---
title: "SC Payments Regulation Monitor | World Payments Monitor"
canonical: https://payments.gi/jurisdictions/seychelles/
source_html: /jurisdictions/seychelles/index.html
description: "SC payments and e-money regulation: 14 modules, 64 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT."
generated_at: 2026-10-26T19:20:26Z
content_sha256: a76412326af33d190c5fa54bedfeb51b925cbf7f93400033cffa19bc340c5eed
generator: "fe-fleet/md-twin@1.0"
---
# SC

SC
schema world-payments-v1
trajectory: not yet assessed

Last updated 2026-10-26 · 14 modules · 64 sourced
findings · 116 sources in the cumulative register

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14 Modules

0 Moved this cycle 1 Key judgments 12 Open gaps 64 Findings

9 Tier-1 sources

Confidence mix 3 confirmed 11 unpopulated
(sums to 14 rendered modules; click to filter)

No modules moved this cycle.

## Jurisdiction brief

Jurisdiction lead brief 358 Full executive summary 270

Standing brief, as of 25 October 2026.

#### Lead Signal

The Central Bank of Seychelles entered a period of leadership transition, with Governor Caroline Abel resigning on 16 September 2026, roughly six months before the scheduled end of her third term in March 2027. First Deputy Governor Brian Commettant has assumed the role of acting Governor pending appointment of a permanent successor. As the primary regulatory authority responsible for payment-system oversight under the jurisdiction&#x27;s National Payment System Act, the Central Bank&#x27;s leadership occupies a central position in the pace and direction of payments-regulatory policy, and a mid-term departure of this kind introduces a period of institutional uncertainty until a permanent appointment is made.

The transition is notable less for any immediate change in rules or supervisory posture, since no accompanying policy announcement accompanied the resignation, and more for the structural question it raises about continuity. A central bank governor&#x27;s departure well ahead of a scheduled term end, with an acting successor in place rather than an already-confirmed permanent replacement, typically signals either a decision taken for personal or political reasons unconnected to payments policy, or the early stage of a broader institutional change whose shape is not yet visible from the public record. Either reading leaves near-term payments-regulatory initiatives in Seychelles in a holding pattern until the succession question resolves.

#### Other Developments

No other licensing, authorisation or market-access development for Seychelles payment-services providers was identified beyond the leadership transition itself.

#### Cross-Monitor Connections

The Central Bank of Seychelles&#x27; leadership transition has no identified direct connection to sanctions, financial-crime or digital-asset developments surfaced elsewhere; it is recorded here as a standalone institutional event affecting the pace of payments-specific regulatory initiatives rather than as a cross-cutting finding.

#### Outlook

The principal open question is the timeline and identity of a permanent successor to Governor Abel, and whether the acting Governor&#x27;s tenure will see any payments-regulatory initiatives paused, continued, or accelerated in the interim. Until a permanent Governor is appointed, near-term policy direction under the National Payment System Act is likely to remain in a steady, cautious posture rather than advancing new initiatives, consistent with how central banks typically operate through an acting-leadership period.

Read full brief · 358 words

Standing brief, as of 25 October 2026.

#### Regulatory Status

The principal payments-regulatory development in Seychelles this period is institutional rather than rule-based: Governor Caroline Abel of the Central Bank of Seychelles resigned on 16 September 2026, roughly six months ahead of the scheduled end of her third term in March 2027. First Deputy Governor Brian Commettant is now serving as acting Governor while a permanent successor is identified. The Central Bank is the jurisdiction&#x27;s primary payments regulator under the National Payment System Act, so this leadership change sits directly within the institutional architecture governing payment-services licensing, authorisation and market access in Seychelles, even though no specific payments-policy statement accompanied the resignation.

No change to the substantive licensing, authorisation or market-access framework for payment-services providers, banks or non-bank payment institutions was identified. The leadership transition is best read as an institutional event with the potential to affect the pace and continuity of payments-regulatory decision-making during the interim acting period, rather than as evidence of a substantive policy shift already underway. No other payments-sector development, whether in stablecoin or digital-money regulation, operational resilience, scheme compliance, corridor dynamics, consumer protection, or correspondent-banking access, was identified for Seychelles.

