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Comoros

Retail_Trading_Status

Allowed-Unregulated Unknown
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#396
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Created
2025-06-26 12:53
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Executive Summary

As of June 2025, the Union of the Comoros maintains an "Allowed-UnRegulated" stance on retail cryptocurrency trading. While the Central Bank of Comoros actively monitors global cryptocurrency trends and issues warnings regarding inherent risks such as price volatility, potential for fraud, and the absence of legal protections, it has not implemented any formal restrictions, prohibitions, or comprehensive legal frameworks specifically governing the use or trading of cryptocurrencies domestically. This means that while retail crypto trading is not banned, there is also no established consumer protection or specific legal recourse for users within the country [Reviewer_Comment].

Key Pillars

  • Observation and Warnings: The Central Bank of Comoros keeps an observation on global cryptocurrency trends and routinely issues public warnings concerning the risks associated with virtual currencies, including price volatility, the potential for fraud, and the lack of legal protections for users. These warnings emphasize that cryptocurrencies are not foreign currencies, are not issued or backed by a government or central bank, and that persons investing in them do so at their own risk [Reviewer_Comment, 13].

  • Absence of Formal Restrictions: There are no formal restrictions or outright bans on cryptocurrency use or trading for retail participants [Reviewer_Comment, 11].

  • Lack of Domestic Legal Framework: Crucially, there is no established consumer protection or specific legal framework domestically for cryptocurrencies, meaning users operate without explicit legal recourse or safeguards [Reviewer_Comment, 11]. This aligns with broader trends in Sub-Saharan Africa, where approximately 85% of surveyed countries had not established crypto asset regulation as of March 2024, and most central banks do not oversee or regulate crypto assets.

Landmark Laws

  • The Central Bank of Comoros actively monitors global cryptocurrency trends and issues warnings to the public about the risks involved, such as price volatility, fraud potential, and the lack of legal protections [Reviewer_Comment]. This proactive warning approach, rather than outright prohibition, signals an ongoing observation of the crypto landscape. There are indications that authorities have initiated discussions and studies with a view to regulating Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) in the future. This suggests a potential for future regulatory developments, although no concrete proposals or pilot programs for domestic retail trading were identified as of June 2025.

Considerations

  • Asset Classification: The legal definition of cryptocurrencies in Comoros is still evolving. However, for tax purposes, they are generally understood to be treated as intangible assets rather than legal tender or currency.

  • Taxation: Comoros has not established a comprehensive legal framework for the taxation of cryptocurrencies. While the tax treatment remains uncertain, it is likely that gains or profits from cryptocurrency transactions would be subject to general income tax rules applicable to the sale or exchange of assets. Income tax rates in Comoros range from 0% to 30%, depending on the individual taxpayer's income bracket. There are no specific exemptions or deductions for cryptocurrency transactions, though general income tax deductions may apply. Taxpayers are required to report all income, including that from cryptocurrency transactions, on their annual tax returns and maintain accurate records.

  • Consumer Protection: As explicitly stated by the reviewer, there is no consumer protection in place for retail crypto users [Reviewer_Comment].

  • Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT): While specific domestic AML/CFT regulations for retail users are not detailed, licensed cryptocurrency businesses operating from Comoros (especially offshore entities) are required to implement AML/CFT measures, including KYC. The Comorian administration aims to be compliant with international AML and CFT regulations.

Notes

Here's the detailed regulatory analysis report on Retail Crypto Trading in Comoros converted into a clear, well-structured bullet point format:

## Comoros: Retail Crypto Trading Regulations (As of June 2025)

### I. Regulatory Status

  • Allowed-UnRegulated: Retail cryptocurrency trading is permitted but not formally regulated.
  • No Formal Restrictions: There are no outright bans or specific prohibitions on individuals engaging in cryptocurrency transactions.
  • Regulatory Vacuum: A comprehensive legal framework specifically governing domestic retail crypto trading is absent.
  • No Consumer Protection: Users operate without established consumer protection or specific legal recourse for disputes or losses.

