Anjouan gaming license
requirements.

Entity requirements

The applicant must be a legal entity — individuals cannot hold the license. In almost every case the entity is a new Anjouan IBC (International Business Company) formed for the purpose of holding the license. Existing operators occasionally apply under a foreign parent, but this is reviewed on a case-by-case basis and usually requires an Anjouan-domiciled operational subsidiary in addition.

The entity's constitutional documents must include a clearly stated gaming-related business purpose. Boilerplate IBC language ("any lawful business") is not sufficient on its own. This is a common and easily avoided source of first-pass rejection.

Ownership and directors

Fit-and-proper review applies to every director and every beneficial owner. Each UBO must be declared individually on the UBO Declaration Form and complete Remote ID Verification, regardless of threshold. Disclosure runs to 10% ownership or lower depending on structure. The review looks for:

• No unspent criminal convictions, particularly for fraud, money laundering, or gambling-related offences.
• No prior license revocations or serious regulatory sanctions in other jurisdictions.
• No adverse financial history — undischarged bankruptcy, recent insolvency, or material civil judgments.
• A demonstrable ability to fund and operate the proposed business.

Nominee structures are permitted but the beneficial owner behind the nominee must be disclosed to the regulator. Attempts to conceal beneficial ownership through nominee chains are the single most common ground for outright rejection.

Document checklist

Every item below goes into the application package. Required items will prevent submission; optional items are strongly recommended and often requested at first review even when not formally required.

• Certificate of incorporation

  Anjouan-incorporated entity, or a qualifying foreign entity with approved local presence.
  Required
• Memorandum and articles of association

  Must include a clear statement of gaming-related business purpose.
  Required
• UBO Declaration Form · every UBO

  Every UBO must be individually declared on ALSI's UBO Declaration Form regardless of threshold. Disclosure runs to 10% ownership (or lower depending on structure). Each named UBO undergoes fit-and-proper review.
  Required
• Director identification

  Passport copy, certified proof of address, CV, and police clearance for each director.
  Required
• Remote ID Verification

  Mandatory for all natural persons named in the application (directors, UBOs, Key Person / Compliance Officer). Confirmed by ALSI in March 2026.
  Required
• Proof and source of funds

  Bank statements or audited accounts evidencing operating capital — typically 6 months of runway.
  Required
• Three-year business plan

  Revenue model, target markets, marketing approach, staffing plan, risk assessment.
  Required
• AML / KYC policy

  Risk-based framework aligned with FATF recommendations. Must name the Compliance Officer / Key Person (ALSI terminology — not MLRO, which is a Malta/Curaçao term).
  Required
• Responsible gaming policy

  Self-exclusion, deposit/session/loss limits, problem-gambling signposting and escalation.
  Required
• Technical infrastructure documentation

  Hosting architecture (international hosting permitted; no local server requirement), RNG certification (if proprietary), game-fairness audits, disaster recovery, compliance with the Technical Standards Code.
  Required
• Data protection policy

  GDPR-equivalent for European players. Required in practice if any EU-adjacent traffic.
  Optional
• Insurance coverage

  Professional indemnity and cyber coverage. Not strictly mandatory at application but expected for renewal.
  Optional

AML and KYC

The AML/KYC framework is risk-based, aligned with FATF recommendations, and must name a Compliance Officer / Key Person (the ALSI terminology — not MLRO, which is the equivalent role under the Malta and Curaçao regimes). The Compliance Officer does not need to be Anjouan-resident but must be contactable and responsible for:

• Customer due diligence at onboarding — identity, address, and source of funds for high-risk customers.
• Ongoing transaction monitoring with documented thresholds.
• Enhanced due diligence for politically exposed persons (PEPs), high-risk jurisdictions, and high-volume customers.
• Suspicious transaction reporting to the Anjouan Financial Intelligence Unit.
• Annual AML training for all staff with customer-facing or transaction-facing duties.

For crypto-denominated operations, the AML policy must additionally cover on-chain provenance screening — typically using a third-party blockchain analytics provider to flag deposits from sanctioned wallets, mixers, and high-risk exchanges.

Responsible gaming

The responsible gaming policy covers player protection and must include, at minimum:

• Self-exclusion — permanent and cooling-off periods, enforced cross-product within the operator.
• Deposit, loss, and wager limits — set at account opening, adjustable upward only with a cooling-off delay.
• Session and reality-check mechanisms — configurable time alerts.
• A clear problem-gambling escalation path with signposting to recognised support organisations.
• Staff training requirements and annual refresher on spotting and responding to problem-gambling indicators.

Technical requirements

The technical review covers platform architecture, game fairness, data security, and operational resilience. Requirements are proportionate to the scope of activity and governed by the Anjouan Technical Standards Code.

Game fairness and RNG

Proprietary RNG systems must be certified by an independent test lab (iTech, GLI, BMM, and others are accepted). Third-party games must come from studios with their own RNG certification — aggregator integrations require the aggregator to evidence this. Content suppliers must themselves hold an Anjouan B2B licence to be recognised as a valid provider on the B2C licence (ALSI, March 2026).

Hosting and infrastructure

Anjouan imposes no local server, ISP, or compliance backup requirement. Confirmed directly with the regulator in April 2026. International hosting on AWS, GCP, or Azure is acceptable. The architecture documentation must show production / backup separation, a documented disaster recovery plan with tested RTO / RPO targets, and logical separation of player funds from operational funds.

Security

SSL / TLS for all player-facing traffic, encryption at rest and in transit, PCI DSS for card handling (or explicit delegation to a compliant PSP), auditable access logs, and documented incident response procedures. A penetration test performed in the preceding 12 months is expected at application.

Financial requirements

There is no formally published minimum capital requirement for a B2C license in Anjouan. In practice, ALSI looks for evidence of approximately six months of operating runway, which in the source-of-funds package typically lands around €100,000–€250,000 depending on proposed scale.

A bank account or EMI account in the operator's name is required before the license issues. Anjouan-domiciled banking is not required — most operators use an EMI such as Paysera, Wise Business, or specialist iGaming EMIs. Segregation of player funds from operational funds is a formal obligation.

Ongoing obligations

After issuance, the license carries ongoing obligations that are enforced through annual reporting and ad-hoc supervision.

• Annual renewal — EUR 17,828 fee (same all-inclusive scope as year one), updated UBO declarations, compliance report. IBC annual maintenance via ALSI is EUR 3,195 from year two.
• Material change notifications — 30 days' notice for changes in ownership >10%, director changes, new product verticals, or major technical migrations.
• Audited financial statements — annually, within six months of financial year-end.
• AML reporting — suspicious transactions reported as they arise; annual AML report submitted with renewal.
• Complaints register — maintained and available for inspection. Player complaints escalated to ALSI when unresolved after 30 days.
• Technical recertification — every 24 months for proprietary RNG; continuous for third-party content.

Back to the pillar: Anjouan Gaming License: the complete guide.