Key Takeaways
- Foreign-owned companies in Seychelles may fall within AML/CFT obligations depending on whether their activity makes them a reporting entity.
- Supervision is shared across the FIU, CBS, and FSA, each overseeing AML compliance within its remit.
- Reporting entities must carry out customer due diligence, monitor relationships on an ongoing basis, and keep records as required.
- Failure to meet AML duties can lead to penalties and enforcement, making a compliance officer and the registered agent central to staying compliant.
AML and KYC Obligations in Seychelles: An Overview
AML/KYC in Seychelles is the set of anti-money-laundering and customer due diligence duties that licensed financial and professional businesses must meet when they take on and service customers. These obligations are real and actively supervised, but who carries them matters: most are borne by regulated businesses, not by the ordinary International Business Company (IBC) that foreign owners typically hold. The governing law is the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, supported by detailed regulations and supervised by three authorities. The primary legislation is published free of charge on SeyLII.
This article explains how the regime works, who counts as a reporting entity, what due diligence and reporting are demanded, and where a foreign-owned company actually sits within it. It is most relevant to non-resident owners and advisers responsible for a Seychelles IBC or a licensed entity such as a fiduciary, fund, or securities business.
The Legal Framework: The AML/CFT Act 2020 and Regulations
The cornerstone is the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020, in force since 28 August 2020. It replaced earlier legislation and pulled the obligations of regulated businesses into a single statute, consolidated in published form as Cap. 251. There is no separate KYC statute; every customer due diligence duty sits inside this Act.
The Act is paired with the AML/CFT Regulations 2020, effective the same day, which set out the practical mechanics of due diligence, record-keeping, and threshold reporting. Several supporting instruments operate alongside it, including amendment regulations from 2022, the Prevention of Proliferation Financing Regulations 2021, and the Prevention of Terrorism Act 2004 for terrorist-financing duties.
A newer addition is the Virtual Asset Service Providers Act 2024, which created a dedicated framework for virtual asset businesses. The Beneficial Ownership Act 2020 runs in parallel and is touched on later in this guide.
The Financial Intelligence Unit (FIU) publishes consolidated text of both the Act and the Regulations updated to 17 January 2025, and the Central Bank of Seychelles maintains an equivalent set on its regulatory framework page. Seychelles is not on the FATF grey list, though it has been within the Eastern and Southern Africa Anti-Money Laundering Group's enhanced follow-up process since 2018.
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Who Supervises AML Compliance: The FIU, CBS, and FSA
Supervision is divided among three bodies, each responsible for a defined slice of the regulated sector. Knowing which one oversees your entity tells you which guidance and circulars apply.
| Supervisor | Oversees |
|---|---|
| Financial Intelligence Unit (FIU) | Lawyers, notaries, accountants, auditors, real estate agents, high-value dealers, dealers in precious metals and stones, Seychelles Pension Fund; receives all STRs; holds the beneficial ownership database |
| Central Bank of Seychelles (CBS) | Banks, credit unions, payment service providers, leasing companies |
| Financial Services Authority (FSA) | Securities dealers, insurers, fund administrators, fiduciary service providers, and VASPs (from September 2024) |
The FIU is the national centre for receiving and analysing suspicious transaction reports. It is an administrative unit: it does not investigate or prosecute, but acts as the channel between the financial sector and law enforcement. All reporting entities must register with it.
The Central Bank issues its own guidelines on suspicious transaction reporting, compliance officer applications, institutional risk assessment, and threshold reporting. The Financial Services Authority publishes circulars covering compliance officer obligations and the annual compliance report. National policy is coordinated through an inter-agency committee that links the three regulators with law enforcement.
Which Businesses Are Reporting Entities
The Act binds all persons in the sense that anyone who forms a suspicion of money laundering in the course of business has a duty to disclose it. Its full regulatory weight, however, falls only on businesses in the regulated sector, known as reporting entities.
