Offshore Licences: What They Actually Are

An offshore registration authorises one named legal entity to carry on one named activity in one place. It does not cover a group, a brand or an evaluation contract. At the far end of the range, the Banque Centrale des Comores has published a communiqué describing the Anjouan and Mwali licensing bodies as “structures fictives”, asserting exclusive competence over financial licensing, and referring them to three prosecutors.

The word “licensed” carries no information on its own. Four narrow questions do: which authority, which licence category, what minimum capital that category requires, and which legal entity in the group holds it. The answers below come from the regulators’ own published rules, for ten jurisdictions, and mark the places where a widely repeated figure does not match the rulebook it is attributed to.

The cluster hub sets out the backdrop: no jurisdiction has created a licensing regime for prop-trading evaluations. No authority below licenses the evaluation product. These regimes license brokerage — dealing, broking, market access — carried on by a company that may or may not be the one a challenge buyer contracts with.

This is a research summary, not legal advice.

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What has the Comoros central bank actually published?

The Banque Centrale des Comores has issued a communiqué headed “sur l’exercice illégal d’activités bancaires offshores”. It names, as bodies purporting to issue authorisations, Mwali International Services Authority (M.I.S.A.), the Anjouan Offshore Finance Authority, Anjouan Corporates Services, Comoros Services LTD and the Comoros International Banking Authority — and calls them “structures fictives”.

The operative sentences, in the central bank’s own words: licensing banks and financial institutions operating in the Comoros is within the BCC’s “ressort exclusif”, and any other such structure and its acts are “illégales et passibles de poursuites”. And: “La Banque Centrale des Comores a d’ailleurs déjà saisi les parquets de Moroni, Mutsamudu et Mohéli contre ces prétendues autorités” — it has already referred the matter to the prosecutors of Moroni, Mutsamudu and Mohéli.

The legal basis it gives is article 9 of the Constitution, under which all questions concerning banks and financial institutions fall to the government of the Union rather than to the individual islands, together with article 18 of banking law no. 13-003/AU of 12 June 2013. The communiqué adds that to date no offshore authorisation has been issued at all. It is published on the central bank’s own site and was republished by the Comorian Ministry of Finance on 10 December 2025.

That is what a central bank has said about a set of licensing bodies. It is not a statement about any company holding a document issued by them, and nothing here should be read as one. Separately: we found no addressed warning against those bodies as institutions from the FCA, ASIC, BaFin, CONSOB, CySEC, FSMA or IOSCO — foreign regulators act against named firms, not registries.

Why the title defect matters

The Anjouan body relies on an “Offshore Finance Authority Act 003 of 2005”, passed during the period of Anjouan’s separatist “independence” between 1997 and 2008. An ABC News investigation published on 31 December 2025 recorded the secretary-general of the Comorian central bank’s financial intelligence unit, Ait-Ahmed Djalim, saying such structures “have in reality no physical or legal existence in the territory of the Union of the Comoros”. That is press reporting of an official statement rather than a regulator’s own publication, and is cited as such.

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What does each regime authorise, and at what capital?

Figures checked against the linked documents on 31 July 2026. Each row gives the category relevant to a firm dealing in leveraged retail products; the DIFC figures are from DFSA PIB 3.6.2.

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Which circulating figures does the regulators’ own paperwork correct?

Numbers repeated across offshore-formation marketing do not always survive contact with the rulebooks they are attributed to.

The BVI “USD 100,000”. The figure commonly circulated for a BVI Category 1 investment business licence is USD 100,000. The regulator’s own published requirement is that there is no fixed numeric minimum at all. Sections 8(1) and 9(1) of the Securities and Investment Business Act make the requirement conditional — they apply “where the Regulatory Code prescribes a minimum capital resource requirement” — and the Code prescribes numeric floors only for trust companies ($250,000), company managers ($25,000) and money services businesses ($10,000), not for investment business. Section 181 of the Regulatory Code requires instead capital “adequate to support its investment business, taking into account the nature, size, complexity, structure and diversity” of it, with the FSC able to impose more, including a regulatory deposit, and stating that it will not assess capital adequacy against best-case projections. The absence of a threshold is not a low threshold. It is an unpredictable one.

The Vanuatu “VT 5,000,000 minimum capital”. Section 5 of the Financial Dealers Licensing Act [CAP 70] provides that the Commissioner shall not grant a principal’s licence unless VT 5,000,000 “has been, and remains, deposited by the applicant… with the Commissioner”. That is a bond held by the regulator, not shareholders’ funds in the business. Vanuatu sets no express capital figure at all.

The Labuan “RM 500,000”. Superseded. The Guidelines on the Establishment of Money Broking Business in Labuan IBFC dated 9 September 2024 replaced the 2017 edition; paragraph 7.1 sets RM 1,000,000 for money and FX broking, or RM 1,500,000 where digital assets are included, with a two-year transition for existing licensees.

The Cyprus “€730,000” and Malta “€125,000 / €730,000”. Both are pre-IFD. Under Article 9 of the Investment Firms Directive as implemented in Cyprus by Law 165(I)/2021, the scale is €750,000 for dealing on own account, €150,000 for a firm holding client money, and €75,000 for one that may not. The MFSA moved Maltese Investment Services Rules onto the same scale in Annex A of September 2025.

One name has also changed: Federal Decree-Law No. 32 of 2025 provides that the UAE Capital Market Authority replaces the Securities and Commodities Authority as its legal successor, with effect from 1 January 2026.

