Comoros
Retail_Trading_Status
- Analysis ID
- #635
- Version
- Archived
- Created
- 2025-12-12 04:05
- Run
- b409e054...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading in Comoros exists in a complex regulatory gray zone characterized by a conflict between the federal Central Bank and the autonomous island of Mwali (Mohéli). While the Central Bank of Comoros (BCC) has not explicitly criminalized the possession of crypto assets by individuals, it has issued warnings against unauthorized financial entities and labeled the offshore licensing regime in Mwali as illegitimate. Consequently, while buying and holding crypto is not a statutory crime, the primary 'licensed' ecosystem is considered fictitious by the supreme monetary authority, creating significant legal and operational uncertainty.
Key Pillars
Banque Centrale des Comores (BCC) - Primary monetary authority for the Union
Mwali International Services Authority (MISA) - Autonomous island body issuing disputed crypto licenses
No national VASP framework - The Union has no enacted crypto-specific legislation
Anti-Money Laundering (AML) - General AML laws apply, but FATF notes a lack of specific VASP implementation
Landmark Laws
Mwali Services Act 1998 (Amended 2001) (Mwali Services Act) - Enacted: 1998-01-01
- Legislation cited by the autonomous island of Mwali to justify its offshore licensing regime, including the issuance of licenses for crypto exchanges and brokerage firms. The validity of this act for financial licensing is disputed by the Central Bank.
- Source
BCC Public Notice on Fictitious Regulators (BCC Warning) - Enacted: 2022-06-15
- A public warning issued by the Central Bank of Comoros explicitly naming the 'Mwali International Services Authority' (MISA) as a fictitious entity without authority to issue banking or financial licenses in the Union.
- Source
FATF Mutual Evaluation Report of Comoros (FATF MER 2024) - Enacted: 2024-05-01
- International assessment stating that virtual assets are 'neither prohibited nor regulated' in the Union of Comoros and that authorities have taken no measures to supervise the sector.
- Source
Considerations
Conflict of Authority: The autonomous island of Mwali issues crypto licenses that the federal Central Bank declares invalid.
Scam Risk: The BCC warns that many entities claiming Comoros regulation are fraudulent or unauthorized.
No Consumer Protection: Traders using Mwali-licensed platforms have no recourse with the national Central Bank.
Banking Access: Local banks are unlikely to process crypto transactions given the BCC's hostile stance toward the offshore sector.
Notes
The 'Comoros Crypto License' is a widely used marketing tool in the global low-tier offshore industry. Analysts should be aware that a 'Comoros License' almost always refers to the Mwali (MISA) license, which is not recognized by the Central Bank of Comoros (BCC). This distinction is critical for compliance: MISA-licensed entities are effectively unregulated from the perspective of the national monetary authority.
Remaining Uncertainties
- Will the Union government take legal action to shut down the MISA registry?
- Are local banks strictly enforcing a ban on transfers to MISA-licensed entities?
- Does the BCC plan to introduce a federal VASP framework to supersede the offshore regime?
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in Comoros is defined by a unique jurisdictional conflict between the federal government (Union of Comoros) and one of its autonomous islands, Mwali (Mohéli). At the federal level, the Banque Centrale des Comores (BCC) maintains that it is the sole authority empowered to license financial institutions across all three islands. The BCC has not established a regulatory framework for virtual assets, and the 2024 FATF Mutual Evaluation Report explicitly states that virtual assets are 'neither prohibited nor regulated' in the Union. This absence of prohibition implies that individual retail trading and possession are not criminal offenses under national law.
However, the situation is complicated by the aggressive activities of the Mwali International Services Authority (MISA). MISA operates as an offshore regulator based on the island of Mwali, issuing hundreds of 'International Brokerage and Clearing House' licenses to crypto exchanges and forex brokers globally. These entities market themselves as 'regulated in Comoros.' The Central Bank of Comoros has publicly denounced MISA, labeling it a 'fictitious entity' and asserting that licenses issued by MISA have no legal validity within the Union's financial system. This creates a severe 'Gray-Zone' scenario where a parallel regulatory regime exists but is rejected by the sovereign monetary authority.
