Back to Analyses

Comoros

Retail_Trading_Status

Allowed-Unregulated Unknown
Edit

Status Changed

Previous status: Unclear

The primary difference between the two analyses is the assessed "Current Status" of retail cryptocurrency trading in Comoros. The previous analysis determined the status as `Unclear`, while the new analysis concludes it is `Allowed-Unregulated`. The justification for this change in the analysis result and status is as follows: 1. **Interpretation of "Legal Gray Area" and Absence of Prohibition:** The previous analysis highlighted that cryptocurrencies exist in a "legal gray area," meaning neither explicitly legal nor illegal, leading to an "Unclear" status due to this ambiguity. The new analysis takes this same fundamental condition – the absence of specific laws prohibiting or explicitly permitting/regulating crypto for individuals – and interprets it differently. It concludes that if an activity is not explicitly illegal or prohibited by the government, then it is, by default, allowed for individual citizens, even if it remains unregulated. The new analysis places more emphasis on the fact that "the government hasn't declared cryptocurrencies illegal" as a basis for the "Allowed" component of its status. 2. **Increased Definitive Stance Based on Available Information:** The previous analysis leaned towards caution due to the lack of explicit legal frameworks or statements from the Central Bank of Comoros regarding domestic retail trading. The new analysis, while acknowledging the same lack of a comprehensive national regulatory framework, makes a more definitive judgment. It reasons that the absence of a ban, coupled with the accessibility of international exchanges and the existence of the Anjouan licensing regime (even if for offshore businesses), points towards an environment where individuals *can* engage in trading, albeit without specific domestic protections or oversight. 3. **Nuanced Understanding of Anjouan's Offshore Regime vs. Domestic Retail Activity:** Both analyses correctly identify the Anjouan Offshore Finance Authority (AOFA) and its role in licensing crypto-related businesses. However, the new analysis more explicitly distinguishes this offshore regime, which targets international businesses, from the regulatory environment for *domestic retail* traders. It clarifies that Anjouan's licensing "does not translate into a regulated domestic market for retail crypto traders within Comoros itself." This clearer separation helps to define the domestic situation as "unregulated" for individuals, even if businesses can obtain licenses in Anjouan for international operations. The previous analysis noted this separation but perhaps didn't use it as strongly to define the domestic retail status beyond "unclear." 4. **Influence of Source Phrasing and Emphasis:** The new analysis incorporates sources, such as UEEx Technology, which state more directly: "Comoros does not have specific laws regulating cryptocurrency. The government hasn't declared it illegal, but no clear rules govern its use either." This type of phrasing lends more direct support to an "Allowed-Unregulated" conclusion than the more general "legal gray area" descriptions heavily relied upon previously. The new analysis seems to leverage such statements to move past ambiguity. 5. **Contextualization of Regional IMF Findings:** While both reports cite the IMF's findings on Sub-Saharan Africa (e.g., 85% of countries lacking crypto regulation), the new analysis specifically addresses the IMF's point that "Eighty percent of respondents report that people are not legally allowed to hold and transact in crypto assets." It then qualifies this by stating it's a "general regional observation and may not precisely reflect the nuanced situation in Comoros where no explicit ban for holding or transacting seems to exist for individuals." This careful contextualization allows the new analysis to maintain its "Allowed-Unregulated" stance for Comoros, suggesting Comoros might be in the minority 20% or that its "non-prohibition" is distinct from an explicit allowance or disallowance. In summary, the shift from "Unclear" to "Allowed-Unregulated" does not necessarily indicate a change in Comorian law itself between the periods of the two analyses. Instead, it reflects a more assertive interpretation of the existing, persistent lack of specific national legislation. The new analysis concludes that the absence of an explicit ban on retail crypto trading, despite the lack of specific regulations and consumer protections for it at the national level (outside the Anjouan offshore framework for businesses), means that individuals are permitted to engage in such activities, albeit in an unregulated environment.