#### Outlook

The trajectory to watch is the appointment of a permanent Governor and whether that appointment signals continuity with, or a departure from, prior payments-regulatory approach. Until a permanent successor is named, payments-sector participants in Seychelles should expect a steady, cautious regulatory posture from the acting Governor, consistent with typical institutional behaviour during a leadership gap, with the pace of any new licensing or market-access initiatives likely to remain subdued until the succession question is resolved.

Read full brief · 270 words

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### W1aLicensing, Authorisation & Market Access1 judgmentlimited signalConfirmedconfirmed 2026-09-08&#9662;#

Payment services in Seychelles are licensed and supervised by the Central Bank of Seychelles (CBS) under the National Payment System Act 2014 (as amended, including the 2023 amendment), with a parallel FSA-run licensing track for virtual asset service providers under the VASP Act 2024. CBS remains the sole banking-licence issuer under the CBS Act 2004.

Key judgment — Probable · impact MONITORED The mid-term resignation of the Central Bank of Seychelles Governor, with an acting successor in place, introduces near-term uncertainty for the pace of payments-regulatory initiatives under the National Payment System Act until a permanent Governor is appointed. claims: none recorded

Standing sub-brief · as of 25 October 2026 515 words · last cycle 2026-10-25

#### Licensing, Authorisation & Market Access

Seychelles&#x27; payments-regulatory landscape saw a significant institutional change rather than a change in substantive rules: Governor Caroline Abel of the Central Bank of Seychelles resigned on 16 September 2026, approximately six months before the scheduled end of her third term, which was due to run to March 2027. First Deputy Governor Brian Commettant has stepped into the role of acting Governor while a permanent successor is identified. As the Central Bank is the primary authority responsible for payment-system licensing, authorisation and oversight under the National Payment System Act, this leadership change sits at the centre of the jurisdiction&#x27;s payments-regulatory architecture even though no accompanying statement addressed payments policy specifically.

The significance of a mid-term resignation, as distinct from an orderly end-of-term transition, lies in the uncertainty it introduces for market participants and applicants currently navigating the authorisation process. A payment-services provider with a licence application pending, or a bank-partnered fintech awaiting a supervisory decision, now faces that process under an acting rather than a confirmed permanent Governor, which can affect both the pace of decision-making and the degree of policy continuity those decisions reflect. Nothing in the evidence indicates that any specific licensing application, approval, or rule change has been delayed or accelerated as a direct consequence of the transition; the observation here is structural rather than an identified operational effect.

No detail was located regarding the circumstances of the resignation itself, whether it reflects personal considerations, a policy disagreement, political pressure, or some other factor. That gap matters for assessing how the transition should be read: a resignation driven by personal circumstance carries different implications for regulatory continuity than one arising from institutional or political friction, and the public record available does not distinguish between these possibilities. Similarly, no timeline for the appointment of a permanent Governor was identified, leaving the duration of the acting arrangement, and therefore the period over which this uncertainty will persist, unknown.

It is also worth noting what the evidence does not show: no indication of any substantive change to licensing criteria, market-access requirements, or supervisory expectations for payment-services providers, banks, or non-bank payment institutions operating in or from Seychelles. The leadership transition is, on the present record, an institutional event layered on top of an otherwise unchanged licensing and authorisation framework, rather than a signal of rule change in progress.

#### Outlook

The central open question for market participants is the timeline for appointing a permanent Governor and whether that appointment will bring continuity with, or departure from, the previous Governor&#x27;s approach to payments-sector licensing and supervision. Firms with applications or supervisory matters pending before the Central Bank may reasonably expect a cautious, steady-state posture from the acting Governor during the interim period, consistent with how institutions typically operate through a leadership gap, rather than new policy initiatives being launched before a permanent appointment is confirmed. Monitoring for the naming of a permanent successor, and for any public statement from the Central Bank regarding payments-policy continuity during the transition, is the most direct way to track how this development resolves in subsequent reporting periods.

