Comoros
Retail_Trading_Status
Status Changed
Previous status: Gray-Zone
Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. The original new analysis incorrectly classified the status as Gray-Zone. The correct status is supported by the Central Bank's warnings (which do not constitute a ban), the explicit FATF assessment that virtual assets are 'neither prohibited nor regulated,' and the absence of any law criminalizing retail trading. The jurisdictional conflict with Mwali's offshore regime adds complexity but does not change the fundamental fact that retail trading is allowed and unregulated at the federal level.
- Analysis ID
- #844
- Version
- Latest
- Created
- 2025-12-13 06:59
- Run
- b409e054...
- History
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- Workflow Stage
- Reconciled
Executive Summary
As of December 2025, the Union of the Comoros maintains an 'Allowed-UnRegulated' stance on retail cryptocurrency trading. The Central Bank of Comoros (BCC) actively monitors global trends and issues public warnings about risks but has not implemented formal restrictions or a domestic regulatory framework. The Financial Action Task Force (FATF) confirms virtual assets are 'neither prohibited nor regulated' in the Union. A jurisdictional conflict exists, as the autonomous island of Mwali (Mohéli) issues offshore crypto licenses through the Mwali International Services Authority (MISA), which the federal BCC declares illegitimate. This creates a complex environment where retail trading is not banned but operates without consumer protection or legal clarity.
Key Pillars
- Observation and Warnings: The Central Bank of Comoros monitors global cryptocurrency trends and issues public warnings concerning risks like price volatility, fraud, and lack of legal protections, emphasizing that cryptocurrencies are not legal tender and investments are at the individual's own risk.
- Absence of Formal Restrictions: There are no formal bans or specific prohibitions on individuals engaging in cryptocurrency transactions.
- Lack of Domestic Legal Framework: No comprehensive legal framework exists for domestic retail crypto trading, meaning no consumer protection or specific legal recourse for users.
- Jurisdictional Conflict and Unrecognized Offshore Regime: The autonomous island of Mwali operates an offshore licensing regime for crypto businesses via the Mwali International Services Authority (MISA), citing the Mwali Services Act. The federal Central Bank of Comoros has publicly denounced MISA as a 'fictitious entity' and states its licenses have no legal validity within the Union's financial system.
- International Assessment: The FATF Mutual Evaluation Report (May 2024) states virtual assets are 'neither prohibited nor regulated' in the Union of the Comoros and that authorities have taken no measures to supervise the sector.
Landmark Laws
- Mwali Services Act 1998 (Amended 2001): Legislation cited by the autonomous island of Mwali to justify its offshore licensing regime, including for crypto exchanges. Its validity for financial licensing is disputed by the Central Bank of Comoros. [Source: https://mwaliregistrar.org]
- BCC Public Notice on Fictitious Regulators (June 15, 2022): 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: https://banque-comores.km]
- FATF Mutual Evaluation Report of Comoros (May 1, 2024): International assessment stating that virtual assets are 'neither prohibited nor regulated' in the Union of the Comoros and that authorities have taken no measures to supervise the sector. [Source: https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-comoros-2024.html]
Considerations
- Asset Classification: Cryptocurrencies are generally understood to be treated as intangible assets for tax purposes, not as legal tender.
- Taxation: No comprehensive legal framework for cryptocurrency taxation exists. Gains are likely subject to general income tax rules (rates 0% to 30%).
- Consumer Protection: Explicitly none in place for retail crypto users.
- Anti-Money Laundering/Counter-Terrorism Financing (AML/CFT): Specific domestic AML/CFT regulations for retail users are not detailed. Licensed offshore businesses are required to implement AML/CFT measures, but the national authority notes a lack of specific VASP implementation.
- Conflict of Authority: The autonomous island of Mwali issues crypto licenses that the federal Central Bank declares invalid, creating legal uncertainty.
- Scam Risk: The BCC warns that many entities claiming Comoros regulation are fraudulent or unauthorized.
- Banking Access: Local banks are unlikely to process crypto transactions given the BCC's hostile stance toward the offshore sector.
