The Seychelles International Business Company (IBC) has been one of the most widely used offshore corporate vehicles since the International Business Companies Act 1994 established the jurisdiction as a leading incorporation centre. With over 250,000 IBCs registered and a cost-effective registration framework, Seychelles IBCs remain popular for international holding, trading, and asset-holding structures. But the compliance environment has changed significantly — and CSPs servicing Seychelles entities face a materially more demanding regulatory landscape in 2025 than existed even five years ago.
The Seychelles Regulatory Framework
The Financial Services Authority (FSA) is the primary regulator for Seychelles IBCs. The FSA supervises registered agents (the equivalent of CSPs in most other jurisdictions), issues and withdraws licences, and conducts inspections of agent records. The FSA also administers the Beneficial Ownership Register, which was introduced as part of Seychelles' response to FATF and EU grey-listing pressure.
The legislative framework governing IBCs was significantly updated by the Business Companies Act 2021 and its associated regulations, which replaced the 1994 Act. Key changes included enhanced beneficial ownership requirements, updated AML provisions, and new financial reporting obligations.
Beneficial Ownership Register Requirements
Seychelles implemented a central Beneficial Ownership Register for IBCs as part of commitments made during its FATF Mutual Evaluation Review. Key requirements:
- All Seychelles IBCs must maintain an up-to-date register of beneficial owners
- A beneficial owner is any individual who ultimately owns or controls 25% or more of the shares, voting rights, or who exercises effective control by other means
- The register must be held by the registered agent in Seychelles (not necessarily at the company's registered office)
- Information required: full legal name, date of birth, nationality, residential address, and nature and extent of beneficial interest
- The register must be updated within 30 days of any change in beneficial ownership
- The FSA has access to beneficial ownership registers and can request disclosure in connection with law enforcement or regulatory enquiries
The register is not publicly accessible — Seychelles does not operate a public UBO register — but it must be maintained accurately and made available to the FSA on request.
Compliance risk: Failure to maintain an accurate beneficial ownership register is a criminal offence under the Business Companies Act 2021. Registered agents who fail to collect or update UBO information face regulatory sanctions including licence suspension.
Annual Filing and Good Standing
Seychelles IBCs must maintain good standing by paying annual fees to the Registrar of Companies. The fee is payable on the anniversary of incorporation, with a grace period before penalties and ultimately strike-off apply. CSPs must track these dates precisely — a lapsed IBC loses its good standing, which can create significant complications for any ongoing transactions or banking relationships.
In addition to fee payment, the registered agent must confirm annually that KYC and beneficial ownership information for the IBC is current. This is an administrative confirmation rather than a full re-verification, but it creates a systematic obligation that must be calendared for every entity in the portfolio.
AML Obligations for Seychelles Registered Agents
Registered agents in Seychelles are Designated Non-Financial Businesses and Professions (DNFBPs) under the Anti-Money Laundering Act 2006 (as amended). AML obligations include:
- Conducting CDD on all clients (individuals and corporations) before providing services
- Identifying and verifying beneficial owners at the 25% threshold
- Applying enhanced due diligence to high-risk clients and Politically Exposed Persons
- Screening clients against international sanctions lists
- Reporting suspicious activity to the Financial Intelligence Unit (FIU) of Seychelles
- Maintaining AML records for a minimum of five years following termination of a business relationship
- Appointing a Money Laundering Reporting Officer (MLRO)
The FSA conducts AML inspections of registered agents and can issue warning notices, financial penalties, and licence suspensions for non-compliance.
Financial Reporting Requirements
Under the Business Companies Act 2021, Seychelles IBCs are required to maintain accounting records sufficient to give a true and fair view of the company's financial position and to explain its transactions. The accounting records do not need to be audited or filed with any public authority (Seychelles does not require public financial statements for IBCs), but they must be:
- Maintained in Seychelles (or at a location known to the registered agent)
- Kept for a minimum of seven years from the date of each transaction recorded
- Available for inspection by the FSA on request
CSPs should collect financial statements or accounting records from clients annually and retain them as part of the entity's compliance file. While the standard is not onerous by audit standards, complete absence of accounting records is a significant AML risk indicator.
Seychelles and the EU Blacklist
Seychelles was placed on the EU list of non-cooperative jurisdictions for tax purposes (the "EU blacklist") in 2022, and was subsequently removed following implementation of additional tax cooperation measures. However, the blacklisting period reinforced banking pressure on Seychelles structures — with some financial institutions applying enhanced scrutiny or outright refusing to open accounts for Seychelles IBCs.
CSPs should advise clients that while Seychelles has addressed the EU's concerns, perceptions among banking institutions may lag behind regulatory reality. Demonstrating substantive activity, complete beneficial ownership information, and well-maintained KYC records remains essential for maintaining banking relationships.
CSP Operational Checklist for Seychelles IBCs
For CSPs administering Seychelles IBC portfolios, the following should be standard practice:
- Maintain a current beneficial ownership register for every IBC, updated within 30 days of any change
- Calendar annual fee payment dates and good standing confirmation obligations
- Complete CDD at onboarding and periodic review at least every three years (annually for high-risk)
- Screen beneficial owners and directors against sanctions lists on an ongoing basis
- Collect accounting records or financial summaries annually and retain for seven years
- Maintain MLRO appointment and SAR filing procedures current with FSA requirements
- Monitor FSA regulatory updates, which have been frequent since the 2021 Act came into force
The Seychelles IBC market remains substantial and the jurisdiction continues to attract offshore structures for legitimate international business purposes. CSPs that maintain robust compliance systems for their Seychelles portfolios are well positioned — both to satisfy the FSA and to help clients navigate banking due diligence requests with confidence.