### II. Key Regulatory Bodies & Their Roles

  • Central Bank of Comoros (CBC):
  • Primary Role: Monitors global cryptocurrency trends and issues public warnings.
  • Warnings Issued: Highlights inherent risks such as:
  • Price volatility.
  • Potential for fraud.
  • Absence of legal protections.
  • Cryptocurrencies are not legal tender.
  • Cryptocurrencies are not issued or backed by a government or central bank.
  • Investments are undertaken at the individual's sole risk.
  • No Direct Oversight: Does not currently oversee or regulate domestic retail crypto assets or activities.
  • Offshore Regulatory Authorities (Distinct from Domestic):
  • Anjouan Offshore Finance Authority (AOFA): Regulates and licenses cryptocurrency businesses operating from Anjouan.
  • Mwali International Services Authority (MISA): Regulates and licenses cryptocurrency businesses operating from Moheli.
  • Scope: These authorities license offshore entities (e.g., exchanges, brokers) primarily catering to international clients, requiring AML/CFT and client fund safeguarding.
  • Crucial Distinction: Their licensing regimes do not constitute a domestic legal framework for retail trading by Comorian citizens.

### III. Legislation & Regulatory Framework

  • Absence of Specific Legislation:
  • As of June 2025, there are no specific landmark legislations in Comoros that formally regulate retail cryptocurrency trading or provide a comprehensive legal framework for digital assets for domestic users.
  • The existing legal environment is characterized by a regulatory vacuum for domestic retail crypto activities.
  • No Domestic Licensing Requirements: There are no licensing requirements for local service providers catering to domestic retail users.

### IV. Compliance Requirements (for Retail Users)

  • No Specific Regulatory Compliance: Due to the "unregulated" status, there are no explicit regulatory compliance requirements for retail users engaging in crypto trading.
  • Tax Reporting (Implied):
  • While no comprehensive framework exists, gains or profits from cryptocurrency transactions are likely subject to general income tax rules applicable to the sale or exchange of assets.
  • Taxpayers are generally required to report all income on annual tax returns and maintain accurate records.

### V. Notable Restrictions or Limitations

  • No Formal Restrictions on Trading: Retail trading is not banned.
  • Lack of Consumer Protection: This is the most significant limitation; users have no explicit legal safeguards or recourse.
  • No Legal Tender Status: Cryptocurrencies are not recognized as legal tender.
  • Self-Responsibility: Individuals engage in crypto activities at their own risk, as emphasized by the Central Bank.

### VI. Other Important Considerations

  • Asset Classification:
  • Generally understood to be treated as intangible assets for tax purposes.
  • Not considered legal tender or currency.
  • Taxation:
  • Framework: No comprehensive legal framework for cryptocurrency taxation.
  • Income Tax: Gains/profits likely subject to general income tax rules (rates 0% to 30% depending on income bracket).
  • Exemptions/Deductions: No specific exemptions or deductions for crypto transactions, though general income tax deductions may apply.
  • Consumer Protection: Explicitly none in place for retail crypto users.
  • Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT):
  • Domestic Retail: Specific domestic AML/CFT regulations for retail users are not detailed.
  • Offshore Businesses: Licensed cryptocurrency businesses operating from Comoros (offshore entities) are required to implement AML/CFT measures, including Know Your Customer (KYC) procedures.
  • National Aim: The Comorian administration aims to be compliant with international AML and CFT regulations generally.

### VII. Recent Developments & Outlook

  • Ongoing Observation: The Central Bank of Comoros continues to actively monitor global cryptocurrency trends and issue public warnings.
  • Future Regulation Discussions: There are indications that authorities have initiated discussions and studies with a view to regulating Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs) in the future.
  • No Concrete Proposals (as of June 2025): No concrete proposals or pilot programs for domestic retail trading regulation were identified as of June 2025.
  • Consistent with Regional Trends: The "Allowed-UnRegulated" status aligns with broader trends in many Sub-Saharan African nations where crypto regulation remains largely underdeveloped.

