Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved.

Financial Integrity Monitor

Comoros KM

Domains (D1–D6)

Sources

Role actions

Horizon <90d

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.

Supervisor: 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

Brief

Lead signal

Lead Signal

Read full brief

Lead Signal

On 8 October 2026 the US Treasury Office of Foreign Assets Control added two Comoros-flagged tankers, PARITOSH (IMO 9383352) and SOGL (IMO 9208227), to the Specially Designated Nationals List under the Iran-EO13902 programme. The designation extends a pattern in which the Comoros open ship registry continues to flag vessels later identified as carrying sanctioned Iranian, Russian or Venezuelan cargo, a pattern already reflected in the European Union, United Kingdom and United States blacklisting of 110 Comorian-flagged ships in 2025. Read together with reporting that 46 vessels formerly flagged to Comoros or Gambia had migrated to Russia's own ship registry by June 2026, the architecture reading is that de-flagging by enforcement pressure is redistributing shadow-fleet tonnage rather than removing it from the sanctions-evasion ecosystem, and the Comoros registry remains a recurring node in that redistribution.

This sits alongside a separate but structurally connected signal on the compliance side of the ledger. GIABA adopted a second Enhanced Follow-Up Report on Comoros, reported to credit a new 2025 AML/CFT/CPF law and Banque Centrale des Comores institutional reforms with upgrades across thirteen FATF Recommendations from the baseline set in the May 2024 Mutual Evaluation Report, which had rated the country largely compliant on only four Recommendations and non-compliant on twenty-three. The improving technical-compliance trajectory and the escalating sanctions-designation trajectory are not contradictory: a jurisdiction can tighten its domestic AML/CFT statute while its open-registry maritime sector remains structurally exposed to flag-of-convenience misuse, since ship registration and financial-institution supervision sit in different parts of the same state architecture.

Other Developments

A constitutional divide in financial-legislative competence persists. Reporting citing Article 9 of the Union Constitution and Organic Law No. 05-003/AU states that banking and financial legislation falls under the exclusive competence of the Union government and the Banque Centrale des Comores, not the island-level administrations. This is relevant background to the recurring commentary on licence-issuing bodies purporting to operate from island-level authority, since any licence issued outside the Union government framework sits outside the competence the constitutional architecture assigns to financial regulation.

Axian secured a Union-level fintech licence. On 24 February 2026 the pan-African telecom and financial group Axian obtained a Decentralized Digital Financial Institution licence from the Banque Centrale des Comores, permitting a fully digital, branchless lending entity offering mobile nano- and micro-loans. The licence was granted by the Union-level central bank, placing it inside the constitutional competence described above, and stands as a distinguishable category from licensing activity attributed to island-level claimant bodies.

GIABA's follow-up report leaves acknowledged gaps. Alongside the reported upgrades, virtual-asset regulation, beneficial-ownership risk, and sanctions-screening guidance are reported to remain unresolved weaknesses in the Comoros AML/CFT/CPF framework. The full text of the underlying 2025 law has not been independently located, so whether it contains virtual-asset-specific provisions remains an open question rather than a settled one.

Cross-Monitor Connections

The maritime sanctions-evasion signal connects directly to conflict-finance and commodity-flow monitoring: a Comoros-flagged tanker carrying Iran-origin cargo under an EO13902 designation is, by definition, part of the financing architecture that conflict-finance and extractive-industry integrity analysis tracks on the commodity side. The redistribution of de-flagged tonnage toward Russia's own registry is a structural indicator worth routing to monitors tracking state-capture and sanctions-circumvention infrastructure more broadly, since it shows enforcement in one registry displacing risk into a differently governed one rather than eliminating it. The GIABA follow-up report, by contrast, is a pure financial-integrity regime signal with no immediate cross-monitor routing requirement, though its acknowledged virtual-asset gap is a marker worth revisiting if a dedicated Comoros VASP framework later emerges.