Reporting entities include banks and credit institutions, payment service providers, bureaux de change, securities dealers, fund managers, insurers, fiduciary service providers, lawyers, accountants, notaries, real estate agents, and gambling operators. Virtual asset service providers joined this population on 1 September 2024. They are listed across three parts of the Act's schedules according to which authority supervises them.
This distinction is the single most important point for a foreign owner.
A Seychelles IBC that carries on no regulated activity is not itself a reporting entity and holds no primary AML/CFT duties. Its registered agent, a licensed fiduciary provider, is the reporting entity and performs due diligence on the IBC as its customer.
Every reporting entity must register with the FIU, appoint a compliance officer and an alternate, and run a documented AML/CFT programme built on an institutional risk assessment. If your Seychelles vehicle is a plain holding or trading IBC, those duties belong to your agent, not to you.
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Customer Due Diligence and KYC Requirements
The statute speaks of "customer due diligence" rather than KYC, but the substance is what most owners recognise as KYC. A reporting entity must verify a customer's identity when it opens a relationship, when it handles an occasional transaction above the relevant threshold, and whenever suspicion arises regardless of value.
For an individual, the file must capture full legal name, date of birth, address, and a government-issued photo identity document. For a company, it must record the registered name, registration number, legal form, registered address, and the identity of those who own or control it.
Beneficial-ownership identification runs through all of this: the entity must trace the natural persons who ultimately own or control a customer, looking past nominee layers and corporate chains. Where the customer is a Seychelles IBC, the standard document set includes the Certificate of Incorporation from the Registrar, the Memorandum and Articles of Association, and the current Register of Directors.
Due diligence is not finished at onboarding. Files must be refreshed across the life of the relationship, particularly when ownership, activity, or risk profile shifts. For a non-resident owner, this is why your registered agent will periodically ask for updated passports, proof of address, or source-of-funds evidence even years after incorporation.
Enhanced and Simplified Due Diligence
Risk drives the depth of scrutiny. Where the money-laundering or terrorist-financing risk is higher, a reporting entity must apply enhanced due diligence, gathering extra information on the customer, the source of funds and wealth, and the purpose behind transactions.
Certain factors automatically raise the bar. Relationships formed in unusual circumstances, customers based in or transacting through high-risk geographies, and structures used purely to hold assets all point toward enhanced measures. A connection to a FATF-listed jurisdiction triggers enhanced due diligence with senior management sign-off.
Politically exposed persons attract mandatory enhanced treatment. The Act defines these as holders of prominent public positions, whether in Seychelles or abroad, including heads of state, senior politicians, senior officials, and senior executives of state-owned enterprises. Their close associates and family typically fall within the same net.
At the other end, simplified due diligence is available where risk is genuinely low. The entity may scale back the extent or timing of its measures, but it must keep enough information to prove the low-risk assessment, continue to meet the Act's core requirements, and carry on monitoring for unusual activity.
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Ongoing Monitoring of Business Relationships
A reporting entity cannot treat compliance as a one-time gate. It must maintain internal controls, written procedures, and staff training that detect and prevent money laundering on a continuing basis.
Practical monitoring duties include keeping beneficial ownership data current, refreshing identity documents as they expire, recording changes in activity, and seeking further evidence when transaction patterns drift from the stated purpose. Anything inconsistent with a customer's known profile must be flagged for review.
For Central Bank-supervised institutions, dedicated directives address periodic review of due diligence and the use of the national digital identity for verification. Reporting entities are also expected to subject their own AML programmes to independent audit, on a risk-based cadence rather than a fixed statutory interval.
AML Record-Keeping Requirements
Records sit at the heart of any examination, because a supervisor judges compliance by what an entity can produce. Customer identification, transaction histories, and due diligence steps must all be retained for long enough to reconstruct events and prove that the rules were followed.
The governing benchmark is a seven-year retention floor, set under Section 47 of the AML/CFT Act for transaction and CDD records and echoed by Section 5 of the Beneficial Ownership Act 2020 for beneficial-ownership and member data. Records must stay accessible and retrievable on request by the supervisor.