Analysis ID
#302
Version
Archived
Created
2025-06-26 09:17
Workflow Stage
Initial Research

Executive Summary

As of June 2025, Comoros allows retail cryptocurrency trading in an unregulated environment. There are no specific laws from the Central Bank of Comoros governing cryptocurrency activities for individuals, neither explicitly permitting nor prohibiting them. The Anjouan Offshore Finance Authority (AOFA) offers licenses for crypto businesses, but this doesn't translate into domestic regulation for retail traders within Comoros. Individuals can access international exchanges like Bitget, but without dedicated consumer protection or clear official guidance from central financial authorities.

Key Pillars

The primary regulator related to financial oversight is the Central Bank of Comoros, responsible for the banking system and financial crime regulations. However, there's no specific regulatory framework or oversight for cryptocurrency trading. The Anjouan Offshore Finance Authority (AOFA) provides licensing for international crypto businesses, but these licenses do not regulate domestic retail crypto trading. There are no specific licensing or registration requirements for retail traders, although general financial laws related to AML/CFT may apply.

Landmark Laws

There are no specific Comorian laws or regulations directly governing cryptocurrency trading as of June 2025. The report references an IMF FinTech Note (2024-03-27) which provides a general overview of Sub-Saharan Africa, but this does not constitute Comorian legislation. Licenses are available through the Anjouan Offshore Finance Authority (AOFA), though these are for international businesses, not for domestic retail regulation.

Considerations

Cryptocurrencies are not recognized as legal tender in Comoros, nor is there a legal framework for their use by individuals, but no explicit prohibition exists. The lack of specific regulation means that cryptocurrency activities are conducted without investor protections or tailored KYC/AML obligations. An IMF report notes that in Sub-Saharan Africa, many countries do not allow crypto asset holding and transactions or exchange for legal tender, although this is not explicitly the case in Comoros, where individuals are not prohibited from holding or transacting, despite the absence of regulation.

Notes

The Anjouan offshore regime offers 'international brokerage licenses' or 'crypto licenses' to businesses, including international crypto exchanges and trading platforms. This allows operation under the AOFA framework, but doesn't regulate the domestic market. The direct applicability and enforcement of AML/CFT measures, including KYC, on retail users resident in Comoros trading outside of these Anjouan-licensed entities, or on peer-to-peer transactions, remains unclear. Bitget is reportedly legally accessible in Comoros for buying Bitcoin. The overall adoption and public engagement with cryptocurrency in Comoros appear to be low.

Detailed Explanation

As of June 2025, the status of retail cryptocurrency trading in Comoros is classified as "Allowed-Unregulated." This means that there are no specific laws or regulations issued by the Central Bank of Comoros or other Comorian government bodies that explicitly permit, prohibit, or regulate cryptocurrency buying, selling, and holding by individuals. While the government has not declared cryptocurrencies illegal, it also hasn't established a clear regulatory framework for their use. According to UEEx Technology on 2025-04-29, "As of 2024, Comoros does not have specific laws regulating cryptocurrency. The government hasn't declared it illegal, but no clear rules govern its use either." This creates a situation where individuals are not legally barred from cryptocurrency activities, but they do so without specific investor protections, licensing requirements for exchanges operating domestically, or tailored KYC/AML obligations beyond general financial laws. The Central Bank of Comoros oversees the banking system and financial crime regulations but does not have specific crypto regulations.

It is important to differentiate the situation for retail traders in Comoros from the licensing regime offered by the Anjouan Offshore Finance Authority (AOFA). Anjouan, a semi-autonomous island, offers "international brokerage licenses" or "crypto licenses" to businesses, including crypto exchanges and trading platforms. These licenses allow companies to legally run crypto exchanges and blockchain services under the AOFA framework. However, this offshore licensing primarily targets international businesses and does not translate into a regulated domestic market for retail crypto traders within Comoros. The Central Bank of Comoros does not appear to oversee or recognize these Anjouan-issued licenses for domestic regulatory purposes.

According to Q Wealth Report (2023-11-15), which references the Anjouan offshore regime, "Each business engaged in crypto-related activity must have a relevant license. This requirement guarantees that the crypto company protects its customers' crypto assets and complies with applicable laws." LegalBison (2025-04-21) states that "The Anjouan International Crypto License is an offshore crypto license that can be granted to a company formed in Anjouan or in another jurisdiction."

