Comoros CFD and VASP licensing route from the Ministry of Finance
The Union of Comoros appears to be positioning a new licensing framework under the Ministry of Finance, Budget, and Banking Sector Services for certain forex brokerage and virtual asset activities. Based on information currently made available to the market, the regime is presented as operational and intended to form part of a broader move toward more centralised national oversight of financial service operators.
The framework is described as covering a range of activities including forex brokerage, virtual asset services, crypto-to-fiat and crypto-to-crypto exchange, digital asset custody and transfer, and related advisory activities, with scope ultimately dependent on the licence category granted and the applicant’s approved business plan.
From a governance perspective, the structure appears to require at least one director and one shareholder, with flexibility as to nationality and residence for the principal participants, but with a local director or resident representative forming part of the regulatory setup. The regime also appears to contemplate the appointment of key control functions, including compliance and AML oversight.
In terms of substance and ongoing obligations, operators are expected to maintain annual financial statements, compliance reporting, AML/CTF monitoring, and internal governance documentation. A local banking arrangement is also indicated as mandatory for the deposit of share capital.
At capital level, the framework has been presented with a minimum share capital requirement of EUR 10,000, while certain virtual asset business lines, including Virtual Asset Exchange, may be subject to a EUR 20,000 capital threshold.
The wider regulatory context remains relevant. The Ministry-led framework is being positioned as part of an effort to consolidate oversight and address historical fragmentation in Comoros-related offshore licensing structures. Market participants currently licensed under legacy or parallel structures, or those exploring transition into a more formalised framework, should assess carefully how the Ministry’s position develops in practice, including recognition, enforcement posture, governance expectations, and operational substance requirements.
For firms wishing to transition from other Comoros regimes, or for those seeking support to explore and crystallise whether this framework is suitable for their business model, the development is one to monitor closely.
If you are considering establishing a Comoros CFD entity or other related entities, contact us at licensing@salvusfunds.com – our team is ready to support your licensing objectives.
SALVUS Funds’ teams can be engaged for guiding on new license authorisations for payment services, ongoing regulatory compliance consultancy for licensed entities, and support in successfully acquiring ready-made regulated entities.
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