Read full sub-brief · 515 words no periodic updates on record for this sub-brief

Evidence 6

Sources and findings (6)
- T1[https://www.cbs.sc/Downloads/legislations/National%20Payment%20System%20Act%202014%20as%20amended%20(Consolidated).pdf](https://www.cbs.sc/Downloads/legislations/National%20Payment%20System%20Act%202014%20as%20amended%20(Consolidated).pdf)retrieved 2026-09-08
- T1[https://www.gazette.sc/sites/default/files/2023-10/Act%2015%20-%202023%20-%20National%20Payment%20System%20(Amendment)%20Act%202023.pdf](https://www.gazette.sc/sites/default/files/2023-10/Act%2015%20-%202023%20-%20National%20Payment%20System%20(Amendment)%20Act%202023.pdf)retrieved 2026-09-08
- T4[https://nobel.capital/seychelles-payment-service-providers-license/](https://nobel.capital/seychelles-payment-service-providers-license/)retrieved 2026-09-08
- T2[https://www.state.gov/reports/2024-investment-climate-statements/seychelles/](https://www.state.gov/reports/2024-investment-climate-statements/seychelles/)retrieved 2026-09-08
- T4[https://tradersquote.com/Seychelles-PSP-Licence.php](https://tradersquote.com/Seychelles-PSP-Licence.php)retrieved 2026-09-08
- T1[https://fsaseychelles.sc/vasp/legal-framework](https://fsaseychelles.sc/vasp/legal-framework)retrieved 2026-09-08

### W1bConduct, Safeguarding & PromotionsConfirmedconfirmed 2026-09-08&#9662;#

Conduct and consumer-facing obligations for payment and other financial service providers sit under the Financial Consumer Protection Act (FCPA, in force since May 2022), jointly administered by CBS and FSA, supplemented by sector-specific safeguarding rules such as the VASP client-asset regulations and CBS&#x27;s surety-bond enforcement practice for PSPs.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Evidence 6

Sources and findings (6)
- T1[https://www.cbs.sc/Consumer/ConsumerLaws.html](https://www.cbs.sc/Consumer/ConsumerLaws.html)retrieved 2026-09-08
- T4[https://www.mondaq.com/financial-services/1369328/protecting-financial-consumers-in-seychelles](https://www.mondaq.com/financial-services/1369328/protecting-financial-consumers-in-seychelles)retrieved 2026-09-08
- T1[https://fsaseychelles.sc/complaint-handling](https://fsaseychelles.sc/complaint-handling)retrieved 2026-09-08
- T1[https://www.cbs.sc/Consumer/ConsumerComplaint.html](https://www.cbs.sc/Consumer/ConsumerComplaint.html)retrieved 2026-09-08
- T3[https://offshoreincorporate.com/seychelles-virtual-asset-service-providers-act-overview/](https://offshoreincorporate.com/seychelles-virtual-asset-service-providers-act-overview/)retrieved 2026-09-08
- T4[https://payatlas.com/regulator/seycb-4829](https://payatlas.com/regulator/seycb-4829)retrieved 2026-09-08

### W2Stablecoins & Digital Money1 gapProbableconfirmed 2026-09-08&#9662;#

Seychelles has no dedicated stablecoin statute; digital-money/virtual-asset activity, including tokens usable for payment purposes, is captured under the Virtual Asset Service Providers Act, 2024 (in force since 1 September 2024), administered by the FSA, with supplementary prudential and disclosure regulations still moving through consultation.