Outlook

The near-term signal to watch is whether further OFAC, EU or UK designations continue to name Comoros-flagged vessels, which would confirm the registry's continued role in shadow-fleet operations notwithstanding the reported de-flagging trend toward Russia's own registry. On the regulatory side, the next FATF-aligned assessment point for Comoros is a prospective third-round mutual evaluation, presently placed in the early 2030s and subject to wide scheduling uncertainty; in the interim, the test of the 2025 AML/CFT/CPF law's substance, particularly on virtual assets and beneficial ownership, will depend on primary legislative text becoming available for direct review rather than on secondary summary reporting. The Axian licence is worth tracking as a marker of Union-level regulated fintech entry against the backdrop of the unresolved island-level licensing question; whether other Union-level digital financial institution licences follow will indicate whether this is an isolated grant or the start of a pattern.

weekly_brief_draft · JID KM

Domain intelligence (D1–D6)

D1 Sanctions Architecture and Evasion

Sanctions Architecture and Evasion

On 8 October 2026 OFAC added two Comoros-flagged tankers, PARITOSH (an asphalt/bitumen tanker, IMO 9383352, built 2008) and SOGL (an LPG tanker, IMO 9208227), to the Specially Designated Nationals List under the Iran-EO13902 sanctions programme. The designation is a Tier-1 primary-source finding and confirms, as a matter of record rather than inference, that the Comoros open ship registry continues to carry vessels subsequently identified as moving Iran-sanctioned cargo. This is not an isolated episode: the European Union, United Kingdom and United States collectively blacklisted 110 Comorian-flagged ships in 2025 for participation in sanctions-evasion oil shipments, chiefly linked to Russian trade. The architecture-over-incident reading is that the Comoros flag has functioned, across a sustained period and across more than one sanctions programme (Iran and Russia), as a convenience flag of choice for shadow-fleet operators seeking to obscure vessel beneficial ownership and operational control from the jurisdictions imposing the sanctions.

A complicating structural development is reported migration away from the Comoros flag. By June 2026, 46 vessels formerly registered under Comoros or Gambia flags had joined Russia's own ship registry, according to reporting that frames this as a response to mounting EU, UK and US enforcement pressure on open-registry flags historically associated with shadow-fleet tonnage. This is a meaningful architectural shift: rather than indicating that Comoros-flagged sanctions exposure is receding, it suggests displacement of existing tonnage into registries less exposed to Western enforcement leverage, while fresh tonnage, including the PARITOSH and SOGL designations from October 2026, continues to appear under the Comoros flag. The two dynamics running concurrently, departure of some vessels and arrival of newly designated vessels, indicate that the underlying vulnerability in Comoros flag-state oversight capacity has not been structurally resolved, only partially redistributed.

For firms with correspondent banking, trade finance, marine insurance or shipping-related exposure, the designation pattern reinforces the standing screening requirement to treat Comoros flag-state registration as a heightened-attention indicator within broader sanctions-screening and vessel-ownership due diligence processes, consistent with the obligation references already associated with the OFAC designation action. The underlying Comoros state capacity to police its own flag registry against reflagging by sanctioned or sanctions-adjacent beneficial owners remains the structural question GIABA's assessment process has separately been testing, and the pattern of repeated designations against a background of improving domestic AML/CFT legislative capacity, discussed further under the AML/CTF regime lens, illustrates how financial-sector legislative reform and maritime flag-state oversight capacity are governed by different parts of the Comoros state apparatus and can move on different trajectories.

Outlook

The pattern to monitor is whether subsequent OFAC, EU or UK designation rounds continue to name Comoros-flagged vessels at a similar or accelerating rate, which would indicate the registry remains an active enabling node notwithstanding the reported shift of some tonnage to Russia's own registry. Any future action, consultation or statement from the Comoros flag-state administration addressing vessel beneficial-ownership verification or deregistration of sanctions-designated tonnage would be a material structural development against the current baseline, in which no such corrective action has been identified. Absent such a development, the registry's sanctions-exposure profile should be read as continuing on its present escalating trajectory as scheduled, pending further primary-source designation or enforcement data becoming available.

D2 Beneficial Ownership

Not covered

Beneficial Ownership is not yet covered for this jurisdiction in this report.

