Illegal Online Casinos: How to Identify Unlicensed Gambling Sites and Recover Your Money
Anjouan Gaming License — A Fake Regulator and Global Gambling Fraud Network
Somewhere in the Indian Ocean, between Madagascar and Mozambique, lies a volcanic island that briefly declared independence, lost a small war, and then—in a twist no novelist would dare invent—became the world’s fastest-growing gambling regulator.
Anjouan has no gambling industry. It has no regulatory infrastructure. Its own central bank says the licensing authority operating in its name is illegal. And yet, by May 2025, this phantom regulator had issued over 1,300 gambling licenses to online casinos targeting players across Europe, North America, and beyond.
The fee? Approximately €17,000 per license. The annual revenue? Approaching €22 million. The regulatory oversight provided? Absolutely none.
This is the story of how a failed separatist movement accidentally created the perfect fraud machine—and how that machine is now systematically draining money from players who believe they’re gambling on licensed platforms.
The house always wins. Unless the house was never legally a house at all.
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I. The Win That Vanished: How Illegal Online Casinos Defraud Players
A player won. The casino froze his account.
The justification? A terms of service violation. He had logged in from Poland—a country designated as “restricted territory.” For the previous three months, he had been draining the family savings with deposit after deposit, clinging to the gambler’s eternal delusion that his luck was about to turn. During that time, no one at the casino seemed troubled that a player from a “restricted territory” was bleeding money. His Polish credit card cleared without incident. The interface helpfully switched itself to Polish.
The moment he tried to withdraw, all of this became irrelevant.
Payout? Denied. Funds? Seized. Complaint? No response.
The casino was called Revolution Casino—one of many illegal online casinos operating in the European market. In the website’s footer sat a license number: ALSI-152406028-FI2. Issued by something called the Anjouan Gaming Authority. It sounded official. It looked credible.
But what does an Anjouan gaming license actually mean? And why does the government of the island that supposedly issued it claim the licensing authority doesn’t legally exist?
For players, the answer has concrete consequences: Revolution Casino is an unlicensed gambling site under European law—and this opens the door to recovering lost funds.
II. How Illegal Online Casinos Defraud Players: Psychological and Technical Mechanisms
Before we explain what an Anjouan license actually is, it helps to understand what protects players in a legitimate online casino—and what happens when that protection disappears.
Let’s be candid: in any casino, the player will eventually lose money. The difference lies in pace and predictability. In a legally operating casino, you lose more slowly—and according to rules that are transparent and verifiable.
The Psychology of the Hook
Online casino addiction is driven by a tight loop between distorted thinking, emotional dysregulation, and highly engineered reward systems. Neurobiological research shows that gambling activates the same reward circuits as drugs—ventral striatum, amygdala, prefrontal cortex—producing dopamine-driven excitement in response to cues.
The “hook” is not just money. It’s a psychological machine that turns random wins into proof of skill, losses into near-victories, and distress into a reason to gamble more.
Cognitive traps. Core distortions include illusion of control, gambler’s fallacy, and selective memory of wins. Near misses and “losses disguised as wins” are processed more like wins than losses.
Dark patterns. Gambling apps are built around dark patterns: frictionless sign-up, one-click bets, interfaces hiding cumulative losses. Safety tools are often buried or made cumbersome.
How Fair Software Works
In a regulated environment, every casino game runs on a Random Number Generator (RNG). UK Gambling Commission in RTS 7 standard specifies: RNGs must be statistically random, with no “adaptive behaviour” modifying probabilities depending on outcome, player type, or stakes.
In recognized jurisdictions, game software is certified by third-party testing laboratories: GLI, iTech Labs, eCOGRA. UKGC requires code versioning: every change must be auditable.
How Illegal Online Casinos Manipulate Games
But what if the operator controls the entire technology stack with no oversight? Unlicensed gambling sites can:
Hide RNG bias. The algorithm can be modified to silently drop RTP from 96% to 82%. Council of Europe policy paper emphasizes that lack of independent certification opens the door to such manipulations.
