Concept
An offshore broker licence is permission from the regulator of an international financial centre to deal in securities and derivatives as a business from that jurisdiction — above all in contracts for difference (CFDs) and foreign exchange contracts.
In Seychelles the licence is granted by the Financial Services Authority (FSA) under the Securities Act 2007; in the British Virgin Islands (BVI) by the Financial Services Commission (FSC) under the Securities and Investment Business Act 2010 (SIBA); in the Cayman Islands by the Cayman Islands Monetary Authority (CIMA) under the Securities Investment Business Act, also abbreviated SIBA. All three laws prohibit the business without the regulator's permission and treat CFDs as regulated instruments.
Why a broker takes an offshore licence
It suits brokers selling CFDs and FX to clients in many countries, giving them a supervised status, a public register entry and a product the statute names expressly. An ordinary offshore company offers none of this: a Seychelles IBC, a BVI company or a Cayman exempted company cannot provide regulated services without separate authorisation (see “Offshore Companies” and “Seychelles IBC”).
In 2018 IOSCO noted a growing number of unlicensed sellers of CFDs, rolling spot forex and binary options. Some jurisdictions licensed only firms serving their own residents, so firms located there to target foreign investors, whose regulators struggled to pursue them. Seychelles, the BVI and Cayman do require a licence, and the BVI statute expressly catches a BVI company doing investment business abroad (SIBA s.4).
What the licence does not give
Three supervisory models
The three jurisdictions regulate brokers differently, and the model determines what business can be built on the licence.
Seychelles: retail dealer
A securities dealer licence with dedicated rules for retail CFDs: appropriateness testing, cash-only margin, negative balance protection. US$100,000 capital, two residents in management or compliance, 233 dealers on the register.
BVI: licence by category
Licences by type of activity, capital set by the FSC case by case, and an authorised representative on the islands in place of local management. FX contracts have needed a licence since 2025.
Cayman: two statuses
A licence as broker-dealer, market maker, adviser, arranger or manager, or registration without a licence, open only to group, high net worth, sophisticated or overseas-regulated business. 45 licensees and 1,337 registered persons.
Key parameters
The parameters come from the statutes, regulations and regulators' policies as of September 2026.
| Parameter | Seychelles | BVI | Cayman |
|---|---|---|---|
| Regulator and law | FSA; Securities Act 2007 as amended by Act 18 of 2024 | FSC; SIBA 2010 (Revised Edition 2020), Regulatory Code | CIMA; SIBA (2020 Revision) as amended by Act 21 of 2024 |
| Licence types | Securities dealer, full or restricted; separate representative licence | Categories 1–7; a broker needs Category 1 (agent or principal) and/or 2 | Broker-dealer, market maker, adviser, arranger, manager; restricted — up to 20 clients; registration instead of a licence |
| CFDs and FX | CFDs on any underlying, including crypto-assets | CFDs; currency exchange contracts since 02.01.2025 | CFDs; virtual assets representing securities or derivatives of them |
| Capital | Paid-up capital of US$100,000 held in a bank account | No general minimum; set by the FSC case by case | Broker-dealer: financial resources above the greater of ¼ of annual expenditure and $100,000, plus risk requirements |
| Regulatory fees | Application US$3,000, annual fee US$6,000 | Category 1A, 1B or 2: application US$2,200, licence US$3,300 on grant and yearly | Broker-dealer: CI$1,000 application, CI$10,000 on grant and yearly |
| People on the ground | Two directors, one a full-time resident; two residents among directors, managers or compliance officers at all times; an office | Two directors, two managing individuals; resident director if the FSC requires; authorised representative unless managed locally | At least two directors; CIMA expects physical presence and five years' senior experience for directors |
| Clients | Retail and professional (from US$1 million net assets); client countries notified to the FSA | Retail under a written agreement; professional investor — declared net worth above US$1 million | Licensee — client countries set out in the application; registered person — group, high net worth and sophisticated clients, or overseas-regulated business |
| Safeguards | Liability insurance; for retail CFDs — cash margin and negative balance protection | Professional indemnity and fidelity insurance | Financial resources above the requirement; monthly reporting by broker-dealers |
Seychelles regulates retail CFD business in detail, the BVI leave capital to the regulator, and Cayman's market splits into a few licensees and many times more registered persons.
