Buying or Selling an Anjouan-Licensed Casino After the Comoros Dispute

An Anjouan-licensed casino can still be bought and sold, but the licence should no longer be priced as settled. The Comoros government says the regime has no legal basis. Anjouan Gaming says its licences are valid. Until a court or government resolves that, the risk sits with whoever owns the asset.

For buyers, that means valuing the business as if it may need a new licence, holding back part of the price, and testing every payment relationship before signing. For sellers, it means showing that revenue can survive a licence change and having a relicensing plan ready before the buyer asks.

Nothing in this article says any individual licensee has done anything wrong. The dispute concerns the framework, and well-run operators are exposed to it too.

What has actually happened

The dispute moved from central bank warnings to a formal request for foreign help in October 2026. As of 6 November 2026, we have found no court ruling on the licences, and the reporting does not show a UK criminal case.

The Comoros position. The government and central bank say the licensing bodies have no lawful authority. The central bank has called the regime illegal activity that misuses the country's name. Casino.org also reports that researchers found the public copy of the 2005 gambling law unsigned and unstamped.

The Anjouan Gaming position. Anjouan Gaming says its licences are valid and cites an independent legal opinion. Casino.org reports that it has not named the law firm or published the opinion. It also points to its licence conditions, due diligence, AML and KYC standards, responsible gaming rules and enforcement actions.

What remains open. Casino.org notes it is unclear whether Anjouan's own authorities authorised the businesses issuing licences. Even if they did, that may not settle the question under national law. Buyers should treat this as an unresolved legal dispute, and neither side's statement as the final word.

Why this matters in a deal

The real exposure sits with the counterparties that rely on the licence. The licence itself is cheap, with advisers quoting about €17,828 a year. The revenue that depends on it can be worth many times that.

• Payments. An analyst told the Guardian that a licence gives banks and payment providers a degree of reassurance, according to Gambling.com. If that reassurance fades, deposits can stop before any authority acts.

• Games. One large supplier group told SBC News that licences in jurisdictions such as Anjouan let it contract with operators licensed there. Each supplier contract may carry its own licence condition.

• Traffic. One licensing adviser says affiliate networks rank Anjouan below Curaçao and Malta. A weaker position with partners can feed through to acquisition costs.

• Exit value. Licensed groups and institutionally funded buyers will have to justify the asset to their own banks, boards and regulators. We expect that to narrow the buyer pool for the next sale as well as this one.

Buyers should also separate two risks that often get mixed together. Framework risk asks whether the licence stands. Conduct risk asks whether the operator takes players from markets where it needs a local licence.

Anjouan Gaming says plainly that no licensing authority can exempt an operator from local law. A resolved dispute would remove the first risk and leave the second untouched.

How the dispute changes price

Price the asset on what it earns today and what it would earn after a licence change. There is no published discount for Anjouan assets yet, so buyers need their own model. We would build it in three steps.

1. Clean the earnings. Take out revenue from markets where the operator needs a local licence it does not hold. That revenue should not earn a full multiple.

2. Add the cost of a move. Include licence fees, legal work, compliance staff, technical changes and any local substance.

3. Weight the outcomes. Estimate how likely each scenario is, then calculate a weighted value.

The example below uses invented figures for a casino earning €600,000 of EBITDA. The multiples and weights are assumptions for illustration, not market benchmarks.

On these assumptions, the buyer's risk-adjusted value is about €1.5m, roughly 17% below the €1.8m headline figure. If the weights shift to 20%, 40% and 40%, the value falls to about €1.31m, roughly 27% below.

The useful output is the range of outcomes more than the final number. It shows which assumption moves value most, and in most files that will be payment continuity. For the wider method, see our guides on valuing an online casino and what your casino is actually worth.

Payment provider and banking risk

Payments are the most likely place for this dispute to hit revenue first. No court decision is needed for a provider to leave. A compliance team only has to decide the risk is no longer worth carrying.

There is a recent example of how fast that can look from the outside. The ABC reported that two payment options vanished from an Anjouan-licensed casino's site within hours of its questions reaching the vendors.

