Comoros
Retail_Trading_Status
- Analysis ID
- #40
- Version
- Archived
- Created
- 2025-04-12 06:40
- Run
- 2250d30b...
- History
- View all versions
- Workflow Stage
- Live
Executive Summary
The legal status of retail cryptocurrency trading in Comoros is unclear, with no specific regulations from the Central Bank of Comoros (BCC) explicitly permitting or prohibiting it. The financial sector is regulated by the BCC, but current regulations on electronic money issuers do not extend to cryptocurrencies. Anjouan Offshore Finance Authority (AOFA) issues licenses for cryptocurrency businesses targeting international markets, operating independently from the BCC. Cryptocurrency activity exists in a legal gray area without specific protections or prohibitions, and adoption rates among Comorian citizens are very low.
Key Pillars
- Primary regulator: The Central Bank of Comoros (Banque Centrale des Comores - BCC) is responsible for monetary policy and financial system stability, but does not explicitly regulate cryptocurrencies.
- Core Compliance: No specific KYC/AML requirements are mentioned regarding crypto assets.
- Licensing: The Anjouan Offshore Finance Authority (AOFA) issues licenses for cryptocurrency businesses, but these are focused on international markets and operate independently from the BCC. No licensing requirements for domestic retail crypto trading.
Landmark Laws
There is no specific legislation or official regulation issued by the central government or the Central Bank of Comoros (Banque Centrale des Comores - BCC) that explicitly permits, prohibits, or regulates cryptocurrency activities for individual citizens.
Considerations
- Cryptocurrencies exist in a "legal gray area" - neither explicitly legal nor illegal.
- Tax treatment is uncertain; cryptocurrencies are likely treated as intangible assets subject to general income tax rules on gains, though no specific crypto tax laws exist.
- Very low crypto adoption rates among the Comorian population.
- Cryptocurrency-related business licensing activities occur within the jurisdiction of Anjouan.
Notes
- A March 2024 IMF survey noted that about 85% of surveyed Sub-Saharan African countries (including Comoros) had not established crypto-asset regulation.
- The Anjouan Offshore Finance Authority (AOFA) issues licenses for offshore financial activities, including cryptocurrency businesses targeting international markets.
- The UPay Blog noted in December 2024 that cryptocurrencies are neither explicitly legal nor illegal in Comoros, existing in a legal gray area with no specific regulatory framework.
- Tax treatment of cryptocurrencies in Comoros remains uncertain and subject to interpretation, according to Heavnn University in March 2024.
Detailed Explanation
Detailed Explanation
The retail cryptocurrency trading status in the Union of the Comoros is 'Unclear.' There is no specific legislation or official regulation from the central government or the Central Bank of Comoros (Banque Centrale des Comores - BCC) explicitly permitting, prohibiting, or regulating cryptocurrency activities for individuals. The BCC regulates the financial sector, focusing on monetary policy, banking system stability, financial institution supervision, and payment systems oversight. While the BCC has regulations for electronic money issuers, these do not specifically address cryptocurrencies as distinct assets.
Recent reports, including an IMF survey from March 2024 covering Sub-Saharan Africa (including Comoros), indicate that about 85% of surveyed countries had not established crypto-asset regulation, with most central banks not overseeing them. Another source from late 2024 describes cryptocurrencies as existing in a "legal gray area" in Comoros, lacking a specific regulatory framework. This absence of clarity implies that individual trading occurs without specific legal protections or prohibitions under Comorian law.
However, there is evidence of cryptocurrency-related business licensing within the jurisdiction of Anjouan, an autonomous island of the Union of Comoros. The Anjouan Offshore Finance Authority (AOFA) issues licenses for offshore financial activities, including banking, forex, and cryptocurrency businesses. These licenses allow companies (often International Business Companies - IBCs) to engage in cryptocurrency trading, exchange operations, and crypto storage, primarily targeting international markets ("outside of the Union of Comoros"). These Anjouan licenses operate independently from the Central Bank of Comoros (BCC) and are sometimes described as being in a "regulatory gray area." These licenses do not clarify the legal status or regulatory environment for domestic retail cryptocurrency trading by Comorian citizens within the country itself; they focus on attracting international business rather than regulating domestic individual activity.
