An Anjouan brokerage license authorizes you to promote, host, and operate an FX and CFD trading platform, and to offer brokerage in securities, commodities, and select crypto‑related services. It is issued by the Anjouan Offshore Finance Authority under Government Notices No. 004/2005 and No. 5/2005, remains valid until its stated expiry, and can be revoked or automatically canceled for prohibited activities. A typical setup requires incorporating a local IBC, passing fit‑and‑proper checks on all controllers, appointing a compliance officer/MLRO, and implementing AML/KYC policies and training. Providers often market low capital needs, no local office or directors, and light taxes for non‑resident activity, with a practical timeline of about 2–3 months from incorporation to go‑live. Note that the Central Bank of the Comoros has publicly stated it does not recognize AOFA as a financial regulator, so recognition, banking, and cross‑border permissions must be assessed before relying on this license.
What an Anjouan brokerage license actually covers
If you strip away the buzzwords, the Anjouan brokerage license authorizes you to promote, host, and operate an FX trading and speculation platform, and to intermediate across a wide set of financial instruments. That means you can broker spot FX, CFDs, commodities, equities, and other regulated securities. In practice, the scope is broad enough to power a modern multi‑asset platform.
The license is aligned with the island’s “International Brokerage and Asset Management” framework. Beyond plain execution, it can cover advisory services to corporate and private clients, receiving and transmitting orders, executing on behalf of clients with their funds, and even proprietary trading for the company’s own account. That blend is why founders use Anjouan to launch agile brokerages and wealth plays without the weight of big‑market licensing.
The crypto and custody dimension
The framework explicitly allows consulting on crypto, managing crypto portfolios, and offering safekeeping, custody, and nominee services for digital assets. That matters if your roadmap includes tokenized products or crypto‑CFDs. As always, delivery versus derivatives makes a legal difference in many countries, so align product design with target-market laws.
Custody is not a free pass. Treat client funds and client assets as sacred. Build segregation and reconciliation into your processes from day one. If you touch custody, you carry fiduciary‑like expectations whether or not the word appears in your license.
Who should consider Anjouan and who should not
Anjouan suits founders who value speed to market, careful cost control, and regulatory flexibility. If you’re launching a cross‑border FX/CFD platform, a white‑label business, or a lean asset management shop for non‑resident clients, this jurisdiction can be a workable starting point. Many teams use it to pilot product‑market fit before graduating into heavier regimes.
It is not a magic key to every market. If your goal is retail mass‑market in the EU, UK, Australia, or the US, you will still need to respect each local perimeter. Use Anjouan to stand up infrastructure, then layer on additional licenses or partnerships where you actively target regulated audiences. Think sequencing, not substitution.
Regulatory fine print you must not skip
An Anjouan license has a defined life. It expires on the date shown on the instrument, or earlier if your company ceases to be incorporated on the island. It can also be revoked by the Anjouan Offshore Finance Authority, and it is subject to amendments made to Government Notice No. 004 of 2005 and Government Notice No. 5 of 2005. Put renewal reminders into governance calendars and track legislative updates instead of learning about them the hard way.
The company’s approved purpose can be wide. It includes advising on investments and FX, receiving and transmitting client orders, executing transactions with client money, managing portfolios across securities and crypto, holding client assets with custody and nominee services, arranging distributions of securities on a guaranteed or non‑guaranteed basis, proprietary trading, securities lending and borrowing, and short selling where rules allow. Map each activity to policies and controls before you advertise it.
Prohibited and restricted activities
Being an International Company comes with fences. You may not run banking, insurance, gambling, or sea and air transport unless separately licensed. You may not own immovable property locally, beyond leasing premises to conduct permitted business. You must maintain at least one member at all times. And you may not invite the Anjouan public to subscribe to your shares or debentures.
Crucially, “doing business in Anjouan” is narrowly defined. Holding board or member meetings on the island, maintaining books and records there, leasing office space, hiring local service providers, making deposits with a licensed brokerage, or dealing with other IBCs does not, in itself, count as carrying on business with the local public. Use that to structure operations without tripping local‑market rules.