Detailed Explanation

The retail cryptocurrency trading landscape in the Comoros, as of June 2025, is best characterized by a state of "Allowed-UnRegulated." This designation reflects a nuanced position where, on one hand, there are no formal bans or restrictions explicitly prohibiting individuals from engaging in cryptocurrency transactions. On the other hand, the absence of a dedicated legal and regulatory framework means that domestic retail users operate in an environment devoid of specific consumer protections, licensing requirements for local service providers, or clear legal recourse in case of disputes or losses [Reviewer_Comment].The Central Bank of Comoros plays a key role in this environment, primarily through its ongoing observation of global cryptocurrency trends and its issuance of cautionary warnings to the public. These warnings are consistent, highlighting inherent risks such as the extreme price volatility of cryptocurrencies, the significant potential for fraud, and the critical lack of legal safeguards typically afforded to participants in regulated financial markets [Reviewer_Comment]. The Central Bank explicitly states that cryptocurrencies are not considered legal tender and are not backed or issued by any government or central bank, underscoring that any investment or engagement is undertaken at the individual's sole risk.Despite these warnings, the government has refrained from implementing formal prohibitions or a comprehensive domestic regulatory structure for retail crypto trading. This distinguishes Comoros from some other jurisdictions that have either adopted stringent regulations or outright bans. The lack of specific legislation extends to key areas such as asset classification and taxation for domestic retail users. While cryptocurrencies are generally viewed as intangible assets for tax purposes, there is no dedicated tax framework, implying that general income tax rules for asset sales might apply to crypto gains. This creates a degree of uncertainty regarding tax obligations for individual traders.It is crucial to differentiate the domestic retail trading environment from the more established, albeit distinct, regulatory frameworks for offshore cryptocurrency businesses within certain islands of the Comoros, particularly Anjouan and Moheli. Authorities like the Anjouan Offshore Finance Authority (AOFA) and the Mwali International Services Authority (MISA) actively license crypto exchanges and other related businesses that often cater to international clients. These offshore licenses typically mandate compliance with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) standards, including Know Your Customer (KYC) protocols, and require measures to protect client funds. However, these are licensing regimes for businesses operating in an offshore capacity, and their existence does not translate into consumer protection or a clear regulatory framework for the average Comorian citizen engaging in crypto trading within the domestic economy.In essence, Comoros maintains a watchful but non-interventionist stance on retail crypto trading. The Central Bank's continuous warnings serve as a primary mechanism to inform the public about the risks, emphasizing self-responsibility for those who choose to participate. The current state suggests that while the authorities are aware of and observing the digital asset space, they have yet to formalize a comprehensive domestic regulatory approach that would provide legal clarity, consumer protection, or specific taxation guidelines for individual crypto users as of June 2025. This "Allowed-UnRegulated" status is consistent with a broader trend in many Sub-Saharan African nations where crypto regulation remains largely underdeveloped. The ongoing discussions and studies by the Central Bank regarding the regulation of virtual assets hint at potential future developments, but for now, the market remains largely open but unsupported by a dedicated legal safety net.

Full Analysis Report

Report on the Current Status of Retail Trading of Cryptocurrencies 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).

Retail_Trading_Status in Comoros

Identified Status: Allowed-UnRegulated

Detailed Narrative Explanation:

The legal status of retail cryptocurrency trading in Comoros for its individual citizens and residents is best described as "Allowed-UnRegulated". While there are no specific laws explicitly prohibiting or comprehensively regulating the direct buying, selling, or holding of cryptocurrencies by individuals for personal use, the broader regulatory landscape, particularly concerning businesses offering cryptocurrency-related services, operates within an offshore financial framework that is distinct from domestic retail activity.

Several sources indicate that Comoros, particularly the autonomous islands of Anjouan and Mohéli, has positioned itself as a jurisdiction for international companies to obtain licenses for various financial activities, including those related to cryptocurrencies. These licenses are issued by authorities like the Anjouan Offshore Finance Authority (AOFA) and the Mwali International Services Authority (MISA). These frameworks are primarily aimed at international businesses seeking an offshore operational base and are not directly focused on regulating domestic retail trading by Comorian citizens.

For individual Comorian residents, there appears to be no specific legislation that explicitly outlaws the ownership or trading of cryptocurrencies. One source explicitly states, "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." Another source notes, "There is no cryptocurrency regulation" and "No legal status for cryptocurrencies" in Comoros, classifying its stance as "Undecided". This lack of specific prohibition or dedicated regulatory oversight for individual retail activity points towards an "Allowed-UnRegulated" environment.

While companies, particularly those licensed in the offshore sector, are expected to adhere to Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) requirements, it's not clear how these directly translate to individual, domestic retail traders outside of their interactions with any licensed Virtual Asset Service Providers (VASPs). The Central Bank of Comoros has not issued explicit, comprehensive regulations governing retail cryptocurrency trading by individuals within the country. Although Comoros is part of the Economic and Monetary Community of Central Africa (CEMAC), whose regional central bank (BEAC) has expressed opposition to regulating cryptocurrencies due to concerns about foreign exchange reserves, this stance doesn't necessarily equate to an outright ban on individual holding or trading within Comoros itself, especially given the autonomous islands' licensing regimes for crypto businesses.