Open gap — wpm-int-1 No stablecoin/digital-money instrument change for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T1[https://fsaseychelles.sc/vasp/legal-framework](https://fsaseychelles.sc/vasp/legal-framework)retrieved 2026-09-08
- T3[https://charltonsquantum.com/seychelles-virtual-assets-regulation/](https://charltonsquantum.com/seychelles-virtual-assets-regulation/)retrieved 2026-09-08
- T3[https://offshoreincorporate.com/seychelles-virtual-asset-service-providers-act-overview/](https://offshoreincorporate.com/seychelles-virtual-asset-service-providers-act-overview/)retrieved 2026-09-08
- T3[https://www.applebyglobal.com/publications/the-seychelles-financial-services-authority-introduces-draft-regulations-under-the-virtual-asset-service-providers/](https://www.applebyglobal.com/publications/the-seychelles-financial-services-authority-introduces-draft-regulations-under-the-virtual-asset-service-providers/)retrieved 2026-09-08
- T3[https://www.applebyglobal.com/publications/the-seychelles-financial-services-authority-introduces-draft-regulations-under-the-virtual-asset-service-providers/](https://www.applebyglobal.com/publications/the-seychelles-financial-services-authority-introduces-draft-regulations-under-the-virtual-asset-service-providers/)retrieved 2026-09-08

### W3Operational Resilience & Critical Infra1 gapProbableconfirmed 2026-09-08&#9662;#

Seychelles has no dedicated cyber-resilience or incident-reporting directive for payment providers akin to South Africa&#x27;s SARB model; operational-resilience obligations for CBS-regulated institutions are instead embedded within CBS&#x27;s general Outsourcing Guidelines, which mandate business-continuity planning and data-confidentiality/security controls for material outsourcing arrangements.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open its jurisdiction pages on Dataprotection.gi &rarr;](https://dataprotection.gi/jurisdictions/)

Open gap — wpm-int-2 No operational resilience/critical infrastructure incident for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 3

Sources and findings (3)
- T1[https://www.cbs.sc/Downloads/legislations/Guidelines%20for%20Outsourcing.pdf](https://www.cbs.sc/Downloads/legislations/Guidelines%20for%20Outsourcing.pdf)retrieved 2026-09-08
- T1[https://www.cbs.sc/Downloads/legislations/Guidelines%20for%20Outsourcing.pdf](https://www.cbs.sc/Downloads/legislations/Guidelines%20for%20Outsourcing.pdf)retrieved 2026-09-08
- T4[https://blog.voveid.com/aml-compliance-in-seychelles-2026-guide-for-fintechs-and-regulated-businesses/](https://blog.voveid.com/aml-compliance-in-seychelles-2026-guide-for-fintechs-and-regulated-businesses/)retrieved 2026-09-08

### W4Scheme & Network Compliance1 gapUncertainconfirmed 2026-09-08&#9662;#

Seychelles has no domestic card scheme, dedicated interchange-fee regulation, or published scheme-rulebook oversight function; card payments run entirely on international Visa/Mastercard rails via foreign/regional acquirers, with PCI DSS applying only as a global scheme-mandated standard rather than a locally legislated one.

Open gap — wpm-int-3 No scheme/network compliance change for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 2

Sources and findings (2)
- T4[https://www.transfi.com/blog/seychelles-payment-rails-how-they-work---instant-transfers-cards-mobile-wallet-adoption](https://www.transfi.com/blog/seychelles-payment-rails-how-they-work---instant-transfers-cards-mobile-wallet-adoption)retrieved 2026-09-08
- T4[https://support.visaacceptance.com/knowledgebase/knowledgearticle/?code=000001926](https://support.visaacceptance.com/knowledgebase/knowledgearticle/?code=000001926)retrieved 2026-09-08

### W5Payment Corridor Dynamics1 gapProbableconfirmed 2026-09-08&#9662;#

Seychelles&#x27; cross-border payment corridors run principally through SWIFT and the SADC Integrated Regional Electronic Settlement System (SADC-RTGS), settling in ZAR; formal remittance inflows are very small, and Seychelles is not yet a live PAPSS-connected jurisdiction. Domestically, CBS operates the SEFT real-time transfer system and ACH batch processing.

