Crypto ATM / kiosk operator in Comoros

Anjouan Offshore Finance Authority (AOFA): This is the primary authority responsible for licensing offshore financial services, including what are often adapted for cryptocurrency businesses.

Central Bank of Comoros (Banque Centrale des Comores - BCC): While the BCC oversees traditional financial institutions and monetary policy for the entire Union of the Comoros, it generally has less direct specific oversight or licensing for offshore virtual asset activities compared to AOFA.

Instead, virtual asset businesses seeking to operate from Comoros (via Anjouan) typically apply for a general financial services license or a Money Service Business (MSB) license under the AOFA framework. These licenses are then interpreted and adapted to cover crypto-related activities.

Exchanges (Spot, Derivatives): Would typically require an AOFA Financial Services License or MSB license. This allows for the facilitation of transactions, trading, and conversion of virtual assets.

Payment Processors (Fiat-to-Crypto, Crypto-to-Fiat, Crypto-only): An MSB license is the most common route for these entities, as they facilitate money transfers and currency exchange, which crypto payments are increasingly seen to represent.

Customer Due Diligence (CDD): Verification of identity for all clients (individuals and corporate).

Enhanced Due Diligence (EDD): For high-risk clients or transactions.

Monitoring: Ongoing monitoring of transactions for suspicious activities.

Reporting: Reporting of suspicious transactions (STRs) to the local Financial Intelligence Unit (FIU), which is likely the National Financial Intelligence Processing Unit (Unité Nationale de Traitement des Renseignements Financiers - UNTRF).

Compliance Officer: Appointment of a qualified AML/CFT Compliance Officer.

Record Keeping: Maintaining records of transactions and client identification for a prescribed period.

Registered Office: All licensed entities must have a registered office address in Anjouan.

Local Agent/Representative: It's common to require a local registered agent or representative who acts as a liaison with the AOFA.

Physical Presence/Staff: While a full physical office with local staff isn't always strictly mandated for the offshore structures, having an operational substance plan is increasingly important for reputational and compliance purposes.

The capital requirement is typically modest compared to many other jurisdictions. For a general Financial Services or MSB license from AOFA, the minimum paid-up capital requirement can be around USD 10,000 to USD 50,000, though this can vary. It's often required to be deposited in a local bank account or an account approved by the AOFA.

Comoros is currently on the FATF (Financial Action Task Force) "grey list" (Jurisdictions under increased monitoring). This means it is actively working with the FATF to address strategic deficiencies in its AML/CFT regimes.

Businesses must formally apply for a license.

They must meet specific criteria and undergo due diligence by the AOFA.

Licenses are granted after approval, requiring ongoing compliance to maintain validity.

The Union of the Comoros does not have a dedicated, comprehensive law specifically for virtual assets or cryptocurrencies akin to those in major financial hubs.

Specific Crypto Law vs. General Financial Services License:

Ordinance No. 19-001/PR of 26 July 2019 on the Fight Against Money Laundering and Terrorist Financing: This is the most recent foundational AML/CFT law in Comoros. It replaced previous legislation (like Law No. 11-002/AF of 29 March 2011) and aims to align the Comorian framework with international standards set by FATF.

Implement AML/CFT requirements: VASPs must comply with all AML/CFT obligations applicable to financial institutions, including customer due diligence, record-keeping, and suspicious transaction reporting.

Identification and Verification:

For natural persons: Obtain and verify the customer's identity using reliable, independent source documents, data, or information (e.g., full name, address, date and place of birth, nationality, unique identification number from an official document like a passport or national ID card).

Beneficial Ownership: Identify and take reasonable measures to verify the identity of the beneficial owner(s) of the customer, including for legal persons and arrangements.

Enhanced Due Diligence (EDD): Apply EDD measures to higher-risk situations, which may include:

Source of Funds/Wealth: For high-risk clients or transactions, VASPs should take reasonable measures to establish the source of funds or source of wealth.

Ongoing Monitoring: Conduct ongoing due diligence on the business relationship and scrutinize transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the obliged entity's knowledge of the customer, their business, and risk profile, including, where necessary, the source of funds.

Obligation to Report: VASPs are obligated to report any transaction (or attempted transaction), regardless of the amount, where there are reasonable grounds to suspect that the funds are the proceeds of a crime or are related to terrorist financing.

Reporting Authority: All STRs must be submitted to the National Financial Information Processing Unit (Cellule Nationale de Traitement des Informations Financières - CNTIF), which is Comoros' Financial Intelligence Unit (FIU).

No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or to third parties that an STR has been filed or that an investigation is underway.

Transaction Records: Records of all transactions (date, type, amount, currency, parties involved, payment methods, digital wallet addresses, transaction hashes).

Customer Identification Data: All documents and information used for CDD, including verification records.

Developing Regulatory Landscape: Comoros is a small, developing island nation. Its financial regulatory framework is still maturing, and specific legislation or dedicated enforcement mechanisms for complex digital assets like cryptocurrencies are likely not yet robust or fully established.

Focus on Warnings, Not Enforcement: Like many emerging economies, the primary approach of its financial regulator (the Central Bank of Comoros – Banque Centrale des Comores, BCC) regarding cryptocurrencies has typically been to issue general warnings to the public about the risks associated with volatile and unregulated assets, rather than to conduct formal enforcement actions against specific entities. Such warnings are often generic and do not name specific actors or impose penalties.

Lack of Transparency/Public Disclosure: Even if minor enforcement actions or investigations were to occur, they are unlikely to be publicly disclosed with the level of detail requested (penalty amounts, specific dates, outcomes, public reports) in a country with less developed financial transparency standards compared to major global financial hubs.

Limited Scale of Crypto Activity: It's also possible that the scale of cryptocurrency operations or significant violations within Comoros has not yet reached a level that would trigger major, publicly reported enforcement actions.