A reporting entity that stops operating must, on the date it ceases, hand over all records required under Section 47 to its supervisory authority in electronic format.
For owners of an IBC, the beneficial-ownership register is filed centrally with the FIU and is not open to the public. Combined with nominee layers common to such structures, this keeps ultimate ownership confidential while still reachable by authorities.
Suspicious Transaction Reporting and Threshold Reporting
Two distinct reporting streams run to the FIU, and they are not interchangeable. The first is the suspicious transaction report; the second is a set of fixed-threshold reports.
Under Section 48, a reporting entity must file a suspicious transaction report whenever there are reasonable grounds to suspect a transaction is linked to money laundering or terrorist financing. This duty applies no matter how small the sum. Warning a customer that such a report has been made is a criminal offence.
Threshold reporting works on hard numbers rather than judgment.
| Report type | Trigger |
|---|---|
| Cash Transaction Threshold Report (CTTR) | Cash transactions of SCR 50,000 or more, individually or aggregated by the same customer |
| Wire Transfer Threshold Report (WTTR) | Wire transfers at or above the applicable threshold set in CBS/FIU guidelines |
| Cross-border cash declaration | Any person physically moving SCR 50,000 or more into or out of the country must declare to Customs (Section 75) |
A single transaction can be both above a threshold and suspicious. In that case both reports are required; one does not substitute for the other. The thresholds and templates were updated by FIU Circular No. 4 of 2021, and submissions run through the FIU's electronic platform. The exact monetary figure for wire transfer reports should be confirmed against the current CBS and FIU guidelines.
The Compliance Officer and Internal Controls
Every reporting entity must name a compliance officer and an alternate under Section 34 of the Act. The role anchors the entity's internal control framework and is the named point of accountability to the supervisor.
One feature matters for foreign owners of licensed businesses: the compliance officer must at all times be resident in Seychelles. For Central Bank-supervised entities, the officer needs at least one year of relevant experience in compliance, AML, or risk management, knowledge of the legal requirements, and familiarity with industry standards.
- Approval of a compliance officer and alternate must be processed within 60 days, excluding the applicant's own processing time
- A supervisor may suspend or withdraw approval, with an appeals mechanism under Section 62(3)
- Compliance officers must attend supervisor-recommended AML/CFT training at least once every two years
- Each entity's institutional risk assessment must address customer, product and service, geographic, and delivery-channel risk
An annual compliance report is required as well. FSA Circular No. 10 of 2024 sets out the obligation for FSA-supervised entities, and Central Bank-supervised entities carry an equivalent duty.
The Role of the Registered Agent in AML Compliance
For most foreign owners, the registered agent is where AML/KYC actually lives. Every Seychelles IBC must keep a registered agent licensed by the FSA under the Registered Agent and Trustee Licensing Act, and that agent is a full reporting entity under the AML/CFT regime.
The agent holds the company's statutory registers, files beneficial-ownership data to the FIU database, and runs the compliance pipeline that the company itself is not equipped to run. It conducts due diligence and, where needed, enhanced due diligence on the owner, directors, and ultimate beneficial owners, both at onboarding and on an ongoing basis.
Under the Beneficial Ownership Act 2020, every Seychelles legal person, including an IBC, must maintain a register of beneficial owners and submit the data through its agent to the private FIU database. Submissions must include the National Identification Number and any Tax Identification Number for each beneficial owner and nominee. These details stay confidential and are not publicly accessible.
The FIU issued Circular No. 2 of 2024 as a final compliance notice, signalling firmer enforcement after uneven results. Penalties on a registered agent under the Beneficial Ownership Act can reach SCR 50,000 for each failure to comply with an inspection or disclosure notice, which is why agents are exacting about the documents they request from you.