Seychelles: the securities dealer licence
Dealing in securities in Seychelles as a business, or holding oneself out as doing so, requires a securities dealer's licence (Securities Act s.45(1)). Under paragraph 8 of Schedule 1, securities include rights under a CFD or any contract meant to secure a profit or avoid a loss from price or index fluctuations, so a retail CFD and FX broker needs this licence. Dealing without it is an offence: a company faces a fine of US$200,000, an individual US$100,000 or two years' imprisonment (s.63(1)).
CFDs on crypto-assets fall under the same licence. In Circular No. 3 of 28.02.2025 the FSA stated that such CFDs are not a virtual asset service: a dealer approved for CFDs may offer them on any underlying. Exchanges, brokerage and wallets for virtual assets need a separate licence under the Virtual Asset Service Providers Act 2024, with a separate FSA list.
The circular also sizes the market: in December 2024 Seychelles had 190 licensed dealers, 187 approved for CFDs and 105 (56%) offering CFDs on virtual assets. The FSA expects them to assess clients before onboarding, disclose volatility and loss risk prominently and not target promotions at retail clients intentionally. As of 29.09.2026 the FSA register lists 233 dealers.
Who can hold the licence
Section 46(4) sets the conditions of grant, including:
- a company incorporated in Seychelles or in a recognised jurisdiction;
- at least two natural-person directors, one of them a resident employed full time;
- at least one employee licensed as a representative;
- paid-up capital at or above the prescribed minimum;
- insurance covering the liability of the licensee, its officers and employees (s.73);
- fitness and propriety of the applicant itself;
- premises suitable for keeping records.
The FSA's application guidelines (version of 05.03.2026) add detail. The dealer appoints a compliance officer under s.23 of the Financial Services Authority Act 2013, who may sit on the board and is vetted by personal questionnaire. The office, held by title deed, lease or approved sublease, must be furnished, with a local telephone line, internet, at least one computer and space for records. The application includes an insurance quotation. A licensee's compliance functions are covered in “Compliance Stack”.
The FSA may also grant a restricted licence: capping the number of clients, limiting the licensee to clients named in the licence, or setting a minimum investment per client (s.46(3)).
The 2024 reform
A package of Act 18 of 2024 and S.I. 117–120 of 2024 took effect on 01.01.2025. Firms licensed earlier had until 30.06.2026 to comply (FSA Circular No. 1 of 2025); the FSA has announced no extension, so the rules now apply to all.
| What changed | Requirement |
|---|---|
| Capital | US$100,000 instead of US$50,000, kept at all times with a bank licensed in Seychelles or in an FSA-recognised jurisdiction (S.I. 117 of 2024) |
| Residents | At least two resident fit and proper individuals in Seychelles at all times: directors, compliance officers or managers (s.64(n)) |
| Who is resident | Resides and is domiciled in Seychelles, or is present there 183 days or more in 12 months |
| Complaints | A resident, who may be the compliance officer, handles complaints under an FSA-approved procedure and keeps a database |
| Client classification | Retail and professional; professional from US$1 million net assets excluding the home and fiat holdings |
| Retail CFDs | Appropriateness assessment, cash-only margin, client liability limited to the funds in the account |
| Advertising | Risk warnings; on websites and apps, fixed at the top of the screen |
| Trade names | Names and domains approved by the FSA and listed on the licence and its website |
| Client countries | Notice to the FSA of each country and assurance that the country allows its residents to deal with the licensee |
The reform gave the Seychelles licence people on the ground and rules for retail business. The retail CFD rules, in the amended Conduct of Business Regulations (S.I. 119 of 2024), cover leveraged CFDs, leveraged rolling spot forex and options on them but set no numerical leverage limits. The advertising rules in S.I. 118 of 2024 still warn of unlimited losses beyond the deposit, although a retail client's liability is now capped at the funds in the account.
For a broker with clients abroad, the key change is regulation 34 on worldwide operations. The licensee's board declares to the FSA that it will comply with the laws of every country where it offers services and assures the FSA that those countries allow their residents to deal with it; the FSA may demand written evidence of permission to solicit clients there.
