Comoros: Financial Intelligence Unit Established but Still in Development
The Union of the Comoros has made significant progress in establishing a financial intelligence unit (FIU), but it still faces challenges in implementing anti-money laundering and combating financing of terrorism (AML/CFT) measures.
Establishing an FIU
According to a recent report by the International Monetary Fund (IMF), the Comorian authorities have established an FIU, but it has not yet received any suspicious transaction reports. The authorities responsible for prosecutions are also facing difficulties in investigating money laundering and terrorist financing cases due to a lack of resources and instances of corruption.
AML/CFT Measures
The report noted that the 2009 ordinance makes main financial institutions operating in the Comoros subject to AML/CFT measures, but does not cover insurance companies. However, currently, insurance companies are not active in life insurance. Due diligence measures have been in place for financial institutions since 2003 and are laid out in the 2009 ordinance.
Areas for Improvement
The report also highlighted that there is no specific provision regarding:
- Reliance on third parties and intermediaries
- Non-face-to-face business relationships
- Branches and subsidiaries abroad
Additionally, the conditions for licensing of insurance companies and registration of exchange houses and money remitters have not been specified.
Strengthening Cooperation and Supervision
The report emphasized the need to strengthen cooperation and supervision between authorities responsible for AML/CFT measures. It recommended that the Comorian authorities should prioritize the implementation of AML/CFT measures, including the establishment of a comprehensive system for reporting suspicious transactions.
Further Reforms Needed
The report also called for further reforms in the legal framework governing financial institutions and designated non-financial businesses and professions (DNFBPs). It emphasized the need to establish a more effective system for supervising DNFBPs and strengthening cooperation between authorities responsible for AML/CFT measures.
Economic Challenges
The Union of the Comoros faces significant economic challenges, including:
- Weak GDP growth rates
- Deteriorating social indicators
- High poverty rates
The country’s Human Development Index ranked 132nd among 177 countries in 2006. Per capita income is estimated to be US$465 in 2005.
Conclusion
In conclusion, while the Comorian authorities have made progress in establishing an FIU, further reforms are needed to strengthen cooperation and supervision between authorities responsible for AML/CFT measures. The country’s economic challenges also require urgent attention to address poverty and improve living standards.