The unlicensed market has a licensing body.
It's called Anjouan.
This week, Anjouan Gaming issued a clarification. Its licences "are not, and have never been presented as, a universal authorisation to operate in every country in the world."
The operators who use Anjouan licences to accept players in the UK, Australia, and Germany may have missed that memo.
The clarification is technically accurate. Anjouan licences do not say "operate everywhere." They also do not list which countries are restricted. They come with KYC requirements, responsible gaming clauses, and AML standards. They look like a compliance framework.
That is the point.
The black market does not want to operate without oversight. It wants to operate with the appearance of oversight while avoiding the substance of it. An Anjouan licence is not a tool for avoiding regulation - it is a tool for performing regulation without delivering it.
Regulators in the UK and Australia are now grappling with operators who are technically "licensed" but practically unlicensed in every way that matters. H2 Gambling Capital estimates £16.6 billion staked with unlicensed operators in the UK in 2025. Much of that came from operators holding a licence - just not one that means what players assume it means.
The Anjouan clarification is not a regulatory intervention. It is a liability transfer. The regulator is now on record saying it did not authorise what its licensees are doing. The licensees will continue doing it.
The pattern is not new. Curacao has spent three years explaining what it did not intend. Tobique is next.
The question for operators who hold legitimate licences in regulated markets is simpler: how much of your competitive disadvantage is priced in at the cost of your licence, while your unlicensed competitors pay a fraction and operate under a flag that confuses rather than protects?
That is not a regulatory problem. It is a market architecture problem.