General information suggests very low crypto adoption rates among the Comorian population. Tax treatment is uncertain, with cryptocurrencies likely treated as intangible assets subject to general income tax rules on gains, although no specific crypto tax laws exist. The UPay Blog noted in December 2024 that cryptocurrencies are neither explicitly legal nor illegal in Comoros, existing in a legal gray area with no specific regulatory framework. Given the absence of specific laws or statements from the BCC regarding domestic retail crypto trading, combined with the existence of an offshore licensing regime in Anjouan that operates separately from the central bank, the overall status for individuals within Comoros remains ambiguous.
Summary Points
Here's a breakdown of the regulatory status of retail cryptocurrency trading in Comoros, presented in a clear, bullet-point format:
I. Overall Regulatory Status: Unclear
- The legal status of retail cryptocurrency trading (buying, selling, holding) by individuals in Comoros is unclear.
- Cryptocurrencies exist in a "legal gray area" – neither explicitly legal nor illegal.
- There is no specific legislation or official regulation from the central government or the Central Bank of Comoros (BCC) that explicitly permits, prohibits, or regulates cryptocurrency activities for individuals.
II. Key Regulatory Bodies and Their Roles
- Central Bank of Comoros (Banque Centrale des Comores - BCC):
- Regulates the financial sector in Comoros.
- Responsible for monetary policy, banking system stability, financial institution supervision, and payment systems oversight.
- Has regulations for electronic money issuers, but these do not explicitly extend to cryptocurrencies.
- Most central banks in Sub-Saharan Africa, including implicitly Comoros, are not overseeing, supervising, or regulating crypto assets.
- Anjouan Offshore Finance Authority (AOFA):
- Located on the autonomous island of Anjouan.
- Issues licenses for offshore financial activities, including banking, forex, and cryptocurrency businesses.
- Licenses allow companies to engage in cryptocurrency trading, exchange operations, and crypto storage, primarily targeting international markets ("outside of the Union of Comoros").
- Operates independently from the BCC.
III. Important Legislation and Regulations
- No specific legislation or regulations exist that directly address retail cryptocurrency trading within Comoros.
- Regulations for electronic money issuers exist but do not explicitly cover cryptocurrencies.
IV. Requirements for Compliance
- Due to the lack of specific regulations, there are no clearly defined compliance requirements for retail cryptocurrency trading.
- KYC/AML requirements are not explicitly imposed on platforms operating within Comoros for crypto trading.
V. Notable Restrictions or Limitations
- Lack of legal protections or prohibitions for individual cryptocurrency trading under Comorian law.
- Uncertain tax treatment: Cryptocurrencies are likely treated as intangible assets subject to general income tax rules on gains, but no specific crypto tax laws exist.
VI. Recent Developments or Changes
- March 2024 IMF Survey: Indicated that approximately 85% of surveyed Sub-Saharan African countries (including Comoros) had not established crypto-asset regulation.
- Late 2024 Reports: Highlighted that cryptocurrencies exist in a "legal gray area" in Comoros.
- Ongoing Offshore Licensing: The Anjouan Offshore Finance Authority (AOFA) continues to issue licenses for cryptocurrency businesses targeting international markets.
VII. Key Considerations
- Offshore vs. Domestic: The existence of offshore licensing in Anjouan does not clarify the legal status or regulatory environment for domestic retail cryptocurrency trading by Comorian citizens within the country itself.
- Low Adoption: General information suggests very low cryptocurrency adoption rates among the Comorian population.
