Holyluck

What the Anjouan licence actually covers

Holyluck is licensed by the Anjouan Gaming Authority, the regulatory body established on the autonomous island of Anjouan (one of the three islands that make up the Union of the Comoros in the Indian Ocean). Anjouan's modern iGaming licensing framework was relaunched in 2023–2024 by Anjouan Licensing Services Inc., the exclusive licence administrator, and has been adopted at scale since by operators that previously sat under Curaçao's old master-licence system. The operator's licence number is ALSI-202509069-FI2, listed as valid on the official Anjouan licence register.

What the licence does

• Operator vetting at issue. The framework requires KYC on beneficial owners and directors, clean criminal-record checks, source-of-funds documentation, a written business plan, and AML/KYC/responsible-gaming policies before the licence is issued.
• Game-software certification. Operators must use certified RNG technology, with provider certificates submitted as part of the licensing pack.
• Segregated player funds. Operators must hold player balances in accounts separate from operating funds. This is the single most consequential player-protection clause in the framework.
• Formal complaint process. Operators must publish a complaint-handling procedure and respond to player disputes within the timeframes defined by the regulator.
• Public register and seal verification. Every licensed operator appears on the official register with licence number, issue and expiry dates, status, and authorised domains. Operators may display a seal whose ID resolves to the register entry in real time.

What the licence does not do

• No binding third-party adjudication. Anjouan provides a formal complaint process between player and operator, but it does not offer the binding ADR (alternative dispute resolution) tier that regulators like the UKGC or MGA mandate. If the operator refuses to pay, the regulator can revoke the licence — but does not order the operator to pay the player.
• No deposit caps or central self-exclusion. Unlike MGA, UKGC, KSA, or Sweden's Spelpaus, Anjouan does not run a cross-operator self-exclusion register or impose mandatory deposit limits. Self-exclusion is a per-operator setting; players who want cross-operator protection have to rely on GamStop / Cruks / Spelpaus where applicable.
• Disputes from excluded territories are not mediated. The Anjouan Gaming Board explicitly excludes mediation for players based in jurisdictions the operator was supposed to block. If you played from a restricted country, the regulator will decline the case.
• No public dispute decisions database. There is no published archive of operator complaints and rulings comparable to the UKGC's enforcement-action page or the MGA's player-complaint summaries. Track-record information has to be reconstructed from third-party sources (Trustpilot, AskGamblers, casino-forum threads).
• Limited recourse outside the licence. Anjouan's jurisdiction is the autonomous island, not the Comorian Union. Comorian union-level law treats most gambling as prohibited, which creates a structural mismatch: the licence is real and the regulator acts, but it operates entirely within the island's autonomy carve-out.

How this compares to other offshore licences

Anjouan sits in the same operational tier as the new Curaçao LOK framework (issued directly by the CGB since 2024, replacing the old master/sub-licence system) and Tobique (Canadian First Nation regulator that took over from Kahnawake for many crypto operators). All three offer real but light-touch licensing: operator vetting at issue, mandated segregated funds, formal complaint handling, no binding third-party arbitration, and minimal ongoing player-protection infrastructure compared to MGA, UKGC, or KSA.

In practical terms: an Anjouan licence means the operator has been vetted by a regulator that exists, will respond, and can revoke. It does not mean a player will be made whole by the regulator if the operator decides not to pay. Players who want that should play at UKGC, MGA, or comparable-tier operators, accepting the friction (KYC at every turn, withdrawal holds, deposit limits) that comes with that protection.

Frequently asked questions