain mapped to ultimate natural persons. Personal documents ordered — police clearance certificates are the long pole; order them inside the first 48 hours. Business plan and three-year projections drafted. Banking and acquiring applications opened here, because underwriting runs longer than licensing does.

Week 2

Phase 2 — Technical & compliance file

AML/CFT policy, KYC procedures, responsible gaming policy and virtual asset policy drafted to Anjouan specification. Technical dossier compiled: hosting architecture, security controls, data handling and mirroring, RNG certificates, game content schedule with each supplier’s B2B authorisation reference. Domain ownership evidenced. T&Cs drafted including the ADR clause. ADR provider selected from the approved list.

Week 3

Phase 3 — Submission & regulatory review

Complete dossier filed with ALSI. Government fee paid — non-refundable regardless of outcome. Key Person Authorisation applications lodged in parallel, not after issuance, which is the most common self-inflicted delay on this route. Due diligence on directors, shareholders and ultimate beneficial owners; source-of-funds review; technical assessment. We handle requests for information directly, on a same-day cycle — that cycle is what keeps a file at the four-week end of the range rather than the six.

Weeks 3-4

Phase 4 — Approval, registry listing & seal integration

License issued. Entry appears on the public register and license validator. Approved domains confirmed. License credentials and ADR details published on the player-facing site. Banking and PSP onboarding completes against the issued license.

DOCUMENTATION

The complete compliance checklist

Every document in English or accompanied by a certified translation, certified in ink, and dated within 90 days where the document type allows. The Authority may request further documentation at any stage; incomplete submissions cause delay or refusal.

FILE / 01 KYC & UBO documentation

Each director, shareholder, UBO and Key Person:

  • Government-issued identification, certified copy
  • Proof of residential address, dated within 90 days
  • Police clearance or certificate of good conduct
  • Signed curriculum vitae
  • Banker’s reference letter
  • Professional reference letter
  • Source of funds declaration with supporting evidence
  • Signed personal declaration

FILE / 02 Corporate file

  • Certificate of incorporation, certified copy
  • Memorandum and Articles of Association
  • Current register of shareholders and directors
  • Certificate of Good Standing
  • Full ownership chain to the ultimate beneficial owner where the applicant sits inside a group
  • Disclosure of any nominee, trust or foundation in the shareholding structure

FILE / 03 Financial

  • Audited financial statements where available
  • Bank references
  • Source of funds evidence sufficient to demonstrate financial standing for the proposed operation
  • Business plan with three-year financial projections

FILE / 04 Technical & operational

  • Gaming content schedule and supplier list, each with the supplier’s Anjouan B2B authorisation reference
  • RNG certification for proprietary and licensed game content
  • Technical dossier: hosting architecture, security controls, data handling and mirroring
  • Domain ownership proof for every operational URL
  • Terms and Conditions, including the named ADR provider clause
  • AML/CFT policy and KYC procedures
  • Responsible gaming policy
  • Virtual asset policy where crypto is accepted: wallet custody, conversion, blockchain analytics and sanctions screening

FOR B2B SUPPLIERS

Your technical file is built on game certifications and executed supply agreements, plus KYC for every director and beneficial owner at 10% or above, a product and service description, and disclosure of significant cross-border financial flows including virtual asset settlements. You will also be asked to demonstrate the commercial rationale for your operator contracts. A supplier with current RNG certificates and signed agreements in hand is the fastest file this jurisdiction processes.

LIMITS OF THE LICENSE

What you cannot do, and what happens if ALSI says no

GEO BLOCKING

Markets you must block

Enforcement must be technical — at IP level and at payment level. A clause in your Terms and Conditions is not compliance, and an acquirer will usually find the gap before the regulator does.

  • United States, United Kingdom, France, Germany, Netherlands, Spain, Austria, Australia
  • Comoros Islands, including Anjouan itself
  • All FATF blacklisted jurisdictions
  • Any jurisdiction subsequently prohibited by AOFA

That final line is the operational one. The list is not static. Configure geo-blocking so a territory can be added in a single operation, and review the AOFA prohibition list at every renewal rather than at every incident.