- Speculation and Value Storage: Crypto usage is reportedly centered around speculation and value storage.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Comoros
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. Current Status: Unclear
2. Detailed Narrative Explanation:
The legal and regulatory status of retail cryptocurrency trading (buying, selling, holding by individuals) in the Union of the Comoros is currently unclear. There appears to be no specific legislation or official regulation issued by the central government or the Central Bank of Comoros (Banque Centrale des Comores - BCC) that explicitly permits, prohibits, or regulates cryptocurrency activities for individual citizens within the national territory.
The financial sector in Comoros is regulated primarily by the BCC, which is responsible for monetary policy, ensuring the stability and proper functioning of the banking system, supervising financial institutions, and overseeing payment systems [9, 11, 20]. While the BCC has regulations for electronic money issuers [9], these do not appear to extend specifically to cryptocurrencies as distinct assets.
Recent reports and surveys indicate a lack of a defined regulatory framework for crypto-assets in Comoros [5, 10]. A March 2024 IMF survey covering Sub-Saharan Africa, which included Comoros, noted that about 85% of surveyed countries (including implicitly Comoros, though not singled out in this specific finding) had not established crypto-asset regulation, and most central banks were not overseeing them [10]. Another source from late 2024 explicitly states that cryptocurrencies exist in a "legal gray area" in Comoros – neither explicitly legal nor illegal – with no specific regulatory framework [5]. This lack of clarity means that individual trading likely occurs without specific legal protections or prohibitions under Comorian law.
Interestingly, there is evidence of cryptocurrency-related business licensing activities occurring within the jurisdiction of Anjouan, one of the autonomous islands of the Union of Comoros [3, 4, 6, 8, 13, 18]. The Anjouan Offshore Finance Authority (AOFA) issues licenses for various offshore financial activities, including banking, forex, and cryptocurrency businesses [3, 8]. These licenses reportedly allow companies (often International Business Companies - IBCs) to engage in activities like cryptocurrency trading, exchange operations, and crypto storage, primarily targeting international markets ("outside of the Union of Comoros") [2, 3, 4, 8]. These licenses are explicitly noted as operating independently from the Central Bank of Comoros (BCC) and are sometimes described as being in a "regulatory gray area" [6]. While these offshore licenses exist, they do not clarify the legal status or regulatory environment for domestic retail cryptocurrency trading by Comorian citizens within the country itself. The focus of these Anjouan licenses appears to be on attracting international business rather than regulating domestic individual activity.
Furthermore, general information suggests very low crypto adoption rates among the Comorian population [5]. Tax treatment is also uncertain, with cryptocurrencies likely treated as intangible assets subject to general income tax rules on gains, though no specific crypto tax laws exist [12].
Given the absence of specific laws or statements from the BCC regarding domestic retail crypto trading, combined with the existence of an offshore licensing regime in Anjouan that operates separately from the central bank, the overall status for individuals within Comoros remains ambiguous.
3. Specific Relevant Text Excerpts/Summaries:
- UPay Blog (Dec 2024): "Adoption Status: Cryptocurrencies are not explicitly legal or illegal in Comoros. There is no specific legal framework regulating them. This means that their use and trade exist in a legal gray area." [5]
- UPay Blog (Dec 2024): "Key Takeaways: Cryptocurrencies exist in a legal gray area - neither explicitly legal nor illegal, with no specific regulatory framework in place." [5]
- IMF FinTech Notes (Mar 2024): Reporting on a survey including 30 Sub-Saharan African central banks (including Comoros): "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..." [10]
