The Anjouan gambling regulator has steadfastly denied that its licences are designed to be used globally and universally.
Anjouan, one of the autonomous islands of the Union of the Comoros in the Indian Ocean, has found itself front-and-centre in conversations around illegal and unlicensed gambling in major betting markets like the UK.
Anjouan Gaming published a statement on LinkedIn on 10 June responding to what it called “public commentary” around its licences and comparisons between its own regulatory standards and those of other national gaming authorities.
The regulator has not singled out any specific examples of the commentary it is referring to.
However, anyone familiar with the betting industry will be very aware that Anjouan is routinely mentioned in conversations around black market, grey market, and unlicensed gaming.
“An Anjouan Internet Gaming Licence is not, and has never been presented as, a universal authorisation to operate in every country in the world,” Anjouan Gaming’s Linkedin statement read.
“No licensing authority can exempt an operator from local law in jurisdictions where local authorisation is required.”
Licences, un-licences, and Anjouan
The problem Anjouan Gaming has is that on the face of it, its licences do appear to be universal to manny of the operators it has licensed.
In the eyes of both regulated local industries and advocates for gambling reform across the world, the Anjouan licence has a degree of universality to it also.
Take the UK for instance. One of the largest markets in Europe, illegal, offshore and unlicensed gambling have dominated industry discussions in the UK for many years, whether in conversations around regulatory issues like affordability checks, marketing, sponsorship, or around taxation.
To understand this fully, we need to draw a line between what black market, unlicensed and offshore gambling mean:
- Black market – fully illegal operations, whether online or offline, as in the case of a den raided in Manchester last month, which lack the required Gambling Commission licences to operate in the UK and are not registered with other government bodies like Companies House.
- Unlicensed (Grey Market) – An operator or business providing online gambling services within a market that has no settled regulatory regime or specific legal determinations for online gambling. Operators may choose to operate in these markets as their regulatory systems offer no specific legislation or licensing framework for online gambling. Examples include Finland, Norway and Chile.
- Unlicensed (Marketing) – a phenomenon seen mainly in the UK, this is where companies which are not licensed or active in the country have struck deals with Premier League clubs to take advantage of the league’s global visibility in the markets they do target, mainly in Asia.
- Offshore – when a company is licensed in a jurisdiction such as Malta, Curacao or Anjouan, and uses this licence as proof of its credibility to operate internationally, including in markets where it may not hold the required local licences or in grey markets.
Anjouan Gaming’s public register has over 1,300 different licences listed.
Many of the operators are active internationally using its licences and could fit into any of the categories outlined above in markets like the UK, depending on if they have a Gambling Commission licence or not.
However, a Google search for ‘non-Gamstop casinos’ will quickly unearth some notable examples of companies licensed in Anjouan which are both a) not licensed in the UK, but b) allow British customers to openly access their platform.
On one casino comparison site, for example, five websites are listed as some of the UK’s top non-Gamstop casinos – i.e. online casinos which are not connected to the Gamestop self-exclusion service, a requirement for Gambling Commission-licensed companies.
All five of these sites are named on the Anjouan Gaming public register as being operated by Softon Ltd, a Cyprus-based company, under licence ALSI-202409012-FI1:
- Kingdom Casino
- Gambiva
- Dracula Casino
- TenoBet
- Smash Casino
Another search of the Anjouan public register shows a licence covering 28 different domains, 27 of which have a .best domain name while one has a .com domain name.
The group’s brands include sites like Daily Luck and Admiral Shark, both of which are accessible from the UK. An Admiral Shark UK domain name also exists, with the company openly branding itself a non-Gamstop casino.
Anjouan calls for line to be drawn
In its LinkedIn statement, Anjouan Gaming has criticised “commentary that inflates offshore licensing with local market authorisation” and “treats operator misconduct as proof against an entire framework”.
The regulator has also defended its licensing process, pointing to its licence conditions, due diligence, AML and KYC standards, responsible gaming requirements, technical, platform and complaint handling standards, website approval requirements, and enforcement actions.
Its website lists due diligence requirements such as submission to a corporate and structural review, a key person assessment, and a requirement to demonstrate adequate financial resources.
The website also states that applicants will be subject to screening against international sanctions lists, politically exposed persons databases, and adverse media sources, and that licences will not be issued if screening identifies any concerns.
In its LinkedIn post, the regulator signed off: “Anjouan Gaming remains committed to the development of a practical, transparent, and commercially accessible internet gaming licensing framework, while making clear that licensees remain responsible for lawful conduct in their chosen markets.”
Anjouan is hardly the only nation to come up in conversations around offshore, unlicensed and illegal gambling. Just as many non-Gamstop casinos can be seen displaying Curacao licences, for example, such as MyStake – regarded by some as one of the biggest illegal operators targeting the UK.
However, the island will no doubt continue to find itself in the firing line as major players in regulated markets continue to hit out at black market activity.
Flutter rallies against black market
With the World Cup kicking off tomorrow, various European regulators have issued warnings to consumers about the risks of black market activity. In the UK, operators like Entain are raising alarm bells about unlicensed firms sponsoring Premier League clubs.
This afternoon, Flutter Entertainment published an op-ed written by its President and the Chief Executive Officer of its Flutter International division, Dan Taylor, who cautioned that “the illegal market is winning major ground”.
“Different countries take different approaches, and the strongest operators respect that and operate within those frameworks,’ Taylor wrote.
“We’ve never viewed strong regulation and commercial success as mutually exclusive. That’s worth saying clearly, because it’s often lost in political debate. What’s also lost – and what deserves far more attention – is the scale of the illegal market threat.
“A risk far greater to consumers than competition between licensed operators is the rapid, largely unchecked growth of offshore illegal betting sites that bypass consumer protections, avoid taxation, offer no meaningful responsible gambling safeguards and, in many cases, have direct links to criminality.”
Anjouan Gaming appears to be calling for a distinction between its own status as a regulator and the “misconduct” some of its licensees may be engaged in.
However, this will likely do little to ease the criticism the regulator and the framework it oversees receives when many of its licence holders are active in markets without the local legally required licences.
This is especially true when concerns about illicit gambling activity are at an all time high.