The wider climate points the same way. FATF's September report flagged illegal and unlicensed offshore gambling, complex ownership and poorly supervised white-label partnerships. It also named e-wallets, mobile money and virtual assets as exposed. FATF does not regulate gambling, but its influence reaches operators through banks, payment providers and acquirers.

The same iGB piece includes a warning from Gibraltar's experience of grey-listing, when some large financial institutions chose blanket de-risking. Anjouan operators start from a narrower base. Advisers already describe PSP access as limited to specialist providers, so losing one provider leaves few replacements.

Three tests tell a buyer more than any seller statement:

• Concentration. Map 12 to 24 months of deposits by provider and method. A single provider carrying most deposits is the biggest red flag in the file.

• Contract terms. Read each agreement for licence conditions, termination rights, change-of-control clauses and rolling reserves. Establish who owns the reserves after closing.

• Live confirmation. Ask the seller to arrange written confirmation from the main providers that they will keep processing under new ownership. Make that a condition of closing where you can.

Crypto volume reduces dependence on card and e-wallet providers, but it does not remove the problem. Crypto rails bring their own AML checks, wallet screening and off-ramp risk. For more on the payments stack, see our iGaming banking and payment processing guide.

Due diligence checklist for an Anjouan asset

Add these checks to your normal process, starting with who holds the licence and what a sale requires. Our due diligence protocols and buyer guide cover the standard workstreams.

Two items need particular care. We could not find a published Anjouan procedure for change of ownership, so get the position in writing and have your lawyer review it. If the conditions are silent, treat that as a risk to price.

The marketing check matters beyond the licence. The Guardian reported that several Anjouan licensees are promoted as being off GamStop, according to Gambling.com. Buyers should remove any such activity from the earnings they pay for, and should end it after closing.

Warranties, indemnities and holdbacks

A seller cannot promise how the Comoros dispute will end, but can stand behind the facts of the business. That is where the contract should focus. A broad warranty that the licence is legally valid is hard for any seller to give and hard for a buyer to rely on.

Warranties cover facts at signing. Useful ones include:

• The licence is in force, and the seller has received no notice of suspension, revocation or investigation.

• All correspondence with licensing bodies, authorities and payment providers has been disclosed.

• Revenue by player country is accurate, and no marketing has targeted listed restricted markets.

• No provider has terminated, restricted or materially raised reserves in the last 12 months.

• Player balances are fully funded, and all financial information is accurate.

Indemnities cover known risks. Buyers should ask for specific indemnities on pre-closing player claims, regulatory penalties, tax, chargebacks and provider fines. Unlike a general warranty claim, a specific indemnity can pay out even where the issue was disclosed.

Holdbacks and earn-outs bridge the price gap. Using the example above, the seller wants €1.8m and the buyer's model says €1.5m. Instead of arguing over a single number, the parties could split the price by risk.

That leaves €450,000 of the price dependent on what happens after closing, and the seller can still reach the full amount. These figures are illustrative, and a real split depends on the file.

Four drafting points protect both sides:

• Use objective triggers. Name the licence, the providers and the percentages. Avoid release conditions that rely on one party's opinion.

• Agree who runs the business. A seller with money in escrow will want limits on buyer actions that could trigger a loss.

• Separate licence events from trading results. Decide in advance whether a market-wide event releases, reduces or extends the holdback.

• Set this out early. Put the structure in the letter of intent, so it does not reopen the price later.

Deal structure matters too. A share deal keeps contracts and licences in place, but the buyer inherits the company's history. An asset deal can leave legacy liabilities behind, but the buyer must rebuild contracts and handle player data lawfully. Your lawyer and tax adviser should confirm which route works for the asset and the jurisdictions involved.

Moving to another licence

Price a licence move before signing, because it takes weeks to months and does not bring payment relationships with it. The right destination depends on where the players are and which providers will accept the business. Fee and speed are secondary.