- IMF FinTech Notes (Mar 2024): "The adoption of crypto assets for payment purposes remains limited in the region, with most usage reportedly centered around speculation and value storage. Regulatory frameworks for crypto assets are underdeveloped in most countries." [10]
- sb-sb.com: "In Anjouan, the Anjouan Offshore Finance Authority (AOFA) is the only body that regulates the local financial sector, including cryptocurrency businesses... Offshore licensing solutions in Anjouan Comoros are available for various industries, including banking, forex, crypto, and insurance." [3]
- Gofaizen & Sherle: "On the island of Anjouan, offshore finance is administered by the AOFA. This authority regulates financial companies... Anjouan has already established itself as an offshore financial center..." [8]
- comoros-services.com: "The Comoros International Banking Authority has also introduced a Banking License including trading in Digital Crypto currency... This is a full-unrestricted Banking license, for all Banking services outside of the Union of Comoros." [2]
- LegalAdvice.com: Lists Comoros under "No legal status for cryptocurrencies. There is no cryptocurrency regulation." [7]
- Heavnn University (Mar 2024): "Comoros... 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." [12]
4. Source URLs:
- Central Bank of Comoros (BCC) - Main Site: http://www.banque-comores.km/ [20, 21]
- Central Bank of Comoros (BCC) - Annual Reports (for general economic/financial context): https://www.banque-comores.km/Publications/le-rapport-annuel [22]
- UPay Blog - Crypto Adoption in Comoros: https://upay.co.uk/blog/crypto-adoption-around-the-world-comoros/ [5]
- IMF FinTech Notes (Mar 2024) - SSA CBDC and Digital Payments Survey: https://www.elibrary.imf.org/view/journals/069/2024/001/article-A001-en.xml [10]
- sb-sb.com - Anjouan Crypto License: https://sb-sb.com/comoros-crypto-license-comoros-licensed-crypto-exchange/ [3]
- Offshore Pro Group - Comoros Crypto License: https://offshorecorpserv.com/crypto-license-in-comoros/ [4]
- Gofaizen & Sherle - Comoros Forex License (mentions crypto & Anjouan AOFA): https://gofaizen-sherle.com/en/blog/forex-license-in-the-comoros-islands [8]
- LegalAdvice.com - Cryptocurrency Regulation Tracker: https://legaladvice.com/crypto/regulation-tracker [7]
- Heavnn University - Crypto Taxes in Comoros: https://heavnn.university/blog/cryptocurrency-taxes-in-comoros [12]
- World Bank - Comoros Payment Systems (context on BCC role): https://documents.worldbank.org/en/publication/documents-reports/documentdetail/942241590747472538/comoros-payment-systems-regulatory-framework-p170411 [9]
**Report on the Current Status of Retail Cryptocurrency Trading in Comoros**
**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. Current Status:** `Unclear`
**2. Detailed Narrative Explanation:**
The legal and regulatory status of retail cryptocurrency trading (buying, selling, holding by individuals) in the Union of the Comoros is currently unclear. There appears to be no specific legislation or official regulation issued by the central government or the Central Bank of Comoros (Banque Centrale des Comores - BCC) that explicitly permits, prohibits, or regulates cryptocurrency activities for individual citizens within the national territory.
The financial sector in Comoros is regulated primarily by the BCC, which is responsible for monetary policy, ensuring the stability and proper functioning of the banking system, supervising financial institutions, and overseeing payment systems [9, 11, 20]. While the BCC has regulations for electronic money issuers [9], these do not appear to extend specifically to cryptocurrencies as distinct assets.
Recent reports and surveys indicate a lack of a defined regulatory framework for crypto-assets in Comoros [5, 10]. A March 2024 IMF survey covering Sub-Saharan Africa, which included Comoros, noted that about 85% of surveyed countries (including implicitly Comoros, though not singled out in this specific finding) had not established crypto-asset regulation, and most central banks were not overseeing them [10]. Another source from late 2024 explicitly states that cryptocurrencies exist in a "legal gray area" in Comoros – neither explicitly legal nor illegal – with no specific regulatory framework [5]. This lack of clarity means that individual trading likely occurs without specific legal protections or prohibitions under Comorian law.