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Why is Labuan structurally unsuitable for retail CFD?

Labuan is the clearest case of a real, functioning regime that cannot host the product regardless of how much capital an applicant has. Four provisions of the September 2024 Guidelines do the work, and they are mechanical rather than discretionary.

1. Scope of the instrument. Paragraph 6.1(i) places outside the licence any “contract for difference (CFD) of which the underlying assets are other than products traded in the money and foreign exchange market”. CFDs on indices, single equities, commodities and crypto therefore fall outside the permission.
2. Agency only. Paragraph 6.1(iii) and footnote 4 require the licensee to “act as a mediator and strictly not permitted to act as a principal”, and state it is “not permitted to speculate or engage in proprietary trading”. The licensee cannot be the counterparty to its client’s trade, which removes the B-book model entirely.
3. Client mix. Paragraph 7.6 sets the target client base as institutional and high-net-worth, and the Labuan FSA FAQ states that retail clients should make up less than half of the portfolio.
4. Leverage. The same paragraph caps FX leverage at 100:1 and digital assets at 1:1.

The alternative category, the Labuan Securities Licensee at RM 150,000, is closed off by paragraph 1.3, under which it may not hold client money or assets.

So the regime with the most prescriptive client-money protection in this register — paragraph 9.4 requires separate accounts, prohibits commingling, sets withdrawal at three business days or less, requires monthly reconciliation and makes client funds immune from the broker’s own debts — is precisely the regime the product cannot use.

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What does St Vincent and the Grenadines authorise?

Very little, and that is the substance of it. Since its memorandum of January 2023, the SVG Financial Services Authority does not issue forex or CFD authorisations; it asks entities carrying on such business to produce a licence from another jurisdiction. Incorporating a business company or LLC there takes days and costs about a hundred US dollars a year. There is no capital requirement, no substance requirement and no client-money rule — because there is no licence.

What makes SVG structurally interesting is not the shell but where it sits in a group. Blueberry Funded’s evaluation terms state that “These Terms and Conditions are agreed between you and Blueberry Markets (SVG) LLC trading as BlueberryFunded (the Company)” — a Kingstown company, registration number 2090 LLC 2022. The group’s Australian licence belongs to a different company, Blueberry Australia Pty Ltd, ABN 67 646 513 797, AFSL 535887, which is not a party to that contract; and Australia appears on the product’s restricted-territories list alongside Cuba, Iran, North Korea, Russia, the United States, Syria, Myanmar and Somalia. This is the two-entity structure that runs across the industry: the contracting entity sits where nothing is licensed, and the licence sits with a company the buyer never contracts with. Axi’s allocation programme is likewise documented as available only to clients of AxiTrader LLC, another SVG entity.

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What happened in the 2026 migration to Mauritius?

Four firms obtained Mauritius FSC licences during 2026 and moved off Comoros registrations: Funding Pips (Investment Dealer, June 2026), FNmarkets (FundedNext), Hola Prime and Finotive Markets. This is reported by Finance Magnates in “The Comoros Was Just a Layover: Prop Firms Are Landing in Mauritius” — trade-press reporting of licence grants rather than a regulator publication. We state no reason for the moves beyond the fact that they happened.

What the destination requires is on the record. SEC-2.1B carries MUR 1,000,000 of stated unimpaired capital — low by European standards — but the FSC’s licensing criteria attach substance to it: two resident directors, a main bank account in Mauritius, accounting and audit performed in Mauritius, two full-time officers, a compliance officer and an MLRO with an independent deputy. GN No. 119 of 2026 raised the annual fee from USD 2,500 to USD 3,400 from 1 July 2026.

Costs are rising across the field. Labuan’s floor moved from RM 500,000 to RM 1,000,000 in September 2024, with its annual fee scheduled to reach USD 5,000 by 2028; Vanuatu’s annual fees rose roughly fivefold under Act No. 5 of 2024, taking a class A+B+C renewal to VT 3,000,000.

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What a licence tells you, and what it does not

A licence is an attribute of a company, not of a website. The only question that resolves anything is which legal entity the terms name as counterparty, and whether that entity appears in a regulator’s public register.

No regime in this register licenses an evaluation. Where a group holds a dealer licence, that licence authorises dealing by the licensed entity; it says nothing about the contract a challenge buyer signs, which is a separate question from whether what is called a funded account involves any real position. Three widely quoted capital figures are wrong at source: BVI has no numeric minimum, Vanuatu’s VT 5,000,000 is a deposit with the Commissioner, and Labuan’s RM 500,000 was superseded in September 2024.

None of that changes what a buyer holds. The consumer position is set out separately in what remains after the financial-services protections do not apply.

The hardest published fact in this register belongs to a central bank. The BCC’s communiqué describes the Anjouan and Mwali bodies as “structures fictives”, asserts exclusive competence over the licensing of banks and financial institutions in the Comoros, and reports referrals to the prosecutors of Moroni, Mutsamudu and Mohéli.

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Written by the upme.com research desk. Every capital figure above comes from the regulator’s own rule, statutory instrument or licensing criteria and links to it; where a figure is commonly repeated but the rulebook says otherwise, we print both. Figures are as of 31 July 2026. Corrections to the address on our sourcing page. Nothing here is investment or legal advice.

Sources

Every factual claim above is drawn from one of the documents below. Where a document has been superseded since the date given, tell us and the piece is corrected with a dated line.

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