Anjouan Gaming License Requirements 2026 – Legarithm

Most “requirements” guides list what the regulator says it wants. This article tells you what actually gets applications approved — the documents, the corporate structure, the compliance programme, and the technical evidence that moves an Anjouan Gaming Board (AGB) review from pending to issued. Incomplete applications are the number one cause of delays. Get the full picture before you start.

Corporate Structure Requirements

Before any documents are prepared, you need a legal entity. The AGB accepts several corporate forms, with the most common being:

• Anjouan LLC (Limited Liability Company registered on the island of Anjouan, Union of Comoros)
• Comoros IBC (International Business Company)
• Other offshore entities accepted on a case-by-case basis

The company must have:

• A registered office address on the island of Anjouan (a registered agent handles this)
• A registered agent holding a valid AGB-recognised agent licence
• A fully documented ownership structure, including all beneficial owners with 10%+ shareholding
• A corporate bank account or evidence of imminent banking arrangement (required before license issuance in practice)

Many operators use a two-tier structure: a UAE, Cyprus, or BVI holding company owns the Anjouan operating entity. This is legal and common — it provides a more recognisable corporate address for banking relationships while the license sits in the Anjouan entity. The AGB requires full disclosure of the entire ownership chain regardless of how many layers it contains.

Personal KYC Documents for Beneficial Owners

Every individual who owns 10% or more of the licensed entity must submit a complete KYC package. The AGB’s requirements mirror standard financial industry due diligence:

1. Valid passport — notarised copy, all pages, not expired. Some agents require apostille. 2. Proof of residential address — utility bill or bank statement, dated within the last 3 months, matching the passport name exactly. 3. Source of funds declaration — written statement explaining the origin of the capital invested in the business. Vague declarations (“savings” or “business income”) are frequently challenged. Be specific: the nature of the business, the approximate amounts, the timeline. 4. Source of wealth declaration — broader than source of funds; covers overall net worth. 5. Bank reference letter — from a recognised bank, confirming the account holder’s good standing. 6. CV / professional background — particularly important if the applicant has prior gambling industry experience (positive signal) or prior regulatory issues (must be disclosed). 7. Criminal background check — clean criminal record is required. Prior convictions related to financial crime, fraud, or gambling regulatory violations are disqualifying.

Directors who are not beneficial owners also require KYC documentation, though the scope is typically narrower.

Business Plan Requirements

The AGB requires a business plan as part of the application. This is not a formality. A weak business plan creates uncertainty during review and may result in additional queries that extend the timeline.

A complete AGB business plan should include:

• Executive summary — business model, target markets (not including restricted jurisdictions), revenue projections for 3 years
• Operational model — whether the platform is proprietary or white-label, the software provider(s) used, and their own regulatory standing
• Marketing approach — how you will acquire players, with explicit confirmation that no marketing will target restricted jurisdictions
• Responsible gambling framework — self-exclusion tools, deposit limits, cooling-off periods, problem gambling resources
• AML/KYC programme summary — referenced in detail in a standalone AML policy
• Staffing plan — key roles, compliance function, customer support

The business plan does not need to be elaborate — a focused 10–15 page document covering these areas is sufficient.

AML/KYC Policy Requirements

This is the document that most first-time applicants underestimate. The AGB requires a full AML (Anti-Money Laundering) and KYC (Know Your Customer) policy, not a template. The policy must cover:

• Customer identification procedures (CIP) for new registrations
• Enhanced due diligence (EDD) triggers — high-value deposits, PEP status, suspicious patterns
• Transaction monitoring procedures — what thresholds trigger review, who reviews, documentation requirements
• Suspicious activity reporting — who files reports, to which authority, under which circumstances
• Record retention — minimum 5 years for all KYC and transaction records
• Staff training requirements — documented training programme for all customer-facing and compliance staff
• Sanctions screening — OFAC, EU, and UN sanctions list checks at onboarding and ongoing

A policy that merely restates AML obligations without operational procedures will be sent back for revision.

Technical Platform Requirements

The AGB’s technical requirements focus on two areas: game fairness and player protection.

RNG certification: All casino games must use a certified Random Number Generator. Certification must come from an accredited laboratory — GLI, BMM Testlabs, iTech Labs, or equivalent. White-label operators can use the platform provider’s existing certification if documented.

Platform security: The application requires a technical description of the platform’s security architecture, including SSL/TLS implementation, data storage and encryption, and DDoS protection measures.

Responsible gambling tools: The platform must have documented and operational self-exclusion, deposit limits, session limits, and reality check features at launch. These cannot be placeholder features — the AGB may request screenshots or a demo.

Geo-restriction implementation: You must describe how you technically enforce the restricted country list — IP-based geo-blocking, registration controls, and payment controls.

Data protection: A privacy policy and data processing agreement compliant with applicable law must be submitted.

The Submission Process

Once all documents are gathered, submission goes through your registered agent or a licensed representative like Legarithm. The AGB conducts its review in two phases:

Phase 1 — Completeness check (1–2 weeks): The AGB confirms all required documents are present. Missing items generate a deficiency notice. This phase is where most delays occur.

Phase 2 — Substantive review (3–6 weeks): The AGB reviews the KYC package, business plan, and AML policy for quality. Queries during this phase extend the timeline but do not reset the clock.

Total timeline from complete submission to license issuance: 4–8 weeks.

Frequently Asked Questions

Q: Do I need a gaming industry background to get an Anjouan license? A: No. The AGB does not require prior gaming industry experience as a prerequisite. However, if key personnel have gaming experience, document it — it strengthens the application. If key personnel have prior regulatory sanctions in any industry, disclose them proactively; undisclosed issues discovered during review are treated more seriously than disclosed ones.

Q: Can I apply for an Anjouan license before my platform is built? A: Yes. You can apply while the platform is in development. However, technical certification of the RNG and platform features is required before the license can be used operationally. Some operators obtain the license during development and complete technical certification in parallel.

Q: What corporate structure is best for an Anjouan gaming license? A: The most common and practical structure is an Anjouan LLC as the licensed entity. For operators who need stronger banking, a UAE or Cyprus parent company holding the Anjouan LLC works well and is accepted by the AGB. Legarithm can structure and register both entities as part of the licensing package.

Q: Can I use a nominee director or shareholder? A: The AGB requires disclosure of the true beneficial owner. Nominee arrangements are not prohibited but the actual beneficial owner must be identified and their KYC documents submitted. Concealing beneficial ownership is grounds for license refusal or revocation.

Q: How long are AGB documents valid for? A: Passport copies must be current (not expired). Proof of address documents must be dated within 3 months of submission. Criminal background checks must be recent — typically within 6 months. Plan your document collection timeline accordingly.

Conclusion

The Anjouan gaming license application is document-intensive but not technically complex. The AGB’s requirements are clear and consistent. The operators who fail or face delays are almost always missing one of three things: a complete KYC package for all beneficial owners, a substantive AML policy rather than a template, or technical documentation of their platform’s compliance features. Get these three elements right and the rest of the process follows predictably.

Ready to obtain your Anjouan gaming license? Legarithm manages the full process — from documentation to banking. Get started

This article is for informational purposes only and does not constitute legal advice. Regulations change frequently — consult a qualified professional before making any decisions.