Overview
The Comoros banking license refers to offshore banking permits issued through the autonomous islands of the Union of the Comoros, a small archipelago nation in the Indian Ocean off the southeastern coast of Africa. Two distinct offshore regulatory frameworks have operated on the islands of Anjouan and Mwali (Mohéli), offering international banking licenses at significantly lower cost and capital thresholds than virtually any other jurisdiction worldwide.
The Anjouan Offshore Finance Authority (AOFA), established under the Offshore Finance Authority Act of 2005, and the Mwali International Services Authority (MISA) have marketed offshore banking licenses to international applicants. However, the legitimacy of these authorities is heavily disputed. The Banque Centrale des Comores (BCC), the national central bank and sole legally recognized financial regulator for the entire Union of the Comoros, has publicly stated that MISA is a fictitious entity with no legal basis or authorization to issue financial licenses. Multiple international sources have issued fraud warnings regarding Comoros offshore licenses.
WARNING: The Comoros offshore banking license is widely considered one of the highest-risk jurisdictions in the world for financial licensing. Applicants face severe correspondent banking challenges, limited international recognition, and significant reputational risk. Thorough independent legal due diligence is absolutely essential before pursuing any Comoros-based financial license.
Regulatory Framework
National Regulator: The Banque Centrale des Comores (BCC) is the central bank and official financial regulatory authority for the entire Union of the Comoros. The BCC supervises domestic banking institutions under Banking Law No. 13-003/AU of June 12, 2013. The Direction of Banking Supervision and Regulation within the BCC is responsible for approving the establishment of new banks on all three islands.
Anjouan Offshore Authority: The Anjouan Offshore Finance Authority (AOFA) was established under the Offshore Finance Authority Act of 2005. AOFA operates through the Comoros International Banking Authority (CIBA), which processes offshore banking license applications on Anjouan island. AOFA claims authority under local island legislation to regulate offshore financial services.
Mwali Offshore Authority: The Mwali International Services Authority (MISA) claims regulatory authority over offshore financial services on Mwali island under the Banking Act 2013, Anti-Terrorism Act 2007, Customer Protection Act 2009, AML Law 2014, and IBC Regulations 2014.
Critical Legitimacy Dispute: The BCC has officially declared that MISA has no legitimacy, no legal basis, and no authorization to issue licenses to companies operating in the banking or financial sector. The BCC considers MISA a fictitious entity. This dispute extends to the fundamental question of whether autonomous island authorities have legal standing to issue offshore financial licenses independently of the national central bank. Applicants must understand that licenses issued by AOFA or MISA may not be recognized by the BCC or international financial regulators.
License Types
Domestic Banking License (BCC-regulated): Issued by the Banque Centrale des Comores under Banking Law No. 13-003/AU. Requires formal approval from the BCC, registration as a legal entity in the Comoros, and compliance with BCC capital adequacy regulations. This is the only license type recognized without dispute by the national government.
International Banking License -- Anjouan (AOFA/CIBA): A full unrestricted offshore banking license issued by the Comoros International Banking Authority for all banking services conducted outside the Union of the Comoros. This license encompasses banking business and investment banking business conducted in all major foreign currencies. An International Business Company (IBC) registration is required alongside the banking license and can be applied for simultaneously.
International Banking License -- Mwali (MISA): An offshore banking license issued under the Mwali Banking Act 2013. Capital requirements are assessed based on planned operational scope, with banks handling only in-house treasury functions requiring less capital than those accepting public deposits.
Banking License with Crypto Authorization: Available through Anjouan, this variant adds cryptocurrency trading, exchange, custody, and deposit capabilities to the standard offshore banking license. It permits opening accounts in any cryptocurrency, taking deposits in cryptocurrency, providing crypto liquidity, and conducting CFD trading alongside traditional banking activities.
Capital Requirements
Domestic Banking License (BCC): Minimum capital requirements are set by BCC Regulation 001 concerning the minimum social capital of financial institutions. Specific amounts are determined by the BCC based on the nature and scope of proposed banking activities.
Anjouan Offshore Banking License: A minimum reserve of USD 100,000 is required. This may be provided as an irrevocable guarantee from a foreign bank or as a deposit at the National Bank of Anjouan. Some service providers have advertised that no minimum capitalization is required for certain license configurations, though this likely refers to specific limited-scope arrangements.