The figures below are regulator fees published by one licensing consultancy, updated 12 October 2026. Company setup, local substance, compliance staff and adviser fees sit on top. Check every figure with the regulator before relying on it.

Curaçao is the obvious destination for many operators, but the bar has risen. The same consultancy says the local substance deadline now runs to April 2027. An operator refused a second provisional or indefinite licence gets six weeks to wind down and must still settle its liabilities.

A sensible migration plan runs in this order:

1. Map the players. Choose the licence that fits the markets you intend to serve, and exit any market that needs a local licence you will not hold.

2. Speak to providers first. Get payment and game suppliers to confirm they will support the new licence before you apply.

3. Build the structure. Prepare the licensed entity, key persons, compliance policies and technical documents.

4. Hold the old licence until the new one is live. Avoid any gap in cover, and take legal advice on running both.

5. Move players carefully. Update terms, migrate data lawfully and tell players what is changing.

6. Re-paper contracts. Update supplier, affiliate and payment agreements in the new entity's name.

A new licence does not clean an old record. Applicants should expect questions about past markets, ownership and complaints. A licence move should never be used to keep serving a market that restricts the operator.

What sellers should do now

Sellers get a better result by raising the issue first. Buyers will read the same reporting, and a seller who stays quiet invites a harsher assumption. A prepared file can protect more of the price than any argument about the licence.

1. Describe the licence accurately. State the licence number, holder and issue date. Drop claims such as "global licence" or a count of covered countries, because Anjouan Gaming itself says the licence is not a universal authorisation.

2. Publish clean numbers. Prepare revenue by player country. Show earnings with and without markets a buyer is likely to exclude.

3. Reduce payment concentration. Add a second provider where you can, and document how quickly deposits could move if one provider left.

4. Get supplier comfort. Ask key game and payment partners how a change of owner or licence would affect them. Written answers are worth far more than verbal ones.

5. Cost a licence move. Choose a realistic destination, and estimate the time and cost. A seller who has done this removes much of the buyer's uncertainty.

6. Fix the record. Close open complaints, tidy AML files and end any marketing aimed at restricted markets or self-excluded players.

7. Offer a structure. If you believe the risk is lower than the buyer does, accept a holdback or earn-out that pays you if you are right.

Timing is a judgement call. Waiting for the dispute to settle could take a long time, and the outcome is uncertain. Selling now may mean a lower closing payment, but it transfers the risk. Our seller guide covers how to prepare a listing, and our free valuation tool gives a starting estimate.

What to watch next

Five developments would change how these deals are priced. Any live negotiation should say what happens if one of them lands before closing.

We will update this article if the position changes materially.

Frequently asked questions

Is an Anjouan gaming licence still valid?

That is disputed. Anjouan Gaming says its licences are valid, while the Comoros government and central bank say the regime is illegal. As of 6 November 2026, we have found no court ruling that settles the point.

Can you still buy an Anjouan-licensed casino?

Yes, but the deal needs more protection than a standard sale. Buyers should model a licence move, test payment continuity and hold back part of the price against agreed events.

How much should a buyer discount an Anjouan casino?

There is no market standard. The discount depends on revenue quality, payment concentration and the cost of moving licence. Our illustrative example produces a 17% to 27% reduction, and real files could land well outside that range.

Does an Anjouan licence allow an operator to take UK players?

No. UK players require a UK Gambling Commission licence. Anjouan Gaming also says its licence is not a universal authorisation and that licensees remain responsible for lawful conduct in each market.

Can an Anjouan casino move to Curaçao or another licence?

It can apply, subject to that regulator's requirements. Curaçao takes months, involves local substance and scrutiny, and can end in refusal. Confirm payment and game supplier support before you commit.

Is there a UK criminal case over Anjouan licences?

The reporting we reviewed does not show one. It shows that Comoros has asked for help from the UK government and law enforcement, and that the Treasury declined to comment.

Should sellers wait for the dispute to end?

Not necessarily. There is no known end date, and the outcome could reduce value further. A seller with clean numbers and a credible relicensing plan can still go to market.