Notes
The retail cryptocurrency trading landscape in Comoros is characterized by a regulatory vacuum for domestic users. The Central Bank's warnings emphasize self-responsibility. The 'Comoros Crypto License' widely marketed globally typically refers to the Mwali (MISA) license, which is not recognized by the federal Central Bank of Comoros (BCC). This distinction is critical: MISA-licensed entities are effectively unregulated from the perspective of the national monetary authority. The BCC has initiated discussions on future regulation of Virtual Assets (VAs) and VASPs, but no concrete proposals exist as of December 2025.
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?
Detailed Explanation
Detailed Explanation
As of December 2025, retail cryptocurrency trading in the Union of the Comoros is in an 'Allowed-Unregulated' state, meaning it is not prohibited but operates without a formal domestic legal framework. The Central Bank of Comoros (BCC) actively monitors global trends and issues public warnings to citizens about the risks associated with cryptocurrencies, such as price volatility, fraud, and the lack of legal protections, emphasizing that they are not legal tender. The Financial Action Task Force (FATF) Mutual Evaluation Report from May 1, 2024, confirms this stance, stating that virtual assets are 'neither prohibited nor regulated' in the country and that authorities have taken no measures to supervise the sector. This creates an environment where individuals can trade but do so entirely at their own risk, with no consumer protection or specific legal recourse available. A significant complication arises from a jurisdictional conflict within the country. The autonomous island of Mwali (Mohéli) operates an offshore licensing regime for crypto businesses through the Mwali International Services Authority (MISA), which cites the Mwali Services Act 1998 (amended 2001) as its legal basis. However, the federal Central Bank of Comoros has explicitly denounced this regime. In a public notice dated June 15, 2022, the BCC declared MISA a 'fictitious entity' without the authority to issue banking or financial licenses within the Union, stating that its licenses hold no legal validity. This conflict means that the 'Comoros Crypto License' marketed globally is not recognized by the national monetary authority, creating profound legal uncertainty. The BCC has also warned that many entities claiming Comoros regulation are fraudulent, and local banks are unlikely to facilitate crypto-related transactions due to this hostile stance. While the BCC has initiated discussions on future regulation for virtual assets and service providers, no concrete proposals or legislation exists as of the reporting date.
Summary Points
I. Regulatory Status
* Allowed-Unregulated for retail trading as of December 2025.
* Cryptocurrencies are not legal tender.
* The Financial Action Task Force (FATF) assessment (May 2024) states virtual assets are 'neither prohibited nor regulated' in the Union.
* No comprehensive domestic legal framework exists for retail crypto trading, resulting in a regulatory vacuum.
II. Key Regulatory Bodies
* Central Bank of Comoros (BCC): The national monetary authority.
* Monitors global crypto trends and issues public risk warnings.
* Does not recognize or regulate domestic crypto activities.
* Publicly rejects the legitimacy of the Mwali offshore licensing regime.
* Mwali International Services Authority (MISA): An entity on the autonomous island of Mwali.
* Issues offshore licenses for crypto businesses under the Mwali Services Act.
* Declared a 'fictitious entity' without licensing authority by the BCC in a June 2022 notice.
III. Important Legislation
* Mwali Services Act 1998 (Amended 2001): Legislation cited by Mwali to justify its offshore licensing regime for crypto exchanges. Its validity is disputed by the federal Central Bank of Comoros.
* BCC Public Notice on Fictitious Regulators (June 15, 2022): Official warning naming the 'Mwali International Services Authority' (MISA) as a fictitious entity without authority to issue financial licenses in the Union.
* FATF Mutual Evaluation Report of Comoros (May 1, 2024): International report confirming virtual assets are 'neither prohibited nor regulated' and that authorities have taken no measures to supervise the sector.
IV. Compliance Requirements
* For domestic retail users: No specific compliance requirements are detailed due to the lack of a regulatory framework.
* For businesses holding an offshore MISA license: Required to implement AML/CFT measures per Mwali's rules, but the national FATF report notes a lack of specific VASP implementation and supervision.
