Comoros Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Key Regulator(s): Central Bank of Comoros, Anjouan Offshore Finance Authority, Ministry of Finance
Primary Legislation: The Union of the Comoros does not have a dedicated, comprehensive law specifical, Comoros lacks specific legislation governing the use and regulation of cryptocur
Travel Rule: Adopted — Threshold: Implemented
Tax Reporting: No Specific Crypto Capital Gains Tax: Comoros does not have a distinct capital gains tax regime specifically for cryptocurrencies.. Application of General Principles: Gains derived from the sale of assets, including potentially virtual assets, may be subject to taxation under the general income tax framework, particularly if the activities are deemed regular or constitute a business.. Individuals: If crypto trading is considered an occasional activity, it might not be explicitly taxed as capital gains unless there's a broad interpretation of "other income." However, if an individual engages in frequent trading with the intent to profit, the gains could be recharacterized as business income and subject to individual income tax rates.. Businesses: For companies dealing in crypto, any profits from the sale or exchange of virtual assets would typically be included in their taxable income and subject to the standard corporate income tax rate.. Mining Income: Income derived from cryptocurrency mining (block rewards, transaction fees) would likely be treated as business income or "other income" and subject to the progressive individual income tax rates.

Key Facts

aml Ordinance No. 19-001/PR of 26 July 2019 on the Fight Against Money Laundering and Terrorist Financing: This is the most recent foundational AML/CFT law in Comoros. It replaced previous legislation (like Law No. 11-002/AF of 29 March 2011) and aims to align the Comorian framework with international standards set by FATF. Note: While this Ordinance may not explicitly name "virtual assets" or "cryptocurrency," the broad definitions of "financial activity," "financial institutions," and "designated non-financial businesses and professions (DNFBPs)" are generally interpreted to encompass activities related to virtual assets and VASPs, especially given FATF Recommendation 15. Be subject to licensing or registration: Depending on the specific interpretation and future regulations, VASPs are expected to be licensed or registered by the relevant authorities (e.g., the Central Bank). Implement AML/CFT requirements: VASPs must comply with all AML/CFT obligations applicable to financial institutions, including customer due diligence, record-keeping, and suspicious transaction reporting. For natural persons: Obtain and verify the customer's identity using reliable, independent source documents, data, or information (e.g., full name, address, date and place of birth, nationality, unique identification number from an official document like a passport or national ID card). For legal entities: Obtain and verify the identity of the legal entity (e.g., name, legal form, address, directors, beneficial owners, proof of incorporation). Understand the ownership and control structure. Beneficial Ownership: Identify and take reasonable measures to verify the identity of the beneficial owner(s) of the customer, including for legal persons and arrangements. Purpose and Intended Nature of Business Relationship: Understand the purpose and intended nature of the business relationship or occasional transaction.
custody Overall Regulatory Landscape: The primary financial regulator in Comoros is the Banque Centrale des Comores (BCC), which oversees traditional banking and financial services. Comoros is also a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), indicating a commitment to international AML/CFT standards. However, these standards typically recommend, rather than mandate, specific digital asset custody rules for individual member states unless adopted into national law. Segregation of Client Assets Rules: None Specific for Digital Assets: Since there are no specific custody laws, there are no explicit rules mandating the segregation of client digital assets from a custodian's proprietary assets. Traditional financial institutions under BCC oversight are subject to segregation rules for fiat currencies and securities, but these do not extend to digital assets without specific legislation. None Specific: There are no specific insurance or bonding requirements for digital asset custodians. None: There are no specific mandates or requirements for the use of cold storage or any particular security measures for digital assets. None: There is no legal definition of a "qualified custodian" in the context of digital assets within Comorian law. No Public Information: There is no publicly available information suggesting that specific legislation for digital asset custody is currently pending or under active consideration in Comoros. Banque Centrale des Comores (BCC): The central bank is the primary financial regulator. Its website contains general laws and regulations pertaining to banking and finance, but no specific crypto provisions.
