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KM
KMschema crypto-v2.0.0trajectory: not yet assessedunregulated gapoverlaps: FIM
Last updated · 8 categories · 15 sourced
findings · 7 sources in the cumulative register
8Categoriesbaseline.
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The Union of the Comoros has no dedicated legal framework governing virtual assets or VASPs. Commercial commentary continues to report fabricated Ministry-of-Finance-branded virtual-asset licences circulating alongside island-level (Anjouan/Mwali) claimant licensing bodies not recognised by the Union government.
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 (3)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian instrument establishes a licensing, registration or notification requirement for crypto-asset service providers; GIABA's 2024 Mutual Evaluation Report records that virtual asset activity has not been reported in the Union of the Comoros and no competent authority has been designated to supervise it.retrieved M5non-bindinga fact about the regime
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No own-funds, minimum-capital or insurance-in-lieu requirement for crypto-asset service providers exists in Comorian law, because no CASP licensing category has been created.retrieved M4non-bindinga fact about the regime
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No administrative fine, criminal offence or publication-of-measures provision specific to unauthorised crypto-asset-service provision exists; general AML/CFT enforcement under Law 12-008/AU and Act 21-004/AU of 29 June 2021 applies to designated financial institutions (banks, credit institutions, MFIs, MVTS, EMIs) but not to a crypto-specific obliged-entity class.retrieved M4non-bindinga fact about the regime
No Comorian statute or regulatory guidance differentiates crypto-asset sub-types (security token, e-money token, asset-referenced token, utility token, stablecoin, NFT). The regulatory vacuum documented for licensing extends to classification: without a VASP/issuer framework, there is no legal trigger requiring the state to classify token types.
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)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — Comorian law contains no statutory or regulatory taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs; all crypto-assets remain legally unclassified in the absence of any VASP/issuer framework.retrieved M3non-bindinga fact about the regime
No Comorian instrument addresses staking, DeFi lending, DEX operation, mining, node operation, validation or tokenization. These activities fall outside the current BCC supervisory perimeter, which is scoped to licensed banks, credit institutions, MFIs, MVTS and EMIs.
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)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian law or BCC regulation addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity or tokenization; none of these activities fall within the BCC's defined financial-institution supervisory perimeter.retrieved M3non-bindinga fact about the regime
No issuance-authorisation, reserve, redemption-right, disclosure or systemic-designation regime for stablecoins, e-money tokens or asset-referenced tokens exists in Comorian law. No evidence of any national EMT/ART framework analogous to MiCA Title III/IV or EMD2 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)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian instrument establishes an issuance-authorisation, reserve-asset, redemption-right or disclosure regime for stablecoins, e-money tokens or asset-referenced tokens; this follows from the general absence of any virtual-asset legal framework documented in the 2024 GIABA Mutual Evaluation.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
No crypto-specific custody/safekeeping, marketing/promotion, complaint-handling, suitability, market-abuse or order-handling-and-conflicts regime exists in Comoros. The BCC's general consumer-alert function was exercised once in November 2019 with a public warning about a pyramid-type scheme, but the underlying GIABA assessment does not identify a crypto-specific consumer-protection instrument, custodian/technology-vendor distinction, or market-abuse prohibition analogous to MiCA Title VI.
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 (5)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian instrument defines a licensed custody/administration service for crypto-assets, distinguishes a custodian from a technology vendor, or imposes client-asset segregation, insolvency-treatment, return-of-assets or liability-cap duties on crypto custodians.retrieved M5non-bindingour coverage gap, expected to resolve on a re-run
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No crypto-specific market-abuse regime (insider dealing, unlawful disclosure of inside information, market manipulation) exists in Comorian law; no prohibitions analogous to those found in comprehensive crypto-asset regimes were located.retrieved M4non-bindingour coverage gap, expected to resolve on a re-run
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian law establishes an approval route, risk-warning requirement, cooling-off period or influencer-labelling rule for crypto-asset promotions and advertising.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No crypto-specific complaint-handling procedure, response deadline, or ombudsman-access right exists in Comorian law; the only documented consumer-facing supervisory action found is a November 2019 Central Bank of the Comoros public warning concerning a pyramid-type scheme, which was not crypto-specific.retrieved M3non-bindinga fact about the regime
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian instrument imposes best-execution, inducement or conflicts-of-interest duties on entities handling crypto-asset client orders.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
No crypto-specific tax guidance (capital gains, income tax, VAT/GST, withholding or reporting obligation) was located for Comoros in this research pass. This is a distinct gap from the AML/VA-regime finding, since fiscal law was not covered by the GIABA Mutual Evaluation and no Comorian tax-authority source was identified or reachable in this pass.
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)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — No Comorian tax-authority instrument addressing the capital-gains, income-tax, VAT/GST, withholding or reporting treatment of crypto-asset transactions was located in this research pass.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run
No Comorian law imposes a crypto-specific outbound restriction, sanctions nexus, reporting threshold or cross-border travel-rule obligation. GIABA's 2024 assessment states directly that Comoros is not an international financial centre or company-incorporation hub, in tension with the commercial reputation of Comorian-incorporated entities (e.g., via the Anjouan/Mwali registries) used by offshore forex/crypto brokers; the Monetary Authority of Singapore's 2025 action against an entity purportedly incorporated in the Union of the Comoros illustrates the resulting cross-border enforcement risk for host-country regulators rather than a Comorian domestic restriction.
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 (2)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — Comoros imposes no crypto-specific outbound capital-transfer restriction; GIABA's 2024 Mutual Evaluation Report states that the Union of the Comoros is not an international financial centre, nor is it an area for the incorporation and registration of companies.retrieved M3non-binding
T1 · Monetary Authority of Singapore (MAS)Monetary Authority of Singapore (MAS) — No Comorian law restricts outbound crypto/forex-related financial services; however, the Monetary Authority of Singapore's 2025 action blocking access to Octa, operated in part by an entity 'purportedly incorporated in the Union of Comoros', illustrates that Comoros-incorporated entities have operated unlicensed cross-border financial platforms without a home-country supervisory nexus.retrieved M3non-binding
AML/CFT treatment of virtual assets is out of scope for this crypto baseline per the crypto-FIM subscription boundary (financial_integrity owns aml_ctf). Disambiguation context only: GIABA's 2024 Mutual Evaluation found that the BCC is the AML/CFT supervisor for the financial sector generally (banks, credit institutions, MFIs, MVTS, EMIs) under Law 12-008/AU and Act 21-004/AU, but that no competent authority has been designated for virtual-asset/VASP supervision specifically, and that Comoros should conduct sector-specific ML/TF risk assessments of virtual assets. As of the FATF's 13 February 2026 and 19 June 2026 statements, Comoros is not currently on the FATF 'grey list' of jurisdictions under increased monitoring.
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)
T1 · GIABA / FATF Global NetworkGIABA / FATF Global Network — GIABA's 2024 Mutual Evaluation Report states that virtual asset activities have not been reported in the Union of the Comoros and that no competent authority has been designated for VASP AML/CFT supervision; the BCC supervises banks, credit institutions, microfinance institutions, MVTS and EMIs generally under Law 12-008/AU, supplemented by Act 21-004/AU of 29 June 2021. This is disambiguation context only; substantive AML/CFT claims are owned by the FIM aml_ctf baseline.retrieved M3non-bindinga fact about the regime
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Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 15 finding(s), 7 source(s) in the cumulative register.
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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.