Automatic cancellation and personal liability
If you act contrary to Anjouan law, the license can be automatically canceled without notice. After cancellation, individuals who manage the business may be held personally, jointly, and severally liable for acts and omissions of the company. Build a compliance culture that treats revocation as a real risk, not a paragraph in the small print.
When you add crypto or leverage, control failures compound quickly. Document decision‑making, record client communications, and enforce change control on trading systems. Personal liability starts feeling very personal when audit trails are thin.
Company build‑out: from IBC to live platform
Every journey starts with an International Business Company (IBC). Incorporate in Anjouan, secure a legal address, appoint directors and members, and establish beneficial ownership records. While a local director is not typically mandated, you will still need local registered agent services and a clean governance file.
Your licensing application rides on a well‑prepared dossier. Expect background checks on founders, directors, shareholders, authorized signatories, and ultimate beneficial owners. You will file corporate documents, fit‑and‑proper declarations, business plans, financial projections, AML/CFT policies, KYC procedures, and client‑asset controls. Treat the AML officer/MLRO appointment as a core hire, not an afterthought.
Compliance staffing and training
Appoint a competent compliance officer with authority and access. Provide EU‑standard AML training if your team will interface with European PSPs or vendors. Create a compliance calendar that covers transaction monitoring, sanctions screening, KYC refresh cycles, and suspicious activity reports. If you manage portfolios, add best‑execution and conflict‑of‑interest registers.
Indicative timelines and expectations
Founders often complete incorporation in a few weeks and the license in roughly one to two months after a clean, complete filing. Banking and PSP onboarding can add several weeks. Plan for a 8–12 week runway to live operations, and longer if your file is incomplete. The fastest teams start compliance documentation in parallel with incorporation.
Operating model choices: B2C, B2B, and asset management
A retail brokerage (B2C) will focus on onboarding flows, appropriateness tests, complaint handling, and leverage risk warnings. Your supervision model should include surveillance for abusive trading patterns, bonus abuse, and affiliate fraud. Client communications must be plain, accurate, and consistent with your T&Cs.
A B2B model can serve introducing brokers, smaller FX firms, and fintechs with liquidity, white labels, and technology. You will still be evaluated on risk management, segregation of flows, and the clarity of your contractual stack. When you offer credit lines or margin to partners, embed covenants and real‑time risk triggers.
If you offer discretionary portfolio management, you are stepping into a higher duty of care. A proper investment policy statement, risk profiling, rebalancing rules, and trade blotters become non‑negotiable. Crypto portfolios need valuation policies, wallet governance, and chain‑analysis procedures for tainted asset screening.
Tax and banking realities
Anjouan markets a tax‑light posture for non‑resident business. Many founders like the simplicity and low overhead. But low tax does not mean low substance everywhere. If management and control sit in another country, or if your team works from the EU or UK, you may trigger tax presence there. Align board locations, key‑man decisions, and transfer pricing with your real operating footprint.
Banking and payment acceptance are the make‑or‑break. Some banks and card acquirers treat offshore FX/CFD with caution. Mitigate by pairing your Anjouan entity with EU or EEA PSPs, adding a payment orchestration layer, and keeping chargeback ratios under control. Provide enhanced documentation: license, AML manual, audited financials once available, and detailed flow of funds. Do not expect a Tier‑1 bank on day one; graduate toward it with clean history.
Marketing and cross‑border compliance
Your license does not grant passporting into major markets. If you target the EU, MiFID II marketing rules apply. In the UK, the financial promotion regime bites even when you are offshore. In Australia, ASIC is vigilant on “reverse solicitation theater.” The US is a hard no for retail off‑exchange FX/CFD without proper registration. Build geofencing, content gating, and tailored disclosures.
Client onboarding must reflect that stance. Apply country blocks, verify residence, collect enhanced KYC for higher‑risk geographies, and avoid local language marketing in restricted states. Train affiliates to stay inside your promotion policy or cut them fast. One rogue banner can poison PSP relationships.
