Financial Integrity Monitor

Comoros — Anjouan KM-A

Sources

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).

Technical compliance is weak (R.7, R.22 rated Non-Compliant) and the FIU is not an Egmont member.

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

The Union of the Comoros FIU is not a member of the Egmont G…

The Union of the Comoros FIU is not a member of the Egmont Group and therefore cannot use the Egmont Secure Web; it relies on only six bilateral cooperation agreements and reciprocal GIABA information-sharing, making little use of foreign-FIU requests when processing suspicious transaction reports.

The Union's 2024 mutual evaluation rated Recommendation 22 (…

The Union's 2024 mutual evaluation rated Recommendation 22 (DNFBP customer due diligence) Non-Compliant, reflecting the absence of an effective AML/CFT supervisory authority or risk-based supervisory procedures for designated non-financial businesses and professions, including company-formation agents.

No island-level Anjouan AML/CFT regulator, beneficial-owners…

No island-level Anjouan AML/CFT regulator, beneficial-ownership registry, or licensing authority exists independently of the Union; the register fields for an Anjouan-specific supervisor could not be populated because none exists in law. Meanwhile, entities styled 'Anjouan Offshore Financial Authority' and 'Mwali International Services Authority' continue to be invoked internationally despite the Comoros Central Bank's public statement that they hold no legitimacy.

The National Anti-Money Laundering and Counter-Terrorist Fin…

The National Anti-Money Laundering and Counter-Terrorist Financing Committee's work on corruption is hampered by the dissolution of the National Anti-Corruption Commission (CNPLC), which had forwarded 55 corruption cases to the Prosecutor's office with outcomes that remain unknown, and no replacement anti-corruption agency has been established.

Evidence

Confidence-tiered claims

No structured claims published for this jurisdiction yet.