Anjouan Licensing Services Inc background check: Reliability & Risks

An Anjouan Licensing Services Inc background check shows that this entity has been managing license administration on behalf of the Anjouan Offshore Finance Authority since May 2023. The procedure is faster and cheaper than in Curaçao, but the Dutch Financial Supervision Act (Wft) prohibits offering games of chance in the Netherlands without a KSA license. Operators do undergo strict Due Diligence, but for Dutch players, any form of legal protection is lacking with these offshore structures.

The role of Anjouan Licensing Services Inc in regulation

An Anjouan Licensing Services Inc background check reveals that this private entity has acted as the designated administrator for gaming licenses since May 2023, under the supervision of the Anjouan Offshore Finance Authority. For Dutch operators, it is important to know that ALSI is not a direct government body. The company operates within the legal frameworks of the Union of the Comoros, with the legal basis resting on the Computer Gaming Licensing Act 007 of 2005.

What is Anjouan Licensing Services Inc (ALSI)?

Anjouan Licensing Services Inc. (ALSI) is a private organization that handles the daily processing of license applications and the management of operator registrations. The Anjouan Offshore Finance Authority (AOFA) determines the regulations and monitors compliance with anti-money laundering (AML) guidelines, but ALSI has taken over the operational tasks to modernize the process. This division of labor means that ALSI acts as the executive arm, while the AOFA safeguards the policy frameworks.

The legitimacy of such offshore structures is sometimes open to debate. The Comoros Financial Services Authority (CFSA) has warned in the past about fictitious entities operating without proper mandates, although ALSI presents itself as the authorized partner within the current system. Thorough due diligence should therefore look not only at ALSI's license, but also at its current recognition by superior authorities. Operators must realize that a license through ALSI offers no protection against local enforcement by the Dutch Gambling Authority.

Relationship with the government of the Union of the Comoros

ALSI operates under the laws of the Autonomous Island of Anjouan, a part of the Union of the Comoros. Physical and administrative connections often run through Moroni, the capital where many financial and corporate services are concentrated. Although Anjouan is semi-autonomous, it remains part of the sovereign nation of the Comoros. This has complex legal implications for international recognition.

The relationship between ALSI and the government is indirect. ALSI is not a ministerial department, but a specialized agency appointed by the AOFA. This distinction is vital for compliance experts: responsibility for financial supervision lies with the AOFA, while ALSI facilitates the commercial settlement. The presence of offices in Moroni supports the claim of local anchoring, but operators must verify whether these entities are actually subject to strict national audits.

Historical context and legal basis

The fundamental legal basis for gambling in Anjouan is the Computer Gaming Licensing Act 007 of 2005. This law opened the market almost two decades ago, but its implementation has recently evolved with the introduction of ALSI in 2023. The law provides a framework for both B2C and B2B operators, whereby a single license can cover all forms of iGaming.

Although the Computer Gaming Licensing Act 007 of 2005 provides the legal foundation, its practical application is now guided by ALSI's modern procedures. This includes annual renewals and enforcing compliance standards, such as submitting reports. Given the historical warnings from bodies such as the Comoros Central Bank about fictitious regulators, a critical look at the implementation of this law remains necessary for any serious market participant.

Background check and Due Diligence procedures at ALSI

An Anjouan Licensing Services Inc background check is at the core of the due diligence process for new applicants. Anjouan Licensing Services Inc. (ALSI) conducts rigorous screening on all parties involved to exclude criminal activities and fraud. This procedure is not merely an administrative formality, but an essential step to guarantee the integrity of the license holder within the offshore gaming regime.

Who is investigated during the screening?

Every Key Person and Ultimate Beneficial Owner (UBO) undergoes an extensive screening for criminal history and financial integrity. A Key Person, such as a director or owner, must be transparent about their role within the corporate structure. The regulator requires passports and CVs of these individuals to verify their professional background. In addition, the check focuses specifically on the Ultimate Beneficial Owner, the natural person who ultimately has control over the entity. This distinction is crucial because fictitious structures are often used to conceal true ownership relationships, as previously noted in reports about the Comoros Central Bank. By screening both the operational management and the ultimate beneficiaries, ALSI tries to prevent individuals with a dubious reputation from gaining access to the gaming ecosystem.

