Financial Crime World

Comoros: Weak AML/CFT Monitoring and Supervision Puts Financial System at Risk

The Union of Comoros has been found to have a weak monitoring and supervision system in place to combat money laundering and terrorist financing (AML/CFT). This lack of oversight puts the country’s financial system at risk and hinders its ability to cooperate with international partners.

Weak Monitoring and Supervision System

  • The Comorian authorities lack the necessary resources to ensure that information recorded manually by the Registry of the Regional Court is up-to-date and accurate.
  • There is no centralized registration system in place for nonprofit organizations (NPOs), based on French law.
  • The Financial Intelligence Unit (FIU) has been criticized for being more like an intergovernmental coordination committee than an operational financial intelligence unit, limiting its effectiveness in domestic coordination.
  • The Comorian legal framework has not transposed key international conventions, including the Vienna, Palermo, and New York Conventions, into domestic law.
  • This hinders the country’s ability to cooperate with foreign counterparts and exchange information on money laundering and terrorist financing cases.

Criminalization of Financing of Terrorism

  • The report highlights weaknesses in the criminalization of the financing of terrorism in Comorian law.
  • Some predicate offenses are not criminalized, limiting the scope of assistance that authorities can provide to other countries.

Economic Situation

  • Real GDP growth rates remain weak and social indicators deteriorate.
  • The Human Development Index ranked the Union of Comoros 132nd among 177 countries in 2006, with per capita income estimated at US$465 in 2005.

Recommendations for Improvement

The Comorian government has been urged to take immediate action to strengthen its AML/CFT monitoring and supervision system, including:

  • Establishing a centralized registration system for NPOs
  • Transposing key international conventions into domestic law
  • Improving the criminalization of financing of terrorism
  • Strengthening cooperation with foreign counterparts