V. Notable Restrictions or Limitations
* Consumer Protection: Explicitly none in place for retail cryptocurrency users.
* Banking Access: Local banks are unlikely to process cryptocurrency transactions given the BCC's hostile stance toward the offshore sector.
* Legal Uncertainty: A direct conflict of authority exists between the federal BCC and the autonomous island of Mwali, creating significant legal risk.
* Scam Risk: High risk of fraud; the BCC warns that many entities claiming Comoros regulation are fraudulent or unauthorized.
VI. Recent Developments or Notes
* The Central Bank of Comoros has initiated discussions on the future regulation of Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs), but no concrete proposals exist as of December 2025.
* Cryptocurrencies are generally treated as intangible assets for tax purposes.
* No comprehensive cryptocurrency tax framework exists; gains are likely subject to general income tax rules (rates 0% to 30%).
* The 'Comoros Crypto License' marketed globally refers to the Mwali (MISA) license, which is not recognized by the national Central Bank of Comoros.
Full Analysis Report
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.
Retail_Trading_Status in Comoros
Identified Status: Allowed-UnRegulated
Detailed Narrative Explanation:
The legal status of retail cryptocurrency trading for individual citizens and residents of the Union of the Comoros is 'Allowed-UnRegulated.' This is supported by the Central Bank of Comoros's (BCC) public stance and international assessments. The BCC has not enacted any laws or regulations that explicitly prohibit or comprehensively regulate the buying, selling, or holding of cryptocurrencies by individuals. The Financial Action Task Force (FATF) Mutual Evaluation Report from May 2024 confirms this, stating virtual assets are 'neither prohibited nor regulated' in the Union and that authorities have taken no measures to supervise the sector.
The BCC's primary role has been one of observation and public warning. It consistently alerts the public to the inherent risks of cryptocurrencies, including extreme price volatility, potential for fraud, and the critical lack of legal protections or government backing. These warnings clarify that cryptocurrencies are not legal tender in Comoros. The absence of formal restrictions means retail trading is not banned.
However, the environment is complicated by a jurisdictional conflict. The autonomous island of Mwali (Mohéli) operates an offshore financial regime through the Mwali International Services Authority (MISA), which issues licenses to cryptocurrency exchanges and brokers under the Mwali Services Act. The federal BCC has explicitly denounced MISA as a 'fictitious entity' in a public notice dated June 15, 2022, stating it has no authority to issue financial licenses. This creates a parallel but unrecognized 'regulatory' ecosystem. For retail users, this means that entities marketing themselves as 'Comoros-licensed' are operating under a regime considered invalid by the national monetary authority, increasing legal and scam risks.
Consequently, while an individual in Comoros may legally access international cryptocurrency exchanges, there is no domestic regulatory framework to protect them. There are no specific AML/CFT rules for retail users, no consumer protection mechanisms, and no clear tax framework for crypto gains (though general income tax rules likely apply). The BCC has indicated discussions about future regulation of Virtual Assets and VASPs, but no concrete proposals exist as of December 2025.
Specific, Relevant Text Excerpts:
- FATF Mutual Evaluation Report (2024): "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..."
- BCC Public Notice (2022): The Central Bank alerts the public to illegal investment offers from unapproved entities, specifically naming MISA as fictitious.
- Proelium Law LLP: "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."
- Heavnn University (2024): "Comoros has yet to establish a comprehensive legal framework for the taxation of cryptocurrencies... The tax treatment of cryptocurrencies in Comoros remains uncertain."