Mwali Offshore Banking License: The regulator requires that banks be sufficiently capitalized for their planned operations. Banks conducting only in-house treasury functions may operate with lower capital, while those accepting public deposits from the general public require higher capitalization. The Mwali regulator reportedly demands high liquidity at all times.
Proof of Capital: Applicants may demonstrate capital availability through corporate or personal bank account statements. Some service providers indicate that cryptocurrency holdings may be accepted as proof of capital for Anjouan licenses.
Important Note: These capital requirements are extremely low by international standards. Major jurisdictions typically require EUR 5 million to EUR 25 million or more for banking licenses. The low capital thresholds in Comoros are a primary reason international regulators and correspondent banks view these licenses with suspicion.
Application Process
Anjouan Application Process:
- •Register an International Business Company (IBC) through the Registrar of International Businesses
- •Submit the banking license application to CIBA simultaneously with or after IBC registration
- •Provide a comprehensive business plan detailing investment strategies, ownership breakdown, and planned banking services
- •Submit directors' CVs, full contact details, and bank references
- •Provide certified passport copies for all beneficial owners
- •Submit proof of address (utility bills) for all principals
- •Provide criminal record certificates for all directors and beneficial owners
- •Submit latest audited financial statements for any shareholding companies
- •Demonstrate proof of paid-in capital
Timeline: Approximately 4 to 6 weeks for company registration and license approval, subject to successful completion of background checks on directors and shareholders and approval of the business plan.
Mwali Application Process: Similar documentation requirements including a comprehensive business plan, background checks on directors and shareholders, and business plan approval from the banking regulator. IBC formation can be submitted simultaneously with the license application.
Post-Approval Requirements: Licensed entities must apply for a SWIFT/BIC code, establish AML and anti-terrorist financing policies, develop a compliance manual, and arrange correspondent banking relationships. Obtaining correspondent banking is widely reported as the most significant practical challenge for Comoros-licensed banks.
Fees and Costs
IBC Registration Fee: Approximately EUR 11,750 for International Business Company registration on Anjouan.
Banking License Fee: Reported ranges vary by service provider and license scope. Figures cited by various sources include EUR 49,000 to EUR 69,000 for the banking license itself. The total cost including company formation, license, and initial setup through a service provider typically falls in the range of EUR 60,000 to EUR 80,000.
Annual Renewal Fees: Annual license maintenance fees apply, though specific amounts vary and are not consistently published. Fees are subject to change and depend on the corporate structure and license type.
Tax Regime: Offshore entities operating under Comoros banking licenses benefit from 0% corporate tax on offshore operations. There is no withholding tax on dividends and no capital gains tax for offshore banking activities conducted outside the Union of the Comoros.
Ongoing Compliance Costs: Licensed banks must submit annual accounts to the regulatory authority within 3 months of year-end. Additional costs include compliance officer remuneration, AML software, audit fees, and correspondent banking arrangement fees.
Cost Comparison: These fees are a fraction of what comparable licenses cost in established jurisdictions. A European banking license may require EUR 500,000 or more in application and setup costs alone. This extreme cost differential is itself a significant risk indicator that prospective applicants should carefully evaluate.
Permitted Activities
The Anjouan offshore banking license authorizes a broad range of financial services conducted outside the territory of the Union of the Comoros:
- •Accepting cash deposits of any type (depositary transactions)
- •Lending and credit facilities
- •Currency and foreign exchange transactions
- •Issuing securities and credit cards
- •Fund administration and custodial services
- •Trusteeship and fiduciary services
- •International portfolio management
- •Money market and treasury operations
- •E-commerce and payment processing services
- •CFD (contract for difference) trading
Cryptocurrency Activities (with crypto authorization):
- •Cryptocurrency trading and exchange (fiat-to-crypto and crypto-to-crypto)
- •Opening accounts in any cryptocurrency
- •Taking deposits in any cryptocurrency
- •Crypto liquidity provision
- •Cryptocurrency custody and storage
- •Issuance of utility tokens and security tokens
- •NFT management and transfer
Territorial Restriction: All offshore banking activities must be conducted outside the Union of the Comoros. Licensed offshore banks may not serve domestic Comorian clients or operate within the local economy. This restriction is a fundamental condition of the offshore license framework.