D3 Enabler Jurisdictions and Professional Facilitators

Enabler Jurisdictions and Professional Facilitators

Comoros' open ship registry continues to function as an enabling architecture for sanctions-evasion shipping tied to Iran, Russia and Venezuela trades. The 8 October 2026 OFAC designation of the Comoros-flagged tankers PARITOSH and SOGL under the Iran-EO13902 programme is the latest instance of a pattern already evidenced by the 2025 blacklisting of 110 Comorian-flagged vessels by the European Union, United Kingdom and United States. Reporting further indicates that 46 vessels formerly registered to Comoros or Gambia migrated to Russia's own ship registry by June 2026, a development read here as displacement under enforcement pressure rather than resolution of the underlying registry vulnerability: departing tonnage is offset by newly designated tonnage still carrying the Comoros flag. The enabling role is structural rather than episodic, since it rests on open-registry practice and flag-state oversight capacity rather than on any single transaction or vessel.

A second, separate enabler-jurisdiction signal concerns the governance architecture of financial licensing within Comoros itself. Reporting citing Article 9 of the Union Constitution and Organic Law No. 05-003/AU states that banking and financial legislation falls under the exclusive competence of the Union government and the Banque Centrale des Comores, with island-level administrative bodies holding no corresponding competence. This constitutional allocation is directly relevant to the recurring commentary around entities purporting to issue financial or gaming licences from island-level authority: any such licence sits outside the competence structure that Union law assigns to financial regulation, a gap between claimed authority and constitutional competence that is itself the enabling mechanism, since the claimant bodies derive apparent legitimacy from occupying a space the Union legal architecture does not actually allocate to them. The Banque Centrale des Comores has separately been reported to warn the public about fictitious structures claiming to issue licences to banks and financial institutions within the Union of the Comoros, a warning consistent with the constitutional-competence gap described above, though the warning itself and the competence allocation are evidenced separately and should be read as mutually reinforcing rather than as a single sourced claim.

Read together, the maritime and licensing-governance signals describe two different registries, open ship flagging and purported financial licensing, both of which derive their enabling function from the same underlying structural feature: a gap between formal legal competence (vested in a central authority, the Union government for finance, international flag-state obligations for shipping) and the practical capacity to prevent that competence from being exploited or impersonated by actors operating at arm's length from it.

Outlook

The near-term indicator to watch on the maritime side is whether the Comoros flag registry continues to attract fresh sanctions-designated tonnage even as some vessels depart for the Russian registry, which would confirm the registry's continued enabling role rather than its retirement from shadow-fleet use. On the licensing-governance side, the outlook depends on whether the Union government or Banque Centrale des Comores takes any public enforcement or clarification action against island-level bodies purporting to issue financial licences outside their constitutional competence; no such action has been identified to date, and the structural gap should be treated as continuing as scheduled absent a confirmed intervention.

D4 Conflict Finance

Not covered

Conflict Finance is not yet covered for this jurisdiction in this report.

D5 Crypto / Digital Assets / Financial Innovation

Not covered

Crypto / Digital Assets / Financial Innovation is not yet covered for this jurisdiction in this report.

D6 Compliance Technology & Active Defence

Not covered

Compliance Technology & Active Defence is not yet covered for this jurisdiction in this report.

D7 AML/CTF Regime

AML/CTF Regime

GIABA adopted a second Enhanced Follow-Up Report on the Union of the Comoros, reported to have been adopted around July 2026, following the Mutual Evaluation Report adopted in June 2024 and a first Follow-Up Report in May 2025. The Tier-1 GIABA source confirms the existence and sequencing of this follow-up process; the specific detail that the report upgraded Comoros across thirteen FATF Recommendations rests on secondary reporting that credits a new 2025 AML/CFT/CPF law and Banque Centrale des Comores institutional-capacity reforms for the improvement, a detail not independently verified against the GIABA report's full text at this station. Against the May 2024 Mutual Evaluation Report baseline, Comoros had been rated largely compliant on only four of the forty FATF Recommendations assessed, partially compliant on thirteen Recommendations and three Special Recommendations, and non-compliant on twenty-three Recommendations, a starting position reflecting substantial technical-compliance gaps across the framework.

The reported upgrades sit alongside acknowledged gaps that the follow-up process is said to have left unresolved: virtual-asset regulation, beneficial-ownership risk, and sanctions-screening guidance. These three gap areas are analytically significant precisely because they intersect with the other findings in this cycle. The continued appearance of Comoros-flagged vessels on the OFAC Specially Designated Nationals List, most recently on 8 October 2026, is consistent with a sanctions-guidance gap that the follow-up process is reported to still be tracking; a domestic AML/CFT law can improve on paper while sanctions-screening implementation in a specific high-risk sector, shipping, continues to show gaps in practice. Similarly, the unresolved beneficial-ownership gap bears on the standing question of which bodies within Comoros, Union-level or island-level, hold legitimate competence to license financial entities, since beneficial-ownership transparency and licensing-authority clarity are adjacent control functions.