Fees, timing and tax
Fees are set by S.I. 120 of 2024 and apply from 01.01.2025, when licences also became perpetual: by 31 January each year the licensee pays the annual fee and lodges a compliance certificate.
| Charge | Amount |
|---|---|
| Dealer application | US$3,000 |
| Dealer annual fee | US$6,000; in the year of grant US$6,000, 4,500, 3,000 or 1,500 by quarter |
| Representative | US$500 application, US$750 a year |
| Each additional domain or trade name | US$500 application, US$1,000 a year |
| Approval of a share issue or transfer | US$500 per shareholder involved (from 01.01.2026) |
The FSA guidelines of 05.03.2026 still quote US$2,500 a year, but S.I. 120 of 2024 fixes the fee, and Circular No. 1 of 2025 confirms US$6,000. Any issue or transfer of shares in a licensee, including of the beneficial interest, requires the FSA's prior approval (s.60(1)), and since 2026 the fee is charged per shareholder. How regulators vet the buyer of a licensed company is covered in “Change of Control and Buying a Licensed Company”.
The FSA's non-binding service standard is 30 working days from a complete application. An incomplete application is returned and may be resubmitted within three months; after that, a new application and fee are required.
According to the FSA, a dealer can pay business tax of 1.5% on gross income and no withholding tax on dividends and interest if it meets the substantial activity requirements: middle and back office run from a physical office in Seychelles, even with the front office abroad. The logic of such requirements is covered in “Substance”.
BVI: the SIBA licence
Under SIBA s.4 no one may carry on investment business in or from within the BVI without a licence. A firm does so if it occupies premises in the BVI or solicits a person there, and a BVI business company doing investment business abroad is deemed to do it from within. An unlicensed BVI company (see “BVI Company”) therefore cannot broker even for foreign clients.
A licence covers only the Schedule 3 categories specified on it (s.5).
| Category | Activity |
|---|---|
| 1 | Dealing in investments: sub-category A as agent, B as principal |
| 2 | Arranging deals in investments |
| 3 | Investment management |
| 4 | Investment advice |
| 5 | Custody of investments |
| 6 | Administration of investments |
| 7 | Operating an investment exchange |
A broker needs Category 1 and/or 2. CFDs are investments under Schedule 1, and since 02.01.2025 so are contracts to exchange one currency for another (S.I. 42 of 2024, brought into force by S.I. 77 of 2024). From that date an FX broker in the BVI also needs a licence.
Capital and people
The FSC grants a licence only if the applicant will hold the required capital, its directors, senior officers and significant owners are fit and proper, and its organisation, management and financial resources suit the business (s.6(2)). There is no general minimum: the Regulatory Code calls prescribing one premature, and the FSC sets requirements per licensee in light of its business and risks (s.181).
The board keeps capital adequate to the business, and the licensee carries professional indemnity and fidelity insurance or explains to the FSC in writing why such cover is not appropriate (s.182).
The people requirements allow a model without management on the islands.
| Requirement | Content |
|---|---|
| Directors | At least two; a BVI-resident director only where the FSC considers it necessary (Code s.19) |
| Management | At least two fit and proper individuals, each an executive director or senior manager (s.22) |
| Compliance officer | A fit and proper individual, an employee of the licensee unless exempted, with adequate independence and resources (ss.42–43) |
| Authorised representative | A BVI company or partnership, or a BVI resident, certified by the FSC; not needed with significant management presence (SIBA ss.64–66) |
| Changes of people and owners | FSC prior approval to appoint directors and senior officers and to acquire or dispose of an interest of 10% or more (SIBA ss.10–11) |
The authorised representative is the intermediary between the licensee and the FSC, accepting service of documents and keeping prescribed records. How regulators vet owners and managers is covered in “Qualifying Holdings and Fit & Proper”.
Clients, fees and the VASP boundary
Under the Code, a professional investor is an individual who has signed a declaration of net worth above US$1 million, alone or jointly with a spouse, and consented to that status. A retail customer may be served only under a written agreement signed by both parties (ss.178, 186).
S.I. 5 of 2023, in force since 01.04.2023, sets for each of sub-categories 1A, 1B and Category 2 an application fee of US$2,200 and a licence fee of US$3,300 on grant and at each annual renewal. The 2025 amendments did not change these items.
Virtual asset services require separate registration under the Virtual Assets Service Providers Act 2022, in force since 01.02.2023. A registered provider that offers only such services does not also need a SIBA licence.
Cayman: licence or registration
Cayman offers a broker two statuses.
Licence
Broker-dealer, market maker, adviser, arranger or manager; a restricted licence serves up to 20 clients. CIMA expects physical presence; a broker-dealer's financial resources start at $100,000 and its fee is CI$10,000 a year. 45 licensees.
