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KM-A Crypto & Digital Asset Regulation
KM-Aschema crypto-v2.0.0trajectory: not yet assessedunregulated gapoverlaps: Sentinel (AML/CFT)
Last updated · 7 categories · 15 sourced
findings · 10 sources in the cumulative register
Evidence re-verified:·Position last changed:·Record history & provenance ▾
Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.
Confidence mix(sums to 7 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction lead brief
Standing brief, as of 4 November 2026.
Lead Signal
No crypto licensing regime recognised by the Comoros government exists on Anjouan. Commentary aimed at prospective licensees warns plainly that a crypto licence obtained through the island's self-styled financial-authority brands is not officially recognised by the national government, making it a risky legal foundation for a crypto entity. This is not a gap awaiting legislative action; it is a structural absence rooted in the constitutional allocation of power. Article 9 of the Union Constitution, together with Organic Law No. 05-003/AU, places banking and financial legislative competence exclusively with the Union government, leaving the island-level bodies marketing these licences with no legal basis to create or confer one. Entities building on an Anjouan crypto credential are building on an instrument the Comoros state does not recognise as its own.
Other Developments
Several competing self-styled authority names circulate in connection with the same marketed regime, and it remains unresolved which name is currently operative for the active licence vendor. A December 2025 communiqué from the Central Bank of the Comoros that bears directly on this question could not be independently retrieved this pass and was only recalled, leaving a gap in primary confirmation of the Central Bank's exact position and timing. No developments were evidenced this period in token classification, on-chain activity, stablecoin treatment, consumer protection, tax treatment, or cross-border transfer for this jurisdiction.
Cross-Monitor Connections
The constitutional basis for the absence of a recognised licensing regime, rooted in the Union government's exclusive competence over financial and gaming legislation, is the same legal foundation underlying the parallel dispute over the jurisdiction's gambling-licensing apparatus, where the Union government has likewise disavowed island-level licensing bodies as unrecognised. Entities relying on an Anjouan-branded crypto licence sit in the same structural position as those relying on an Anjouan-branded gambling licence: an instrument issued by a body with no constitutional standing to issue it.
Outlook
The outlook for a nationally recognised crypto licensing regime in this jurisdiction remains closed absent a change in the constitutional allocation of competence, which no evidence this period suggests is under consideration. Resolution of which self-styled authority name is currently active, and independent retrieval of the Central Bank's December 2025 communiqué, would materially sharpen the picture; until then, the practical position for any entity holding or considering an Anjouan crypto licence is that it holds an unrecognised instrument.
Key regulatory facts for KM-A
Regulatory Dimension
KM-A Standing Position
Jurisdiction
KM-A (KM-A)
Regulatory Scope
Crypto & Digital Asset Regulation (7 modules, 15 sourced findings)
Crypto Licensing
No crypto-asset licensing regime recognised by the Union of the Comoros applies to KM-A specifically.
Token Classification
The Union of the Comoros has no statutory taxonomy distinguishing security tokens, e-money tokens, asset-referenced tokens, utility tokens, stablecoins or NFTs.
On-Chain Activity Regime
No regulation of staking, DeFi lending, DEX operation, mining, node/validator operation, or tokenization activity has been identified in Comoros law.
Stablecoin Regime
No stablecoin or e-money-token specific issuance, reserve, redemption, or systemic-designation framework exists in Comoros law.
Primary Instruments Cited
FATF / ESAAMLG, U.S. Securities and Exchange Commission (EDGAR filer disclosure), Anjouan crypto licence (AOFA/AFSA/AFSC), Union Constitution Art. 9 / Organic Law No. 05-003/AU
Last Confirmed / Updated
2026-11-04 (10 sources in cumulative register)
7 of 7 categories
Signal
Density
Selections OR within a group, AND across groups. Press / to search.
No crypto-asset licensing regime recognised by the Union of the Comoros applies to KM-A specifically. Multiple competing self-styled Anjouan financial authorities market crypto-related licences, none recognised by the Central Bank of the Comoros.
Open gap — crypto-int-1Which of the three competing self-styled Anjouan financial-authority names (AOFA/AFSA/AFSC) is currently used by the active crypto-licence vendor remains unresolved; one T1 source (Dec 2025 BCC communique) was only recalled, not independently retrieved, this pass.no under-indexing note recorded
No sub-brief written this cycleThe module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.
No periodic updates recorded in this cycle
Sources and findings (6)
T2FATF / 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
T2FATF / 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
T4U.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
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.
C2 · Token Classification — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04
The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).
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.
C3 · On-Chain Activity — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04
The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).
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.
C4 · Stablecoins & EMTs — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04
The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).
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 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.
C6 · Tax Treatment — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04
The decision headline, regulatory posture (Amber), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).
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.
The decision headline, regulatory posture (Red), primary framework, and supervisory authority above are open on the Free Explore layer. Register free with a business email for 3 full-record passes a month, or unlock all 170 jurisdictions with Pro (£39/mo · £99/mo all products) or Firm (£199/mo · £449/mo all products).
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Band honesty: uncertainty bands are computed against a frozen build clock of 2026-11-04. A year-precision row is never promoted into a tighter band.
Orphan deltas: 0 cycle_delta row(s) target non-module objects and are listed in the rail rather than attached to a card.
Envelope: baseline resolved at jurisdiction_json.baseline; 7 module(s), 15 finding(s), 10 source(s) in the cumulative register.
Audit trail
Machine checkChallenged on 24 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.
KM-A