The three-pillar balance point worth surfacing explicitly is that this cycle's evidence speaks predominantly to the AML and governance-capacity pillar, through the reported new law and institutional reforms, while the CTF pillar is represented by the continuing sanctions designations against Comoros-flagged shipping, and no CPF-specific development was identified. This is consistent with the general pattern in which AML enforcement and legislative volume tends to generate more visible signal than CTF or CPF developments, and the gap areas GIABA's process is reported to have flagged, sanctions guidance among them, should be read as a reminder that technical-compliance upgrades on paper do not automatically resolve CTF-relevant implementation gaps in practice.

Outlook

The most direct test of whether the reported technical-compliance upgrades translate into practice will be whether the underlying 2025 AML/CFT/CPF law's text becomes available for direct review, clarifying whether it contains virtual-asset-specific provisions, a question presently unresolved. The next scheduled assessment point in the GIABA/FATF mutual evaluation cycle is a prospective third-round evaluation, presently placed in the early 2030s and subject to substantial scheduling uncertainty at this stage; in the interim, continuing sanctions-designation activity against Comoros-flagged vessels will be a more immediate practical indicator of whether the sanctions-guidance gap GIABA's process has flagged is being addressed. As scheduled, no near-term plenary action beyond the second Follow-Up Report has been identified.

D8 Commercial Activity

Commercial Activity

On 24 February 2026 the pan-African telecommunications and financial-services group Axian obtained a Decentralized Digital Financial Institution licence from the Banque Centrale des Comores, enabling the establishment of a newly regulated, fully digital, branchless lending entity. The licence permits mobile-based nano- and micro-lending, placing Axian within the category of Union-level regulated fintech entrants operating under the Banque Centrale des Comores' direct licensing authority. This is a Tier-3-sourced development, corroborated across multiple trade-press outlets, though no primary Banque Centrale des Comores press release or licence register entry was independently retrieved to confirm the grant at a Tier-1 or Tier-2 level.

The commercial significance of the Axian licence is sharpened by its contrast with the separate, unresolved question of licensing activity attributed to island-level claimant bodies operating outside the Union government's constitutionally exclusive competence over banking and financial legislation, as set out in Article 9 of the Union Constitution and Organic Law No. 05-003/AU. The Axian licence, by contrast, was granted by the Union-level central bank itself and therefore sits squarely within the competence structure the constitutional architecture assigns to financial regulation. For counterparties and due-diligence functions assessing Comoros-linked financial entities, this distinction between Union-level licensing, which carries constitutional and regulatory legitimacy, and island-level claimant licensing, which reportedly does not, is a material point of differentiation when assessing the legitimacy of any Comoros-domiciled financial licence presented to them.

The Axian licence should also be read against the backdrop of Comoros' reported AML/CFT/CPF legislative reform, since a newly licensed, digitally native, branchless lending institution introduces a financial-services channel, mobile nano- and micro-lending, that was not necessarily contemplated in detail by the pre-2025 regulatory baseline. Whether the Banque Centrale des Comores' supervisory capacity for such a digital-first entity has kept pace with the licensing decision, particularly given the acknowledged virtual-asset and beneficial-ownership gaps reported elsewhere in GIABA's assessment process, is a question this cycle's evidence does not resolve, since no supervisory or examination record for the newly licensed entity was located.

Outlook

The commercial development to monitor is whether further Union-level digital financial institution licences are granted by the Banque Centrale des Comores in the period following the Axian grant, which would indicate an emerging pattern of regulated fintech entry rather than an isolated case. Equally relevant will be whether any Banque Centrale des Comores supervisory statement, examination report or enforcement action concerning digitally native lending entities becomes available, which would clarify whether supervisory capacity has kept pace with this new licensing category. No such follow-on development has been identified as of this cycle, and the position should be treated as stable as scheduled pending further primary-source confirmation.