REFUSAL

If the application is refused

  • The €17,828 is not returned. Application fees are non-refundable regardless of outcome
  • The most common causes are an incomplete UBO file, undisclosed nominee or trust layers surfaced during review, and source-of-funds evidence that does not reconcile with the business plan
  • A refused applicant may re-apply, but the second file is reviewed against the first — which is why a file is worth delaying by a week rather than submitting thin

SUBSTANCE AND TAX · THE PART 0% DOES NOT ANSWER

What the 0% actually means

Anjouan imposes no local director, no resident Key Person and no physical office requirement, and applies 0% to gross gaming revenue. That is the Anjouan position. It is not a statement about your tax position: where the operating company is effectively managed, where its directors sit, and where its revenue is booked determine what your own jurisdiction will assess. Treat the Anjouan license as one entity inside a structure and get the holding layer, IP ownership and inter-company agreements right at the start — retrofitting them after two years of trading is expensive and visible.

LICENSE VERIFICATION

How to confirm an Anjouan license is real

BELOW €17,828 IS NOT A LICENSE

What that actually means

€17,828 is the statutory fee the Authority charges for issuance. It is published, it is not negotiable, and it is not refundable. No intermediary holds a discount on a government fee, because no such discount exists.

When a reseller quotes €6,000, €9,000 or €12,000 “for an Anjouan license,” one of three things is on the table. A sub-license or white-label arrangement — you operate under someone else’s license with nothing in your own corporate name, and when their license is suspended your operation stops the same day with your player balances inside a structure you do not control. A certificate that is not on the register — a document that looks like a license and resolves to nothing, usually discovered at acquirer underwriting after you have paid a setup fee and integrated a platform. Or a deposit, with the government fee invoiced later, once you are committed.

JURISDICTION MATRIX

Anjouan vs Nevis vs Curaçao vs Kahnawake vs Malta

METRICANJOUANNEVIS (NOGA)CURACAO (GCB)KAHNAWAKEMALTA (MGA)
REGULATORAOFA / ALSINOGACGAKGCMGA
FRAMEWORKComputer Gaming Licensing Act 007 of 2005Nevis Online Gaming Ordinance 2025LOK, effective 24 December 2024Kahnawake Gaming LawGaming Act 2018
APPROVAL TIME2-4 Weeks8–12 weeks3–6 months (post-LOK backlog)6 months6–12 months
ANNUAL GOV. FEE€17,828€28,000€47,450 (€24,490 Treasury + €22,960 CGA)USD 20,000 from year 2 (USD 40,000 year 1)€25,000+ plus compliance
contribution & gaming tax
TAX ON FOREIGN GGR0%0%0% GGR tax; corporate tax rules apply0%15% on on Maltese players, plus monthly compliance contribution €15,000–€25,000
BANKING/PSP ACCESSCrypto-native and tier-2 acquirers; tier-1 EU generally needs an EU licenseEU/UK EMIs and merchant acquiring; broader than AnjouanBroad, historically entrenchedStrong for North America-adjacent processingStrongest — full EU acceptance
LOCAL SUBSTANCENoneNevis IBC or NBCO, Reporting OfficerLocal managing director from grant, statutory seat, MLRO and Compliance Officer; resident Key Persons and office phasing in 2028–2029Gaming equipment hosted by the sole IGL holder, Mohawk Internet TechnologiesShare capital up to €100,000, verticals approved individually
BEST FORStartups, crypto-first brands, fast launches, B2B suppliers, Curaçao migrantsOperators & B2B suppliers
wanting credibility without EU cost
Operators contractually required to hold CuraçaoNorth America-adjacent processing needsEU-facing brands with capital and a nine-month runway

Where Nevis sits: Anjouan is the entry point, and it is honest about being one. It sits below Nevis on banking credibility and below Malta on market access, and it beats both on cost and speed by a wide enough margin that the comparison is rarely close for an operator still proving a product.

The sharpest comparison is Curaçao. The LOK reform replaced sub-licensing with direct issuance by the Curaçao Gaming Authority, and the 0% GGR outcome survived while the cost and the timeline did not: a roughly €20,000 sub-license became a €47,450 annual supervisory relationship with a local managing director, a statutory seat, an MLRO, a dedicated Compliance Officer, and resident Key Persons and a physical office phasing in through 2028–2029. Anjouan reaches the same tax position for 38% of the Curaçao annual fee, with no local substance and a timeline measured in weeks. That gap is why migration out of Curaçao is one of the most common instructions we handle in 2026.

One correction worth making, because competitors lean on it: the Union of the Comoros is not on the FATF grey list and is not subject to a call for action as of the FATF’s June 2026 statement. Anjouan’s banking constraint is acquirer appetite and jurisdictional familiarity, not an AML listing.