enforcement Developing Regulatory Landscape: Comoros is a small, developing island nation. Its financial regulatory framework is still maturing, and specific legislation or dedicated enforcement mechanisms for complex digital assets like cryptocurrencies are likely not yet robust or fully established. Focus on Warnings, Not Enforcement: Like many emerging economies, the primary approach of its financial regulator (the Central Bank of Comoros – Banque Centrale des Comores, BCC) regarding cryptocurrencies has typically been to issue general warnings to the public about the risks associated with volatile and unregulated assets, rather than to conduct formal enforcement actions against specific entities. Such warnings are often generic and do not name specific actors or impose penalties. Lack of Transparency/Public Disclosure: Even if minor enforcement actions or investigations were to occur, they are unlikely to be publicly disclosed with the level of detail requested (penalty amounts, specific dates, outcomes, public reports) in a country with less developed financial transparency standards compared to major global financial hubs. Limited Scale of Crypto Activity: It's also possible that the scale of cryptocurrency operations or significant violations within Comoros has not yet reached a level that would trigger major, publicly reported enforcement actions.
general Customer Due Diligence (CDD) and Know Your Customer (KYC): Mandatory identification and verification of all customers and beneficial owners. Sanctions List Screening: Continuous screening of all customers, beneficial owners, and, where feasible, transaction counterparties against: OFAC Specially Designated Nationals (SDN) and other sanctions lists Adverse Media Screening: Checking for any public information linking customers to illicit activities or sanctioned entities. Transaction Monitoring: Implementing systems to detect unusual or suspicious transaction patterns, including those that might indicate sanctions evasion (e.g., unusual geographies, high-risk counterparties, structuring transactions). Source of Funds/Wealth: Understanding the origin of virtual assets and funds to mitigate ML/TF and sanctions risks. Prohibition on transactions with sanctioned jurisdictions: This includes countries subject to comprehensive UN, OFAC, or EU embargoes (e.g., North Korea, Iran, Cuba, certain regions in Ukraine/Russia). Geo-blocking: Implementing technological controls to prevent access to services from sanctioned IP addresses or jurisdictions.
licensing Anjouan Offshore Finance Authority (AOFA): This is the primary authority responsible for licensing offshore financial services, including what are often adapted for cryptocurrency businesses. Central Bank of Comoros (Banque Centrale des Comores - BCC): While the BCC oversees traditional financial institutions and monetary policy for the entire Union of the Comoros, it generally has less direct specific oversight or licensing for offshore virtual asset activities compared to AOFA. Ministry of Finance: Holds general oversight over financial matters. Specific Crypto Law vs. General Financial Services License: The Union of the Comoros does not have a dedicated, comprehensive law specifically for virtual assets or cryptocurrencies akin to those in major financial hubs. Instead, virtual asset businesses seeking to operate from Comoros (via Anjouan) typically apply for a general financial services license or a Money Service Business (MSB) license under the AOFA framework. These licenses are then interpreted and adapted to cover crypto-related activities. Exchanges (Spot, Derivatives): Would typically require an AOFA Financial Services License or MSB license. This allows for the facilitation of transactions, trading, and conversion of virtual assets. Custody Providers: Would also fall under the broader Financial Services License, as they manage and secure virtual assets on behalf of clients. Specific conditions regarding security, insurance, and segregation of assets might be imposed.
sanctions Requirements: Comoros is obligated to implement all UN Security Council Resolutions, which include asset freezes, travel bans, and arms embargoes against individuals, entities, and countries designated by various UN sanctions committees (e.g., Al-Qaida, ISIS, Taliban, DPRK, Iran, etc.). Screen all customers (KYC/CDD) and transactions against the UN Consolidated Sanctions List. Freeze virtual assets and funds of designated persons and entities without delay. Prohibit making virtual assets, funds, or economic resources available to sanctioned parties. Report any matches or suspicious activities to the relevant Comorian authorities (e.g., CENTIF). Legal Reference: UN Security Council Resolutions (e.g., UNSCR 1267, 1373, 1718, etc.) are binding on all UN member states. UN Sanctions Lists: https://www.un.org/securitycouncil/sanctions/information U.S. persons wherever they are located (U.S. citizens, permanent residents, entities incorporated in the U.S., and their foreign branches).