Use “adaptive RTP”. Code checks player variables—VIP status, cumulative profit, bet size—and dynamically switches payout tables.
Deploy “superuser” access. In notorious poker scandals, insiders used back-end functionality to see all players’ hole cards in real time.
- Further reading: Online Casino Scams: How Internet Gambling Sites Defraud Players
AML Schemes in Illegal Online Casinos
UNLV report shows that even with honest RNG, an illegal online casino can be a money laundering tool:
- modifying bonus conditions to facilitate fund recycling
- creating “layers” of intermediaries (e-wallets, vouchers, prepaid cards)
- masking MCC codes as “e-commerce”
Kleiman’s article emphasizes: unlicensed casinos with loose onboarding are ideal for “layering”—fast deposit–few bets–withdrawal cycles.
III. What Is an Anjouan Gaming License? A Fake Gambling Regulator
Back to the footer number: ALSI-152406028-FI2. What does an Anjouan gaming license mean and why is it illegal?
Anjouan is one of four islands in the Union of the Comoros—an impoverished archipelago in the Mozambique Channel. In 1997, the island declared independence. The international community never recognized it. During eleven years of separatist rule, the breakaway government established something called the Anjouan Offshore Finance Authority (AOFA)—or rather, it handed the right to use that name to a group of private individuals connected to the offshore company industry.
The transaction had a certain literary quality. A jurisdiction that no one recognized sold something that cannot be sold. The result: a handful of private entrepreneurs began issuing colorful PDF files and calling them “licenses.”
In 2008, the separatist government collapsed. Anjouan returned to the Union of the Comoros. But the offshore licensing business survived—despite having lost whatever legal foundation it might once have claimed. Tradepass analysis now describes AOFA as a “fictitious structure.”Tradepass analysis describes AOFA as a “fictitious structure.”
Why the Anjouan License Is Illegal
Ait-Ahmed Djalim, Secretary General of the Comoros Central Bank’s Financial Intelligence Unit, told Australia’s ABC:
“These entities operate illegally. They have no legal existence in the territory of the Union of the Comoros.”
The FATF/GIABA mutual evaluation report from 2024 confirms that gambling is prohibited under Union of Comoros law. There is no national “regulated sector” that Anjouan licenses could claim to operate within.
Who Is Behind the Fake Gambling Licenses?
UK Companies House records show a dissolved company Anjouan Corporate Services Ltd. In May 2023, domains were registered for the alleged Anjouan Gaming Control Board. Domain records lead to Fast Offshore—a Costa Rica consultancy run by Ron Mendelson.
By May 2025, over 1,300 such licenses had been issued. At roughly €17,000 each, that’s annual revenue approaching €22 million—flowing to entities operating illegal online casinos worldwide.
IV. Revolution Casino and NovaForge Ltd: Case Study of an Illegal Online Casino
Revolution Casino—an unlicensed gambling site under European law—operates under NovaForge Ltd, a company registered in the Marshall Islands. Investigative reports from FinTelegram and Scam-Or Project reveal a complicated lineage.
Before NovaForge, the same network operated under Rabidi N.V.—a Curaçao company. In 2024, following a player lawsuit seeking approximately €245,000, Rabidi was declared insolvent. The Curaçao Gaming Control Board revoked its license.
The brands didn’t disappear. They migrated to new shells with new offshore credentials. NovaForge acquired the portfolio. The Anjouan license provided the veneer of legitimacy.
FinTelegram assessed: NovaForge “simultaneously acts as casino operator and payment processor within a network considered illegal.” Fraudulent conveyance and actions harming creditors and offshore structures require specialized legal expertise.
V. How Illegal Online Casinos Process Payments
Casino Guru documented a 90% increase in unresolved complaints against operators with Anjouan licenses in 2024—148 cases. Blocked accounts. Denied withdrawals.
The “geo-blocking applied only at withdrawal” scheme is documented in e-Play Africa investigative materials. The pattern at illegal online casinos is always identical: deposits work instantly, withdrawals never.