While some sources indicate that exchanges licensed in Anjouan are required to implement AML/CFT measures, including KYC, the direct applicability and enforcement of these measures on retail users resident in Comoros trading outside Anjouan-licensed entities, or on peer-to-peer transactions, remains unclear due to the absence of a national regulatory framework. A 2024 IMF FinTech Note on Sub-Saharan Africa noted that about 85% of surveyed countries have not established crypto asset regulation, and most responding central banks do not currently oversee, supervise, or regulate crypto assets. The same report notes that "Eighty percent of respondents report that people are not legally allowed to hold and transact in crypto assets, which also cannot be exchanged for legal tender." However, Comoros' specific stance for individuals appears to be one of non-prohibition rather than an explicit ban, despite the lack of regulation.

The overall adoption and public engagement with cryptocurrency in Comoros appear to be low, although the report notes that Bitget is legally accessible in Comoros for buying Bitcoin. In summary, individual Comorian citizens and residents can engage in retail cryptocurrency trading, but they do so in an environment that lacks specific regulations, dedicated consumer protections, or a clear official stance from the central financial authorities regarding domestic crypto activities, distinct from the Anjouan offshore licensing for international businesses.

Summary Points

Retail Cryptocurrency Trading Status in Comoros: Key Regulatory Points (June 2025)

I. Overall Regulatory Status:

  • Allowed-Unregulated: Retail cryptocurrency trading (buying, selling, and holding) is not explicitly prohibited for individual citizens and residents of Comoros.
  • Lack of Specific Regulations: There are no specific laws or comprehensive regulations issued by the Central Bank of Comoros or other government bodies directly governing cryptocurrency activities for retail traders.
  • No Explicit Ban: The government has not declared cryptocurrencies illegal.
  • Absence of Investor Protections: Retail traders operate in an environment without specific investor protections or tailored KYC/AML obligations beyond general financial laws.

II. Key Regulatory Bodies and Their Roles:

  • Central Bank of Comoros:
    • Responsible for ensuring the proper functioning of the banking system.
    • Oversees financial activities.
    • Applies regulations concerning financial crime, money laundering, and terrorism financing.
    • Does not currently oversee, supervise, or regulate crypto assets specifically.
  • Anjouan Offshore Finance Authority (AOFA):
    • Offers "international brokerage licenses" or "crypto licenses" to businesses, including international crypto exchanges and trading platforms.
    • This licensing regime primarily targets international businesses and does not translate into a regulated domestic market for retail crypto traders within Comoros itself.
    • The Central Bank of Comoros does not appear to directly oversee or recognize these Anjouan-issued licenses for domestic regulatory purposes.

III. Important Legislation and Regulations:

  • No Specific Crypto Legislation: There are no specific laws regulating cryptocurrency trading for individuals at the national level.
  • General Financial Laws Apply: General financial crime, money laundering, and terrorism financing regulations apply.
  • Anjouan Offshore Licensing Framework: The AOFA provides a licensing framework for crypto businesses, but this does not directly regulate retail trading within Comoros.

IV. Requirements for Compliance:

  • Limited Specific Requirements: Due to the lack of specific regulations, there are limited specific compliance requirements for retail traders beyond general financial laws.
  • AML/CFT Measures (Anjouan-Licensed Exchanges): Exchanges licensed in Anjouan are reportedly required to implement AML/CFT measures, including KYC.
    • The direct applicability and enforcement of these measures on retail users resident in Comoros trading outside of these specific Anjouan-licensed entities, or on peer-to-peer transactions, remains unclear.

V. Notable Restrictions or Limitations:

  • Lack of Investor Protection: The absence of specific regulations means retail traders lack dedicated consumer protections.
  • Regulatory Uncertainty: The lack of a clear official stance from central financial authorities creates regulatory uncertainty.
  • Limited Oversight: There is limited oversight of cryptocurrency activities by Comorian authorities.

