The pitch arrives by direct message. A brokerage licence from an island authority in the Comoros, issued in a matter of days, no local office, no capital to deposit, no examination of your risk framework. Founders who have just been quoted a multi year process elsewhere find it hard to ignore. Then the first payment provider asks who the regulator is, and the conversation becomes very short.
What is actually being issued
The Union of the Comoros is a federal republic made up of autonomous islands. Licences marketed to brokers have been issued in the name of island level bodies, most visibly under the Mwali, or Mohéli, banner and previously under an Anjouan one. The documents look like licences: a certificate, a number, an authority name, sometimes a register you can search on a website built for the purpose.
The dispute is about authority. Whether an autonomous island body may lawfully grant international financial services licences, and whether such licences are recognised by the national institutions of the Comoros including the central bank, has been publicly contested. There is a long documented history of Comorian offshore banking licences being disowned by national authorities and of foreign regulators warning about entities presenting them. That history is the reason a compliance officer treats one of these certificates as unverified rather than as a licence, and it is why we will not describe the arrangement here as regulation.
This is a description of a contested arrangement, not advice, and the position may have changed since publication. Verify any claim about who may issue licences in the Comoros with Comorian counsel and with the national authorities directly, not with the agent selling the licence.
The test that matters is not legality, it is acceptance
Set aside the constitutional argument, because a founder cannot settle it. Ask instead what happens when the certificate is presented to each counterparty a broker needs.
A bank runs the jurisdiction through its country risk model and the authority through its list of recognised supervisors. If the supervisor is not on the list, the file usually cannot proceed regardless of how the analyst feels about it, because the internal policy is written in terms of recognised regulators. An acquirer wants to place the merchant in a category and satisfy the card scheme's rules on regulated activity, which typically means evidence of authorisation in the jurisdictions where the customers live, not where the certificate was printed. A liquidity provider is required by its own regulator to understand its counterparty, and a disputed licence gives it a reason to decline that costs it nothing.
Advertising platforms restrict financial services and generally require an authorisation declaration tied to the targeted country. App store review of trading applications applies a comparable standard. None of these gates is passed by a certificate that the bank could not verify. This is the mechanism described in regulated versus unregulated brokers: the market prices supervision, and where supervision cannot be confirmed the price is exclusion.
What the client loses
Everything a licence exists to provide. There is no capital requirement anyone verifies, so nothing stands behind client balances. There is no client money rule anyone inspects, so segregation is whatever the firm chooses to do. There is no complaints mechanism, no ombudsman, no compensation scheme, and realistically no forum where a retail client in another country can enforce anything. If the firm stops answering emails, the client's practical options are close to zero.
Brokers using these certificates rarely explain that. They put a licence number on the website and let the reader assume it means what the word normally means. Clients can protect themselves by treating any unfamiliar authority as unproven until they find it on a recognised list, the habit we set out in how to check a broker licence.
Why the market for these certificates exists
Because the alternatives are genuinely expensive and slow. A supervised regime asks for capital scaled to the permissions, a compliance officer, audited accounts, local substance and an application process measured in quarters rather than days. Faced with that, some founders reach for the cheapest thing that produces a number for the footer. It is an understandable decision and a bad one, because the saved cost reappears immediately as failed payment applications, higher processing fees where anything is accepted at all, no advertising channels, and a business that cannot be sold or partnered with.
If the budget genuinely does not stretch to a supervised licence, the honest options are to narrow the product to something that is not a regulated activity, to operate as a technology or introducing business under someone else's authorisation, or to wait and raise more. Firms that want an offshore base with a real supervisor and a public register should look at the regimes compared in offshore broker licences and at broker licence costs compared, then choose on total cost of ownership rather than headline price.
The practical rule
Before you buy any licence, run the acceptance test in advance. Ask a payment provider, a liquidity provider and a banking partner, in writing, whether they onboard firms holding that specific authorisation. Their answers cost nothing and arrive in days. A licence that no counterparty in your supply chain will accept is not a licence in any way that matters to your business, and no software fixes it. SINGUARD builds platforms, CRMs and client portals; the authorisation behind them has to be real, and leveraged trading remains high risk for every client on the other side of it.
"When a licence costs less than a month of compliance salary, you are not buying supervision. You are buying a certificate, and the bank knows it."
— Alex Onta, Executive Director, SINGUARD
Key Takeaways
- Licences marketed under the Mwali and Anjouan names come from island level bodies whose authority to issue them has been publicly disputed.
- Bank and PSP policies are written around recognised supervisors, so an unverifiable authority stops the file before any human judgement applies.
- Clients get none of what a licence normally provides: no verified capital, no inspected segregation, no complaints or compensation route.
- Run the acceptance test first: ask your bank, PSP and liquidity provider in writing whether they onboard firms with that licence.
Frequently Asked Questions
Is a Mwali or Anjouan licence a real regulatory licence?
The certificates exist and are issued in the name of island level bodies in the Comoros, but whether those bodies have authority to grant international financial services licences has been publicly contested, and there is a documented history of national authorities disowning Comorian offshore licences. Treat it as unverified until you have confirmation from Comorian national authorities and your own counsel.
Will banks and payment providers accept one?
Compliance policies are usually written around lists of recognised supervisors. An authority that does not appear on such a list generally means the application cannot proceed, whatever the individual reviewer thinks. Acquirers separately want evidence of authorisation where the customers live. Ask each counterparty in writing before you buy anything.
What should a founder do if a supervised licence is out of budget?
Narrow the activity to something that is not a regulated service, operate under another firm's authorisation as a technology or introducing partner, or delay launch until the capital exists. Those routes are slower. Buying an unverifiable certificate is not faster in practice, because the payment, banking and advertising gates stay shut and the business cannot grow through them.
About the Author
Alex Onta is an Executive Director at SINGUARD. He built eTrader, the terminal, the mobile apps, eTrader Broker, Copytrading, Business and Community, along with the worldwide clustered-server infrastructure it all runs on, with his brother Roman Onta helping on the design, and he leads that division today. Together with Roman he builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals, and the two of them carry worldwide compliance, payment processing and international business structuring side by side. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.