Financial Integrity Monitor

Seychelles SC

Sources
9
Jurisdiction profile
Largely CompliantTier BRisk: StableMixed

AML/CFT governed by the Anti-Money Laundering and Countering the Financing of Terrorism Act 2020 (Cap 251, as revised 17 Jan 2025), Beneficial Ownership Act 2020, and VASP Act 2024.

MoreThree supervisors (Central Bank of Seychelles, Financial Services Authority, FIU) oversee reporting entities. ESAAMLG member, under Enhanced Follow-up since the 2018 MER; not FATF grey/black-listed.

Key deficiencies
  • R.7 (proliferation-financing targeted sanctions) rated Non-Compliant and unresolved since 2018 MER
  • R.22 (DNFBP customer due diligence) rated Non-Compliant; DNFBP sector supervision rated ineffective due to competing priorities
  • No autonomous Russia/Iran sectoral sanctions regime domestically — Seychelles implements only UN Security Council listings, creating a structural gap exploited by shadow-fleet shipping/insurance registrations
  • VASP Act 2024 in force since July 2024 but zero licenses granted as of the 2025 reporting cycle despite >100 historically-registered VASPs
  • Asset-forfeiture legal framework gaps identified across the Criminal Procedure Code, AML/CFT Act and Anti-Corruption Act
Recent developments (18m)
  • Second National Risk Assessment launched February 2025 and published (sanitized edition) August 2025, covering Jan 2017-June 2022
  • VASP Act 2024 transition period closed 31 December 2024; FSA assessing 9 pending licence applications with zero approvals as of the 2025 reporting cycle
  • Joint Communiqué: the three AML/CFT supervisors (CBS, FSA, FIU) signed a joint Enforcement Policy (Notice No. 1 of 2025)
  • FSA revoked the licences of Alpha Consulting, a Seychelles CSP implicated in the Pandora Papers for creating anonymous UK shell companies for Russian-linked clients (reported March 2025)
  • Multiple OFAC secondary-sanctions designations of Seychelles-registered shipping and insurance entities under Russia (EO 14024) and Iran (EO 13902) programs through 2025
  • EU high-risk AML third-country list updates of June and December 2025 leave Seychelles unlisted
  • EU list of non-cooperative tax jurisdictions (Feb 2026 update): Seychelles received a positive Global Forum rating and was removed from the state-of-play document
Regulatory horizon
No dated horizon items this cycle. 4 items tracked without a confirmed date.
4 pending date · baseline financial-integrity-2026-10-03
Registers

Enforcement actions

  • OFAC added Seychelles-registered Seapalm Shipping Limited (IMO 6347414) to the SDN List under Executive Order 13902 as part of a network supporting Iran's oil exports, alongside recordkeeping-rule changes extending OFAC retention requirements to 10 years. 20 Mar 2025
  • OFAC designated three further Seychelles-registered shipping companies under Iran-related and counter-terrorism authorities (EO 13902 and EO 13224 as amended), continuing the pattern of Seychelles IBC shells identified as Iranian petroleum sanctions-evasion vehicles. 3 Jul 2025
  • The FSA revoked the operating licences of Alpha Consulting, a Seychelles CSP named in the Pandora Papers for creating anonymous UK shell companies via nominee directors for Russian-linked clients, 16 months after a police/regulatory raid on its Victoria headquarters. 26 Mar 2025
  • Following the close of the VASP Act 2024 transition period, the FSA issued more than 20 public warnings against unauthorized entities, including large multinational service providers, claiming Seychelles affiliation or licensing while taking a cautious approach to the 9 licence applications under assessment. 1 Jun 2025
  • The three statutory AML/CFT supervisory authorities jointly signed and published an Enforcement Policy (Notice No. 1 of 2025), formalising coordinated supervisory and sanctioning standards across banking, non-bank financial and DNFBP sectors. 15 Jan 2025

Sanctions changes

  • The European Commission's December 2025 update to the AML high-risk third-country list (Delegated Regulations (EU) 2026/46 and 2026/83) added Bolivia and the British Virgin Islands and delisted six African states; Seychelles was not added, continuing its non-listed status aligned with its absence from the FATF grey list. 4 Dec 2025
  • The EU Council's February 2026 update to the list of non-cooperative tax jurisdictions recorded a positive Global Forum rating for Seychelles' tax-information-exchange systems, resulting in its removal from the Annex II 'state of play' monitoring document. 17 Feb 2026
  • Through 2025, OFAC added a succession of Seychelles-registered shipping corporations to the SDN List under Russia (EO 14024) and Iran (EO 13902/13224) sanctions authorities, reflecting continued identification of Seychelles IBC shells as flag-of-convenience vehicles in sanctions-evasion shipping networks. 3 Jul 2025

Regulatory horizon (register)

  • ESAAMLG 5th round Mutual Evaluation of Seychelles
  • FSA decisions on pending VASP licence applications
  • Next EU non-cooperative tax jurisdictions list revision
  • National AML/CFT Strategy and Action Plan update post-2nd NRA

Active schemes

  • [CRITICAL] Seychelles-registered shadow-fleet shipping and insurance vehicles
  • [HIGH] Offshore VASP incorporation arbitrage via Seychelles IBCs
  • Nominee-director shell network for anonymous UK companies
Sources
  1. Ministry of Finance, National Planning and Trade (Seychelles)
  2. Seychelles Financial Intelligence Unit
  3. Financial Action Task Force
  4. US Department of the Treasury — Office of Foreign Assets Control
  5. European Commission, DG FISMA
  6. Council of the European Union
  7. International Consortium of Investigative Journalists
  8. TRM Labs
  9. Organized Crime and Corruption Reporting Project
Coverage gaps
FATF Recommendation 7 (targeted financial sanctions related …
FATF Recommendation 7 (targeted financial sanctions related to proliferation financing) remains rated Non-Compliant, unresolved since the 2018 MER and not upgraded in the 2023 Follow-Up Report.
FATF Recommendation 22 (DNFBP customer due diligence) is rat…
FATF Recommendation 22 (DNFBP customer due diligence) is rated Non-Compliant; the 2nd NRA separately rates DNFBP vulnerability (accounting, legal, real estate, precious metals) as medium-high, citing ineffective supervision from competing regulatory priorities.
Seychelles' domestic sanctions implementation (Prevention of…
Seychelles' domestic sanctions implementation (Prevention of Terrorism Regulations 2015) is limited to freezing UN Security Council-listed assets within 24 hours; the jurisdiction maintains no autonomous Russia- or Iran-specific sectoral sanctions regime matching EU/UK/US measures.
Despite the VASP Act 2024 entering into force in July 2024 a…
Despite the VASP Act 2024 entering into force in July 2024 and the application transition period closing December 2024, zero VASP licences had been granted as of the 2025 reporting cycle against a historical population of over 100 Seychelles-registered VASPs.
Sector-specific national risk assessments beyond the virtual…
Sector-specific national risk assessments beyond the virtual-assets/VASP sector (e.g. private banking, TCSP, fund management) were not locatable in the public domain during this baseline; only the 2022 VA/VASP overall national risk assessment is publicly indexed on the Ministry of Finance site.

Evidence

Confidence-tiered claims

Seychelles AML/CFT regime, jointly supervised by FSA and Seychelles FIU SRC-fim-SC-001
Probable · 1 source
VASPs (exchanges, wallet providers, brokers, investment providers) SRC-fim-SC-002
Probable · 1 source