VI. Recent Developments or Changes:

  • No Significant Changes: As of June 2025, the "Allowed-Unregulated" status remains unchanged.
  • IMF Report (2024): A 2024 IMF report on Sub-Saharan Africa noted that most surveyed countries have not established crypto asset regulation, and most responding central banks do not currently oversee, supervise, or regulate crypto assets. While not specific to Comoros, it provides regional context.
  • Bitget Accessibility: Some platforms, like Bitget, explicitly state that they are legally accessible in Comoros for buying Bitcoin.

Full Analysis Report

Report on the Current Status of Retail Cryptocurrency Trading in Comoros

Date: 2025-06-26

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Identified Current Status:
Allowed-Unregulated

2. Detailed Narrative Explanation:

As of June 2025, retail cryptocurrency trading in Comoros is best described as "Allowed-Unregulated." There are no specific laws or comprehensive regulations issued by the Central Bank of Comoros or other Comorian government bodies that explicitly permit, prohibit, or regulate the buying, selling, and holding of cryptocurrencies by individual citizens and residents. The government has not declared cryptocurrencies illegal, but neither has it established a clear framework to govern their use.

This lack of specific crypto-focused regulation means that while individuals are not legally barred from participating in cryptocurrency activities, they do so in an environment without specific investor protections, licensing requirements for exchanges operating domestically (unless through the Anjouan offshore regime), or tailored KYC/AML obligations for crypto transactions beyond general financial laws.

It's important to distinguish the situation for retail traders within Comoros from the licensing regime offered by the Anjouan Offshore Finance Authority (AOFA). Anjouan, one of the semi-autonomous islands of Comoros, has positioned itself as an offshore financial center and offers "international brokerage licenses" or "crypto licenses" to businesses, including international crypto exchanges and trading platforms. These licenses allow companies, whether local or international, to legally run crypto exchanges, trading platforms, and blockchain-related services under the AOFA framework. However, this offshore licensing primarily targets international businesses and does not translate into a regulated domestic market for retail crypto traders within Comoros itself. The Central Bank of Comoros does not appear to directly oversee or recognize these Anjouan-issued licenses for domestic regulatory purposes.

While some sources indicate that exchanges licensed in Anjouan are required to implement AML/CFT measures, including KYC, the direct applicability and enforcement of these specific measures on retail users resident in Comoros trading outside of these specific Anjouan-licensed entities, or on peer-to-peer transactions, remains unclear due to the absence of a national regulatory framework for cryptocurrencies.

The Central Bank of Comoros is responsible for ensuring the proper functioning of the banking system, overseeing financial activities, and applying regulations concerning financial crime, money laundering, and terrorism financing. A 2024 IMF report on Sub-Saharan Africa noted that about 85% of surveyed countries (which may or may not specifically detail Comoros' individual stance in this particular statistic) have not established crypto asset regulation, and most responding central banks do not currently oversee, supervise, or regulate crypto assets. It further states that in 80% of respondent countries, people are not legally allowed to hold and transact in crypto assets, which also cannot be exchanged for legal tender; however, this is a general regional observation and may not precisely reflect the nuanced situation in Comoros where no explicit ban for holding or transacting seems to exist for individuals, even if not formally regulated or recognized as legal tender.

The overall adoption and public engagement with cryptocurrency in Comoros appear to be low. International exchanges are accessible to Comorian residents, and some platforms explicitly state that Bitget is legally accessible in Comoros for buying Bitcoin.

In summary, individual Comorian citizens and residents can engage in retail cryptocurrency trading, but they do so in an environment that lacks specific regulations, dedicated consumer protections, or a clear official stance from the central financial authorities regarding domestic crypto activities, distinct from the Anjouan offshore licensing for international businesses.

