COMOROS: A Compliance Checklist for Financial Institutions

The International Monetary Fund (IMF) has recently issued a report assessing the technical compliance of Comoros, a small island nation in the Indian Ocean, with the Financial Action Task Force (FATF) Recommendations. These recommendations aim to combat money laundering and terrorist financing.

Compliance Progress

According to the report, Comoros has made significant progress in implementing the FATF recommendations, with 14 out of 40 areas rated as “largely compliant” or better. However, there are still several areas where improvement is needed.

Key Areas for Improvement

Here are the key areas that financial institutions operating in Comoros should prioritize to ensure compliance:

• Assessing risk and applying a risk-based approach (R.1): LC
• National cooperation and coordination (R.2): LC
• Money laundering offence (R.3): LC
• Confiscation and provisional measures (R.4): PC
• Terrorist financing offence (R.5): PC

Progress in Implementing Measures

The report notes that Comoros has made significant progress in implementing measures to prevent the misuse of financial institutions, including:

• Customer due diligence (R.10)
• Record keeping (R.11)

Areas for Improvement

However, there are still several areas where improvement is needed, including:

• Non-profit organisations (R.8): NC
• Financial institution secrecy laws (R.9): C
• New technologies (R.15): NC

Conclusion and Recommendations

The report concludes that while Comoros has made significant progress in implementing the FATF recommendations, there is still much work to be done to ensure full compliance.

To prevent money laundering and terrorist financing, financial institutions operating in Comoros should prioritize these areas and take steps to improve their compliance with international standards.