The Role of Payment Processors
UNLV report describes payment processor schemes:
- using processors in jurisdictions with weaker oversight
- masking MCC codes and transaction descriptions
- creating multi-layered intermediary structures
Swedish regulator Spelinspektionen identified a pattern: operators with Anjouan licenses process payments through agents in Cyprus, “often disguised as e-commerce.”
VI. Historical Parallels: Nauru, Western Sahara, and Sovereignty Monetization
The Anjouan gaming license model isn’t new. History records states that tried to profit from selling credentials—creating illegal online casinos and shell banks on a global scale.
Nauru: 400 Shell Banks
In the 1990s, the Republic of Nauru licensed approximately 400 offshore banks. Most existed only as mailboxes. Over $70 billion was laundered through them. FATF blacklisted Nauru in 2000. Under pressure, Nauru abolished all 400 banks.
The Structural Pattern
The “sovereignty monetization” pattern connects to the broader phenomenon of money laundering.
Nauru, Anjouan, Western Sahara—the same architecture:
- Sovereignty monetization: jurisdiction sells licenses as export products
- Regulatory vacuum: no KYC, oversight, or inspections
- Risk externalization: jurisdiction collects fees, damage falls on players
- Collapse or disavowal: under pressure, the scheme is shut down
VII. How to Recover Money from an Illegal Online Casino: Legal Options
For a law firm advising clients defrauded by illegal online casinos, the legal landscape presents obstacles—but also opportunities to recover funds.
- Further reading: How to Get Your Money Back from an Online Casino: Three Landmark E.U. Cases Against Maltese Operators
Jurisdictional Obstacles
NovaForge Ltd exists in the Marshall Islands. Traditional enforcement mechanisms struggle to reach across these distances.
How to Recover Money from Unlicensed Gambling Sites
Under Polish and EU law, Revolution Casino operates without authorization. Gambling laws require a local license or credentials from a recognized regulator. An Anjouan gaming license doesn’t qualify.
Contract invalidity. Agreements for illegal services may be unenforceable. The casino cannot enforce terms that are part of illegal activity—similar to fraud cases.
Payment processor liability. EU AML regulations impose due diligence obligations on payment service providers—Kancelaria Skarbiec analyzes these issues in detail.
Consumer protection. The “restricted country” clause—allowing deposits but blocking withdrawals—may constitute an unfair contract term.
Rome I and Brussels I bis. Revolution Casino—with its Polish interface—clearly directs activities toward Poland. Polish courts may assert jurisdiction. Kancelaria Skarbiec has experience in cross-border disputes.
Polish Jurisdiction and Consumer Protection in Disputes with Revolution Casino
European Union law affords Polish consumers robust protection in disputes with foreign online gambling operators, even those operating from exotic offshore jurisdictions.
Jurisdiction of Polish Courts
Regulation Brussels I bis (Articles 17–19) grants consumers the right to sue a business before the courts of their own domicile, provided the business “directs activities” to the consumer’s Member State. The Court of Justice of the European Union, in Pammer and Hotel Alpenhof, clarified that this assessment requires a holistic analysis of circumstances: the language of the website, currency options, payment methods, marketing content, and explicit references to customers from a particular country.
In the case of Revolution Casino, these indicators converge unambiguously. The operator maintains a dedicated Polish-language version of its platform, offers bonuses denominated in Polish złoty, provides Polish payment methods, and directs marketing communications expressly to “Polish players.” This constellation satisfies the EU standard for “directing activities” to Poland, thereby establishing grounds for proceedings before Polish courts.
Protection Independent of Contractual Choice-of-Law Clauses
Regulation Rome I (Article 6) ensures that a choice of foreign law in the operator’s terms and conditions cannot deprive consumers of the protection afforded by the mandatory provisions of their country of habitual residence. Even where Revolution Casino’s terms purport to designate the law of Anjouan or another offshore jurisdiction, Polish consumers retain the protections guaranteed by Polish consumer law — including provisions on unfair commercial practices, abusive contract terms, and liability for non-performance.
