Financial Integrity Monitor

Comoros — Mohéli (Mwali) KM-M

Sources
8
Jurisdiction profile
CompliantTier CRisk: StablePermissive

Mohéli has no distinct island-level AML/CFT legal framework; it is governed entirely by Union of the Comoros law (Law 12-008/AU, Act 21-004/AU of 29 June 2021) and supervised by the national Central Bank (BCC) and Financial Intelligence Service (SRF, Decree 20-145/2020).

MoreGIABA's May 2024 MER rated the Union Non-Compliant/Partially Compliant on most of the 40+9 Recommendations, placing it under enhanced follow-up.

Key deficiencies
  • No beneficial-ownership register or mechanism to identify BOs of legal persons (R.24/R.25 rated LC/PC)
  • FIU (SRF) not an Egmont Group member; limited foreign cooperation agreements
  • No effective AML/CFT supervisory authority or risk-based supervision of DNFBPs (R.26/R.22 rated NC)
  • Persistent impersonation of Mohéli's name by fake 'Mwali International Services Authority' banking/offshore licenses
  • No TF-related financial-intelligence disseminations despite elevated regional CTF exposure
  • No island-level AML/CFT data, statistics or supervisory primary sources distinct from the Union
Recent developments (18m)
  • GIABA adopted the Union of the Comoros' first full-cycle Mutual Evaluation Report in May 2024, rating it Largely Compliant on only 4 of 40+9 Recommendations and placing it under enhanced follow-up
  • GIABA published a follow-up progress report on 31 May 2026 analysing technical-compliance remediation since the 2024 MER
  • OCCRP's December 2025 'Scam Empire' investigation documented continued use of fake 'Mwali International Services Authority' and 'Anjouan Offshore Financial Authority' licenses by a transnational scam network, reconfirmed as illegitimate by the Central Bank of the Comoros
  • Multiple Comoros-flagged oil/LPG tankers were added to OFAC's SDN list under Iran-related sanctions programs across at least six separate actions between July 2025 and April 2026
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 the Comoros-flagged LPG tanker FOTIS to the SDN List under Iran-related sanctions (IRAN-EO13902) for its role in transporting Iranian petroleum products. 3 Jul 2025
  • OFAC designated four Comoros-flagged tankers (crude oil and LPG carriers) under Iran-related sanctions (IRAN-EO13902), linked to entities including S E A Ship Management LLC, Vega Star, Bertha Shipping Inc. and Sullana Inc. 9 Oct 2025
  • OFAC designated three further Comoros-flagged tankers under Iran-related sanctions (IRAN-EO13902), linked to Aayat Ship Management Private Limited and Trade Bridge Global Inc. 23 Jan 2026
  • GIABA published a follow-up report analysing the Union of the Comoros' progress in addressing the technical-compliance deficiencies identified in its May 2024 Mutual Evaluation Report, under the enhanced follow-up process. 31 May 2026

Sanctions changes

  • OFAC listed multiple Comoros-flagged tankers (AVON, CHIRON 5, KEEL) on the SDN List under Iran-related sanctions, continuing a pattern of individual vessel designations rather than any blanket Comoros country-level measure. 23 Jan 2026
  • OFAC designated the Comoros-flagged crude oil tanker FELICITA and the oil-products tanker MIRAAN (a.k.a. CHINTAMANI) and crude tanker GOLDEN SUNRISE under Iran-related non-proliferation and sanctions programs across two further 2026 actions. 24 Apr 2026
  • The EU Council added 41 further vessels to its Russia shadow-fleet listing (port access ban and maritime-services ban), bringing the EU's total designated shadow-fleet vessels to almost 600, alongside new listings of nine shadow-fleet enabler entities. 18 Dec 2025

Regulatory horizon (register)

  • Next GIABA enhanced follow-up report on Comoros
  • 5th-round FATF/GIABA Mutual Evaluation of Comoros
  • Possible FIU (SRF) application for Egmont Group membership

Active schemes

  • [HIGH] Fake 'Mwali' offshore banking/registry impersonation
  • [HIGH] Comoros flag-of-convenience use by Iran shadow fleet
Sources
  1. Banque Centrale des Comores / Government of the Union of the Comoros
  2. GIABA (FATF-Style Regional Body, first-party assessment)
  3. FATF
  4. U.S. Department of the Treasury, OFAC
  5. OCCRP
  6. OCCRP
  7. Council of the European Union
  8. GIABA / FATF
Coverage gaps
The Comorian FIU (Service de Renseignements Financiers) is n…
The Comorian FIU (Service de Renseignements Financiers) is not a member of the Egmont Group, has signed few cooperation agreements with foreign counterparts, and makes little use of requests for information from foreign FIUs, despite the Union being more exposed to ML of proceeds of crimes committed abroad than domestically.
The Union of the Comoros lacks a register and an appropriate…
The Union of the Comoros lacks a register and an appropriate mechanism for identifying beneficial owners of legal persons; MER 2024 flagged this, alongside a lack of ML/TF risk assessment of legal persons, as a serious and ongoing deficiency (R.24/R.25 rated LC/PC).
No actively maintained international blacklist or searchable…
No actively maintained international blacklist or searchable island-level verification portal exists to pre-empt continued impersonation of Mohéli's name by self-styled 'Mwali International Services Authority' and similar fake offshore bodies; the Central Bank of the Comoros only responds reactively, case by case, to journalist or regulator inquiries.
No island-level (Mohéli-specific) AML/CFT supervisory statis…
No island-level (Mohéli-specific) AML/CFT supervisory statistics, sectoral risk assessment, or primary regulatory source distinct from the Union-level NRA/MER exists; all cited primaries necessarily speak to the Union of the Comoros as a whole rather than to Mohéli specifically.

Evidence

Confidence-tiered claims

Gambling is prohibited nationally under the Comorian Penal Code and therefore outside sectoral AML/CFT supervisory scope. SRC-fim-KM-M-001
Probable · 1 source
Comoros is not on the FATF grey list; GIABA's 2nd Enhanced Follow-Up Report cycle (2026) proceeded without a re-rating request. SRC-fim-KM-M-002
Probable · 1 source
Licences issued by MISA have no legal or practical validity according to investigative press coverage. SRC-fim-KM-M-003
Probable · 1 source
The Comoros does not have a dedicated legal framework governing virtual assets. SRC-fim-KM-M-004
Probable · 1 source