Open gap — wpm-int-4 No payment corridor dynamics change for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T2[https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008](https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008)retrieved 2026-09-08
- T1[https://www.cbs.sc/Financial/ModernisationPaymentSystem.html](https://www.cbs.sc/Financial/ModernisationPaymentSystem.html)retrieved 2026-09-08
- T4[https://www.transfi.com/blog/seychelles-payment-rails-how-they-work---instant-transfers-cards-mobile-wallet-adoption](https://www.transfi.com/blog/seychelles-payment-rails-how-they-work---instant-transfers-cards-mobile-wallet-adoption)retrieved 2026-09-08
- T1[https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-sa-sadc.pdf](https://www.resbank.co.za/content/dam/sarb/what-we-do/payments-and-settlements/cross-border-payments-conference/documents/paper-sa-sadc.pdf)retrieved 2026-09-08
- T4[https://www.accessbankplc.com/personal/money-transfer/papss](https://www.accessbankplc.com/personal/money-transfer/papss)retrieved 2026-09-08

### W6Industry Structure & Commercial1 gapProbableconfirmed 2026-09-08&#9662;#

Seychelles&#x27; financial-services industry structure is bank-dominated (seven commercial banks as of April 2024, several foreign-owned), with CBS acting as sole banking and payments supervisor; a small but growing cohort of non-bank PSP/fintech entrants (Fusepay, Nebula FinTech) is emerging alongside the incumbent banks.

Open gap — wpm-int-5 No industry structure/commercial dynamics development beyond the CBS leadership event was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T2[https://www.state.gov/reports/2024-investment-climate-statements/seychelles/](https://www.state.gov/reports/2024-investment-climate-statements/seychelles/)retrieved 2026-09-08
- T2[https://www.state.gov/reports/2024-investment-climate-statements/seychelles/](https://www.state.gov/reports/2024-investment-climate-statements/seychelles/)retrieved 2026-09-08
- T1[https://www.cbs.sc/Aboutus/BankingServices.html](https://www.cbs.sc/Aboutus/BankingServices.html)retrieved 2026-09-08
- T3[https://innovation-village.com/fusepay-launches-digital-payment-platform-to-modernize-business-transactions-in-seychelles/](https://innovation-village.com/fusepay-launches-digital-payment-platform-to-modernize-business-transactions-in-seychelles/)retrieved 2026-09-08
- T3[https://allafrica.com/stories/202408230420.html](https://allafrica.com/stories/202408230420.html)retrieved 2026-09-08

### W7Legal & Litigation1 gapProbableconfirmed 2026-09-08&#9662;#

Seychelles&#x27; payments-adjacent litigation and enforcement activity in the current period is concentrated in the virtual-asset space: the Supreme Court has issued a significant default judgment against KuCoin-linked entities over custody of delisted tokens, and the FSA has exercised its VASP Act enforcement powers to reject or refuse several licence applications and is engaged in a major crypto-liquidation matter (Yield App).

Open gap — wpm-int-6 No legal/litigation development for the Seychelles payments sector was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T1[https://fsaseychelles.sc/enforcement/disciplinary-actions](https://fsaseychelles.sc/enforcement/disciplinary-actions)retrieved 2026-09-08
- T3[https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3](https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3)retrieved 2026-09-08
- T3[https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3](https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3)retrieved 2026-09-08
- T3[https://www.offshorealert.com/category/jurisdictions/seychelles/](https://www.offshorealert.com/category/jurisdictions/seychelles/)retrieved 2026-09-08
- T3[https://www.comsuregroup.com/news/crypto-chaos-in-court-seychelles-sets-precedent-on-commingled-assets-in-yield-app-liquidation/](https://www.comsuregroup.com/news/crypto-chaos-in-court-seychelles-sets-precedent-on-commingled-assets-in-yield-app-liquidation/)retrieved 2026-09-08

### W8Merchant Acquiring & Risk1 gapUncertainconfirmed 2026-09-08&#9662;#

Seychelles has no dedicated merchant-acquiring or chargeback-specific regulatory framework; acquiring is delivered through domestic bank channels (e.g., MCB Seychelles) using international scheme rails, and offshore-registered Seychelles merchants seeking card acceptance are typically routed to higher-cost third-party processors abroad due to high-risk-jurisdiction treatment by foreign acquirers.