Direct, Accessible URL Links to Sources:
* FATF Mutual Evaluation Report: https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER-Comoros-May-2024.pdf
* BCC Warning: https://banque-comores.km
* Proelium Law LLP - Cryptocurrency Regulation Tracker: https://www.proeliumlaw.com/crypto-regulation-tracker/
* UEEx Technology - Best Crypto Exchanges in Comoros 2025: https://ueex.com/en/blog/best-crypto-exchanges-in-comoros/
* Heavnn University - Cryptocurrency Taxes in Comoros: https://www.heavnn.university/cryptocurrency-taxes-in-comoros/
* Q Wealth Report - A Crypto License in the Comoros Islands: https://qwealthreport.com/a-crypto-license-in-the-comoros-islands/
* EarnForex - MISA Regulator Warning: https://www.earnforex.com/guides/mwali-international-services-authority-misa/
## 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. --- ### Retail_Trading_Status in Comoros **Identified Status:** Allowed-UnRegulated **Detailed Narrative Explanation:** The legal status of retail cryptocurrency trading for individual citizens and residents of the Union of the Comoros is 'Allowed-UnRegulated.' This is supported by the Central Bank of Comoros's (BCC) public stance and international assessments. The BCC has not enacted any laws or regulations that explicitly prohibit or comprehensively regulate the buying, selling, or holding of cryptocurrencies by individuals. The Financial Action Task Force (FATF) Mutual Evaluation Report from May 2024 confirms this, stating virtual assets are 'neither prohibited nor regulated' in the Union and that authorities have taken no measures to supervise the sector. The BCC's primary role has been one of observation and public warning. It consistently alerts the public to the inherent risks of cryptocurrencies, including extreme price volatility, potential for fraud, and the critical lack of legal protections or government backing. These warnings clarify that cryptocurrencies are not legal tender in Comoros. The absence of formal restrictions means retail trading is not banned. However, the environment is complicated by a jurisdictional conflict. The autonomous island of Mwali (Mohéli) operates an offshore financial regime through the Mwali International Services Authority (MISA), which issues licenses to cryptocurrency exchanges and brokers under the Mwali Services Act. The federal BCC has explicitly denounced MISA as a 'fictitious entity' in a public notice dated June 15, 2022, stating it has no authority to issue financial licenses. This creates a parallel but unrecognized 'regulatory' ecosystem. For retail users, this means that entities marketing themselves as 'Comoros-licensed' are operating under a regime considered invalid by the national monetary authority, increasing legal and scam risks. Consequently, while an individual in Comoros may legally access international cryptocurrency exchanges, there is no domestic regulatory framework to protect them. There are no specific AML/CFT rules for retail users, no consumer protection mechanisms, and no clear tax framework for crypto gains (though general income tax rules likely apply). The BCC has indicated discussions about future regulation of Virtual Assets and VASPs, but no concrete proposals exist as of December 2025. **Specific, Relevant Text Excerpts:** * **FATF Mutual Evaluation Report (2024):** "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..." * **BCC Public Notice (2022):** The Central Bank alerts the public to illegal investment offers from unapproved entities, specifically naming MISA as fictitious. * **Proelium Law LLP:** "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." * **Heavnn University (2024):** "Comoros has yet to establish a comprehensive legal framework for the taxation of cryptocurrencies... The tax treatment of cryptocurrencies in Comoros remains uncertain." **Direct, Accessible URL Links to Sources:** * FATF Mutual Evaluation Report: https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER-Comoros-May-2024.pdf * BCC Warning: https://banque-comores.km * Proelium Law LLP - Cryptocurrency Regulation Tracker: https://www.proeliumlaw.com/crypto-regulation-tracker/ * UEEx Technology - Best Crypto Exchanges in Comoros 2025: https://ueex.com/en/blog/best-crypto-exchanges-in-comoros/ * Heavnn University - Cryptocurrency Taxes in Comoros: https://www.heavnn.university/cryptocurrency-taxes-in-comoros/ * Q Wealth Report - A Crypto License in the Comoros Islands: https://qwealthreport.com/a-crypto-license-in-the-comoros-islands/ * EarnForex - MISA Regulator Warning: https://www.earnforex.com/guides/mwali-international-services-authority-misa/
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."
"Undecided. No legal status for cryptocurrencies. There is no cryptocurrency regulation."
"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."
"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."
"With no currency controls in the Comoros, brokers can easily transfer funds in and out of the country without facing any regulatory obstacles..."
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/