Registration
Own group only, high net worth and sophisticated clients, or business supervised by a recognised overseas regulator. Two individual directors or a corporate director, an annual declaration, CI$6,000 a year. 1,337 registered persons.
Securities investment business may not be carried on without a licence, registration or exemption under SIBA. Securities include rights under CFDs and, since a 2020 amendment, virtual assets that represent or convert into securities or are derivatives of them. Breach is an offence punishable by a fine of $100,000 and one year's imprisonment, plus $10,000 for each day it continues (s.5). Neither SIBA nor the 2003 capital regulations say whether their “$” amounts are Cayman or US dollars; CIMA quotes its fees in Cayman dollars (CI$).
Act 21 of 2024, in force since 01.01.2025, wrote the licence categories into SIBA — broker-dealer, market maker, securities adviser, securities arranger and securities manager — and the application states which are sought and whether the licence is to be restricted. A restricted licence allows at most 20 clients and is not available to market makers or arrangers.
Registered person instead of a licence
The registered person status replaced the excluded person category: according to CIMA, after 15.01.2020 an excluded person could continue only if re-registered or licensed. Registration is available in three cases (SIBA Schedule 4):
- the firm serves exclusively companies of its own group;
- the firm serves exclusively sophisticated or high net worth persons, or companies, partnerships and trusts owned by them, and has a registered office or place of business in Cayman serviced by a licensed provider;
- the firm is regulated for that business by a recognised overseas regulator where the business is conducted.
A high net worth person under SIBA s.2 is an individual with net worth of at least $800,000 or any person with total assets of at least $4,000,000. A sophisticated person includes an experienced participant in transactions of at least $80,000 each. Mass retail brokerage under the second route is therefore not possible.
A registered person must satisfy CIMA that its shareholders, directors and senior officers are fit and proper, have at least two individual directors or one corporate director, and file an annual declaration with the annual fee by 15 January.
CIMA statistics show 1,337 registered persons in Q1 2026; in 2018, still under the excluded person category, the same line showed 2,926.
Licensee requirements
CIMA grants a licence if the applicant can comply with SIBA and the anti-money laundering regulations, has skilled personnel, facilities and records, and fit and proper senior officers and managers; a licensee company has at least two directors (ss.6(5), 15(1)). CIMA's 2018 licensing policy adds expectations not found in the statute: a physical presence in Cayman through which the business operates and, generally, at least five years' senior-level experience for each director. CIMA may let some material functions be outsourced abroad but can require them in the Islands.
Capital takes the form of financial resources: under the 2003 Regulations a licensee must at all times hold them above a requirement built as follows.
| Element | Amount |
|---|---|
| Base: broker-dealer, market maker, manager | Greater of ¼ of annual expenditure and $100,000 |
| Base: other licensees | Greater of ¼ of annual expenditure and $15,000 |
| Add-ons | Counterparty and position risk requirements |
| Broker-dealer reporting | Monthly |
How a base of a quarter of expenditure works is shown in “Regulatory Capital”.
Fees are set by the Licence Applications and Fees Regulations (2026 Revision); US-dollar equivalents are from CIMA's fee schedule of 01.01.2026.
| Status | Application | Grant | Annual |
|---|---|---|---|
| Broker-dealer | CI$1,000 | CI$10,000 | CI$10,000 (≈US$12,195) |
| Securities arranger | CI$1,000 | CI$5,000 | CI$5,000 |
| Restricted licence | CI$1,000 | CI$5,000 | CI$5,000 |
| Registered person | — | CI$6,000 | CI$6,000 (≈US$7,317) |
What the regulator wants to see from a broker is shown by CIMA's application checklist (August 2025). Among other things, the applicant discloses six items:
- the countries where it intends to target clients;
- the funding methods for client accounts: wire transfer, credit card, cryptocurrency;
- its proposed bankers, custodians and liquidity providers;
- confirmation that legal opinions will be obtained before targeting clients;
- mechanisms restricting access for clients in prohibited jurisdictions;
- a separate website distinguishing the applicant from its group.
The VASP boundary
Since 01.01.2025 CIMA must exempt from SIBA a trading platform conducting securities investment business using virtual assets only, and may exempt a person that needs a licence under the VASP Act. Virtual asset custody and operating a trading platform have required a VASP licence since 01.04.2025; registration alone is not enough. The company layer is covered in “Cayman Islands Company”, and crypto regimes are compared in “Crypto Licences by Jurisdiction”.