Open gap — wpm-int-7 No merchant acquiring/risk development for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 3

Sources and findings (3)
- T3[https://mcb.sc/corporate/payment-and-services/merchant-services](https://mcb.sc/corporate/payment-and-services/merchant-services)retrieved 2026-09-08
- T4[https://www.webhostingtalk.com/showthread.php?t=1305416](https://www.webhostingtalk.com/showthread.php?t=1305416)retrieved 2026-09-08
- T3[https://innovation-village.com/fusepay-launches-digital-payment-platform-to-modernize-business-transactions-in-seychelles/](https://innovation-village.com/fusepay-launches-digital-payment-platform-to-modernize-business-transactions-in-seychelles/)retrieved 2026-09-08

### W9Product Innovation & Market Development1 gapProbableconfirmed 2026-09-08&#9662;#

CBS is running a FinTech Regulatory Sandbox Framework (stakeholder engagement since October 2022) alongside FSA&#x27;s separate 2019 sandbox exemption regime, against a backdrop of domestic instant-payment and mobile-wallet product launches (eboo, Fusepay) aimed at digitising cheque-based and paper-based transaction flows; no CBDC pilot has been identified.

Open gap — wpm-int-8 No product innovation/market development for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T1[https://www.bis.org/review/r221125f.htm](https://www.bis.org/review/r221125f.htm) Applies beyond this jurisdiction (Basel Committee)retrieved 2026-09-08
- T3[https://www.ifcreview.com/articles/2021/february/seychelles-regulatory-sandbox-exemption/](https://www.ifcreview.com/articles/2021/february/seychelles-regulatory-sandbox-exemption/)retrieved 2026-09-08
- T3[https://allafrica.com/stories/202408230420.html](https://allafrica.com/stories/202408230420.html)retrieved 2026-09-08
- T3[https://businessbeat24.com/fusepay-to-launch-secure-payment-platform-in-seychelles/](https://businessbeat24.com/fusepay-to-launch-secure-payment-platform-in-seychelles/)retrieved 2026-09-08
- T1[https://www.cbs.sc/Financial/ModernisationPaymentSystem.html](https://www.cbs.sc/Financial/ModernisationPaymentSystem.html)retrieved 2026-09-08

### W10Consumer Protection & APP Fraud1 gapConfirmedconfirmed 2026-09-08&#9662;#

Consumer protection for financial and payment services is anchored in the Financial Consumer Protection Act (in force since May 2022) and its Complaint Handling Regulations, jointly enforced by CBS and FSA; no dedicated APP-fraud mandatory-reimbursement regime (of the UK PSR type) has been identified.

Open gap — wpm-int-9 No consumer protection/APP fraud development for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T1[https://www.cbs.sc/Consumer/ConsumerLaws.html](https://www.cbs.sc/Consumer/ConsumerLaws.html)retrieved 2026-09-08
- T4[https://www.mondaq.com/financial-services/1369328/protecting-financial-consumers-in-seychelles](https://www.mondaq.com/financial-services/1369328/protecting-financial-consumers-in-seychelles)retrieved 2026-09-08
- T1[https://fsaseychelles.sc/complaint-handling](https://fsaseychelles.sc/complaint-handling)retrieved 2026-09-08
- T1[https://www.cbs.sc/Consumer/ConsumerComplaint.html](https://www.cbs.sc/Consumer/ConsumerComplaint.html)retrieved 2026-09-08

### W11AML/CFT & Financial Crime1 gapSourced from Sentinel.gi &#8599;Probableconfirmed 2026-09-08&#9662;#

sentinel.baseline: Seychelles operates a sectoral AML/CFT supervision model under the AML/CFT Act 2020, split across CBS (banks, credit unions, PSPs, leasing), FSA (non-bank financial institutions) and the FIU (STR receipt/analysis), with the country remaining under ESAAMLG&#x27;s Enhanced Follow-up Process since 2018 pending its third mutual evaluation cycle from June 2025. Live Sentinel.gi feed content was not accessible in this research pass; this baseline reflects primary CBS/FSA/FIU regulator sourcing pending Sentinel sync.