3. Specific, Relevant Text Excerpts:

  • UEEx Technology (2025-04-29): "As of 2024, Comoros does not have specific laws regulating cryptocurrency. The government hasn't declared it illegal, but no clear rules govern its use either."
  • UEEx Technology (2025-04-29): "Despite this regulatory uncertainty, businesses looking to operate crypto exchanges, trading platforms, or blockchain projects can still obtain a cryptocurrency business license through the Anjouan Offshore Finance Authority (AOFA). With this license companies, whether local or international, can legally run crypto exchanges, trading platforms, and blockchain-related services. Additionally, you don't need to be based in Comoros to apply. Thus, while crypto itself isn't fully regulated in Comoros, exchanges can operate legally under the AOFA framework."
  • UEEx Technology (2025-04-29): "Cryptocurrency trading in Comoros is not explicitly regulated, meaning that exchanges can operate, but there are no clear government guidelines governing their use."
  • Q Wealth Report (2023-11-15), citing the Anjouan offshore regime: "Each business engaged in crypto-related activity must have a relevant license. This requirement guarantees that the crypto company protects its customers' crypto assets and complies with applicable laws. Obtaining a crypto license in the Comoros is a straightforward and reliable way to conduct legal activities related to cryptocurrencies." (Note: This refers to the Anjouan offshore license for businesses, not direct regulation of retail trading for individuals by national authorities).
  • LegalBison (2025-04-21), regarding Anjouan: "The Anjouan International Crypto License is an offshore crypto license that can be granted to a company formed in Anjouan or in another jurisdiction."
  • IMF FinTech Note (2024-03-27), on Sub-Saharan Africa generally: "Regulations. About 85 percent of surveyed countries have not established crypto assets regulation. Most responding central banks do not currently oversee, supervise, or regulate crypto assets, and frequently no other national institution is charged with regulating crypto assets."
  • IMF FinTech Note (2024-03-27), on Sub-Saharan Africa generally: "Eighty percent of respondents report that people are not legally allowed to hold and transact in crypto assets, which also cannot be exchanged for legal tender." (Note: This is a general regional finding; Comoros' specific stance for individuals appears to be one of non-prohibition rather than an explicit ban, despite the lack of regulation).

