How illegitimate regulators operate in the name of a tiny African island
SOURCE:ABC Australia|BY:Julian Fell
An ABC investigation has identified several individuals involved in a network of illegitimate corporate regulators and service firms.
At first glance, Anjouan looks like a stereotypical offshore secrecy haven.
It has no corporate taxes, minimal red tape and limited oversight — the perfect conditions for businesses seeking to avoid scrutiny.
The tiny African island plays host to banks, insurance brokers and cryptocurrency exchanges, plus a thriving industry of black-market gambling websites, including several known to be illegally targeting Australian customers.
There's just one problem: none of the licences — financial or gambling — are worth the (virtual) paper they are written on.
Local authorities say the island's regulators are "fictitious entities" that are operating "illegally".
But this hasn't stopped a network of companies from selling hundreds of licences, likely making millions in yearly fees paid by the banks and casinos.
A lack of jurisdiction
Anjouan is one of three semi-autonomous islands that make up the Comoros Union, a sovereign nation off the east coast of Africa.
In the late 90s, the Comoros went through a turbulent period, with Anjouan claiming independence from its neighbouring islands in 1997.
The separatist government soon established its own corporate regulator: the Anjouan Offshore Finance Authority (AOFA).
But it immediately struggled for legitimacy. The Comoros's vice-president accused it of being comprised of "money laundering operations" in 2007. A few years later, a World Bank mission reported that "the creation of offshore banks in Anjouan was illegal" under Comoros law.
Following reunification in the Comoros, the AOFA was officially stripped of its status as a recognised regulator by banking laws passed in 2013 and 2015.
However, it has continued to maintain a public register of licensed companies, signing up more than 50 banks, insurance companies, brokers and gambling sites since being officially dissolved.
The network of companies selling these fraudulent licences is likely to be raking in tens of millions of dollars a year in fees.
The practice has prompted multiple warnings from the Comoros Central Bank. In a 2023 statement, the central bank said several Anjouan regulators — and the firms selling their licences — were "fictitious structures".
"They … have in reality no physical or legal existence in the territory of the Union of the Comoros," Ait-Ahmed Djalim, a Comoros Central Bank official, said of these outfits in 2020.
"They operate online via websites to scam people."
Despite the warnings from Comoros authorities, online casinos continue to sign up.
Leon Casino proudly displays its Anjouan licence, which it has held onto despite being named as an illegal operation by Australian officials in early 2025.
It does not hold an Australian gambling licence, and offers several products that are banned in the country, including virtual slot machines, blackjack and in-play sports betting.
Despite this, Leon has sponsored Australian UFC fighters, put on flashy VIP events for its top customers and paid for local influencers to promote it. There is no suggestion the influencers or sponsored fighters were aware of the casino's illegal status at the time.
Leon Australia's VIP event in Perth (left) and an influencer promoting Leon in Sydney. (Supplied: Instagram)
Even after being singled out by Australian authorities, Leon continues to target Australian customers with local payment options.
To test it out, the ABC signed up to the Leon website using a random address in Adelaide.
The deposit methods available included credit card, Pay ID, Apple Pay, Google Pay and cryptocurrency.
One option, called MiFinity, appears on an industry expert's list of six payment companies that work with casinos licensed in Anjouan.
Under even the most basic scrutiny, however, Leon's payment options began to fall apart. Two vendors — including MiFinity — disappeared from the casino's website hours after receiving questions from the ABC. MiFinity did not respond to the ABC's email.
This was an early sign, perhaps, that the Anjouan licence did not come with a whole lot of oversight of the casinos operating under its name.
But it still opens doors for them, making it easy to accept player deposits.
The mystery operators
There are other signs that the supposed regulator underpinning the entire industry — the Anjouan Offshore Finance Authority (AOFA) — lacks both credibility and accountability.
Its "official" website offers a misspelled email address and no sign of any government official involved in its operation. The AOFA cites the now-defunct legislation — passed by the Anjouan separatist government in 2005 — as sole proof of its legitimacy.
To purchase a licence with the AOFA, businesses are directed to its "sole authorised" agent, Anjouan Corporate Services, which also lists no directors or board members on its website.