For retail investors, this environment presents significant risks. While a user in Moroni might legally access an international exchange, the local 'licensed' options are legally dubious. The BCC has issued warnings advising the public to avoid offers from entities not on its official list—a list that currently excludes all crypto service providers. Furthermore, the FATF report highlights that Comoros has not implemented the 'Travel Rule' or other VASP-specific AML measures, leaving the sector vulnerable to illicit finance risks. Consequently, while not explicitly banned, crypto trading in Comoros operates in a legal vacuum filled with conflicting claims of legitimacy.
The regulatory status of cryptocurrency in Comoros is defined by a unique jurisdictional conflict between the federal government (Union of Comoros) and one of its autonomous islands, Mwali (Mohéli). At the federal level, the Banque Centrale des Comores (BCC) maintains that it is the sole authority empowered to license financial institutions across all three islands. The BCC has not established a regulatory framework for virtual assets, and the 2024 FATF Mutual Evaluation Report explicitly states that virtual assets are 'neither prohibited nor regulated' in the Union. This absence of prohibition implies that individual retail trading and possession are not criminal offenses under national law. However, the situation is complicated by the aggressive activities of the Mwali International Services Authority (MISA). MISA operates as an offshore regulator based on the island of Mwali, issuing hundreds of 'International Brokerage and Clearing House' licenses to crypto exchanges and forex brokers globally. These entities market themselves as 'regulated in Comoros.' The Central Bank of Comoros has publicly denounced MISA, labeling it a 'fictitious entity' and asserting that licenses issued by MISA have no legal validity within the Union's financial system. This creates a severe 'Gray-Zone' scenario where a parallel regulatory regime exists but is rejected by the sovereign monetary authority. For retail investors, this environment presents significant risks. While a user in Moroni might legally access an international exchange, the local 'licensed' options are legally dubious. The BCC has issued warnings advising the public to avoid offers from entities not on its official list—a list that currently excludes all crypto service providers. Furthermore, the FATF report highlights that Comoros has not implemented the 'Travel Rule' or other VASP-specific AML measures, leaving the sector vulnerable to illicit finance risks. Consequently, while not explicitly banned, crypto trading in Comoros operates in a legal vacuum filled with conflicting claims of legitimacy.
Source Evidence
Primary and secondary sources cited in this analysis
"Virtual assets are neither prohibited nor regulated in The Union of the Comoros. The authorities have not taken any measures to monitor, identify and sanction, where appropriate, virtual asset providers..."
"La Banque Centrale des Comores (BCC) alerte le public de la recrudescence... d'offres illégales d'investissements... provenant d'entités non agréées."
"Mwali International Services Authority (MISA) is the regulatory body that licenses and oversees cryptocurrency businesses in the Comoros."
"The Central Bank of Comoros has also published a public notice about MISA, confirming that it is not a legitimate regulator."
"In Comoros, a crypto license is a reliable and simple way for a company to operate legally... issued by MISA in Moheli."
Web Sources (7)
Sources discovered via web search grounding
Search queries used (10)
- Comoros crypto currency legal status
- Banque Centrale des Comores cryptomonnaie
- Mwali International Services Authority crypto license regulation
- Banque Centrale des Comores warning virtual assets
- Mwali crypto license legit or scam
- Comoros crypto tax laws
- Is it legal to buy bitcoin in Comoros
- Comoros FATF Mutual Evaluation Report "virtual assets"
- "Mwali International Services Authority" Central Bank of Comoros conflict
- Banque Centrale des Comores "cryptomonnaie" circular
https://traderhelpbook.com/fxtropico/
https://www.earnforex.com/guides/misa-mwali-international-services-authority/
https://publications.banque-france.fr/sites/default/files/medias/documents/focus-10_2013-12-05_en.pdf
https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MER-Comoros-May-2024.pdf.coredownload.pdf
https://ifhaonline.org/AibResources/Papers/Mapping%20the%20Offshore%20Gambling%20Regulators_Final.pdf
https://www.fastbull.com/brokersview/news/valuta-markets-review-scam-warning-signs-and-regulatory-concerns-263609
https://www.offshore-pro.com/comoros-crypto-license-a-profitable-and-affordable-solution-for-business/