Use of international databases and tools

ALSI uses tools such as World-Check and LexisNexis Risk Solutions to screen Politically Exposed Persons (PEP) and sanction lists. A Politically Exposed Person (PEP) is an individual who holds a prominent public function and therefore runs a higher risk of corruption or money laundering. Identifying a PEP requires extra vigilance within the compliance framework. By consulting databases like World-Check, consultants such as NUR Legal can proactively signal potential red flags before the application is submitted. LexisNexis Risk Solutions provides additional data on legal histories and connections to terrorist financing. This technological support enables the authorities to make faster and more accurate decisions than would be possible with manual checks alone.

Difference between standard and Enhanced Due Diligence

In case of higher risks, Enhanced Due Diligence (EDD) is applied, where sources of wealth are verified more strictly. Standard due diligence focuses on basic documentation, while EDD digs deeper into the origin of capital and complex corporate structures. For operators working from an offshore jurisdiction, this is essential to maintain correspondent banking relationships, as financial institutions monitor AML compliance increasingly strictly. If the screening shows that a Key Person or UBO is linked to sanction lists, this can lead to direct rejection or subsequent revocation of the license. Transparency in this stage protects not only the operator, but also the broader network of payment providers and partners.

Legal position and restrictions for the Dutch market

An Anjouan Licensing Services Inc background check reveals crucial legal restrictions for the Dutch market. The Anjouan license offers no legal coverage in the Netherlands, where the Financial Supervision Act (Wft) and the Gambling Authority (Kansspelautoriteit) enforce strict licensing requirements. Operators with this offshore license risk sanctions from the Dutch Authority for the Financial Markets (AFM) and the Dutch Central Bank (DNB) when offering services to Dutch players without local authorization.

Is an Anjouan license valid in the Netherlands?

No, a license granted by Anjouan Licensing Services Inc (ALSI) or the Anjouan Offshore Finance Authority (AOFA) is not valid for offering games of chance in the Netherlands. Dutch legislation requires operators to possess a specific license from the Gambling Authority in order to operate legally. In our analysis of the jurisdiction, we see that Anjouan explicitly excludes the Netherlands from its allowed markets, along with other strictly regulated countries such as Germany, France, and the United Kingdom. This means that any operator targeting Dutch consumers with an Anjouan license is in violation of local law.

The Financial Supervision Act (Wft) forms the framework in which financial services and games of chance are assessed. Although the Wft is primarily aimed at financial institutions, the regulation overlaps with the Remote Gambling Act regarding integrity and anti-money laundering measures. The Ministry of Finance oversees broader financial stability, but for gambling, the Gambling Authority is the designated body. An Anjouan license does not meet the strict requirements that these Dutch authorities set for player protection and technical integrity. Players must be aware that with such providers, they cannot appeal to the Dutch disputes committee or guarantee schemes.

Restricted markets and geographical limitations

In addition to the Netherlands, Anjouan maintains a list of restricted jurisdictions. Operators obtaining a license through ALSI must technically guarantee that players from these areas are blocked. Ignoring these geographical restrictions can lead to the immediate revocation of the license by the AOFA. For Dutch businesses, it is therefore risky to enter into a business relationship with an Anjouan-licensed entity in the first place, as this can be seen as facilitating illegal activities under the Wwft.

Risks of Shell Companies and fictitious entities

There are serious concerns about the structure of some licensed entities, with the use of Shell Company structures being central. Investigations show that local authorities in the Comoros have labeled certain regulatory bodies as "fictitious entities" operating illegally. The Central Bank of the Comoros has warned that many of these structures continued to issue licenses even after the official dissolution of certain powers. For partners and investors, thorough due diligence is essential to verify whether an operator is actually subject to effective supervision or is merely a paper construct.

The Dutch Government Sanctions List plays a critical role in risk assessment here. Operators linked to entities on international blacklists or who have ties to jurisdictions monitored by the FATF (Financial Action Task Force) run the risk of being blocked by Dutch banks and payment providers. A Shell Company with no substantial economic activity in Anjouan itself, but only registered for tax purposes, is often flagged as high-risk by Dutch compliance officers. This lack of transparency makes it difficult to trace the ultimate beneficial owners (UBOs), which conflicts with the strict anti-money laundering guidelines enforced in the Netherlands.

Supervision by Dutch authorities

The Dutch Authority for the Financial Markets (AFM) and the Dutch Central Bank (DNB) work closely together to tackle illegal financial flows and unauthorized gambling providers. Although the Gambling Authority is the primary regulator for gambling, the AFM and DNB monitor the financial infrastructure these operators use. If an Anjouan-licensed casino processes payments via Dutch bank accounts or payment service providers, these authorities can take action against the intermediaries for violating the Wft.