PAYMENTS & BANKING

What the license actually buys: onboarding outcomes

A license certificate does not process a deposit. Operators who buy licensing as a standalone product find this out at acquirer underwriting, four to six weeks after they expected to launch. We open banking and acquiring in Phase 1 and close them against the issued license in Phase 4.

UNLOCKED / 01

Corporate banking and EMIs

Offshore gaming banking is a relationship business across a narrow field of institutions. We prepare the pack a compliance committee actually reviews — structure chart, source of wealth, projected flows, AML/CFT manual, flow-of-funds diagram and processing history where available — and introduce you to institutions onboarding Anjouan licensees now, rather than to a list that was accurate two years ago.

UNLOCKED / 02

Merchant acquiring

Card acquiring and alternative payment methods matched to your target markets and projected volumes. The underwriting pack covers license verification against the public validator, chargeback history, documented evidence of geo-blocking configuration, and responsible gaming controls.

UNLOCKED / 03

Crypto-fiat gateways

The segment where Anjouan’s cost and speed advantage is widest, because tier-1 EU acquiring was never part of the plan. Gateways expect a documented virtual asset policy and blockchain analytics screening before they will quote.

UNLOCKED / 04

B2B contracting

A verifiable Anjouan authorization is what lets aggregators and platform providers contract with you at all after July 2025. Suppliers without one are being dropped from operator content schedules, not negotiated with.

What it does not unlock: US-facing processing, UK-facing processing, or any market on your geo-block list. No offshore license does — and any provider implying otherwise is selling you a chargeback problem.

PRACTICAL NOTE FROM OUR FILES

The pack an EMI asks for is consistent across institutions: license certificate, register extract from the public validator, AML/CFT manual, flow-of-funds diagram, and processing history where available. Operators who assemble it after the license issues lose three to five weeks. Operators who assemble it in Phase 2 go live the week the license lands. The document set is identical either way — only the sequencing differs, and the sequencing is the whole cost.

CRYPTO OPERATIONS

Running a crypto casino under NOGA

Anjouan permits crypto deposits and withdrawals under the license. That is the easy part, and it is where most providers stop explaining. What matters operationally is the four things underneath it.

01

Your AML programme has to cover chain analytics

The license permits crypto-denominated gaming; the conditions require you to control it. Full KYC and AML/CFT procedures apply to crypto deposits and withdrawals, with blockchain analytics screening and source-of-funds verification at defined thresholds.

02

The virtual asset policy belongs in the dossier

Wallet custody, conversion mechanics, sanctions screening and threshold triggers, drafted into the application rather than retrofitted when a gateway asks. B2B licensees additionally disclose significant cross-border financial flows including virtual asset settlements — the conditions name this expressly.

03

Fiat off-ramping is the real constraint

The gaming side is straightforward; converting and banking the proceeds is where structures fail underwriting. Model the off-ramp before you model the product.

04

Provably fair does not replace certification

A provably fair mechanism is a player-trust feature, not a substitute for RNG certification on the content in your game schedule. Both go in FILE / 04.

WRITTEN AND REVIEWED BY

Alex Szilaghi · Founder, Szilaghi Consulting

Over two decades in gambling licensing and corporate structuring across offshore and EU jurisdictions, including Romanian ONJN Class 1 and Class 2 licensing, Curaçao and Curaçao LOK transitions, Nevis, Anjouan and Malta. Szilaghi Consulting acts for operators and B2B suppliers as licensing counsel, corporate service provider and ongoing compliance function.

This page is maintained against the Authority’s published fee schedule, license conditions and approved ADR provider list. Last reviewed September 2026. Statutory fees and conditions are set by AOFA and ALSI and are subject to change — confirm current figures before submission. General information, not legal advice; no advisory relationship is created by reading it.

QUESTIONS

Frequently asked questions

How much does an Anjouan gambling license really cost?

The government fee is €17,828 for issuance and €17,828 for annual renewal, identical for B2C and B2B. That is the fee, not the cost. A realistic Year 1 total is €24,000–€32,000 once due diligence (€1,700–€3,700), Key Person Authorisation (€2,000 per person), company formation, the policy pack, ADR designation and application management are included. Additional operational domains are €500 each. The full register is above.

How long does an Anjouan license really take?

Two to four weeks from submission on a complete file — document preparation five to ten working days, regulatory review two to three weeks, issuance within days of approval. Six weeks where the ownership chain runs through trusts, foundations or three or more corporate layers. Incomplete UBO documentation is the single most common cause of delay, and police clearance certificates are the item that should be ordered on day one.