Interestingly, there is evidence of cryptocurrency-related *business licensing* activities occurring within the jurisdiction of Anjouan, one of the autonomous islands of the Union of Comoros [3, 4, 6, 8, 13, 18]. The Anjouan Offshore Finance Authority (AOFA) issues licenses for various offshore financial activities, including banking, forex, and cryptocurrency businesses [3, 8]. These licenses reportedly allow companies (often International Business Companies - IBCs) to engage in activities like cryptocurrency trading, exchange operations, and crypto storage, primarily targeting international markets ("outside of the Union of Comoros") [2, 3, 4, 8]. These licenses are explicitly noted as operating independently from the Central Bank of Comoros (BCC) and are sometimes described as being in a "regulatory gray area" [6]. While these offshore licenses exist, they do not clarify the legal status or regulatory environment for *domestic retail* cryptocurrency trading by Comorian citizens within the country itself. The focus of these Anjouan licenses appears to be on attracting international business rather than regulating domestic individual activity.
Furthermore, general information suggests very low crypto adoption rates among the Comorian population [5]. Tax treatment is also uncertain, with cryptocurrencies likely treated as intangible assets subject to general income tax rules on gains, though no specific crypto tax laws exist [12].
Given the absence of specific laws or statements from the BCC regarding domestic retail crypto trading, combined with the existence of an offshore licensing regime in Anjouan that operates separately from the central bank, the overall status for individuals within Comoros remains ambiguous.
**3. Specific Relevant Text Excerpts/Summaries:**
* **UPay Blog (Dec 2024):** "Adoption Status: Cryptocurrencies are not explicitly legal or illegal in Comoros. There is no specific legal framework regulating them. This means that their use and trade exist in a legal gray area." [5]
* **UPay Blog (Dec 2024):** "Key Takeaways: Cryptocurrencies exist in a legal gray area - neither explicitly legal nor illegal, with no specific regulatory framework in place." [5]
* **IMF FinTech Notes (Mar 2024):** Reporting on a survey including 30 Sub-Saharan African central banks (including Comoros): "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..." [10]
* **IMF FinTech Notes (Mar 2024):** "The adoption of crypto assets for payment purposes remains limited in the region, with most usage reportedly centered around speculation and value storage. Regulatory frameworks for crypto assets are underdeveloped in most countries." [10]
* **sb-sb.com:** "In Anjouan, the Anjouan Offshore Finance Authority (AOFA) is the only body that regulates the local financial sector, including cryptocurrency businesses... Offshore licensing solutions in Anjouan Comoros are available for various industries, including banking, forex, crypto, and insurance." [3]
* **Gofaizen & Sherle:** "On the island of Anjouan, offshore finance is administered by the AOFA. This authority regulates financial companies... Anjouan has already established itself as an offshore financial center..." [8]
* **comoros-services.com:** "The Comoros International Banking Authority has also introduced a Banking License including trading in Digital Crypto currency... This is a full-unrestricted Banking license, for all Banking services outside of the Union of Comoros." [2]