Penalties and Enforcement for Non-Compliance
Enforcement sits on three tracks. Supervisors can impose administrative sanctions, including fines, warnings, temporary suspension of operations, and revocation of an operating licence. Serious conduct can lead to criminal prosecution carrying imprisonment, substantial fines, and asset freezing or seizure, and civil penalties may apply on top.
Several specific exposures are worth flagging for company owners. A registered agent faces fines up to SCR 50,000 for each beneficial-ownership inspection or disclosure failure, and the 2024 IBC Act amendments allow a penalty of up to US$10,000 for failing to update the Register of Members on time. An IBC that does not pay its licence fee within 180 days is struck off and dissolved.
Virtual asset providers that operated before 1 September 2024 and missed the 31 December 2024 application deadline face heavy penalties, including being struck off the Registry. The FSA has already taken public enforcement action against an unlicensed virtual asset operator.
The Act's section-by-section monetary figures are not all reproduced in secondary materials. Where a precise penalty matters, the consolidated AML/CFT Act (Cap. 251, to January 2025) should be consulted directly.
Conclusion
The practical truth for most non-resident owners is reassuring: if your Seychelles vehicle is an ordinary IBC with no regulated activity, the AML/KYC burden rests on your registered agent, not on you. Your real obligation is to feed that agent accurate, current identity and ownership documents, on time, so they can keep their own filings clean.
The calculation changes entirely if you hold a licensed entity such as a fiduciary, fund, securities, or virtual asset business, where the full reporting-entity machinery applies directly. Decide which side of that line your structure falls on before anything else, because it determines whether AML compliance is a document-supply task or an operational programme you must build and staff.
How Expanship Can Help Your Business in Seychelles
Expanship acts as your point of contact for AML/KYC in Seychelles, handling the due diligence and beneficial-ownership filings that your registered agent must complete and keeping your customer file current as ownership or activity changes. The same team manages the wider obligations a foreign-owned entity carries, from formation through ongoing maintenance.
- Company formation and IBC setup
- Registered agent and registered office services
- Ongoing compliance and filing management
- Accounting and bookkeeping support
- Economic-substance and beneficial-ownership assistance
- Banking introductions
To discuss your structure and its AML obligations, contact Expanship Seychelles.
Frequently Asked Questions
Generally no. An IBC that carries on no regulated activity is not a reporting entity under the AML/CFT Act 2020 and holds no primary AML duties; the obligations rest with its licensed registered agent, who performs due diligence on the company as a customer.
For individual owners the agent collects full legal name, date of birth, address, and a government-issued photo ID, plus source-of-funds evidence where risk warrants it. For the company itself the standard set includes the Certificate of Incorporation, the Memorandum and Articles of Association, and the current Register of Directors.
The retention floor is seven years. This applies under Section 47 of the AML/CFT Act for transaction and due diligence records and under Section 5 of the Beneficial Ownership Act 2020 for beneficial-ownership and member data.
A reporting entity must file a suspicious transaction report with the FIU whenever there are reasonable grounds to suspect a link to money laundering or terrorist financing, regardless of the amount. Cash and wire transactions of SCR 50,000 or more also trigger separate threshold reports, and a transaction can require both.
No. The register is filed through the registered agent to a central FIU database that is not accessible to the public, though it remains available to authorities on request.
Only if it is a reporting entity such as a licensed fiduciary, fund, or virtual asset business. Those entities must appoint a compliance officer and an alternate, and the compliance officer must be resident in Seychelles at all times; an ordinary IBC has no such requirement.
Legal Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal, tax, or professional advice. While we strive to ensure the accuracy and timeliness of the content, laws and regulations are subject to change, and the application of laws can vary widely based on specific facts and circumstances.
Readers should not act upon this information without seeking professional counsel tailored to their individual situation. Expanship and its authors disclaim any liability for actions taken or not taken based on the content of this article.
For specific advice regarding your business setup, compliance requirements, or any legal matters, please consult with qualified legal and tax professionals in the relevant jurisdiction.
