It's like a different universe compared to Dr No and FRWL
Certainly it's in a very different style to DN and FRWL. More of a lighthearted caper, versus the moodier thrillers that the series started with. DN had its funnier moments, with the one liners. FRWL had a couple. And by the time DAF comes along these comedic touches...one liners, innuendos, even moments of near slapstick have become more prominent. So, yes, it certainly is more of a comedy than those earlier films.
But can it be called a full-blown comedy? i.e is it's primary purpose to be a funny film? I'd say probably not. But a crime/espionage caper with comedic elements? For me, yes.