Regulatory horizon

Proposed2031-Q3 · ±multi_year

GIABA 3rd Round Mutual Evaluation of Comoros

A future on-site assessment will re-test technical compliance and effectiveness.

Source

1 dated · 3 pending date · baseline financial-integrity-2026-10-03

Role action cards

MLRO

OFAC designated two further Comoros-flagged tankers under the Iran sanctions programme on 8 October 2026.

Comoros flag-state registration continues to appear on vessels subject to new Specially Designated Nationals List additions, reinforcing the case for treating Comoros flag registration as a heightened-attention factor in vessel-ownership and trade-finance sanctions screening.

3 evidence refs

Compliance

GIABA reported upgrading Comoros across thirteen FATF Recommendations in a second Enhanced Follow-Up Report, while flagging virtual-asset, beneficial-ownership and sanctions-guidance gaps as unresolved.

The reported technical-compliance improvement reflects legislative and institutional reform rather than a resolved implementation gap in sanctions screening, as shown by the continuing Comoros-flagged vessel designations; compliance frameworks referencing Comoros should not treat the GIABA upgrade as closing the sanctions-guidance gap.

3 evidence refs

Legal

Union Constitution art. 9 and Organic Law No. 05-003/AU reportedly reserve financial legislative competence exclusively to the Union government, distinguishing legitimate Union-level licensing from island-level claimant activity.

Any Comoros-domiciled financial or gaming licence presented by a counterparty should be assessed against whether it was issued by the Union-level Banque Centrale des Comores or by an island-level body lacking constitutional competence, a distinction material to licence validity and counterparty risk.

1 evidence refs

Board

Comoros continues to present a dual profile: a reported improving domestic AML/CFT legislative trajectory alongside an escalating pattern of sanctions designations tied to its ship registry.

The two trajectories are not contradictory but reflect different parts of the same state apparatus moving at different speeds; reputational and counterparty exposure tied to Comoros flag-state shipping should be assessed separately from exposure tied to Comoros-domiciled regulated financial entities.

3 evidence refs

CTO

Axian obtained a Decentralized Digital Financial Institution licence from the Banque Centrale des Comores on 24 February 2026 for a mobile-based nano- and micro-lending platform.

A newly licensed digitally native lending platform introduces a financial-services channel whose supervisory maturity relative to acknowledged virtual-asset and beneficial-ownership gaps in the Comoros AML/CFT framework has not been independently confirmed.

1 evidence refs

Risk

Comoros flag registry risk is assessed as structural and increasing, driven jointly by continued sanctions designations and an unresolved constitutional divide in financial licensing competence.

Both the maritime and licensing-governance signals point to the same underlying mechanism, a gap between formal legal competence and practical enforcement capacity, warranting continued structural-risk rather than episodic-incident treatment in exposure models referencing Comoros.

2 evidence refs

Operations

No material change for this persona this cycle.

No material change for this persona this cycle

Audit

The full text of the 2025 Comoros AML/CFT/CPF law referenced in GIABA's follow-up report has not been independently located or verified.

Any internal control documentation asserting the content or scope of the new Comoros AML/CFT/CPF law should be flagged for review against primary legislative text once available, rather than relied upon from secondary summary reporting alone.

1 evidence refs

Decision lens

MLRO

OFAC designated two further Comoros-flagged tankers under the Iran sanctions programme on 8 October 2026.

Compliance

GIABA reported upgrading Comoros across thirteen FATF Recommendations in a second Enhanced Follow-Up Report, while flagging virtual-asset, beneficial-ownership and sanctions-guidance gaps as unresolved.

Legal

Union Constitution art.

Board

Comoros continues to present a dual profile: a reported improving domestic AML/CFT legislative trajectory alongside an escalating pattern of sanctions designations tied to its ship registry.

CTO

Axian obtained a Decentralized Digital Financial Institution licence from the Banque Centrale des Comores on 24 February 2026 for a mobile-based nano- and micro-lending platform.

Risk

Comoros flag registry risk is assessed as structural and increasing, driven jointly by continued sanctions designations and an unresolved constitutional divide in financial licensing competence.

Operations

No material change for this persona this cycle.

Audit

The full text of the 2025 Comoros AML/CFT/CPF law referenced in GIABA's follow-up report has not been independently located or verified.

