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KM Crypto & Digital Asset Regulation
KMschema crypto-v2.0.0trajectory: not yet assessedunregulated gapoverlaps: Sentinel (AML/CFT)
Last updated · 8 categories · 23 sourced
findings · 12 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 8 rendered categories; click to filter)
No categories moved this cycle.
Jurisdiction brief
KM operates under a unregulated gap supervised by GIABA / FATF Global Network, with 8 regulatory modules assessed in the current cycle.
C1 · Crypto Licensing: 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.
C2 · Token Classification: 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.
C3 · On-Chain Activity: 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.
C4 · Stablecoins & EMTs: 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.
All 8 module posture summaries
C1 · Crypto Licensing: 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.
C2 · Token Classification: 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.
C3 · On-Chain Activity: 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.
C4 · Stablecoins & EMTs: 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.
C5 · Consumer Protection: 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.
C6 · Tax Treatment: 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.
C7 · Cross-Border & Travel Rule: 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.
C8 · AML/CFT Regime: 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.
Key regulatory facts for KM
Regulatory Dimension
KM Standing Position
Jurisdiction
KM (KM)
Regulatory Scope
Crypto & Digital Asset Regulation (8 modules, 23 sourced findings)
Crypto Licensing
The Union of the Comoros has no dedicated legal framework governing virtual assets or VASPs.
Token Classification
No Comorian statute or regulatory guidance differentiates crypto-asset sub-types (security token, e-money token, asset-referenced token, utility token, stablecoin, NFT).
On-Chain Activity Regime
No Comorian instrument addresses staking, DeFi lending, DEX operation, mining, node operation, validation or tokenization.
Stablecoin 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.
Primary Instruments Cited
GIABA / FATF Global Network, Anjouan-branded licensing network, Union of the Comoros, Ministry of Finance, Budget, and Banking Sector Services, Comorian Ministry of Finance
Last Confirmed / Updated
2026-10-25 (12 sources in cumulative register)
8 of 8 categories
Signal
Density
Selections OR within a group, AND across groups. Press / to search.
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.
Open gap — crypto-int-1Whether the Comoros Ministry of Finance CFD/VASP licensing route (reported March 2026) has been adopted as a legal instrument and remains operative is unconfirmed.no under-indexing note recorded
Standing sub-brief · as of 25 October 2026319 words · last cycle 2026-10-25
Crypto Licensing
Comoros has no operative national licensing regime for crypto-business activity. No statute defines the concept of a virtual-asset service provider, and none imposes mandatory requirements on share capital, compliance procedures, or reporting standards for crypto-market participants. The only visible licensing activity associated with the Comoros name is the Anjouan-branded network, which markets crypto-business authorisations alongside gambling and forex or contract-for-difference licences. None of these authorisations is recognised by the Union government or by the Banque Centrale des Comores, and the Comoros government has this period escalated its response, requesting United Kingdom law-enforcement and financial-intelligence cooperation and stating that it is preparing domestic legal action against those involved in the network.
Separately, a route reportedly presented by the Ministry of Finance, Budget, and Banking Sector Services since March 2026 would cover forex brokerage and virtual-asset activity, with a minimum share capital requirement of ten thousand euros for general licensing and twenty thousand euros for a Virtual Asset Exchange line specifically. Whether this route has been formally adopted as a legal instrument, and whether it remains operative, is unconfirmed this period; the reporting describing it predates and has not been independently verified against a current legal text. Taken together, the record shows a jurisdiction with no statutory crypto-licensing foundation, a disputed and actively challenged island-branded alternative, and an unconfirmed ministry-level proposal sitting in between, none of which currently provides lawful authority for crypto-business activity under the Comoros name.
Outlook
What would change this assessment is confirmation that the Ministry of Finance route has been enacted as binding law, or alternatively the emergence of a dedicated Comoros virtual-asset statute of any kind. Absent either, and pending the outcome of the government's cooperation request to the United Kingdom and its stated domestic legal action, Comoros remains a jurisdiction where no crypto licence, whether marketed under the Anjouan brand or proposed by the Ministry of Finance, rests on confirmed, operative legal authority.
No periodic updates recorded in this cycle
Sources and findings (8)
T3Anjouan-branded licensing network — Comoros government is seeking UK cooperation and preparing legal action over the Anjouan network, which markets crypto-business authorisations alongside gambling and forex/CFD licences, none recognised by the Union government or Central Bankretrieved M4non-binding
T3Union of the Comoros — No Comoros statute defines a VASP concept or imposes mandatory capital, compliance or reporting requirements on crypto-market participantsretrieved M3bindingin force
T3Ministry of Finance, Budget, and Banking Sector Services — A reported licensing route for forex brokerage and virtual-asset activity since March 2026, with minimum share capital EUR 10,000 (EUR 20,000 for Virtual Asset Exchange); current legal status unconfirmedretrieved M3non-binding
T3 · YB CaseUnion of the Comoros — No VASP licensing, registration or notification regime exists in Comorian national law; a crypto business may operate without a formal authorisation because none exists.retrieved M4non-binding
T3 · Finance MagnatesComorian Ministry of Finance — Market commentary records that purported virtual-asset licences bearing the Comorian Ministry of Finance's name have circulated that the Ministry did not issue and has no authority to issue; no prosecution or crypto-specific penalty identified.retrieved M3non-binding
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.
C2 · Token Classification — Full Module Record0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25
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 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.
C3 · On-Chain Activity — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-10-25
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 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.
C4 · Stablecoins & EMTs — Full Module Record0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-10-25
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 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 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.
C6 · Tax Treatment — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-10-25
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 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.
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).
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.
C8 · AML/CFT Regime — Full Module Record0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-10-25
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).
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Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 23 finding(s), 12 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