Governance, risk, and AML playbook
Your AML/KYC program should be risk‑based and documented. Screen names and wallets against sanctions, PEP, and adverse media lists. Calibrate thresholds to your product mix; high‑velocity CFD accounts are not the same as buy‑and‑hold portfolios. Keep audit trails of every decision. Regulators and banks love good records more than great speeches.
On client money and custody, separate house funds from client funds, reconcile daily, and lock down payment permissions with dual control. If you hold crypto, implement multi‑sig or MPC wallets, cold storage for long‑term balances, and tested key‑recovery procedures. Disclose clearly how you safeguard assets and how you handle forks, airdrops, and staking (if any).
Common misconceptions and red flags
An Anjouan license is not a universal hall pass. It gives you a structured home for your brokerage, but you still need to comply with the laws of every country where you acquire clients. Build that into your sales scripts and your term sheets with partners.
You will read polarized takes online. Some hail Anjouan as a nimble haven; others question the weight of island‑level authorizations in the wider Union of the Comoros framework or cite critical statements from national bodies in adjacent sectors. The responsible path is simple: perform independent legal due diligence, verify the current status of issuing authorities, and document your basis for reliance before you invest.
A pragmatic roadmap and cost drivers
Start with clarity on the model: B2C, B2B, or discretionary management. Incorporate your IBC, scope your anjouan brokerage license application, and draft AML/KYC and client‑asset policies that match your actual platform. In parallel, open dialogues with at least two PSPs and one bank, and collect the heavy documentation they will request.
Your biggest cost drivers will be compliance labor, trading technology, liquidity, card acquiring, and dispute handling. Licensing and incorporation are only part of the bill. The firms that last keep complaints low, disclosures honest, leverage reasonable, and ops disciplined. That’s how an offshore launch becomes a durable global business, not a seasonal experiment.
| Aspect | Key facts | Actionable notes |
|---|---|---|
| What the anjouan brokerage license is | An authorization issued in Anjouan to operate a brokerage platform and related investment services. It is often marketed as the “Anjouan International Brokerage and Asset Management License.” | Use this license to run multi‑asset brokerage and asset management from an offshore base. Confirm exact scope stated on your specific license certificate. |
| Legal basis and authority | Commonly linked to Government Notice No. 004 of 2005 and Government Notice No. 5 of 2005 and administered by the Anjouan Offshore Finance Authority (AOFA). | Ask your agent for the current legal instruments referenced in your license and keep copies on file for counterparty due diligence. |
| Recognition caveats | Public reports note that the Central Bank of the Comoros has previously disavowed island‑level offshore financial licensing (including references to AOFA) in certain contexts. | Before onboarding PSPs, banks, or large partners, provide them with your full license pack and seek written confirmation of acceptability. Expect enhanced DD and varied risk appetites. |
| Corporate form | International Business Company (IBC) registered in Anjouan. | Retain a local registered agent and a legal address. Keep your Constitution/Articles aligned with licensed activities. |
| License scope (core) | • Promote, host, and operate an FX trading and speculation platform • Brokerage of shares, CFDs, FX, commodities, and other regulated securities | Scope is broad for brokerage. Keep product lists and T&Cs consistent with your license wording. |
| License scope (extended, if stated on license) | • Investment advice and investor consultations • Receiving and transmitting orders • Executing client orders using client funds • Portfolio management (including crypto assets) • Holding client funds/securities; safekeeping, custody, nominee (including crypto) • Proprietary trading • Distribution of securities on non‑guaranteed and guaranteed (underwriting) basis • Securities lending/borrowing, client margin, short selling as permitted | Only offer extended services if they appear in your individual license or accompanying schedules. Build controls for custody, segregation, and margin risk. |