The focus of Comorian authorities, particularly on Anjouan and Mohéli, seems to be on attracting international financial service providers, including crypto businesses, through a lenient and quick licensing process. This offshore framework exists somewhat separately from the day-to-day financial regulation of Comorian citizens.

Therefore, while businesses operating from Comoros in the crypto space are subject to the licensing requirements of the specific island authority (e.g., AOFA, MISA) and associated AML/CFT rules, individual Comorians engaging in retail cryptocurrency trading appear to do so in an environment that lacks specific, direct regulation or prohibition. General financial laws may apply, but there are no crypto-specific rules governing their personal trading activities. Some platforms, like Binance, are noted as accessible to Comorian traders.

Specific, Relevant Text Excerpts:

  • Proelium Law LLP (referring to Comoros): "Undecided. No legal status for cryptocurrencies. There is no cryptocurrency regulation."
  • UEEx Technology (2025): "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): "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 (2023-11-14): "With no currency controls in the Comoros, brokers can easily transfer funds in and out of the country without facing any regulatory obstacles, currency conversion costs, or compliance requirements." (This refers more to licensed brokers than individual retail traders directly, but indicates a generally permissive financial environment).
  • Heavnn University (2024-03-29): "Comoros, an archipelago nation in the Indian Ocean, has yet to establish a comprehensive legal framework for the taxation of cryptocurrencies. As a result, the tax treatment of cryptocurrencies in Comoros remains uncertain and subject to interpretation." And, "The taxation of cryptocurrency transactions in Comoros is not explicitly addressed in any specific laws or regulations." This further implies a lack of specific crypto-focused regulation for individuals.

Direct, Accessible URL Links to Sources:

  • Proelium Law LLP - Cryptocurrency Regulation Tracker: https://www.proeliumlaw.com/crypto-regulation-tracker/ (Note: While this link is general, the specific information for Comoros was visible in the search snippet.)
  • Q Wealth Report - Cryptocurrency Licensing: Thailand vs. Portugal and the Comoros (2023-11-14): https://qwealthreport.com/cryptocurrency-licensing-thailand-vs-portugal-and-the-comoros/
  • Q Wealth Report - A Crypto License in the Comoros Islands (2024-08-26): https://qwealthreport.com/a-crypto-license-in-the-comoros-islands/
  • Heavnn University - Cryptocurrency Taxes in Comoros (2024-03-29): https://www.heavnn.university/cryptocurrency-taxes-in-comoros/
  • Comoros Crypto License: An Affordable and Profitable Solution for Your Business (2024-08-12): https://eternitylaw.com/crypto-license-in-comoros/
  • UEEx Technology - Best Crypto Exchanges in Comoros 2025 (2025-04-29): https://ueex.com/en/blog/best-crypto-exchanges-in-comoros/
  • Gofaizen & Sherle - Forex license in the Comoros Islands: https://gofaizen-sherle.com/forex-license/comoros
  • Global Law Experts - Crypto License In Comoros: https://www.globallawexperts.com/crypto-license-in-comoros/
  • Comoros Services - Banking with Crypto: https://comorosservices.com/banking-with-crypto/
  • Q Wealth Report - A Crypto License in Comoros: A Universal and Reliable Solution (2023-11-15): https://qwealthreport.com/a-crypto-license-in-comoros-a-universal-and-reliable-solution/
  • Business in Cameroon - Cemac: Beac rejects cryptocurrency regulation amid fintech demands (2024-02-05): https://www.businessincameroon.com/public-management/0502-14080-cemac-beac-rejects-cryptocurrency-regulation-amid-fintech-demands

Web Sources (11)

Sources discovered via web search grounding

Search queries used (6)
  • current status of retail cryptocurrency trading in Comoros
  • Comoros cryptocurrency laws and regulations
  • Central Bank of Comoros stance on cryptocurrency
  • Comoros financial intelligence unit (FIU) cryptocurrency guidelines
  • AML/CFT regulations for cryptocurrency in Comoros
  • Is cryptocurrency legal in Comoros for individuals?
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