Comoros Cryptocurrency Regulation: The BCC Warning Behind Offshore Licence Claims
Read the BCC’s warning on Comoros crypto and VASP licences, the Finance Ministry’s unofficial-licence notice and GIABA’s 2026 AML findings.
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The Banque Centrale des Comores has expressly warned about purported crypto and VASP licences. Its signed notice of 8 December 2025 says virtual-asset and related service-provider activities were not authorised on national territory and no corresponding licences had been issued.
That is a dated central-bank position. A company claiming a later approval should produce the relevant legal instrument and decision.
The latest GIABA follow-up reviewed here still records a gap concerning virtual assets and their service providers. It also records wider AML reforms. Both findings need to be read together.
Use our Africa cryptocurrency regulation directory to compare those distinctions across countries.
What does the 2026 follow-up say?
GIABA’s second enhanced follow-up report for the Union of the Comoros records adoption of AML/CFT/CPF Law No. 25-004/AU on 30 June 2025.
The report’s summary table retains a non-compliant rating for Recommendation 15 and records that provisions concerning virtual assets and VASPs had not been issued. Its risk-assessment discussion also identifies gaps in coverage of the sector.
A country-level technical-compliance rating is not a company licence decision. It assesses a different question.
What was the earlier assessment’s baseline?
The 2024 mutual evaluation reflects an onsite visit from 12–26 July 2023. Its virtual-asset findings must retain that period.
The newer report is important because the surrounding AML framework subsequently changed. An article that stops at the older assessment risks overlooking those reforms.
This article does not claim that every activity involving crypto is prohibited. It also does not treat an identified regulatory gap as permission to offer financial services.
What do the official offshore warnings say?
The BCC’s offshore warning, republished by the Finance Ministry on 10 December 2025, names Mwali International Services Authority (MISA), Anjouan Offshore Finance Authority, Anjouan Corporates Services, Comoros Services LTD and CIBA among structures purporting to issue banking and financial approvals.
The BCC says those purported authorities and their offshore entities are operating illegally in that sphere. Its regulatory materials state that banking and financial authorisation falls at Union level rather than to island governments.
The BCC communiqué dated 8 December 2025 and its signed attachment go further. The attachment identifies virtual assets and VASP activities among activities not authorised at that date, with no corresponding licences issued. It also warns that the named structures have no legal authority to issue financial or banking licences for the Union or its islands.
The notice concerns professional activities and purported approvals. It does not establish a blanket criminal prohibition on personal crypto possession.
A certificate marketed by an island authority should not be described as recognised national approval on the seller’s assurance.
What did the ministry say about crypto licences?
The Finance Ministry’s separate information note of 10 December 2025 specifically reports fraudulent licence issuance in forex and cryptocurrency.
It says it was working on an official licensing framework with PAIA FINANCE. Pending that framework, it prohibits promotion or use of unofficial licences.
That statement describes work towards a framework. It does not itself supply an operative VASP statute, application procedure or company-specific approval. This review did not independently establish a later completed framework or validate a commercial distributor’s licence offer.
How should a licence claim be tested?
Ask for the full legal name of the issuer. Then obtain the legislation that gives that issuer authority over the proposed service.
Compare the certificate with an official decision or register entry. Check the legal entity, validity period, service scope and any restrictions.
| Claim | Evidence to request |
|---|---|
| “Licensed in Comoros” | Issuing authority and statutory power |
| “Registered company” | Incorporation record and separate financial permission |
| “Authorised for crypto” | Decision explicitly covering the claimed activity |
| “International licence” | Legal basis for serving each customer market |
| “Banking access included” | Bank agreement and permitted funds flow |
A seller’s description should lead to verification. It should not substitute for it.
What can the central-bank materials establish?
The Banque Centrale des Comores publishes banking and financial legislation and regulatory texts.
Those are useful starting points for checking the instrument cited by an applicant or adviser. They do not establish that a particular certificate covers exchange, custody or remittance.
An island-issued or other offshore certificate must be assessed against those official warnings. Incorporation, a promotional certificate and the right to conduct regulated financial business are distinct matters.
What should a proposed business document?
Describe the complete service. Show the contracting company, the operator controlling crypto and the party handling fiat.
Identify where customers reside and where complaints or legal claims can be brought. Record which authority supervises each part of the arrangement.
A cross-border service needs analysis in the markets it targets. Registration in one jurisdiction does not by itself resolve the rules in every other market.
Is there a verified minimum capital?
A universal current Comorian VASP capital requirement was not independently verified. Nor was a complete public VASP application route or a named approval.
A commercial quotation should identify its legal basis and separate capital from adviser charges, company formation and banking costs. Avoid presenting a package price as a regulator’s fee.
For context, read Seychelles cryptocurrency regulation and VASP licensing, Mauritius virtual-asset regulation and Madagascar’s cryptocurrency legal framework.
Research scope
Reviewed 5 November 2026. Sources include GIABA’s retrieved 2026 follow-up, the earlier assessment, BCC warnings and the Finance Ministry’s separate crypto-licensing note. The 2025 AML law is discussed through GIABA’s assessment; no claim is made that every provision was independently reconciled with later instruments. No complete current public VASP application route, universal capital figure or named provider approval was independently confirmed.