| Activities not covered or prohibited | • Banking, insurance, sea/air transport, gambling, and other specifically licensed sectors are out of scope • The IBC should not conduct local business in Anjouan (other than permitted brokerage) or own immovable property (beyond leased office space) | If you need adjacent permissions (e.g., money services, gaming), obtain separate licenses where required. Keep local activity limited per IBC rules. |
| Validity and renewal | Valid until the date shown on the license or until the company ceases to be incorporated in Anjouan, unless revoked earlier by AOFA. | Diary annual renewal and keep company in good standing (filings, fees, agent). Track any amendments to governing notices. |
| Automatic cancellation triggers | Automatic cancellation without notice can occur if the company breaches Anjouan laws/regulations. | Maintain a legal watch, audit trail, and board oversight. Stop restricted activities immediately if rules change. |
| Liability after cancellation | Managers can be personally, jointly, and severally liable for acts/omissions/violations occurring after cancellation. | Implement a wind‑down plan and cease regulated activity at once if a cancellation risk appears. Notify clients and counterparties promptly. |
| Doing business in anjouan vs abroad | The IBC is generally restricted from doing domestic business in Anjouan; activities aimed at non‑residents are permitted. The following do not count as “doing business” locally: leasing premises, holding meetings, maintaining books, working with local service providers, deposits with licensed brokerages, transacting with other IBCs, issuing/holding IBC securities. | Keep client base non‑resident. Use Anjouan only for necessary corporate presence, record‑keeping, and professional services. |
| Geography and client targeting | Marketed as global. In practice, onboarding residents of jurisdictions that require local authorization (e.g., US, UK, EU, AU, CA, JP) without that authorization is risky. | Maintain a restricted‑countries list, geo‑blocking, and KYC address checks. Tailor marketing disclaimers by jurisdiction. |
| Tax posture | Frequently promoted as no corporate income tax for foreign IBCs in Anjouan. | Obtain written tax advice for your structure, revenue flows, and substance. Consider home‑country CFC, GILTI, and economic‑substance rules. |
| Substance and presence | Often marketed as no requirement for a physical office or local directors. A local registered office/agent is standard. | Even if not mandated, keep governance robust: named directors, minutes, policies, and a reachable compliance function. |
| AML/CFT and compliance | • Appoint a Compliance Officer/MLRO • Adopt AML/KYC policies and risk assessment • Screen UBOs, directors, and key staff • Ongoing monitoring, sanctions screening, SARs where applicable | Use EU/UK‑grade AML templates. Train staff (documented). Calibrate EDD for PEPs, crypto, and high‑risk geos. |
| Client money and assets | License may allow holding client funds and assets, including crypto, plus safekeeping/custody and nominee services. | Maintain segregated accounts, daily reconciliations, safeguarding letters, and clear client agreements. Consider PI insurance. |
| Trading features | Margin/leverage, short selling, securities lending, and proprietary trading may be permitted if listed in the license. | Implement margin policies, liquidation rules, stress tests, and conflict‑of‑interest controls for prop vs client flow. |
| Crypto coverage | Consulting, trading, custody/nominee, and crypto‑derivatives issuance are described within the broader license framework by some providers. | Add crypto‑specific risk, custody tech audits, chain‑analysis tools, and wallet governance (MPC/multisig). |
| Documentation for application | • Passports and proof of address for shareholders, directors, UBOs • CVs and “fit & proper” forms • Corporate documents (IBC) • Business plan, financial projections, organizational chart • AML/KYC/CTF policies, risk assessment, compliance manual • IT/security, order‑handling, best‑execution, complaints policy | Prepare clean, consistent packs. Translate and notarize/apostille where needed. Disclose any adverse history early. |
| Capital and insurance | No fixed statutory minimum capital is publicly standardized across sources; “adequate capital” is expected. PI insurance is advisable. | Set internal capital targets (e.g., X months of OPEX + market/credit/operational buffers). Maintain a capital policy and early‑warning triggers. |
