Financial Integrity Monitor

Comoros KM

Sources
9
Jurisdiction profile
Largely CompliantTier CRisk: StableMixed

AML/CFT governed by Law N°20-005/AU, implemented via Decision n°12-2023/BCC/DSBR and TFS Decree N°23-074/PR.

MoreSupervisor: Banque Centrale des Comores (BCC); FIU: Service de Renseignements Financiers (SRF), est. Décret N°03-025/PR (2003), reinforced Ordinance N°09-002/PR (2009). Assessed by GIABA (FSRB) under 2012 FATF Recommendations/2013 Methodology; 2nd round MER adopted May 2024 found mixed technical compliance and very low effectiveness, placing Comoros under enhanced follow-up. Not on FATF or EU high-risk lists.

Key deficiencies
  • R.7 (proliferation-related TFS) rated Non-Compliant; no national PF cooperation framework
  • R.22 (DNFBP customer due diligence) rated Non-Compliant; DNFBPs have never filed a single STR
  • No mechanism to collect/verify beneficial ownership of legal arrangements (trusts) — R.25 Partially Compliant
  • Only one ML conviction ever obtained nationally; zero TF prosecutions despite TF criminalisation
  • Corruption within law-enforcement agencies hampers ML investigations; National Anti-Corruption Commission (CNPLC) dissolved
  • No asset recovery/management mechanism for seized and confiscated property
  • Virtual-asset/VASP framework underdeveloped per MER
Recent developments (18m)
  • GIABA published a progress/follow-up report (31 May 2026) analysing Comoros's steps to address the 2024 MER's technical-compliance deficiencies
  • OCCRP's 'Scam Empire' investigation (published ~Dec 2025) exposed transnational investment-fraud platforms using fake licences purportedly issued by non-existent 'Mwali International Services Authority' and 'Anjouan Offshore Financial Authority'; BCC publicly confirmed these bodies are not official
  • EU Commission reviewed and again excluded Comoros from its AMLD high-risk third-country list through successive December 2025 and June 2025 delegated-regulation updates
  • FATF's 19 June 2026 Plenary update confirmed Comoros remains absent from both the grey list and the call-for-action (black) list
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

  • GIABA published a progress/follow-up report analysing Comoros's steps to address the technical-compliance deficiencies identified in its May 2024 second-round Mutual Evaluation Report, as part of the enhanced follow-up process Comoros was placed under. 31 May 2026
  • BCC publicly confirmed to investigative journalists that these two purported offshore regulatory bodies are not official and have no legitimacy to grant licences, after OCCRP identified at least four fraudulent investment-platform licences citing them. 18 Dec 2025
  • Regulators in Switzerland, Canada and the UK flagged a majority of the 81 investigated investment-platform brands, including those citing the fake 'Mwali' and 'Anjouan' Comoros authorities, as unauthorized to offer financial services. 18 Dec 2025

Sanctions changes

  • On 3-4 December 2025 the European Commission adopted Delegated Regulations (EU) 2026/46 and (EU) 2026/83 updating the AMLD Article 9 high-risk third-country list, adding Russia, Bolivia and the British Virgin Islands while delisting Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania. Comoros was neither added nor removed, confirming its continued non-listed status through this review cycle. 4 Dec 2025
  • On 10 June 2025 the European Commission added Algeria, Angola, Côte d'Ivoire, Kenya, Laos, Lebanon, Monaco, Namibia, Nepal and Venezuela to the AMLD high-risk third-country list and delisted Barbados, Gibraltar, Jamaica, Panama, the Philippines, Senegal, Uganda and the UAE. Comoros was not part of either list movement in this update. 10 Jun 2025

Regulatory horizon (register)

  • GIABA next enhanced follow-up report on Comoros
  • Next GIABA Mutual Evaluation onsite (5th Round Methodology)
  • Next EU AMLD high-risk third-country list update

Active schemes

  • [HIGH] Fake Comoros offshore regulators licensing scam platforms
  • Anjouan legacy offshore banking/shell sector
  • [HIGH] Indian Ocean Southern Route transit: heroin and gold smuggling
  • Gulf faith-based foundation funding flows (CTF risk)
Sources
  1. Banque Centrale des Comores
  2. Banque Centrale des Comores / Union of the Comoros Council of Ministers
  3. GIABA (FATF-Style Regional Body)
  4. Financial Action Task Force
  5. European Commission (DG FISMA)
  6. OCCRP
  7. UNODC
  8. ICIJ Offshore Leaks
  9. FATF / GIABA
Coverage gaps
The Comorian authorities have obtained only one money-launde…
The Comorian authorities have obtained only one money-laundering conviction in the country's history, and law-enforcement agencies have yet to identify a single terrorist-financing case despite TF being fully criminalised in domestic law.
Comoros has no mechanism to collect or verify beneficial-own…
Comoros has no mechanism to collect or verify beneficial-ownership information for legal arrangements such as trusts, and DNFBP customer due diligence (R.22) is rated Non-Compliant.
Comoros's National Anti-Corruption Commission (CNPLC) has be…
Comoros's National Anti-Corruption Commission (CNPLC) has been dissolved, and corruption within law-enforcement agencies is repeatedly cited by assessors as hampering ML investigations and undermining judicial independence in corruption-linked cases.
All suspicious transaction reports received by the FIU origi…
All suspicious transaction reports received by the FIU originate from banks; designated non-financial businesses and professions (notaries, real-estate agents, DFIs) have never filed a single STR, and supervision of these sectors is not risk-based.
Fraudulent entities invoking the Comoros name ('Mwali Intern…
Fraudulent entities invoking the Comoros name ('Mwali International Services Authority', 'Anjouan Offshore Financial Authority') continue to be used by transnational scam networks years after the Central Bank publicly disclaimed them, with no confirmed takedown or international notification mechanism identified.
No OFAC SDN designation, OFSI UK sanctions listing, or UN Se…
No OFAC SDN designation, OFSI UK sanctions listing, or UN Security Council 1267/1988/2231 Committee action specific to a Comorian national or entity was identified within the 18-month window across the T1/T2 sources reviewed.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.