Banking with Crypto

The Comoros International Banking Authority has certain requirements for a Banking License to be satisfied, namely the Banking Law.
The key features of the Law are as follows:
The Law establishes a licensing regime for banks; licenses which are issued by the CIBA are for offshore banks only.
A Bank must inform the CIBA about any change in its share ownership.

Banking with Crypto

The Comoros International Banking Authority has also introduced a Banking License including trading in Digital Crypto currency. The conditions allow clients who have these Licenses to operate within the Digital Crypto global market.

This is a full-unrestricted Banking license, for all Banking services outside of the Union of Comoros. It encompasses banking and investment banking business and can be conducted in all major foreign currencies. Services such as fund administration, custodial services, trusteeship, international portfolio management, money market and other treasury operations may be undertaken by an offshore bank.


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  1. To accept cash deposits of any type (depositary transactions).
  2. To provide loans and borrow funds (loan transactions).
  3. To carry out currency and exchange transactions.
  4. To issue securities  
  5. To issue credit cards and processing.
  6. To issue Letter of Credit
  7. To provide securities safekeeping, manage securities and accomplish securities purchase or sale.
  8. To act as intermediary in securities trading.
  9. To provide guarantees of any type (guarantee business).
  10. To effect payments (opening of accounts for legal entities and individuals).
  11. Payment processing services and issue of electronic money
  12. To hold assets, capital, precision metals, bonds, shares or another financial instruments for third parties.
  13. To undertake electronic commerce (e-commerce).
  14. To provide other financial services.
  15. Cryptocurrency trading.
  16. Crypto Currency Exchange Operator (utility token and security token)
  17. Crypto liquidity.
  18. Crypto storage.
  19. CFD contract for difference.
  20. To open accounts in any crypto currency.
  21. To take deposits in any crypto currency.
  22. To provide loans in crypto currency.


Forming a bank is a relatively quick process due to the lack of bureaucracy. Approval can be granted swiftly if the necessary requirements are met. There are no requirements for local offices or staff, although we would suggest that all companies do have this facility which can be arranged at a minimal cost. Application for permission for a banking license should be made to the CIBA after an IBC is obtained and after completing an Application Form from the Registrar of International Businesses. A Licenses can be applied for at the same time as an IBC.

On top of the KYC and due diligence requirement, the following documents are required:

  • A detailed business plan of the company: Activities of the bank; Countries in which the bank is looking to invest; The percentage of ownership by the shareholders; The details of the ultimate beneficial owners (chart may help if many); Any other useful information to support the application.
  • CVs of all the directors
  • Full contact details of the directors 
  • Bank reference for all the beneficial owners
  • Clear certified passport copies of all beneficial owners
  • Proof of addresses (utility bills)
  • Business or legal reference for the beneficial owners
  • Legal document for the shareholding companies (articles, certificate of incorporation etc)
  • Latest audited financial statements for all shareholding companies (if any)
  • A certificate to prove that the Directors and beneficial owners do not have a criminal record

Furthermore, all companies with banking licenses are required to submit their annual accounts to the Comoros International Banking Authority within 3 months of the year end.

SWIFT membership can be applied for as Licenses are authorized bt the Comoros Central Bank