Banking licence in AnjouanOverview
The Union of the Comoros is made up of three islands with a degree of autonomy: Grande Comore, Mohéli and Anjouan. Anjouan adopted an offshore financial services framework in 2005, including legislation on international banks, international business companies and anti-money laundering, and uses it to license international banks and other financial businesses that deal exclusively with non-residents. The licences are issued by the island's offshore finance authority rather than by the national central bank.
That distinction is central. The Banque Centrale des Comores describes itself as the sole monetary authority of the Union and is the body that approves banks and financial institutions operating in the Comoros. An Anjouan international banking licence is therefore not a licence from the Comoros central bank, and it does not authorise deposit-taking from the public in the Comoros or in any other country. Any business that solicits deposits or provides regulated services to residents of the EU, UK, US or elsewhere needs the authorisation of those jurisdictions.
Anjouan licences are attractive to some sponsors because of short timelines, low cost and light initial requirements compared with onshore banks. The same features explain the reservations of correspondent banks, payment schemes and foreign regulators, several of which have issued warnings over the years about entities holding offshore licences from small jurisdictions. In practice, obtaining correspondent accounts, card-scheme membership or SWIFT connectivity for an Anjouan-licensed bank is difficult, and counterparties will look closely at ownership, management and controls.
Legitimate uses are narrow: a captive or group treasury vehicle serving related entities, a structure for a defined set of sophisticated international clients who understand the regulatory position, or a transitional step within a broader, properly licensed group. Sponsors whose goal is to offer banking or payment services to the public in major markets will usually be better served by an EU specialised bank, an EMI or a payment institution licence, even though these take longer and require more capital.
Key benefits
- Relatively short licensing timeline compared with onshore banking authorisations
- Lower set-up cost and lighter initial capital expectations
- Foreign ownership permitted, subject to due diligence
- Can serve as a captive or group treasury vehicle for related international entities
- International business company framework allows a simple holding structure
Requirements
- Incorporation of an international company under Anjouan's 2005 legislation
- Due diligence on shareholders, directors and ultimate beneficial owners, including source of funds
- Business plan describing the non-resident client base and services
- AML/CFT policies consistent with Anjouan's money laundering legislation and international standards
- Clear statement that services will not be offered to the public in jurisdictions requiring local authorisation
- Annual renewal of the licence and ongoing reporting to the issuing authority
- A realistic correspondent banking and safeguarding plan before any client funds are accepted
- Independent legal analysis of the target markets' licensing rules
Licence options & capital
New Anjouan international banking licence
A new international company applies for a licence. Suitable only where the limits on recognition and correspondent access are acceptable for the intended model.
Captive or group treasury structure
An Anjouan bank used solely for intra-group treasury or a closed circle of related clients, combined with properly licensed entities for any external activity.
Alternative regulated routes
For public-facing banking or payments, an EU specialised bank, an EMI, a payment institution or a money services registration usually provides the recognition the business needs.
Step-by-step process
- 1
Suitability assessment
We assess the objectives, target markets and client base, and advise candidly on whether an Anjouan licence can achieve them.
- 2
Target-market analysis
Licensing rules in each market where clients are located are reviewed to avoid unauthorised activity.
- 3
Due diligence file
Shareholder, director and beneficial owner documentation is assembled with source-of-funds evidence.
- 4
Company formation and application
The international company is incorporated and the licence application, business plan and AML policies are submitted.
- 5
Banking infrastructure
Correspondent, custody and payment arrangements are explored, with realistic expectations about acceptance.
- 6
Ongoing compliance
Annual renewal, record keeping and AML controls are maintained, with periodic review of the structure's continued suitability.
Typical documents
- Certified passports and recent proof of address for shareholders, directors and beneficial owners
- CVs demonstrating relevant financial services experience
- Bank and professional references
- Police clearance certificates
- Source of funds and source of wealth evidence
- Corporate documents for any corporate shareholders
- Business plan and financial projections
- AML/CFT manual and compliance officer details
How Legal Wealth helps
Legal Wealth advises on Anjouan international banking licences with a compliance-first perspective. We explain clearly what such a licence can and cannot do, analyse the licensing rules in the markets you intend to serve, and recommend alternative regulated structures where they better protect your reputation and your clients. Where an Anjouan structure is appropriate, for example as a captive vehicle, we prepare a well-documented file and keep ownership information confidential.
Enquire with Legal WealthFrequently asked questions
Is an Anjouan licence issued by the Comoros central bank?
No. It is issued under Anjouan's own 2005 offshore legislation. The Banque Centrale des Comores is the body that approves banks and financial institutions in the Union of the Comoros.
Can an Anjouan bank take deposits from EU or US clients?
Not lawfully on a solicited basis without authorisation in those jurisdictions. An Anjouan licence does not grant rights to offer banking services abroad.
Will correspondent banks work with an Anjouan bank?
Access is limited. Many correspondent banks and payment schemes decline banks licensed in small offshore jurisdictions or apply very stringent due diligence.
Why choose Anjouan at all?
Mainly for captive, group-treasury or closed-circle international structures where speed and cost matter and public-facing activity is not intended.
What is a better route for a fintech bank?
For public-facing services, an EU specialised bank, an EMI or a payment institution licence generally provides the recognition, passporting and correspondent access a fintech requires.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