Mr Djalim, the secretary general of the Comoros Central Bank's financial intelligence unit, confirmed to the ABC that Anjouan Corporate Services is "operating illegally".
The firm's social media presence is run by someone called "Toby S", who describes himself as a "consultant" for the company. His phone number carries the country code of the United Arab Emirates.
He did not respond to the ABC's emails.
"Toby S" is a "consultant" for Anjouan Corporate Services. (LinkedIn: Toby S)
The history of Anjouan Corporate Services stretches back to the industry's formative years, and reveals clues about who used to be running it.
A speech from the Comoros's vice-president, made back in 2007, identified a British man in connection with the company.
His name: Ronnie Dvorkin.
Company searches in the UK showed that Dvorkin was the director of another of the "fictitious entities" called out by the Comoros Central Bank. This one was called Comoros Services Limited.
Dvorkin is in his late 70s now; a younger member of the Dvorkin clan appears to have since taken his place in the industry.
Adam Dvorkin was seen as part of the Anjouan Corporate Services delegation at a Dubai conference in 2025.
Elliot Sorsky (left), Adam Dvorkin (centre-left) and Toby Sorksy (centre-right) at a conference in Dubai. (Anjouan Corporate Services)
Joining him were Toby and Elliot Sorksy — two representatives of the other English family with links to the firm.
One of whom turns out to be "Toby S".
The conference directory lists Elliot Sorsky as the director of Anjouan Corporate Services, with Adam Dvorkin there only as a "consultant".
Another family member, Harold Sorsky, is also listed as co-director of a now-dissolved UK company called Anjouan Corporate Services Ltd, alongside Elliot Sorksy.
Harold Sorsky — who is now in his 80s — is a business associate of Ronnie Dvorkin, having shared the directorship of another now-dissolved UK company.
Anjouan Corporate Services, Toby Sorksy, Harold Sorsky and Elliot Sorsky did not reply to the ABC's emails with questions about the operations of Anjouan Corporate Services.
Adam and Ronnie Dvorkin were unable to be reached for comment.
The Costa Rica connection
Records show that Anjouan Corporate Services has a sister company.
Anjouan Licensing Services came into being in May 2023 by registering two domain names on consecutive days.
One appeared to be for a new gambling regulator, called the Anjouan Gaming Control Board, while the other — anjouangaming.com — sold its gambling licences.
The gambling licence granted to betting exchange Sx Bet. (Supplied: Anjouan Gaming Control Board)
Anjouan Licensing Services claims to have issued more than 1,300 gambling licences. At around 17,000 euros ($30,000) per licence per year, the company could be making up to 22 million euros a year.
Like Anjouan Corporate Services, it cites oversight from the AOFA as the basis for its authority to issue the licences. Azad Mzé, a former attorney-general of the Comoros, told the ABC that Anjouan Licensing Services was also "an illegal entity".
The operation's website gives no information about who controls it, listing no directors, board members or business addresses. It did not respond to the ABC's emails about its ownership or connections to Anjouan.
But Anjouan Licensing Services does have one name associated with it. Domain registration records for its two websites, from back in May 2023, show them both being set up by a Costa Rican company.
Fast Offshore — then called Overseas Business Services Ltd — is run by a Canadian named Ron Mendelson.
Ron Mendelson has worked in the offshore finance industry since the 90s. (X: Ron Mendelson)
The consultancy assists companies to apply for gambling licences in several jurisdictions, including Anjouan.
Mendelson himself has published numerous articles, regularly touting the benefits of choosing the tiny African island when setting up an online casino. "How Anjouan saves you thousands compared to other jurisdictions," he wrote in December.
These articles, published on industry news sites, also serve as ads for his business. "With the lowest market costs and a setup process that takes just days when you partner with Fast Offshore, Anjouan is redefining offshore success for [gambling] businesses," he wrote.
Mendelson appears to be well-connected to the Anjouan licensing industry.
Mendelson posted about attending a global gambling conference in Barcelona, which triggered Elliot Sorsky — the CEO of Anjouan Corporate Services — to suggest the pair meet up.
An exchange between two individuals with connections to different Anjouan regulators. (Screenshot: LinkedIn)
Ron Mendelson and Fast Offshore did not respond to the ABC's request for comment.