Verify an Anjouan
gaming licence.

Why verification matters

The Anjouan ecosystem has two parallel realities. Real licences are issued, registered, and enforceable — operators are active on the public register under the current framework. Alongside that, a persistent inventory of forged PDFs circulates, some of them sophisticated enough to fool non-specialist counterparties.

The ABC News investigation¹ that drew public attention to this problem conflated the two. The takeaway for many readers was "Anjouan licences are fake." The accurate takeaway is: real Anjouan licences exist under the AGA framework administered by ALSI. So do forgeries. The verification protocol takes fifteen minutes and settles the question.

The stakes are meaningful. Wiring capital, onboarding player funds, or entering a commercial partnership on the basis of a forged licence PDF exposes you to fraud losses and, depending on jurisdiction, to regulatory consequences if you should have detected the forgery.

The regulator hierarchy

The single most common source of confusion is the assumption that one entity does everything. In the current framework, responsibility is split: the Anjouan Gaming Board provides oversight, the Anjouan Gaming Authority (AGA) is the regulator that issues licences, and Anjouan Licensing Services Inc. (ALSI) is the designated administrator that processes applications and maintains the register. AOFA — the Anjouan Offshore Finance Authority — issued gaming licences before 2023 but is no longer a legitimate basis for a current licence.

A current, legitimate licence traces to AGA (the regulator) and is administered by ALSI. A licence that cites AOFA as the current issuing authority is not a current licence — AOFA is flagged by FATF and disavowed by the Comorian government. A licence that references an unfamiliar fourth-party entity is also a red flag and warrants further checks.

Verification protocol

Five steps. Fifteen minutes. Do every one of them before trusting a licence.

1. Extract the licence number and issuing entity from the displayed certificate. The issuing authority should be AGA; the administrator reference should be ALSI. If the certificate names only AOFA, treat it as not-current.
2. Cross-reference the licence number against the ALSI public register. ALSI publishes the register of issued licences with the licensed entity name and licence number. The operator-claimed entity name must match the register entry.
3. Confirm the date of issue is consistent. A licence first issued before 2023 under AOFA should have been re-confirmed under the AGA / ALSI framework during the transition. Operators unable to evidence that re-confirmation are operating on a stale basis at best.
4. Check that licence scope matches the operator's activity. A B2C operator licence does not authorise B2B service provision and vice versa. The displayed licence and the operator's actual business must match.
5. Confirm the operator's corporate entity. The licence is held by a specific Anjouan-incorporated company. The operator website's footer and terms should name the same company. Mismatches here are almost always forgery.

If verification stalls at any step, do not proceed. Ask the operator to provide written clarification through their licensing consultant or counsel. Legitimate operators expect these questions; illegitimate ones disappear.

Red flags for forgeries

A forged licence PDF usually displays one or more of the following. Any single flag should trigger additional verification; two or more means walk away.

• Missing or impossible dates — licences issued in years before the regulator existed, or with issuance dates that don't align with the stated authority's operational period.
• AOFA cited as the current issuing authority — post-2023 licences are issued by AGA and administered by ALSI. AOFA-only documents are not current.
• An unfamiliar entity name claiming regulator status — current Anjouan gaming licences are issued by AGA. Certificates naming other regulatory bodies warrant extra scrutiny.
• Signature blocks with no named signatory — legitimate licences are signed by named officials, not by a generic "Anjouan Gaming Authority" stamp alone.
• Inconsistent file metadata — PDF creation dates, authors, or software versions that don't match what a regulator would produce.
• Licence number formats inconsistent with ALSI's scheme — legitimate ALSI-administered numbers follow a specific structure. Invented numbers often don't.
• Operator unwilling to provide the licence directly — legitimate operators share their licence openly. Reluctance is a strong flag.
• Cloned or duplicated licences — the same licence number appearing across multiple unrelated operators.

The Comoros Central Bank and FATF position

Two external authorities bear directly on the legitimacy question and are frequently cited — in both directions — with varying degrees of accuracy.

Central Bank of the Union of the Comoros

The Central Bank's mandate is financial services, not gaming. Public statements by the Bank about "offshore licensing" generally address banking and financial services activity rather than gaming authorisation. The Bank has disavowed AOFA in its modern form. Gaming regulation is conducted under the Anjouan Gaming Board / AGA structure, not the Central Bank.

FATF 2024 Mutual Evaluation Report

The FATF's 2024 Mutual Evaluation Report of the Union of the Comoros flagged AOFA in the context of AML deficiencies and regulatory coherence concerns. This is the authoritative basis for treating AOFA as not-legitimate in current operations. Operators and counterparties should treat any licence traceable only to AOFA — without AGA / ALSI confirmation — as out of step with the current regime.

Reporting a suspected fake

If you identify a suspected forged licence or an operator misrepresenting their regulatory status:

• Report to ALSI directly. The administrator reviews forgery reports and can confirm whether a licence number is genuine. Published contact: info@alsi-anjouan.com or info@anjouan-licensing.com.
• Report to your own jurisdiction's financial regulator if the operator has taken funds from you. Forged regulatory credentials used to obtain money are typically prosecutable as fraud.
• Report to the hosting platform if the operator runs on a white-label platform — most platform providers have abuse mechanisms and will terminate fraudulent operators.
• Report to payment processors involved in the operator's flow — PSPs have strong incentives to de-platform operators misrepresenting their regulatory status.

Why working with a qualified consultant reduces risk

The verification protocol above is the minimum any operator or commercial counterparty should run before trusting a licence. In practice, specialist consultants do this routinely and have accumulated knowledge of:

• Known-good and known-forged licence templates in circulation.
• Current ALSI personnel and official channels.
• Operators with patterns of regulatory misrepresentation across multiple jurisdictions.
• The distinction between legitimate transition-period documents and backdated forgeries.

Our firm runs this verification on every Anjouan operator we engage with or refer. If you are about to commit meaningful capital based on an Anjouan licence — as an operator, investor, partner, or customer — a second pair of experienced eyes is cheap insurance.