Open gap — wpm-int-10 No AML/CFT sentinel feed for the Seychelles payments sector was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 5

Sources and findings (5)
- T4[https://blog.voveid.com/aml-compliance-in-seychelles-2026-guide-for-fintechs-and-regulated-businesses/](https://blog.voveid.com/aml-compliance-in-seychelles-2026-guide-for-fintechs-and-regulated-businesses/)retrieved 2026-09-08
- T?FIM (sentinel.gi) per-JID baseline profile — Seychelles — 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. Three 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.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: sourcing-thinness
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: legal-gap

### W12Correspondent Banking, Settlement & Access1 gapProbableconfirmed 2026-09-08&#9662;#

Correspondent-banking de-risking has materially affected Seychelles banks since at least 2017, prompting CBS/FSA outreach roadshows and a Crown Agents Bank capacity-building engagement; settlement access runs through SADC-RTGS and PIRI regional cooperation, while CBS is separately pursuing IMF-guided bank-resolution reform given the absence of a formal depositor-protection scheme.

Open gap — wpm-int-11 No correspondent banking/settlement/access development for Seychelles was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 6

Sources and findings (6)
- T2[https://www.state.gov/reports/2024-investment-climate-statements/seychelles/](https://www.state.gov/reports/2024-investment-climate-statements/seychelles/)retrieved 2026-09-08
- T2[https://www.nation.sc/archive/259566/financial-stability-and-correspondent-banking-the-cbs-perspective-](https://www.nation.sc/archive/259566/financial-stability-and-correspondent-banking-the-cbs-perspective-)retrieved 2026-09-08
- T2[https://www.nation.sc/archive/259566/financial-stability-and-correspondent-banking-the-cbs-perspective-](https://www.nation.sc/archive/259566/financial-stability-and-correspondent-banking-the-cbs-perspective-)retrieved 2026-09-08
- T2[https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008](https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008)retrieved 2026-09-08
- T2[https://forumsec.org/sites/default/files/2024-05/CBR%20Report_FINAL.pdf](https://forumsec.org/sites/default/files/2024-05/CBR%20Report_FINAL.pdf)retrieved 2026-09-08
- T1[https://www.elibrary.imf.org/view/journals/019/2024/054/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/019/2024/054/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08

### W13Commercial Intelligence (M&A, Investment & Product)1 gapProbableconfirmed 2026-09-08&#9662;#

Trailing-12-month commercial activity centres on early-stage fintech funding (Fusepay pre-seed round and product launch) and VASP-sector regulatory/legal events (FSA&#x27;s Mek Global/KuCoin licence rejection and the subsequent Supreme Court default judgment) rather than any bank-sector M&A.

Open gap — wpm-int-12 No M&A/investment/product commercial event for Seychelles payment companies was located this cycle. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

no periodic updates on record for this sub-brief

Evidence 4

Sources and findings (4)
- T3[https://www.startupresearcher.com/news/fusepay-raises-usd350k-to-digitize-payments-in-island-economies](https://www.startupresearcher.com/news/fusepay-raises-usd350k-to-digitize-payments-in-island-economies)retrieved 2026-09-08
- T3[https://businessbeat24.com/fusepay-to-launch-secure-payment-platform-in-seychelles/](https://businessbeat24.com/fusepay-to-launch-secure-payment-platform-in-seychelles/)retrieved 2026-09-08
- T3[https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3](https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3)retrieved 2026-09-08
- T3[https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3](https://finance.biggo.com/news/J3UXvZ4BFVfA5plg7XH3)retrieved 2026-09-08

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## Provenance and declared absence

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