Financial Integrity Monitor
Comoros — Anjouan KM-A
Sources
8
Jurisdiction profile
CompliantTier CRisk: IncreasingPermissive
Anjouan has no distinct island-level AML/CFT law or regulator; it is governed entirely by the Union of the Comoros' national framework (BCC supervision, FIU under the Ministry of Finance, GIABA-assessed 2024 MER).
Key deficiencies
- FIU is not a member of the Egmont Group and makes limited use of foreign-FIU information requests
- No effective AML/CFT supervisory authority or practices for DNFBPs (R.22 rated Non-Compliant)
- No targeted financial sanctions framework for proliferation financing (R.7 rated Non-Compliant)
- National Anti-Corruption Commission (CNPLC) dissolved with 55 unresolved cases pending
- Island-level offshore 'authorities' purporting to license financial firms from Anjouan are publicly disclaimed by the Union Central Bank as having no legal legitimacy
- High level of informality in the economy and weak inter-agency AML/CFT cooperation
Recent developments (18m)
- GIABA/FATF follow-up report (31 May 2026) analysing Comoros' progress addressing 2024 MER technical compliance deficiencies
- FATF confirms Comoros remains off both the grey list and call-for-action list as of the 19 June 2026 plenary
- EU Delegated Regulations (EU) 2026/46 and (EU) 2026/83 (in force 29 January 2026) update the high-risk third-country list without adding Comoros
- OCCRP (December 2025) documents a global investment-scam network using fake licenses purportedly issued by the 'Anjouan Offshore Financial Authority' and 'Mwali International Services Authority', both publicly disclaimed by the Comoros Central Bank as illegitimate
- Repeated OFAC SDN designations (2024–2026) of Comoros-flagged oil and LPG tankers linked to Iran's shadow fleet oil-export network
Regulatory horizon
No dated horizon items this cycle. 3 items tracked without a confirmed date.
3 pending date · baseline financial-integrity-2026-10-03
Registers
Enforcement actions
- OFAC added two Comoros-flagged oil tankers to the SDN List under Iran sanctions authority EO 13902, linking them to Iran's oil export network used to fund the regime's military and proliferation activities. 24 Apr 2026
- OFAC designated the Comoros-flagged crude oil tanker FELICITA as part of a package targeting Iran's shadow fleet and networks supplying Iran's ballistic missile and advanced conventional weapons programs. 25 Feb 2026
- Four separate Comoros-flagged LPG and crude oil tankers, linked to distinct shipping-company fronts, were added to OFAC's SDN List for carrying Iranian-origin petroleum in violation of U.S. sanctions. 9 Oct 2025
- GIABA published a follow-up report analysing the Union of the Comoros' progress in addressing technical compliance deficiencies identified in its May 2024 mutual evaluation report, as part of the FATF Global Network's standard post-MER monitoring process. 31 May 2026
Sanctions changes
- Recurring OFAC SDN designations of individually-named Comoros-flagged oil and LPG tankers under Iran sanctions executive orders (EO 13902, EO 13846), spanning at least seven separate designation actions between April 2024 and April 2026, each tied to a different nominal shipping-company owner. 24 Apr 2026
- The European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 (in force 29 January 2026), updating the AML/CFT high-risk third-country list to add Bolivia, the British Virgin Islands and Russia while Comoros remained unlisted, consistent with FATF's parallel exclusion of Comoros from its grey list. 29 Jan 2026
- As part of a broader administrative consolidation of duplicate OFAC SDN List entries, a Comoros-issued passport number entry was deleted; OFAC clarified that underlying designations and blocked property remain in effect despite the removal of the duplicate record. 27 Jul 2026
Regulatory horizon (register)
- GIABA next follow-up report on Comoros MER progress
- Next FATF plenary grey/black list review
- Possible GIABA full re-evaluation onsite period
Active schemes
- [HIGH] Comoros flag-of-convenience Iran shadow-fleet tankers
- Impersonated Anjouan/Mwali 'offshore finance authority' licenses
- Anjouan-coast gold smuggling transit route
Sources
Coverage gaps
Evidence
Confidence-tiered claims
No structured claims published for this jurisdiction yet.