Jurisdiction clauses purporting to channel disputes to courts of third states are, as a general rule, ineffective against consumers where they would curtail protections conferred by EU law.
The Critical Dimension: Fraud
Beyond civil law arguments, the most serious and often most effective instrument in cases involving unlicensed online casinos remains the allegation of fraud under Article 286 § 1 of the Polish Criminal Code. The essence of this offence lies in inducing another person to dispose of property to their detriment through deception.
In the context of online casinos operating without a Polish licence, the elements of deception may include: holding oneself out as a legitimate operator while concealing the absence of the requisite licence; suggesting realistic prospects of winning in games whose parameters are subject to no independent oversight; deploying manipulative techniques through so-called “VIP account managers” who cultivate a false sense of personal relationship with the player; and systematically disregarding requests to close an account while simultaneously offering bonuses designed to trap the player in an addictive cycle.
Filing a criminal complaint costs the victim nothing, yet activates investigative tools unavailable in civil proceedings — law enforcement authorities possess the capacity to identify perpetrators, secure assets against future claims, and engage in international cooperation through the European Judicial Network. The criminal pathway may therefore prove more effective than attempting to enforce a civil judgment against an entity registered in the Marshall Islands.
First, though, let’s be frank: the odds of recovering your money are not great.
VIII. Scale of the Problem: How Many Illegal Online Casinos Operate with Anjouan Licenses?
IFHA research from September 2025: Anjouan became “the most popular new offshore regime”—825 active licenses by May 2025.
Spelinspektionen: 5% of all traffic to illegal gambling sites in Sweden goes to operators with Anjouan licenses.
FinTelegram to payment processors:
“We strongly warn all payment processors against facilitating transactions for illegal online casinos registered in Anjouan and targeting players in Europe.”
IX. Summary: How to Identify an Illegal Online Casino
A Comoros Central Bank official was asked what consumers should understand about Anjouan gaming licenses.
The answer: these are entities that “operate online through websites to scam people.”
An Anjouan gambling license is not a regulatory credential issued by a governmental authority. It is a commercial product sold by private companies operating illegally.
How to Identify Unlicensed Gambling Sites
- Check if the casino holds a license from a recognized regulator (Malta Gaming Authority, UK Gambling Commission)
- Anjouan licenses, Curaçao, or other offshore jurisdictions are not recognized in the EU
- Be wary of casinos that accept deposits without verification but block withdrawals
- Check forum reviews—the pattern “deposits work, withdrawals don’t” is a red flag
The number in Revolution Casino’s footer—ALSI-152406028-FI2—represents not regulatory approval but regulatory theater.
This analysis is provided for informational purposes and does not constitute legal advice. Clients with claims against illegal online casinos or operators with Anjouan gaming licenses should consult qualified counsel.
Need help recovering money from an illegal online casino? Contact Kancelaria Prawna Skarbiec—we specialize in cross-border cases and consumer protection.
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Founder and Managing Partner of Skarbiec Law Firm, recognized by Dziennik Gazeta Prawna as one of the best tax advisory firms in Poland (2023, 2024). Legal advisor with 19 years of experience, serving Forbes-listed entrepreneurs and innovative start-ups. One of the most frequently quoted experts on commercial and tax law in the Polish media, regularly publishing in Rzeczpospolita, Gazeta Wyborcza, and Dziennik Gazeta Prawna. Author of the publication “AI Decoding Satoshi Nakamoto. Artificial Intelligence on the Trail of Bitcoin’s Creator” and co-author of the award-winning book “Bezpieczeństwo współczesnej firmy” (Security of a Modern Company). LinkedIn profile: 18 500 followers, 4 million views per year. Awards: 4-time winner of the European Medal, Golden Statuette of the Polish Business Leader, title of “International Tax Planning Law Firm of the Year in Poland.” He specializes in strategic legal consulting, tax planning, and crisis management for business.
