Key Points
- FATF’s September 2026 report drew on 80 jurisdictions and written input from 29 countries, identifying illegal offshore gambling as a risk that rivals or exceeds legal markets in some jurisdictions.
- Anjouan Gaming confirmed it has enhanced its licence conditions and application requirements in direct response to FATF’s findings, but has not publicly detailed which specific rules changed.
- The jurisdiction sits inside a contested legal dispute, with Comorian federal authorities separately warning that entities selling gambling licences in Anjouan’s name lack a legal basis.
Anjouan Tightens Gaming Licence Rules After FATF Flags Offshore Gambling as Major Financial Crime Risk
The Financial Action Task Force doesn’t issue reports like this often. When it published its Risks of Gaming and Gambling report on 9 September 2026, the message was pointed: online platforms, anonymous payments and unlicensed offshore operators have turned the gambling sector into a widening gap for global financial crime. Within two weeks, one of iGaming’s most debated offshore jurisdictions had already signalled changes to its rulebook.
Anjouan Gaming, which administers the internet gaming licensing framework for the Autonomous Island of Anjouan, confirmed via LinkedIn that it had enhanced its licence conditions and application requirements. “FATF’s newly published ‘Risks of Gaming and Gambling’ report reinforces the standards we hold licensees to: robust KYC and ongoing due diligence aren’t optional in this industry, they’re the baseline,” the authority said. It added: “In light of the report’s findings, we’ve enhanced our licence conditions and strengthened our application requirements to stay aligned with evolving global AML/CFT standards.”
What changed, specifically? That part remains unanswered. Anjouan Gaming has not publicly detailed which individual conditions were revised or how applicants will be affected.
What FATF Actually Found?
The project ran over the course of a year, drawing on questionnaire contributions from 80 jurisdictions and written comments from a further 29, alongside consultations with industry bodies, researchers and private-sector stakeholders. It also marks FATF’s first detailed examination of risks specifically linked to online and illegal gambling, building on earlier casino-focused work published in 2009.
Land-based casinos, online casinos and sports betting were identified as carrying the highest money laundering exposure across the sector. FATF President Giles Thomson was direct: “Without robust safeguards, these sectors can be attractive gateways for fraudsters, professional money launderers and organised criminal networks.”
Illegal gambling markets were flagged as one of the sector’s most significant risks. In some jurisdictions, unlicensed markets rival or exceed the size of legal ones. That’s not a peripheral concern; it’s the central problem FATF is pushing governments to act on.
Payment methods got close attention. Cash, e-wallets, mobile money and virtual assets all create conditions where rapid, anonymous cross-border transfers can move funds before investigators have a chance to trace them. Online platforms increasingly operate across multiple jurisdictions, often sitting outside national AML and counter-terrorist financing frameworks entirely. Criminals, the report found, aren’t always gambling at all. They use platforms as a pass-through for funds, run smurfing strategies through small structured deposits and place co-ordinated bets on events flagged for potential competition manipulation.
Why Anjouan’s Response Matters More Than It Appears?
Public recognition from Anjouan is important considering the growing regulatory pressure on the iGaming industry in such offshore jurisdictions. The jurisdiction noted that it has improved its framework to align with the changing international standards in anti-money laundering and anti-terrorism. This suggests an intention, whether the system is able to cope with this intention is another matter.
The jurisdiction had already issued more than 1,650 Internet Gaming Licences as of 14 July 2026, with nearly 1,500 active at the time. Those operators are now subject to whatever changes the regulator has implemented, none of which have been spelt out in public-facing documentation. For a licensing body that already operates in a space where transparency is under constant examination, that silence draws attention.
A Jurisdiction Navigating Pressure on Several Fronts
The FATF response is just one pressure point Anjouan is managing right now. In June 2026, the authority published a clarification addressing what it called conflated public commentary, stating that “an Anjouan Internet Gaming Licence is not, and has never been presented as, a universal authorisation to operate in every country in the world.” The statement arrived as discussions around the black market intensified during the World Cup season, with offshore licensing frameworks again at the centre of the debate.
Separately, in July 2026, Comorian federal authorities issued a warning about entities selling gambling licences in Anjouan’s name, stating those licences lacked a legal basis. That warning sits alongside a longer-running institutional dispute. The Comoros Central Bank has, in communiqués concerning offshore financial licensing activity, described the Anjouan Offshore Finance Authority and related entities as having no physical or legal existence in the country, with those findings applied to banking and financial approvals. Independent reporting by outlets including ABC Australia and Focus Gaming News has also documented Comorian officials questioning the legal standing of the wider Anjouan gambling licensing network more broadly.
These are competing institutional positions, not a settled legal conclusion. Anjouan Gaming administers its framework under what it describes as Anjouan’s autonomous authority, rooted in the Computer Gaming Licensing Act of 2005. Federal Comorian law, which prohibits gambling under the national penal code, sits in direct tension with that claim. The outcome of that jurisdictional dispute has not been resolved by any court, and both positions remain formally contested.
The Gap Between Compliance Signals and Compliance Substance
We think this is where the industry needs to be precise about what Anjouan’s September statement actually represents. An offshore regulator communicating KYC priorities in a LinkedIn post is not the same thing as a regulator with the institutional capacity to enforce them. FATF’s report specifically flagged jurisdictional gaps and limited international cooperation as conditions that allow offshore platforms to thrive. Anjouan sits directly at that fault line.
That’s not automatically disqualifying for every operator. The jurisdiction has carved out a clear space for crypto-native startups, early-stage platforms and operators targeting markets where Tier-1 licensing is neither required nor commercially viable at launch. Fee structures at Anjouan are significantly lower than those at Malta, Curaçao or Isle of Man. But the practical operating reality is documented: Anjouan operators face constrained banking access, with mainstream banking partners declining Anjouan-licensed entities and most tier-1 payment processors refusing to serve them, making crypto rails the primary viable payment infrastructure for most licensees.
FATF’s core recommendations push jurisdictions toward stronger licensing controls to prevent criminal ownership of gambling operators, greater public-private information sharing and tighter international coordination. What Anjouan communicated in September 2026 is that it is paying attention. What remains open is whether its framework can back that up, with nearly 1,500 active licensees now operating under conditions the authority itself hasn’t publicly defined.
Expert Analysis: The Credibility Gap Offshore Regulators Can’t Close With a Statement
There’s a pattern worth naming plainly. When a significant AML report lands, offshore licensing bodies issue public statements referencing it. The framing is alignment. The specifics, however, stay vague, and the structural conditions that created the scrutiny in the first place remain unchanged.
Anjouan’s September 2026 response fits that pattern almost exactly. The authority confirmed enhanced licence conditions. It gave no detail about what changed, who is affected or how compliance will be tested. FATF didn’t ask for better communication; it called for stronger licensing controls to prevent criminal infiltration, improved international information sharing and genuine action on illegal offshore markets. Those are structural asks. Issuing a statement about KYC being “the baseline” doesn’t meet them.
The 2026 report built on FATF’s earlier casino work, because the industry has changed beyond recognition since then. Platforms processing crypto payments across dozens of jurisdictions, white-label arrangements obscuring beneficial ownership, networks running smurfing operations through structured deposits, these are now the mainstream operating environment, not edge cases. Anjouan’s response arrives at exactly the moment when its legal standing at the federal level is being questioned by the country it operates within, and when the financial infrastructure around its licensees is already constrained by a market that has reached its own verdict on the jurisdiction’s credibility. For operators genuinely planning their licensing strategy, the honest question isn’t whether Anjouan listened to FATF. It’s whether the framework behind the statement has the institutional weight to act on it.
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