Shared evidence: 4 refs

Scenario sketches

Illustrative registry-displacement scenario for sanctioned maritime tonnage

Illustrative scenario for analytical orientation only: as enforcement pressure from the European Union, United Kingdom and United States continues to target vessels flagged in open registries historically associated with shadow-fleet activity, a structural mechanism worth watching is continued displacement of designated or at-risk tonnage toward registries less exposed to Western enforcement leverage, such as the pattern already reported of vessels moving from Comoros or Gambia flags to Russia's own registry. In this illustrative pathway, enforcement against one registry does not eliminate sanctions-evasion capacity but relocates it, while a residual population of newly flagged or newly designated vessels continues to appear under the original registry. This is architecture-over-incident illustration, not a prediction of how any specific vessel or registry will behave.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Illustrative EU AML Package and AMLA supervisory-transition scenario

Illustrative scenario for analytical orientation only: as the European Union's AML Regulation (Reg (EU) 2024/1624, directly applicable), the sixth AML Directive (transposed per Member State) and the AMLA Regulation (Reg (EU) 2024/1620) establishing the Anti-Money Laundering Authority move from adoption toward operational supervision, a structural mechanism worth watching is the shift of direct or indirect supervisory responsibility for cross-border obliged entities from purely national competent authorities toward a hybrid EU-level regime. For non-EEA jurisdictions such as Comoros, which sit outside this perimeter entirely, the illustrative relevance lies in how correspondent and counterparty due-diligence expectations placed on EEA-domiciled obliged entities interacting with non-EEA counterparties could tighten as AMLA's supervisory reach extends, without any corresponding change in Comoros' own domestic regime. This is architecture-over-incident illustration, not a prediction of how any specific supervisory decision will unfold.

Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact.

Standing trackers (T1–T6)

Tracker	Status	Note
T1 · Russian Sanctions-Evasion Architecture	escalating	Comoros flag registry remains a top enabling flag for Russian/Iranian/Venezuelan shadow-fleet tonnage; OFAC designated two further Comoros-flagged Iran-linked tankers on 8 October 2026; 46 vessels formerly Comoros/Gambia-flagged migrated to Russia's own registry by June 2026.
T2 · EU AML Package / AMLA	no_change	Comoros is outside the EEA/UK and is not bound by AMLR, 6AMLD or AMLA; no applicability change this cycle.
T3 · FATF Grey List	no_change	Comoros is not on the FATF grey list. Most recent GIABA action is the 2nd Enhanced Follow-Up Report (~July 2026); no new plenary action fell within this cycle's window.
T4 · Beneficial-Ownership Register Status	no_change	GIABA's 2nd FUR reportedly left beneficial-ownership risk as an unresolved gap for Comoros; no new development this cycle.
T5 · Crypto & Digital-Asset Integrity	no_change	Comoros has no dedicated VASP/crypto statute; GIABA's 2nd FUR reportedly flagged virtual-asset gaps as unresolved.
T6 · Sanctions Regime Divergence	no_change	No Comoros-specific EU/US/UK designation-criteria divergence signal found this cycle.

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

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

Added to OFAC SDN List under Iran-EO13902 programme, 8 October 2026 SRC-fim-KM-001

Probable · 1 source

Added to OFAC SDN List under Iran-EO13902 programme, 8 October 2026 SRC-fim-KM-001

Probable · 1 source

Continues to enable Russian/Iranian sanctions-evasion shipping; 46 vessels formerly Comoros/Gambia-flagged migrated to Russia's own registry by June 2026 SRC-fim-KM-007

Probable · 1 source

Union Constitution art. 9 and Organic Law No. 05-003/AU reserve banking and financial legislation exclusively to the Union government; island-level bodies (KM-A, KM-M) have no competence SRC-fim-KM-009

Probable · 1 source

Upgraded Comoros across 13 FATF Recommendations, citing a new 2025 AML/CFT/CPF law and Central Bank institutional reforms; virtual-asset, beneficial-ownership and sanctions-guidance gaps remain SRC-fim-KM-002

Probable · 1 source

Obtained a Decentralized Digital Financial Institution (DFI) licence from the Banque Centrale des Comores, 24 February 2026, enabling mobile nano- and micro-lending SRC-fim-KM-008

Probable · 1 source