Mauritius's journey from FATF grey list in 2020 to a significantly strengthened regulatory framework by 2021, and its continued regulatory evolution since, is a case study in how a jurisdiction can rebuild regulatory credibility through substantive reform. For CSPs managing structures in or through Mauritius — particularly those serving African investment flows, Indian Ocean trade structures, and Asia-Africa corridor holdings — the current Mauritius regulatory framework is materially stronger than it was five years ago, and the compliance obligations have kept pace.
The GBC Framework: Category Consolidation
The most significant structural change in recent Mauritius company regulation was the consolidation of the Global Business Corporation category structure. The former GBC1 and GBC2 categories were replaced by a single GBC category, with the previous GBC2 (Authorised Company) category carved out as a distinct entity type for entities with no Mauritius-resident beneficial owners conducting no business with residents of Mauritius.
For CSPs administering legacy Mauritius structures, the critical ongoing obligations of the current GBC framework include:
- GBC companies must appoint a resident management company as their registered agent — the management company must be licensed by the FSC
- GBC companies must demonstrate central management and control in Mauritius: at least two resident directors (qualified individuals, not nominees), board meetings held in Mauritius (either physically or with a quorum present in Mauritius), and key management decisions taken in Mauritius
- The FSC requires annual substance demonstration — a detailed filing showing the GBC's economic activity, Mauritius-based employees (if any), expenditure, and the nature of its management activities in Mauritius
- GBC companies must file audited financial statements with the FSC annually
AML/CFT Framework Enhancements Since Grey Listing
Mauritius's exit from the FATF grey list in October 2021 was conditional on demonstrating sustained implementation of 57 action points, covering customer due diligence, beneficial ownership transparency, suspicious transaction reporting, and international cooperation. The financial industry has continued operating under an enhanced AML/CFT framework since delisting.
"Mauritius after grey listing is a fundamentally different regulatory environment from Mauritius before. The FSC examinations are more rigorous, the FIU is more active, and the management companies that survived the reform process are genuinely stronger compliance operators."
— Africa-focused structuring specialist, 2025
Key AML obligations for Mauritius management companies — relevant for offshore CSPs working with Mauritius correspondents:
- Customer due diligence must include verification of the identity of all beneficial owners with a controlling interest, with specific guidance on what "control" means for trust structures vs. corporate structures
- Source of funds must be documented and verified for all GBC company client relationships at onboarding and at enhanced review intervals
- Suspicious transaction reporting to the FIU of Mauritius (FIU-MRU) is mandatory on the same basis as equivalent obligations in other FATF-member jurisdictions
- Management companies must conduct annual AML/CFT risk assessments specific to their client portfolios
Economic Substance: Current Requirements
Mauritius's economic substance framework — introduced as part of its BEPS compliance commitments — requires that entities engaging in relevant activities demonstrate genuine substance in Mauritius. The relevant activities for GBC companies typically include holding company activities, headquartering activities, and in some cases financing and leasing or distribution and service centre activities.
Implications for Offshore CSPs
Offshore CSPs that administer Mauritius structures through a local management company relationship have specific due diligence obligations that go beyond standard client file maintenance.
The local management company (LMC) serves as the Mauritius regulatory interface — it is the licensed entity responsible to the FSC for the GBC's compliance. Offshore CSPs working with LMCs as correspondent agents must conduct appropriate due diligence on the LMC relationship: confirming FSC licence currency, reviewing the LMC's AML framework documentation, and maintaining records that demonstrate the adequacy of the correspondent relationship.
In practice, this means annually confirming the LMC's licence status with the FSC (FSC maintains a public register of licensed entities), reviewing any FSC enforcement actions against the LMC, and documenting your assessment of the LMC's AML programme currency. This is not a rubber-stamp exercise — a poorly-run LMC creates compliance exposure that runs through to your client file and your home-jurisdiction regulatory standing.
The Africa Gateway: Mauritius's Positioning and Future
Mauritius's primary structural role is as a gateway for investment into Africa — leveraging its network of double tax treaties with over 40 African states, its political stability, its English common law legal system, and its proximity to major African investment destinations. This positioning has proven durable, and demand for Mauritius holding and investment structures remains strong despite the enhanced compliance environment.
Looking ahead, CSPs with Mauritius-heavy portfolios should track two developments. First, the OECD's review of Mauritius treaty benefits in light of BEPS minimum standards — the substance requirements have addressed some concerns, but treaty shopping arguments against certain Mauritius treaty routes remain a live issue that affects structuring advice. Second, the FSC's own regulatory development programme, which has signalled interest in further AML/CFT enhancements aligned with FATF's revised guidance on beneficial ownership and legal arrangements.