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Cryptocurrency Licensing: Thailand vs. Portugal and the Comoros

In terms of the regulatory process, cryptocurrency licensing requires careful assessment of legal requirements and crypto market regulations in different jurisdictions. The regulatory bodies in charge will only issue a crypto license to the applicant after it has met all the said regulatory requirements. In the comparison below, we will look at how you can get a cryptocurrency exchange license in Thailand, Portugal, and the Comoros. We will compare the application procedures, the costs, and the timelines for each jurisdiction.


Cryptocurrency licensing in Thailand

In 2018, Thai authorities implemented the Digital Asset Business Emergency Decree to legally regulate businesses that deal with digital assets. These businesses fall into 3 main types:

  • Virtual Currency Dealers: These are businesses that buy and sell cryptocurrencies on their own. Although virtual currency dealers work with cryptocurrency exchanges, they are not part of the latter.
  • Cryptocurrency Exchanges: The above platforms let people exchange and trade cryptocurrencies while following the rules of the U.S. Securities and Exchange Commission (SEC).
  • Digital Asset Brokers: Whether individuals or legal entities, digital asset brokers offer brokerage or agency services, enabling others to engage in the exchange or trading of virtual assets.

Willing to work with crypto in Thailand? You will have to register with the Securities and Exchange Commission (SEC), the authority in charge of digital assets.

To apply for a crypto license, please fill out an application form and pay a fee of EUR 800. License costs per se depend on your business type:

  • EUR 65,000 for a cryptocurrency exchange
  • EUR 40,000 for a digital asset broker
  • EUR 27,000 for a virtual currency dealer.

Here’s what you need to do to secure your cryptocurrency license in Thailand:

  • Register a company in Thailand that follows local laws.
  • Appoint directors and executives with excellent reputations and qualifications that meet the SEC standards.
  • Have the authorized capital that is high enough for your business. The amount depends on the type of business you have:
    • For a cryptocurrency exchange, you need EUR 1,300,000, along with a deposit of EUR 650,000 in a Thai bank.
    • For a digital asset broker, you should have EUR 650,000, along with a deposit of EUR 375,000 in a Thai bank.
    • For a virtual currency dealer, the required amount is EUR 130,000, along with a deposit of EUR 65,000 in a Thai bank.

The documents you’ll have to prepare and submit to obtain your cryptocurrency license in Thailand are listed below:

  • detailed business plan
  • documents that prove the identity and background of your company directors and owners
  • financial statement of your business that is verified and approved by an auditor.
  • audited statement of your company’s financial position
  • documents verifying  your company’s performance potential and functionality
  • plan outlining your company’s strategy for protecting and safeguarding the personal data of its customers from the corresponding risks or threats.

You also need to duly fill out an application form and send it to the relevant authorities. A company seeking a cryptocurrency license in Thailand must prove through documentation its compliance with SEC requirements. All your documents shall be translated into English. FYI: It can take from 5 to 12 months for the authorities to process your application and issue the license to you.


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Cryptocurrency licensing in Portugal

The Central Bank of Portugal, also known as Banco de Portugal, is the regulatory authority for cryptocurrency activities in the country. With its approval, companies may offer various services related to digital currencies:

  • exchanging cryptocurrencies for traditional fiat currencies and vice versa
  • securely storing digital assets for their customers
  • making crypto transactions
  • trading digital assets on the market.

Apart from being registered in Portugal, companies about to operate a cryptocurrency business in the jurisdiction shall have a real (physical) office there. Another requirement is to ensure that their directors complete training on fraud prevention and anti-money laundering (AML/KYC). 

Take a look at what documents you must submit to apply for a cryptocurrency license in Portugal:

  • detailed business plan
  • risk management scheme
  • evidence of the company’s financial solvency
  • CVs of the company’s key executives (with no criminal records in them)
  • documents that verify the company’s local presence, like a lease agreement, a tax registration certificate, and a special NIF number.

The costs of registering a cryptocurrency business in Madeira or Portugal start from EUR 35,000. The processing time is about 6 months.

Cryptocurrency licensing in the Comoros

The Comoros is a union of 3 autonomous islands: Moheli, Anjouan, and Grande Comore. It also claims the French territory of Mayotte as its 4th island. Each island has its own constitution, president or governor, and parliament, as provided for under the Comorian constitution.

Depending on the island they operate on, cryptocurrency businesses in the Comoros follow different rules, provisions, and licensing requirements. Moheli and Anjouan are the preferred islands for cryptocurrency startups, as they offer more favorable conditions.

In Moheli, the Mwali International Services Authority (MISA) is the regulatory body that licenses and oversees cryptocurrency businesses in the Comoros. In charge of the Moheli-incorporated crypto businesses, the above authority has a lenient approach with minimal oversight and simple legal requirements for cryptocurrency license applicants at present.