* **LegalAdvice.com:** Lists Comoros under "No legal status for cryptocurrencies. There is no cryptocurrency regulation." [7]
* **Heavnn University (Mar 2024):** "Comoros... 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." [12]
**4. Source URLs:**
* **Central Bank of Comoros (BCC) - Main Site:** [http://www.banque-comores.km/](http://www.banque-comores.km/) [20, 21]
* **Central Bank of Comoros (BCC) - Annual Reports (for general economic/financial context):** [https://www.banque-comores.km/Publications/le-rapport-annuel](https://www.banque-comores.km/Publications/le-rapport-annuel) [22]
* **UPay Blog - Crypto Adoption in Comoros:** [https://upay.co.uk/blog/crypto-adoption-around-the-world-comoros/](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAL0E0kKXj0FtcPldSR8oHD2_qoB8VcYH5SRSgynhiabprPs7GPS5EtoBpsyTQt8kBnpBrTYin523v11n-TqGh3RtaJPctyjE3dTaFJr9GvruQEWI9IVw-LJ4HdAfPUdWf9fiUsc) [5]
* **IMF FinTech Notes (Mar 2024) - SSA CBDC and Digital Payments Survey:** [https://www.elibrary.imf.org/view/journals/069/2024/001/article-A001-en.xml](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJhfXyoCUE8eTvew0GPiP_T1rdAA-bfOixlirEtWeA_PL7l2kli3-ZcxRZH3Cuw45CzIoQaseYjZ6lQRvPXfLfwBj9LMBWGUBLnWHHcHYa-04FIE2flLag4qpIg_gszejTuIpL3Bc-xDxWqNqntHhzvolvlwNcS7TaLl_TooSvM0w==) [10]
* **sb-sb.com - Anjouan Crypto License:** [https://sb-sb.com/comoros-crypto-license-comoros-licensed-crypto-exchange/](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALbbyuX8ytwgs82A3OmCteSoK6gTYEcTisYWd6sCJBW7Q0nDj3qnw4T-cxCqeyNM7kltSAf0NWU1pY2UoYhTYaJJghn-IUKQHRBeg000RYSNgn69vvv0hDjPoswLIcdkjZGv_T2vdqZ7JSBj1Z0c2fX_OwwaVkevg==) [3]
* **Offshore Pro Group - Comoros Crypto License:** [https://offshorecorpserv.com/crypto-license-in-comoros/](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIQTKL0H4NzwNhRp4Ikq-XubabH8vPQBUlJ8zEcTqRGPbmQ_Zti5LEuj7xHuN8kGnQeUV_Y6XmGzfBDzoGIWHdZ6sB7jfC89ZB1DXKoMAU2jY55rm8l8a8NzCq8KunSELR6GL_ZChl07xArDaIL4_-4HorWR5tFMC_cKbw=) [4]
* **Gofaizen & Sherle - Comoros Forex License (mentions crypto & Anjouan AOFA):** [https://gofaizen-sherle.com/en/blog/forex-license-in-the-comoros-islands](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAI0-r3wFsDmSKy64IllGyR4YgDqqXsYlmaPCPeaFklCMrTf4Q-EfB0x_fZoDVMgs10Be7sMLf8WTT3nRyr6Umblrh6YkIr8Wk5i7CXOTZEFRYCBDqHTMVOh57U9gzJP6n6G4oLWjA4YOcBIs_KcTQ==) [8]
* **LegalAdvice.com - Cryptocurrency Regulation Tracker:** [https://legaladvice.com/crypto/regulation-tracker](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKr0R3SJX8gS-EFgXSNu5oHBSDQi2VyQXUk08zASldDIBo08cGjPJHbkbm0leUuc24L_0CqFKJ_U1oSpHnajBlzdTqvC27uVE-_mrNDV5bhzXX_Hb0a1Q8oNZGFleOtS3FSAFD4h0JiffJdzizS7O8=) [7]
* **Heavnn University - Crypto Taxes in Comoros:** [https://heavnn.university/blog/cryptocurrency-taxes-in-comoros](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIBvDPldIjIk4ioMrbCrGRKJ_UPRtzTOvjhOMlMibzvRFAQazgFVCdjWT6XRc5dnTeUAtjOYYLJkeopX7mXm0Oon15_SMN1ex5qXJ8Wt3Q5A0bdmGR_W8UrDM0cZ4hKpH9gtSNPUsakPf6xbC17UXpGFxs=) [12]
* **World Bank - Comoros Payment Systems (context on BCC role):** [https://documents.worldbank.org/en/publication/documents-reports/documentdetail/942241590747472538/comoros-payment-systems-regulatory-framework-p170411](https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJBPMGK2OFihuPB2AGPqG2cr38syIkTThafG-UMagS0S9s075sAnw6f9AiypbfPeCIFjJNXl8arXAOM5nod_Ba7K8f8zIneuOBKt5ljlMZS0EZsc5_c3z3QdofBjgz8sNGEg_SbS6p9tVxNPXr3UOBubbY1nSN-ZvHARhruR7BlQH_mg3TAWXl5SL-VTboXHF0rFL-U0F22OQVHLcONvoobi74rp70qJ8z2eEYuWq7w_bNLUMqzicF4ePooKjRqSg==) [9]