Do B2B suppliers need an Anjouan license?

Yes. Since July 2025 every B2B supplier serving an Anjouan licensee must hold a full B2B License (€17,828/yr) or an approved B2B License Recognition Certificate (~€9,500/yr). That captures game studios, content providers, platform and turnkey providers, aggregators, RNG and testing vendors, payment service providers and compliance technology suppliers. The operator carries the exposure for contracting an unauthorised supplier, so verification belongs in procurement.

What is the ADR requirement and which providers are approved?

Every licensee must designate at least one Authority-approved ADR provider and name it, with contact details, in player-facing Terms and Conditions. Four are approved: EGIS ADR, Axion ADR, iGaming ADR and CADRE B.V. You resolve internally within 30 days, after which the player may escalate; you bear the cost of the proceedings; most providers decline complaints filed more than 12 months after your final response.

Can I target the US, UK or major EU markets?

No. Anjouan licensees must geo-block the United States, United Kingdom, France, Germany, Netherlands, Spain, Austria, Australia, the Comoros Islands including Anjouan itself, all FATF blacklisted jurisdictions, and any territory subsequently prohibited by AOFA. Enforcement must be technical, at IP and payment level. No offshore license reaches those markets — if your revenue plan depends on them, Malta is the conversation.

Do I need to live in Anjouan, or open an office there?

No. There is no local director requirement, no resident Key Person requirement and no physical office requirement. This is the principal operational distinction from the Curaçao LOK regime and the reason the total cost of ownership gap is wider than the headline fee gap suggests. You must appoint Key Persons holding Authority-issued Key Person Authorization, but they are not required to reside in Anjouan.

What happens if the application is refused?

The €17,828 is not returned — application fees are non-refundable regardless of outcome. Re-application is possible, but the second file is reviewed against the first. This is the entire case for not submitting until the UBO file, the source-of-funds evidence and the disclosure of any nominee, trust or foundation layers are complete.

How does renewal work?

Annually, at €17,828, payable before the renewal date, alongside Key Person Authorization renewals at €2,000 per person. Beneficial ownership records must be current and available to the Authority on request, material changes notified, and domain additions or removals filed and approved before use. We handle renewal as a retainer item rather than as an annual emergency.

Is Anjouan better than Nevis?

Different tools. Nevis costs €28,000 a year against Anjouan’s €17,828 and takes 8–12 weeks against 2–4, and buys measurably broader banking and EMI acceptance. Anjouan is the right call when speed and cost decide the launch, when the payment stack is crypto-first, or when you are migrating off Curaçao and need continuity now. Nevis is the right call when an EMI or acquirer relationship is the gating factor for the whole business. Operators frequently start on Anjouan and add Nevis at scale.

Is Anjouan a viable alternative to the Curaçao LOK license?

For most startup and mid-market operators, yes. LOK, effective 24 December 2024, replaced sub-licensing with direct CGA issuance: €4,592 application fee, €47,450 annual license fee, a local managing director from grant, a Curaçao statutory seat, a dedicated MLRO and Compliance Officer, and a three-to-five-month timeline. Anjouan reaches the same 0% GGR outcome at €17,828 with no local substance in two to four weeks. If a partner or payment provider contractually requires Curaçao, keep it. Otherwise model Anjouan first.

Can I migrate an existing license to Anjouan?

Yes, and it runs in parallel with your existing license, so there is no dark period. Migration covers re-papering supplier agreements to the new licensee, updating T&Cs including the ADR clause, re-verifying domain approvals, notifying payment providers and re-running acquirer underwriting against the new license, and reconfiguring geo-blocking to the AOFA prohibition list. Six to eight weeks end to end, of which licensing is the fastest component.

Does an Anjouan license allow crypto gambling?

Yes, and the B2B conditions expressly contemplate disclosure of virtual asset settlement flows. Full KYC and AML/CFT apply to crypto deposits and withdrawals, with blockchain analytics screening and source-of-funds verification at defined thresholds, and a documented virtual asset policy covering custody, conversion and sanctions screening belongs in the application dossier rather than in a later remediation.

Is the Comoros on the FATF grey list?

No. As of the FATF’s June 2026 statement on jurisdictions under increased monitoring, the Union of the Comoros is not grey-listed and is not subject to a call for action. Anjouan’s banking constraint is acquirer appetite and jurisdictional familiarity, not an AML listing — a distinction competitors selling more expensive jurisdictions tend to blur.

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