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Which Staff Does an FSC Mauritius or Seychelles FSA Licence Need?

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In short: A Mauritius Investment Dealer (a Global Business Company licensed by the FSC) needs at least two Mauritius-resident directors, a Compliance Officer, and an MLRO plus a Deputy MLRO. All of them must be at senior level and meet the FSC's competency standards, and the MLRO and compliance functions cannot be outsourced. A Seychelles Securities Dealer must appoint a compliance officer and an alternative compliance officer, both approved by the FSA. The alternate must be physically present in Seychelles when acting, and the FSA expects real local substance.

This is the people side of the licence: who you need, what the rules say about them, and where firms get stuck.

Mauritius: FSC Investment Dealer

Required roles

RoleWhat the rules say
Resident directorsA Global Business licence holder must have at least 2 directors resident in Mauritius with sufficient calibre to exercise independent judgement.
Compliance OfficerRequired under FIAMLR 2018, reg. 22. Must be at senior management level. The function may not be outsourced.
MLRORequired under FIAMLR 2018, reg. 26. Must be sufficiently senior, or have sufficient experience and authority.
Deputy MLROAlso required under reg. 26, to cover the MLRO.
Key staff, officers and representativesMust be fit and proper. Broker and Discount Broker licensees must meet minimum competency standards for representatives and officers.

Can one person be Compliance Officer and MLRO? FIU guidance says yes, provided they have enough time and resources to do both properly.

Competency standards for MLRO, Deputy MLRO and Compliance Officer

For appointments since 1 June 2022, the FSC's competency standards require:

  • a relevant qualification from a recognised institution, plus at least 5 years' industry experience; or
  • 3 years' experience plus a recognised AML/CFT certification (FSI, ACAMS, ICA or equivalent);
  • without a qualification, the FSC may consider candidates case by case with 10+ years' relevant experience;
  • 10 hours of structured CPD per year;
  • a Statement of Declaration by the licensee on appointment, and a Certificate of Character from the officer.

Capital, for context

Minimum unimpaired stated capital depends on the Investment Dealer category: MUR 10 million for Full Service including underwriting, MUR 1 million for Full Service excluding underwriting, MUR 700,000 for Broker and MUR 600,000 for Discount Broker. Professional indemnity cover is also required.

Roles you will need operationally

Beyond the mandatory officers, a functioning broker needs dealing, back-office and platform staff. See our guides on Head of Dealing for a Mauritius Investment Dealer and hiring local staff in Mauritius and Seychelles.

Seychelles: FSA Securities Dealer

Required roles

RoleWhat the rules say
Compliance officerMust be appointed with the approval of the FSA (AML/CFT Regulations 2020, reg. 8). Must be senior enough to exercise sound, independent judgement (reg. 12).
Alternative compliance officerMust be appointed alongside the compliance officer and approved by the FSA. Must be physically present in Seychelles when acting as compliance officer (reg. 8(1)(g)).
Local substanceAdvisers report the FSA expects at least two full-time resident personnel, such as directors or compliance staff.

Key rules about the compliance officer

  • Experience: for FSA-supervised entities, generally at least 2 years of AML or compliance experience in the 4 years before the application (AML/CFT Regulations 2020, Schedule 1).
  • No dual executive role: the compliance officer cannot also be CEO, deputy CEO, COO or CFO without the supervisor's authorisation (reg. 12(2)).
  • Approval time: the supervisor has up to 60 days to decide on the appointment (reg. 9). Build this into your launch plan.
  • Replacement: if approval is withdrawn, a replacement must be appointed within 90 days (reg. 10).
  • Small firms: entities with five or fewer staff (except virtual asset service providers) may apply to have a single compliance officer without an alternate (reg. 8(2)).

Capital, for context

Consultancies cite a minimum paid-up capital of USD 100,000 for a Securities Dealer. The FSA can require more depending on risk profile.

Side by side

Mauritius Investment DealerSeychelles Securities Dealer
Resident directorsAt least 2 (GBC rule)Local substance expected (2 full-time resident staff reported)
Compliance officerRequired, senior, not outsourcedRequired, FSA-approved
Second AML officerDeputy MLROAlternative compliance officer (physically present in Seychelles when acting)
Minimum experience5 yrs, or 3 yrs + AML certification2 yrs AML/compliance in the last 4
Regulator decision on appointmentLicensee declaration + certificate of characterFSA approval, up to 60 days

Where firms get stuck

  1. Finding resident, experienced people. Both talent pools are small. Candidates with 5+ years' experience, a recognised AML certification and local residency are scarce and well paid. Our current Mauritius benchmark for a Compliance Officer/MLRO is USD 2,000–4,000 net per month.
  2. Relocating someone and waiting for the permit. If the best candidate is not resident, plan the work or occupation permit in parallel with the regulator's approval. Our work permit assistance covers this.
  3. Naming people too late. Regulators assess the people as part of the application. Line up candidates before you file.

Summary of published rules and practitioner sources as of October 2026. Requirements change, so confirm with the FSC or FSA and your licensing adviser before filing.

FAQ

How many resident directors does a Mauritius Investment Dealer need? At least two directors resident in Mauritius, under the rules for Global Business licence holders.

Does a Mauritius licensee need both an MLRO and a Deputy MLRO? Yes. FIAMLR 2018 regulation 26 requires both. A separate Compliance Officer is required under regulation 22, although the same person can be Compliance Officer and MLRO if they have the capacity.

Does the Seychelles compliance officer have to live in Seychelles? The alternative compliance officer must be physically present in Seychelles when acting. In practice the FSA expects a resident compliance presence, and both officers need FSA approval.

How long does FSA approval of a compliance officer take? The AML/CFT Regulations 2020 give the supervisor up to 60 days to decide.

Can HRFinEase recruit these roles? Yes. We recruit compliance officers, MLROs, deputies and resident directors for FSC and FSA licensees, and we only invoice once the candidate starts.

Sources

  • FSC Mauritius, CEO speech on director duties (Financial Services Act, GBC resident directors): fscmauritius.org
  • FIU Mauritius, Tip of the Month: The MLRO and the Compliance Officer (FIAMLR 2018, regs 22 and 26)
  • FSC Mauritius, Amendments to Competency Standards for MLRO and Compliance Officer (June 2022)
  • Sovereign Group, Investment Dealer Licence: Mauritius
  • Seychelles AML/CFT Regulations 2020: finance.gov.sc
  • Salvus Funds, Establishing a Securities Dealer in Seychelles in 2026

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Written by

Aleksandr Kazak

Founder & Managing Partner · HRFinEase

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