Financial Crime World

Banking Regulations for AML in Comoros Receive Scrutiny

The Union of Comoros has undergone a comprehensive assessment of its anti-money laundering and combating the financing of terrorism (AML/CFT) system by a team of experts from the International Monetary Fund (IMF), the World Bank, and an independent expert. The evaluation was based on the 2003 Forty Recommendations and the 2001 Nine Special Recommendations developed by the Financial Action Task Force (FATF).

Assessment Methodology

The assessment was carried out in accordance with the 2004 AML/CFT Methodology, as updated in October 2008. The team assessed laws, regulations, and other documents provided by the Union of Comoros, as well as gathered information during an on-site visit from May 6-20, 2009.

Expert Team

The assessment team consisted of:

  • Emmanuel Mathias (LEG, mission chief)
  • Chady El Khoury (LEG)
  • Habib Hitti (expert under the supervision of LEG)
  • André Cuisset (expert under the supervision of the World Bank)

Assessment Findings

The experts analyzed the institutional framework, laws, regulations, guidelines, and obligations related to AML/CFT within financial institutions and designated non-financial businesses and professions. They also evaluated the adequacy, implementation, and effectiveness of these mechanisms.

Key Areas Assessed

  • Institutional framework
  • Laws and regulations
  • Guidelines and obligations
  • Adequacy, implementation, and effectiveness of AML/CFT measures

Report Highlights and Recommendations

The report provides a summary of the AML/CFT measures in effect in the Union of Comoros as of or shortly after the on-site visit. It describes and analyzes these measures, indicates the level of compliance with the 40+9 FATF Recommendations (see Table 1), and makes recommendations to strengthen certain aspects of the system.

Areas for Improvement

The report highlights areas where the Union of Comoros needs to improve its AML/CFT regime to meet international standards. These include:

  • Enhancing transparency and cooperation between financial institutions
  • Improving customer due diligence and transaction monitoring
  • Strengthening sanctions and enforcement mechanisms
  • Increasing awareness and training for financial institution staff

Recommendations for Improvement

The assessment team provides guidance on how to implement these improvements, which will help to enhance transparency, stability, and integrity in the financial sector.