4. Direct, Accessible URL Links to Specific Sources:

  • UEEx Technology (2025-04-29): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFCFvRVX93T0YmDJiAIXFcL_SgWJxWF_Dbg2jHqcbWcwOnDed0GK8bsMW-kajFKURdE4vsEOk5DNdI7vmsg3hAtsVMrxJFuGTMMTjEGiGVrnub6bidv2yI9BiguuF57c-GgVtv4Qohxfg0ngfW0GoCyfNO_q71UjmY=
  • Comoros Crypto License: An Affordable and Profitable Solution for Your Business (2024-08-12) - Prifinance: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGQH3rTHipdbk9sCK9LBW8k5ZP0L4EZ4kyqOwwpzIt4QgLTCbaWQqnRhoThh_i0r4j0yDGhP38Eo5GWW4eST4Zt7kA-dnn91FyI0zGVffickEG-A-rQaVdXN7U2iTqhw3zTrJkXMKkM7MY8-R1JGnWM9Qtxmvdqbdg49yUNUthB8f14xpDwA0BW5gIYAmSMC3tMyDm9SRvxyeFXZVtJkCMgQg== (Note: This link is to a Prifinance article hosted on Google's grounding API; the original Prifinance URL may differ but the content is as cited).
  • A Crypto License in Comoros: A Universal and Reliable Solution - Q Wealth Report (2023-11-15): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHl28Z_vJ7Ffwx8aomLdMwBUmRJwI-PYo7ckxzgCTho2UJb8TEPlFIKaaiBQ5wkewM_T6nbtTkv-WF3JfkwthXG_Z3KwpvoqjW5woVy1Az_t7NOgWekl5XhmwFH82js7nfmMJR57Pa8i0JGnwT8H15elTeBCrBYMtnID2DY-D59Fy6sOPTgK9YddrMrocS2sIaH9HkTV_1kFa2EXakNF9ZBuwklOWo2neDr
  • Anjouan Crypto License - Costs and Process in 2025 - LegalBison (2025-04-21): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEIWzF6U3K6eb5i20VgSZeZ7-M_A9y8XxL9nNZYSR98plJZb1MkoCgOi0RPxtBnWnLTp8DMa1pMk1FIojMLIvodwl-WxHLaluxFk0TNE_gZ-cSvAqMDQ8vwKKU7F2GRmZnmmULOAj7MYig=
  • Crypto Licence in Comoros - Global Advisory Experts: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFEHHdfEFa7mZZkYJ_jjwQOuH57hLFnbFUOCvORFQsVJLJXztitC8zY4ALzlMYRQ9KOIFu9Fykyuzu6y6309W41Sp_07fd16cOJA895ONO8xL3my8m8WIP1IgiBqlha6O7JYlkRoFss99FuPrcGGYl7-dQP1-wWIkoF
  • Cryptocurrency Licensing: Thailand vs. Portugal and the Comoros - Q Wealth Report (2023-11-14): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEjqulVhlEuNTZgk85n9ORVV5BIXH0npVG5IcuGngQrOD2QFAMARZiq9e1ClC03tYjkUIW96eS-bD9QN61Aq8mz2qkpkWMwF-GcOSZfO0p5KQy2l5t_q8LS0p8pC9eHRi4CVKqS57MV5Sj3Rn3ew7PwlbFDtdA1AZ-R_mDmbR9oVNkhUcFeXqmbtqhdBGQvkkXyLnxqwfglmjJxJlJLxjRm9yolk6U=
  • Fast and affordable banking license from Comoros/Anjouan. No Miniumum capitalization. - Offshore Pro Group: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFtzoPTLYBVz17CUQ9UMoeBeWsCh_N-L7NjKgi8SaX43jh7-ikZ9hF8emH0WBghAlueehzwaKgpVMUUTcTegEkUB2RMp2cuSd9MU7mbyI-5KdgIIm7gUhKx5Zefvmn9MfxVRdf1pVPsVaRO_FjWiKMdg72SCrN5r4Ty8Xrep30=
  • Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey - IMF FinTech Note (2024-03-27): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFOKgTQFMEliJew1NXAq2nc8oq8OehiughfqroKfefVvZMOXpD4npY65KDrQQB7ttWfwqEY5ZDql6oULF3GKwonZXkdYtI8yXgSzQYkyW6VsXLugSYUKonYvEpnMTZ-iulAhtf847GXJGL51KAYcJt6-nfmVVBpthyp17IkrDgcMs9h7NO7ng==
  • How to buy Bitcoin(BTC) in Comoros | Bitget Guide: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQG00uNP35wUWNkCTr97BML7RrgS9HzdNp_0n3P9Eg7LcbMarsKfx9O6Yk8AoptFdARZ9M1lYEoL0rQU7GfsNozslnUnfTBN81MKOB55wIdPUhq8eVwzm7N9wtASNfAbN0sq3NRIpjV6B1_6L3U=
  • Statuts de la Banque centrale des Comores - Banque Centrale des Comores: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHTOhxhfG8EkFCuV4CVleybQhK5eizMlyBxZyiFOZrq_DvvULXnsaMcwImOyWht-L9sTrYZc2TFZ2PXuEN7RDcyem1gbzllGmWZdRM9nz0KGGoOysyA50xH1jxQ6g4n3jIHmoYwBY51y5iSEQwMphTMYXSL9je_JKo4-mes1WwujRdRAqxVswU99l7AStThlDeb_MTEHaFoyaVIHd_MHK0=

Web Sources (10)

Sources discovered via web search grounding

Search queries used (7)
  • current status of retail cryptocurrency trading in Comoros
  • Comoros cryptocurrency regulation 2024 2025
  • Central Bank of Comoros cryptocurrency policy
  • Comoros financial intelligence unit cryptocurrency
  • Are Comorian citizens allowed to trade cryptocurrency?
  • Lois sur les cryptomonnaies aux Comores
  • Réglementation des cryptomonnaies par la Banque Centrale des Comores
Source

Source

Source

Source

Source

Source

Source

Source

Source

Source

Reviews

No reviews yet

Submit Review

Challenge: Disagree with the analysis | Approval: Confirm it's correct | Refinement: Suggest improvements