Key takeaways
- Most regulated jurisdictions now require some local substance.
- Comoros licences and no-licence IBC routes need none, with clear trade-offs.
- Substance can often be provided by licensed local service companies.
- Low substance usually means harder banking.
The trend
Under pressure from international standards, offshore regulators have steadily raised substance expectations: local directors, compliance officers, offices and real decision-making. Licences that require nothing locally are now the exception.
Routes with little or no substance
- Comoros – Mwali and Anjouan: offshore licences without local office requirements, with disputed recognition.
- Saint Lucia, St Vincent and Marshall Islands companies: no FX licence at all.
Substance as a service
In jurisdictions such as Mauritius and the Bahamas, licensed management companies can provide resident directors, officers and office space, so founders do not need to relocate.