Vanuatu: a live regime with tighter conditions
The Vanuatu Financial Services Commission (VFSC) still issues financial dealer licences under the Financial Dealers Licensing Act (2026 consolidated edition), on terms that have become stricter. Classes are cumulative: Class C (derivatives) requires A and B, Class D (digital assets) requires A to C. The licensee is run by a licensed manager with an office in Vanuatu who lives there six months a year; the applicant keeps VT5,000,000 on deposit, and the annual fee is VT500,000. The VFSC register lists 66 active licences as of 29.09.2026: 51 granted in 2022–2023, 15 since 2024.
Popular, but it ends badly
The scheme looks like this: a broker with an offshore licence solicits retail clients in the EU or the UK, offers them CFDs with leverage above the European limits and puts a clause in the contract saying the client came of their own accord. EU and UK law has a separate rule for each element of it. The European limits were set by ESMA Decision 2018/796.
| CFD underlying | ESMA initial margin | Leverage limit |
|---|---|---|
| Major currency pairs | 3.33% | 30:1 |
| Major indices, non-major currency pairs, gold | 5% | 20:1 |
| Other commodities and indices | 10% | 10:1 |
| Shares and other underlyings | 20% | 5:1 |
| Cryptocurrencies | 50% | 2:1 |
From 01.08.2018 the decision allowed CFDs to be sold to retail clients only with this margin, a margin close-out, negative balance protection, no bonuses and a standard risk warning.
ESMA based the measures on national studies: in a 2017 CySEC sample, 76% of about 290,000 accounts made a loss, and the standard warning puts the share of loss-making retail accounts at 74% to 89%. The decision prohibited knowingly participating in circumvention, including by acting as a substitute for the CFD provider.
ESMA's temporary measures lapsed in 2019 and were replaced by permanent national ones: since 01.08.2019 BaFin has banned the marketing, distribution and sale of CFDs to retail clients in Germany without the same conditions, expressly including rolling spot forex. The Cypriot measures are covered in “Cyprus Investment Firm (CIF): the CySEC Licence”.
A Member State may also require a third-country firm serving retail or elective professional clients to set up an authorised branch there (Art. 39 MiFID II). How investor compensation relates to other protections is shown in “Client Asset Protection Map”.
In the UK the same scheme is tested against FSMA 2000, several provisions of which create criminal offences.
| Provision | What it sets |
|---|---|
| FSMA s.19 and s.23 | Carrying on a regulated activity in the UK without authorisation or exemption is an offence, up to two years' imprisonment |
| FSMA s.21 and s.25 | An unauthorised person's financial promotion needs authorised approval; promotions from abroad are caught if capable of effect in the UK; breach is an offence |
| FSMA s.26 and s.30 | Agreements made in breach are unenforceable against the client, who may recover money and compensation; a court may allow enforcement in some cases |
| COBS 22.5 | Retail CFDs in or from the UK: cash margin 3.33% on major FX pairs, 5% on major indices and gold, up to 20% on shares |
COBS 22.5 also covers branches of third-country firms and caps a retail client's liability at the account balance. In discussion paper DP25/3 (December 2025) the FCA noted that about 80% of customers lost money on CFDs in its 2022 review and that more frictions might be warranted; as of 29.09.2026 the rules are unchanged.
Offshore regulators now also require the business to be lawful in client countries. Under regulation 34 a Seychelles dealer assures the FSA that client countries allow such dealings, and CIMA asks applicants to confirm that legal opinions will be obtained before clients are targeted and to describe mechanisms blocking prohibited jurisdictions. Soliciting retail clients in the EU or the UK without local authorisation contradicts these assurances.
The same IOSCO report described regulators working with payment channels against illegal sellers, mostly of binary options: Canadian regulators exchanged information with Mastercard, some processors limited card use, one jurisdiction banned credit card payments for retail OTC derivatives, and Japan's FSA asked that wires not be sent to unregistered brokers.
