Comoros -- Regulatory Status Regulatory Overview

The regulatory landscape for cryptocurrencies and virtual assets in Comoros has been evolving, moving from a largely unregulated space to one that is now seeking to establish a framework, primarily through a licensing regime for Virtual Asset Service Providers (VASPs).

Current Regulatory Status in Comoros

• Regulatory Approach: Partial, moving towards a licensing-based regulation. Comoros has not implemented a comprehensive, broad regulatory framework covering all aspects of blockchain or digital assets. However, it has moved to regulate key activities related to virtual assets, particularly those performed by VASPs, requiring them to be licensed. This is a significant shift from a previous lack of specific regulation, or a generally restrictive environment for unsanctioned crypto activities.
• Primary Regulatory Bodies:
  • Central Bank of Comoros (Banque Centrale des Comores - BCC): This is the primary financial regulator and has been designated as the key authority responsible for licensing, supervision, and enforcement related to virtual assets and VASPs.
  • Ministry of Finance: Likely involved in the policy and legislative development.
• Key Legislation Names and Dates:
  • Virtual Asset Service Providers (VASP) Act, 2023: This is the most significant piece of legislation. It aims to establish a regulatory and licensing framework for entities dealing with virtual assets in the Union of Comoros. While specific details can be elusive for smaller jurisdictions, this Act is reported to designate the Central Bank of Comoros as the primary supervisory authority for VASPs. It likely covers aspects such as licensing requirements, anti-money laundering (AML) and combating the financing of terrorism (CFT) obligations, and consumer protection.
    • Date: Enacted in 2023.
    • URL: Official gazette publications for Comoros are not always readily available online in easily searchable formats. Information about the VASP Act often comes from legal updates or news sources citing the BCC's new powers. A direct, official government URL for the full text of the Act is difficult to pinpoint publicly.
      • Reference (indirect, often cited in legal summaries): The Act empowers the Central Bank of Comoros. You might find general information or warnings on the BCC website, but the full legislative text is typically not directly linked.
        • Central Bank of Comoros Website: http://www.banquecentrale.km/ (While not linking directly to the Act, this is the official body responsible).
• Current Stance on Crypto Trading and Exchanges:
  • Regulated and Permitted under License: The VASP Act of 2023 signifies that crypto trading and the operation of crypto exchanges (and other virtual asset services) are no longer implicitly banned or operating in a legal vacuum. Instead, they are now subject to a licensing regime enforced by the Central Bank of Comoros.
  • Entities wishing to operate as virtual asset service providers (e.g., exchanges facilitating trading, custodians, issuers of virtual assets) are expected to apply for and obtain a license from the BCC.
  • Unlicensed operations are likely illegal and subject to penalties under the new framework. This move aims to bring greater oversight, combat illicit financial activities, and potentially attract legitimate digital asset businesses to operate under a regulated environment.

Summary:

Comoros has taken a definitive step towards regulating the virtual asset sector with the enactment of the VASP Act in 2023. This marks a shift from a less defined or restrictive stance to one that seeks to formalize and supervise virtual asset services through a licensing framework overseen by the Central Bank of Comoros. For individuals and entities, this means that engaging in virtual asset activities, especially trading and operating exchanges, is now conditional on compliance with these new licensing and regulatory requirements.