| Audits, records, and reporting | Keep books and records. Meetings and records may be held/maintained in Anjouan. | Retain trade logs, KYC files, reconciliations, and board minutes. Prepare for ad‑hoc regulator or bank queries. |
| Timelines | Provider timelines often cite: incorporation ~2 weeks; license review ~3–6 weeks after a complete file; corporate bank/PSP ~4 weeks; total ~2–3 months end‑to‑end. | Build contingency for clarifications. Parallel‑process bank/PSP onboarding after preliminary license comfort. |
| Costs | Marketed as cost‑effective vs EU/UK. Fees usually split into incorporation, application, annual renewal, and advisory. Exact pricing is “on request.” | Budget for legal, compliance setup, AML courses, tech, PI insurance, PSP reserves, and ongoing audits/reviews. |
| Packages often offered by providers | • IBC setup and legal address • Assistance with the Anjouan brokerage and asset management license • Draft AML/KYC policies • Website legal docs • Help hiring AML Officer/MLRO • AML training (EU‑based) | Validate deliverables, version control on policies, and named accountability. Ensure documents match your actual business model. |
| PSPs and banking | Acceptance varies. Some banks/PSPs favor stricter jurisdictions. Additional scrutiny for CFDs, leverage, and crypto. | Approach multiple PSPs. Provide enhanced compliance pack: license, org chart, policies, KYC samples, flow of funds, GEOs, and marketing. |
| Complaints and dispute handling | No widely known, independent ombudsman process. Complaints typically handled by the licensee and escalated to the licensing authority as applicable. | Publish a clear, time‑bound complaints policy. Keep a case log. Offer ADR/mediation options for credibility. |
| Marketing and disclosures | Avoid implying passporting or recognition in onshore markets. Disclose risks on leverage/CFDs/crypto, execution model, fees, and conflicts. | Use plain‑English risk warnings. Include key information docs, best‑execution summary, and order‑handling policy on your site. |
| Change management | Material changes (controllers, directors, business model, products, key policies) should be notified and may require prior approval. | Maintain a regulatory change log. Pre‑clear new assets (e.g., new crypto pairs) and leverage limits. |
| Revocation risks | Breach of laws/regulations, unsafe practices, misleading conduct, or operating outside license scope can trigger suspension or revocation. | Run quarterly compliance reviews. Conduct annual board attestations against license scope and policies. |
| Best‑fit use cases | • Startup FX/CFD brokerage • White‑label platform operators • Boutique asset managers with offshore client base • Prop trading with client services | Align your target markets to jurisdictions where an anjouan brokerage license is acceptable to counterparties. |
| Not ideal for | • Onshore retail in the US, UK, EU, AU, CA, JP without local authorization • Firms needing guaranteed Tier‑1 banking or universal PSP access | If your plan is heavy EU/US retail, consider parallel licensing in a recognized onshore hub. |
| Infrastructure | Anjouan service ecosystem offers cloud, dedicated racks/servers, VPN, email, and hosting services marketed to brokerages. | Host trading infrastructure redundantly. Document vendor due diligence, SLAs, and cybersecurity controls (ISO/NIST‑aligned). |
| First 90‑day compliance roadmap | • Finalize governance, appoint MLRO • Approve AML/CTF and risk frameworks • KYC tool selection and sanctions screening • Client asset segregation setup • PSP/bank onboarding pack • Complaints and disclosures live on website • Staff AML training | Keep board minutes for all approvals. Test client money reconciliations and leverage/liquidation logic in UAT before go‑live. |
| Renewal checklist | • Pay annual fees • Refresh FIT & PROPER declarations • Update AML risk assessment • Test BCP/DR and cyber controls • Review restricted‑countries list • Reconfirm PSP/bank comfort | Submit renewals early. Attach updates on business model, volumes, markets, and capital position. |
| Common mistakes | • Marketing into restricted jurisdictions • Offering products not covered by license • Poor client money segregation • Weak KYC and sanctions controls • Over‑promising “global recognition” to clients/PSPs | Map every product/feature to a policy control and a license clause. Keep conservative GEO targeting and leverage caps at launch. |