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KM-A
KM-Aschema crypto-v2.0.0trajectory: not yet assessedunregulated gapoverlaps: FIM
Last updated · 7 categories · 13 sourced
findings · 5 sources in the cumulative register
7Categoriesbaseline.
13Findings.claims[]
0Tier-1 sourcesrun_metadata.t1_source_count
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No crypto-asset-specific licensing statute or regulator has been identified for the Union of the Comoros or its Anjouan island. The FATF/ESAAMLG Mutual Evaluation Report (May 2024) states directly that no VASPs have been reported to exist or operate in the country, and flags the absence of any ML/TF risk assessment or regulatory framework for virtual assets as a major technical-compliance deficiency. General commercial entities (including those registered on Anjouan) fall under OHADA-derived company law and are recorded at the Commercial Courts of Moroni, Moheli and Anjouan, but this is ordinary company registration, not a crypto-asset licence. Anjouan is separately referenced in market/corporate disclosure as a source of low-cost offshore licences (historically associated with online gambling), and some crypto-adjacent or forex operators informally cite an 'Anjouan licence' in marketing; this practice has not been verified against any primary Comoros state regulator and should be treated as unconfirmed pending primary-source verification.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (4)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No virtual-asset-service-provider (VASP) licensing or registration regime exists in the Union of the Comoros (including Anjouan); the national AML/CFT mutual evaluation records that no VASPs have been reported to exist or to operate in the country.retrieved M5non-binding
T2 · FATF / ESAAMLGFATF / ESAAMLG — General commercial entities, including those formed on Anjouan, must be registered at the Commercial Courts of Moroni, Moheli or Anjouan (or with the national business registry APNI) under OHADA-derived company law; this is a general corporate registration duty, not a crypto-specific licence.retrieved M3bindingin force
T4 · U.S. Securities and Exchange Commission (EDGAR filer disclosure)U.S. Securities and Exchange Commission (EDGAR filer disclosure) — Market and corporate-disclosure sources (e.g., an SEC filing listing acceptable offshore gambling licence origins) refer to 'an offshore license from a nation such as Anjouan,' indicating informal commercial recognition of Anjouan-issued offshore licences in some sectors; no primary Comoros state regulator confirming a dedicated crypto-asset licensing authority on Anjouan has been located, and the official FATF mutual evaluation states the Union of the Comoros is not an international financial centre nor an area for company incorporation/registration in the IFC sense.retrieved M4non-binding
T2 · FATF / ESAAMLGFATF / ESAAMLG — No crypto-asset-specific enforcement or penalty provisions (fines, criminal offences, publication of measures) have been identified for unlicensed virtual-asset activity in the Union of the Comoros; only general AML/CFT Law enforcement powers over regulated financial institutions were found, and these do not reference virtual assets or VASPs.retrieved M4non-bindinga fact about the regime
The Union of the Comoros has no statutory taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs. The FATF mutual evaluation attributes this to the fact that virtual-asset activity has not been reported in the country, so no classification framework has been triggered or developed.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / ESAAMLGFATF / ESAAMLG — Crypto-assets are not classified under any Comoros statute or regulatory instrument; activities relating to virtual assets and virtual asset service providers have not been reported in Comoros, so no classification taxonomy has been developed.retrieved M3non-bindinga fact about the regime
No regulation of staking, DeFi lending, DEX operation, mining, node/validator operation, or tokenization activity has been identified in Comoros law. The absence of any reported VASP activity in the FATF mutual evaluation implies these on-chain activities are likewise unregulated and unsupervised.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No rule governing staking, DeFi lending, DEX operation, mining, validator/node operation or tokenization has been located in Comoros law; the national mutual evaluation reports no virtual-asset activity of any kind operating in the country.retrieved M2non-bindinga fact about the regime
No stablecoin or e-money-token specific issuance, reserve, redemption, or systemic-designation framework exists in Comoros law. No evidence of any stablecoin issuer operating under Comoros/Anjouan authorisation was found.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No stablecoin or e-money-token issuance authorisation regime exists in Comoros law; no issuer operating under a Comoros/Anjouan licence has been identified, consistent with the mutual evaluation's finding that no VASP activity is reported in the country.retrieved M3non-bindinga fact about the regime
No crypto-specific consumer-protection rules — custody/segregation of client crypto-assets, market-abuse prohibitions, order-handling/conflicts rules, marketing restrictions, complaint-handling procedures, or suitability/appropriateness duties — have been identified for Comoros or Anjouan. General consumer-protection or financial-conduct law, where it exists, has not been shown to extend to crypto-asset services. The global FATF work on offshore VASPs (oVASPs) explicitly cautions that jurisdictions permitting the creation of VASPs without effective home supervision raise elevated risk for clients of firms using such licences.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (4)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No custody, safekeeping, or client-asset segregation rule applicable to crypto-asset service providers has been identified in Comoros/Anjouan law.retrieved M5non-bindinga fact about the regime
T2 · FATF / ESAAMLGFATF / ESAAMLG — No crypto-specific market-abuse regime (insider dealing, unlawful disclosure, market manipulation) has been identified in Comoros/Anjouan law.retrieved M4non-bindinga fact about the regime
T4 · U.S. Securities and Exchange Commission (EDGAR filer disclosure)U.S. Securities and Exchange Commission (EDGAR filer disclosure) — No crypto-asset promotion or financial-advertising restriction specific to virtual assets has been identified in Comoros/Anjouan law; informal third-party use of an 'Anjouan licence' label in marketing by offshore operators has not been verified against any state approval regime.retrieved M3non-bindinga fact about the regime
T2 · FATF / ESAAMLGFATF / ESAAMLG — No complaint-handling, response-deadline, or ombudsman-access regime specific to crypto-asset clients has been identified in Comoros/Anjouan law.retrieved M3non-bindinga fact about the regime
No crypto-specific tax guidance (capital gains, income tax, VAT/GST, withholding, or reporting obligations) has been located for the Union of the Comoros or Anjouan. This research pass did not establish whether general Comoros corporate/income tax law is applied by the tax administration to crypto-asset transactions by default.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No crypto-asset-specific tax treatment (capital gains, income tax, VAT, withholding, or reporting obligation) has been identified for Comoros/Anjouan; whether general tax code provisions are applied by default to crypto-asset transactions has not been confirmed in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
No crypto-specific cross-border transfer rule (outbound restriction, sanctions nexus, reporting threshold, or cross-border travel rule) has been identified for Comoros/Anjouan. General exchange-control or financial-reporting rules administered by BCC and the FIU were not confirmed to extend to crypto-asset transfers.
Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.
no periodic updates on record for this sub-brief
Sources and findings (1)
T2 · FATF / ESAAMLGFATF / ESAAMLG — No crypto-asset-specific cross-border transfer restriction, reporting threshold, or travel-rule-crossborder provision has been identified in Comoros/Anjouan law; the Financial Intelligence Unit operates under the Minister of Finance for general AML/CFT purposes but no virtual-asset-specific cross-border rule was found.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
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pass
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every_practical_object_has_source_id
n/a — no subject in this jurisdiction
min_quoted_text_present
waived — floor 0%
egress_verified
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FAIL
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tier_a_b_national_primary_pct
80.0
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0
Editorial metadata
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Editorial metadata for KM-A
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Provenance and declared absence
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Envelope: baseline resolved at jurisdiction_json.baseline; 7 module(s), 13 finding(s), 5 source(s) in the cumulative register.
Audit trail
Machine checkChallenged on 6 Oct 2026: nothing tested (no claim on this page was eligible for an automated test). An automated, adversarial test run by a second model; no person has assessed the result.