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Banking licensing · Dominica

Offshore banking licences in the Commonwealth of Dominica

Dominica licenses offshore banks through its Financial Services Unit, which also acts as the island's money laundering supervisory authority. An offshore bank serves non-resident clients under the Offshore Banking Act, while domestic commercial banking falls within the Eastern Caribbean Central Bank framework. The route suits carefully structured international banking projects with strong governance and a credible correspondent strategy.

Enquire with Legal WealthBanking licence in Dominica
Key facts
Regulator
Financial Services Unit (FSU), Ministry of Finance, Dominica
Legal basis
Offshore Banking Act, 1996 (as amended) and AML/CFT legislation
Client base
Non-residents; domestic commercial banking is under the ECCB regime
AML supervisor
FSU as Money Laundering Supervisory Authority
Currency area
Eastern Caribbean dollar, pegged to the US dollar
Ownership
Foreign ownership permitted subject to fit-and-proper review
Ongoing
Annual licence fees, audited accounts and prudential reporting to the FSU
01

Overview

Dominica is an independent member of the Eastern Caribbean Currency Union. Commercial banks serving the domestic market are licensed under the harmonised banking legislation and supervised by the Eastern Caribbean Central Bank. Offshore banks, by contrast, are licensed and supervised locally by the Financial Services Unit under the Offshore Banking Act. The FSU's remit also includes credit unions, insurance, money services businesses and gaming, and it serves as the Money Laundering Supervisory Authority for the jurisdiction.

An offshore banking licence permits banking business with non-residents, typically deposit-taking, lending, payments, trade finance and treasury services for international clients, conducted in currencies other than the Eastern Caribbean dollar. The licensee is a Dominica company whose shareholders, directors and senior officers must pass the FSU's fit-and-proper assessment. The Act sets a statutory minimum paid-up capital and requires capital to be maintained throughout the life of the licence; the current figure and any deposit or pledge requirements should be confirmed with the FSU at the time of application, as they are subject to amendment.

The practical success of an offshore bank depends less on obtaining the licence than on what follows. Correspondent banks apply rigorous due diligence to small international banks, and they assess the jurisdiction, the ownership, the quality of the AML framework, the business model and the management team. A Dominica offshore bank therefore needs experienced management, a fully documented AML/CFT programme, independent audit, information security and a realistic plan for correspondent and payment-network access before it launches.

Applicants should approach the jurisdiction with clear expectations. Offshore banking regimes across the Caribbean are under sustained international scrutiny from standard setters and correspondent banks, and regulators have become more demanding about substance, governance and the source of capital. A Dominica licence is best suited to sponsors with an established financial services background and a genuine international client base, rather than as a shortcut to a banking label.

02

Key benefits

  • Full banking licence for international business with non-resident clients
  • Foreign ownership permitted, subject to fit-and-proper review
  • Local, accessible regulator through the Financial Services Unit
  • Common-law jurisdiction and English-language legal system
  • Membership of the Eastern Caribbean Currency Union with a US dollar–pegged currency
  • Can support private banking, trade finance and treasury services for an international group
03

Requirements

  • Incorporation of a Dominica company to hold the licence
  • Minimum paid-up capital as prescribed under the Offshore Banking Act, verified and maintained
  • Fit-and-proper shareholders, directors and senior officers, with evidence of source of funds and wealth
  • Experienced management with banking backgrounds, including a qualified compliance officer
  • Registered office and local presence in Dominica
  • Detailed business plan with multi-year financial projections and risk management framework
  • Comprehensive AML/CFT programme consistent with Dominica's money laundering legislation
  • Independent external auditor acceptable to the FSU
  • IT, information security and business continuity arrangements
  • Payment of application and annual licence fees set by the FSU
04

Licence options & capital

New offshore banking licence

A fresh application by a new Dominica company, giving the sponsor full control over governance, systems and business model from the outset.

Acquisition of an existing licensee

Acquiring an existing offshore bank requires FSU approval of the change of control and thorough legal, financial and AML due diligence on the target's history.

Alternative structures

Where the business model is payments or e-money rather than full banking, an EU specialised bank, EMI or money services route may be more practical for correspondent access.

05

Step-by-step process

  1. 1

    Feasibility and model review

    We assess whether an offshore bank is the right vehicle and how correspondent access will be achieved.

  2. 2

    Sponsor due diligence

    Shareholders and management are prepared for fit-and-proper review, with source of funds documented.

  3. 3

    Company formation

    A Dominica company is incorporated with appropriate constitutional documents and registered office.

  4. 4

    Application file

    Business plan, projections, AML/CFT programme, governance and IT documentation are prepared and submitted to the FSU.

  5. 5

    Regulatory review

    The FSU reviews the application and may request clarification, meetings or additional documents.

  6. 6

    Licence and launch

    On approval, capital is confirmed, fees paid, correspondent relationships finalised and operations begun under FSU supervision.

06

Typical documents

  • Certified passports, proof of address and CVs for shareholders, directors and officers
  • Bank and professional references for key individuals
  • Police clearance certificates
  • Source of funds and source of wealth evidence for capital
  • Corporate documents for any corporate shareholders, with ownership charts
  • Business plan with multi-year financial projections
  • AML/CFT manual, risk assessment and compliance officer details
  • Governance, risk management, IT and business continuity policies
  • Auditor engagement letter
07

How Legal Wealth helps

Legal Wealth helps sponsors decide whether a Dominica offshore bank fits their strategy and, if it does, prepares a licensing file that reflects real banking substance. We coordinate company formation, fit-and-proper documentation and source-of-wealth evidence with discretion, and we help design governance, AML/CFT and correspondent banking plans that will stand up to regulators and counterparties. Where another route serves the client better, we say so.

Enquire with Legal Wealth
08

Frequently asked questions

Who regulates offshore banks in Dominica?

The Financial Services Unit of the Ministry of Finance licenses and supervises offshore banks under the Offshore Banking Act. Domestic commercial banks fall under the Eastern Caribbean Central Bank.

Can an offshore bank serve Dominica residents?

Offshore banks are intended to serve non-residents. Domestic banking business is governed by the separate ECCB-supervised regime.

What is the minimum capital?

The Offshore Banking Act sets a statutory minimum paid-up capital. Because figures and deposit arrangements can change, the current requirement should be confirmed with the FSU before planning capital.

Is foreign ownership allowed?

Yes, subject to the FSU's fit-and-proper review of shareholders, directors and officers and evidence of the source of capital.

What is the main practical challenge?

Obtaining and keeping correspondent banking relationships. This depends on management quality, AML controls and the business model as much as on the licence itself.

Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.

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