Compliance and Ongoing Obligations
AML/KYC Requirements: Licensed entities must implement Anti-Money Laundering (AML) and Know Your Customer (KYC) policies in accordance with the AML Law 2014. This includes customer due diligence procedures, transaction monitoring, and suspicious activity reporting.
Anti-Terrorist Financing: Compliance with the Anti-Terrorism Act 2007 is mandatory. Banks must screen customers and transactions against international sanctions lists.
Annual Reporting: Annual audited accounts must be submitted to the regulatory authority within 3 months of the financial year-end.
Ownership Disclosure: Any change in share ownership must be disclosed to the regulator promptly.
Confidentiality: The framework provides statutory confidentiality for legitimate offshore banking clients, though this is subject to AML and anti-terrorism exceptions.
Compliance Manual: Licensed banks must maintain a current compliance manual covering all regulatory obligations.
Local Presence: While no physical office requirement is typically imposed for offshore licenses, licensed entities should maintain a registered agent and registered office address in the relevant island jurisdiction.
Director Requirements: No explicit residency or nationality restrictions on directors are imposed for offshore licenses. Background checks (criminal records verification) are required for all directors and beneficial owners. Professional director services are available through local corporate service providers.
Advantages
Low Entry Cost: Total setup costs including company registration and license fees are among the lowest globally for a banking license, typically under EUR 80,000 compared to millions of euros in established jurisdictions.
Minimal Capital Requirements: The USD 100,000 minimum reserve requirement for Anjouan is a fraction of what major jurisdictions demand, making it accessible to smaller operators and startups.
Fast Processing: The 4 to 6 week approval timeline is significantly faster than the 6 to 18 months typical of major banking jurisdictions.
Broad Scope of Activities: A single license covers traditional banking, investment banking, forex, e-commerce, payment processing, and optionally cryptocurrency services.
Crypto-Friendly: Explicit authorization for cryptocurrency activities including trading, custody, deposits, and token issuance is available, which remains difficult to obtain in many jurisdictions.
Zero Offshore Taxation: The 0% tax rate on offshore operations, with no withholding tax or capital gains tax, provides a favorable fiscal environment.
Minimal Bureaucracy: The application process involves less documentation and fewer procedural steps than comparable licenses in regulated jurisdictions.
Privacy Protections: Statutory confidentiality provisions exist for legitimate offshore banking clients.
Important Risks and Considerations
CRITICAL WARNING: Prospective applicants must carefully evaluate the following risks before pursuing a Comoros banking license. These risks are severe and well-documented.
Disputed Regulatory Legitimacy: The Banque Centrale des Comores (BCC), the national central bank, has officially declared that MISA is a fictitious entity with no legal authority to issue financial licenses. The legal standing of AOFA on Anjouan faces similar questions. Any license obtained through these offshore authorities may not be recognized by the national government or international regulators.
Correspondent Banking Challenges: Obtaining and maintaining correspondent banking relationships is the single greatest practical obstacle for Comoros-licensed banks. Major international banks routinely refuse to establish correspondent accounts with Comoros offshore banks due to perceived high risk. Without correspondent banking, an offshore bank cannot effectively process international transactions.
Fraud Warnings: Multiple international sources, financial watchdog organizations, and the BCC itself have issued warnings about Comoros offshore licensing. Some entities marketing Comoros licenses have been linked to fraudulent activities. The jurisdiction attracts a disproportionate number of questionable operators precisely because of its low barriers to entry.
Limited International Recognition: Comoros offshore banking licenses are not recognized or respected by regulators in the European Union, United States, United Kingdom, or most developed economies. Operating under a Comoros license may trigger enhanced due diligence scrutiny from counterparties and financial institutions worldwide.
Reputational Risk: Association with the Comoros offshore banking sector carries significant reputational risk. Legitimate clients, partners, and counterparties may refuse to engage with a Comoros-licensed institution. This reputational damage can be difficult or impossible to reverse.
Regulatory Instability: The conflict between island-level offshore authorities and the national central bank creates fundamental legal uncertainty. Regulatory frameworks may change without notice, and licenses issued by disputed authorities could be retroactively invalidated.
Due Diligence Advisory: Any individual or entity considering a Comoros banking license should retain independent legal counsel with expertise in international banking regulation before proceeding. Do not rely solely on information provided by corporate service providers or licensing agents who have a financial interest in completing the transaction. Verify all claims about regulatory authority, license validity, and correspondent banking access independently.