In Anjouan, the Anjouan Offshore Finance Authority (AOFA) is the only body to regulate the local financial sector, including cryptocurrency businesses. Compared to Moheli, Anjouan is a more reputable offshore financial center.

The Comoros International Banking Authority issues a special international broker’s license to interested parties. The latter extends to operations with digital cryptocurrencies. With this regulatory document, license holders are free to operate in the global digital cryptocurrency market.

With a cryptocurrency license, companies can engage in various financial activities:

  • fund management
  • custodial services
  • trusteeship
  • international portfolio management
  • deposit operations
  • currency exchange
  • securities offerings
  • securities custody, and more.

With a Comoros cryptocurrency license, a company has the right to offer services related to digital currencies and cryptocurrencies:

  • cryptocurrency trading
  • cryptocurrency exchange
  • storage of digital currencies
  • cryptocurrency account opening
  • contracts for difference (CFD)
  • accepting cryptocurrency deposits
  • granting cryptocurrency loans.

No requirements are set as to having an office or hiring local staff in the Comoros. 

These are the documents a company will have to submit to apply for a cryptocurrency license in the Comoros:

  • detailed business plan
  • CVs of all the company directors
  • complete contact details for all company directors
  • bank references for all beneficial owners
  • notarized passport copies for all beneficial owners
  • proof of address for all beneficial owners, e.g., utility bills
  • latest audited financial statements
  • certificates of no criminal record for company directors.

The minimum authorized capital for a company is EUR 50,000 (about KMF 24 million). The figure may vary depending on the company’s license type and scale of operations. The company’s directors and key personnel have to go through a rigorous screening process, which includes a comprehensive background check. This ensures that the regulatory body can trust the individuals in charge of the cryptocurrency business and that the latter have no criminal record.

The license is issued under Act 17-008/01/CFC/AU 2017 on Comoros Finance Commission, Law No. 17-008/AU, as amended and/or supplemented. 

Compared to similar licenses issued in other jurisdictions, the Comoros cryptocurrency license is more affordable, as it starts from EUR 39,750. This makes it an attractive option for cryptocurrency startups and investors.

Interested in setting up a cryptocurrency exchange in a reliable offshore jurisdiction? Don’t hesitate to talk to the International Wealth team about how you can obtain a cryptocurrency license the easiest way!

Why choose the Comoros for crypto licensing?

The Comoros Islands offer a favorable tax system for offshore companies. There, they do not pay corporate income tax or capital gains tax on the sale of any assets, including currency and financial instruments. Neither income tax on dividends nor VAT on financial services like Forex trading are imposed in the jurisdiction.

With no currency controls in the Comoros, brokers can easily transfer funds in and out of the country without facing any regulatory obstacles, currency conversion costs, or compliance requirements. This gives such brokers unrestricted access to international financial markets and allows them to use multiple currencies, assets, and trading opportunities.

Cryptocurrency exchanges in the Comoros follow these rules:

  • They have to implement anti-money laundering and counter-terrorism financing (AML/CFT) measures, which include verifying the identity and background of their customers (KYC).
  • In the Comoros, cryptocurrency exchanges are obliged to safeguard client funds by keeping them separate from transaction accounts, so that the assets are protected in case of insolvency or financial difficulties.
  • Cryptocurrency exchanges in the Comoros will establish mechanisms for dispute resolution, which can help resolve conflicts between the cryptocurrency exchange and its clients.
  • To ensure transparency and accountability, they submit financial reports and undergo audits.

The International Brokerage License for offshore operations is one of the most desirable licenses for cryptocurrency businesses in the Comoros. It allows them to trade in futures, contracts for difference (CFD), and other related financial services. Issued by MISA in Moheli, it is recognized by international banks, which makes it easier for cryptocurrency businesses to partner with them.

Learn how you can open a corporate bank account with access to cryptocurrency in the Comoros as an international company, broker, or trader.

Summing up

Jurisdiction for cryptocurrency license registrationCosts associated with obtaining a cryptocurrency licenseProcessing time for a cryptocurrency licenseAuthorized capital requirements for cryptocurrency companiesPermitted activities
ThailandEUR 27,000 to EUR 65,0006 to 12 monthsEUR 130,000 to EUR 1,300,000 + deposit with a Thai bankPermitted activities vary with each license type
Portugalfrom EUR 35,0006 months or longerNo requirementsCryptocurrency exchange,
storage of digital currencies, cryptocurrency trading
Comorosfrom EUR 39,7501 to 2 monthsFinancial guarantees of EUR 50,000 or moreGeneral license

With a cryptocurrency license in the Comoros, you will also benefit from a lower tax burden. Willing to get yours soon? Get in touch with International Wealth experts to make this plan a reality.

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