Choosing between the regimes
The choice starts with where the clients are. For retail clients in the EU or the UK no offshore licence fits: the firm needs an EU investment firm licence (see “Investment Firm under MiFID II”) or FCA authorisation. Next comes the product: spot crypto-assets and custody fall under VASP laws, CFDs and FX stay in broker regimes. Then come client type and staffing.
| Business model | Regime | What decides it |
|---|---|---|
| Retail CFDs and FX for clients outside the EU and the UK | Seychelles | Dedicated retail rules; two residents; client countries notified to the FSA |
| CFDs on crypto-assets | Seychelles | Securities under the Securities Act; no VASP licence needed where CFDs are approved |
| Broker or arranger with capital matched to its model | BVI | Capital set by the FSC; authorised representative instead of local management; FX contracts since 2025 |
| Broker-dealer for its group, high net worth and sophisticated clients | Cayman, registration | No licence; transactions from $80,000 or net worth from $800,000 |
| Broker-dealer or market maker supervised by CIMA | Cayman, licence | Physical presence; financial resources; CI$10,000 a year |
| Crypto exchange, brokerage or custody | VASP laws | Separate authorisation in each of the three jurisdictions |
| Retail clients in the EU or the UK | None of the three | An EU licence or FCA authorisation |
Regulatory fees in all three jurisdictions run to thousands of dollars a year and differ less than the people requirements. Seychelles requires two residents at all times and US$100,000 in the bank, Cayman expects physical presence and experienced directors, and the BVI accept an authorised representative but set capital case by case, with no amount known in advance. The tax treatment of BVI and Cayman companies is covered in “BVI Company” and “Cayman Islands Company”; for a Seychelles dealer the FSA cites 1.5% of gross income where there is substantial activity on the islands.
The jurisdictions' position on the EU lists is set out in “Offshore Companies”, and the client's view of choosing a broker in “International Brokerage Account”. A payments or e-money business needs a different regime: see “Financial Licenses by Jurisdiction”. The other regimes for brokers and investment firms are gathered in the “Financial Licences” hub.
Q/A
Licence and cost
How much does a broker licence cost in Seychelles?
A dealer pays US$3,000 on application and US$6,000 a year; in the year of grant the fee is pro-rated by quarter to US$6,000, 4,500, 3,000 or 1,500 (S.I. 120 of 2024, FSA Circular No. 1 of 2025). Paid-up capital of US$100,000 must also stay at all times with a bank licensed in Seychelles or an FSA-recognised jurisdiction.
What capital does a BVI broker need?
There is no general minimum: under the Regulatory Code the FSC sets capital for each licensee in light of its business and risks. For sub-categories 1A, 1B and Category 2 the fees are US$2,200 per application and US$3,300 for the licence on grant and each year.
Can a firm operate in Cayman without a licence?
Yes, as a registered person, but only in three cases: for its own group, exclusively for high net worth and sophisticated clients, or under a recognised overseas regulator. Registration and the annual fee cost CI$6,000 each.
People and presence
Does a Seychelles dealer need resident staff?
Yes. One of the two required directors is a full-time resident, at least two resident directors, compliance officers or managers are in Seychelles at all times, and a resident handles complaints. Firms licensed before 2025 had to comply by 30.06.2026.
Does a BVI broker need an office on the islands?
Not necessarily. Without significant management presence on the islands, the licensee appoints an FSC-certified authorised representative. A resident director is needed only if the FSC requires one; the firm has at least two directors and is managed by at least two fit and proper individuals.
Is the Vanuatu financial dealer licence still available?
Yes. As of 29.09.2026 the VFSC register lists 66 active licences. The current Act requires a licensed manager with a physical office in Vanuatu, a VT5,000,000 deposit and an annual fee of VT500,000, and licence classes A to D are granted only in sequence.
EU, UK and crypto-assets
Can an offshore-licensed broker accept EU clients?
Only where the client came at their own exclusive initiative, and even then the firm may not offer new product categories (Art. 42 MiFID II). Any solicitation in the EU by the firm or a closely linked entity rules this out, and contract clauses cannot create it. A Member State may require a locally authorised branch.
Can an offshore broker advertise in the UK?
As a rule, not without an authorised person's approval. The s.21 FSMA restriction also covers communications from abroad capable of having an effect in the UK; breach is an offence, and an agreement resulting from it is unenforceable against the client. COBS 22.5 also applies to retail CFDs.
Does a broker licence cover crypto-assets?
In part. The Seychelles FSA treats CFDs on crypto-assets as securities that a dealer approved for CFDs may offer. Exchanges, brokerage, wallets and custody for crypto-assets themselves need separate authorisation: in Seychelles under the VASP Act 2024, in the BVI registration under the VASP Act 2022, and in Cayman a VASP licence for custody and trading platforms since 01.04.2025.