The Dutch Central Bank (DNB) specifically monitors the integrity of the payment system. Banks in the Netherlands are obliged to block transactions related to illegal gambling activities. This means that players often experience problems when depositing or withdrawing money at casinos with only an Anjouan license. The Dutch Authority for the Financial Markets (AFM) regularly publishes warnings about parties offering financial services without a license. For operators, this means that ignoring the Dutch restrictions not only leads to fines from the Gambling Authority, but also to the cut-off of essential banking services, making business operations unsustainable.

Comparison: Anjouan (ALSI) versus Curaçao

An Anjouan Licensing Services Inc background check reveals that this private administrator issues licenses for approximately €17,828 per year, significantly lower than European alternatives. Although the Anjouan Gaming License is granted quickly, it provides no legal coverage in the Netherlands and requires strict compliance with international anti-money laundering directives to retain payment partners such as MiFinity.

Cost structure and tax benefits

The Anjouan Gaming License positions itself as a cost-efficient option for offshore operators. The total initial investment, including due diligence and compliance costs, is approximately €18,000 for the first year, with similar annual renewal costs. This stands in sharp contrast to jurisdictions such as Malta or the UK, where costs are many times higher. A crucial financial advantage is the 0% tax on gross gaming revenue (GGR). This allows operators to maximize their profit margins without payout to the local government of Anjouan.

For Dutch players, this structure is irrelevant, but for operators such as Leon Casino, which holds a license from Anjouan Licensing Services Inc., this offers operational flexibility. However, these tax benefits come at a price: the lack of a robust regulatory framework makes it difficult to access traditional Correspondent Banking networks. Banks are reluctant due to low transparency and the risk of money laundering, forcing operators to rely on e-wallets and crypto solutions.

Speed of issuance versus reputation

Speed is a major selling point for Anjouan. A license application is typically processed within three to six weeks, whereas the new LOK regime in Curaçao can take three to six months. This efficiency attracts operators looking for a fast time-to-market. However, this speed comes at the expense of reputation. The Anjouan Offshore Finance Authority (AOFA) and related entities are sometimes labeled as "fictitious" by local authorities, casting doubt on legitimacy.

This perception has direct consequences for payment processors. Services like MiFinity, a popular e-wallet for online gaming, conduct strict compliance checks. Without a solid reputation, operators risk blocks. Leon Casino, for example, uses MiFinity for transactions, but must continuously demonstrate that it complies with international standards to maintain this connection. The lack of brand awareness with banks means that operators often pay higher transaction fees or have limited payment options compared to Curaçao-licensed competitors.

Compliance with international standards

Although Anjouan utilizes a local regime, operators must comply with global standards to remain operational. This includes compliance with the Anti-Money Laundering Directive (AMLD5/AMLD6). These EU directives oblige operators to implement strict customer identification (KYC) and monitoring of suspicious transactions. For operators wishing to access the European market, even indirectly, adherence to AMLD5/6 is essential.

The Anjouan Gaming License requires holders to adhere to anti-money laundering provisions and responsible gaming practices. However, enforcement by Anjouan Licensing Services Inc. is less transparent than by the Gambling Authority in the Netherlands. Operators must proactively report in accordance with the license conditions themselves. Without this compliance, they lose not only their license, but also access to critical infrastructures such as Correspondent Banking and payment providers that enforce AMLD5/6 compliance.

About This Article - Editorial Standards

This article on "anjouan licensing services inc achtergrond check" was written by Sarah Weber and factually reviewed by Dr. Markus Hoffmann. Both regularly update the content for changes in regulation, licensing and bonus terms. All references to licences, regulators and statutes link to public sources (the local gambling regulator, the applicable local gambling statute).

About the Author

8+ years reviewing casinos, 200+ personally tested platforms across the EU and globally. Former member of the eCOGRA Player Advocacy Program (2018-2022). Specialty: wagering requirements, withdrawal workflows, customer-support evaluation.

About the Reviewer

12+ years in the iGaming industry, including 5 years as a compliance consultant for licensed operators across multiple regulated markets. PhD in Economic Mathematics. Focus areas: bonus mathematics, wagering analysis, and player-protection systems.

Responsible Gambling

Gambling can be addictive. If you feel you are losing control of your play, please reach out to the relevant problem-gambling helpline or use the national self-exclusion register (the relevant national self-exclusion register). Set personal deposit and loss limits BEFORE you play with real money. Operator pauses and cooldown tools exist to keep play sustainable.

Legal Notice

The information in this article is provided for editorial and comparison purposes only and does not constitute legal advice. Players are responsible for compliance with local regulations.