securities No primary legislation, law numbers, promulgation dates, Journal Officiel de l'Union des Comores (Official Gazette) references, MISA circulars, or Central Bank circulars cited anywhere in the available material. The entire legal framework described is unverified. Tax treatment cannot be confirmed. No Corporate Income Tax rate, withholding tax rates, VAT/GST provisions, economic substance rules, or treaty status can be verified from available sources. This is a critical gap. No FATF/Moneyval assessment exists; Comoros is not a FATF member and has not undergone a Moneyval mutual evaluation. No verifiable banking or payment-processor relationships have been confirmed. No KMF amounts stated. The Comorian Franc (KMF) is the legal tender. No regulation is cited to confirm whether amounts are prescribed in EUR or KMF. Conversion rates cannot be verified without a dated primary source. "Declared capital" is undefined. Unclear whether this means subscribed share capital with no paid-up requirement, or a regulatory attestation without bank verification. No legal definition is cited. Relationship between €50,000 baseline and €250,000 brokerage threshold is unexplained in the source. Comparison claim (unverified): The source claims EU/CySEC requires €125,000–€730,000 for comparable licenses. [No verifiable primary source provided for this comparison.]
stablecoin No Official Classification: There is no specific legislation that classifies stablecoins as e-money, payment tokens, or securities in Comoros. Potential Interpretation: In the absence of specific rules, a stablecoin could potentially be viewed by the Central Bank under existing general financial laws depending on its specific design and use case. If it functions purely as a medium of exchange backed by fiat, it might implicitly fall under broad concepts related to payment services or e-money, though this would require an official interpretation or directive from the BCC. If it represents an ownership stake or a claim on future profits, it might be interpreted as a security, but again, without specific guidance, this is speculative. No Specific Requirements: Since there are no specific stablecoin regulations, there are no prescribed reserve requirements for stablecoin issuers in Comoros. Risk: This lack of requirements means that any stablecoin operating without specific oversight would not be subject to mandates regarding the quality, segregation, or auditing of its reserves, posing significant risks to users. No Specific Licensing: There is no specific licensing regime for stablecoin issuers. General Financial Licenses: If a stablecoin issuer were to engage in activities that are already regulated under existing financial laws (e.g., operating as a bank, money transmitter, or e-money institution), they would likely be required to obtain those general financial licenses from the Central Bank of Comoros. However, these licenses are designed for traditional financial services and might not fully address the unique risks of stablecoins.
status The current regulatory framework in Comoros does not explicitly address cryptocurrencies, leading to a largely unregulated environment for digital assets. Comoros lacks specific legislation governing the use and regulation of cryptocurrencies, resulting in ambiguous legal status. No licensing requirements are established for cryptocurrency exchanges or service providers within Comoros due to the absence of dedicated regulatory provisions. The application of Anti-Money Laundering (AML) and Know Your Customer (KYC) regulations to cryptocurrency transactions is unclear in Comoros, as no specific guidelines have been issued. There are no documented enforcement actions targeting cryptocurrency activities in Comoros, reflecting the minimal regulatory oversight in this sector. The tax treatment of cryptocurrencies and digital assets is undefined in Comoros, with no clear guidance on taxation for gains, income, or transactions involving such assets. The absence of a comprehensive regulatory framework poses significant risks, including potential financial instability, exposure to illicit activities, and uncertainty for investors and businesses operating in the digital asset space. Comoros | Population, Religion, Flag, Language, Culture ...
tax No Specific Crypto Capital Gains Tax: Comoros does not have a distinct capital gains tax regime specifically for cryptocurrencies. Application of General Principles: Gains derived from the sale of assets, including potentially virtual assets, may be subject to taxation under the general income tax framework, particularly if the activities are deemed regular or constitute a business. Individuals: If crypto trading is considered an occasional activity, it might not be explicitly taxed as capital gains unless there's a broad interpretation of "other income." However, if an individual engages in frequent trading with the intent to profit, the gains could be recharacterized as business income and subject to individual income tax rates. Businesses: For companies dealing in crypto, any profits from the sale or exchange of virtual assets would typically be included in their taxable income and subject to the standard corporate income tax rate. Mining Income: Income derived from cryptocurrency mining (block rewards, transaction fees) would likely be treated as business income or "other income" and subject to the progressive individual income tax rates. Staking Rewards, Lending, Airdrops, DeFi Yields: Income received from these activities would likely be treated as "other income" or investment income, taxable at the individual's progressive income tax rates. The taxable amount would generally be the fair market value of the crypto at the time of receipt. Salary/Payments in Crypto: If an individual receives salary or payment for services in cryptocurrency, the fair market value of the crypto at the time of receipt would be treated as taxable income, similar to non-cash benefits. Regular Trading Profits: If an individual engages in frequent and organized cryptocurrency trading with the intention of making profits, these activities might be considered a business, and the profits would be subject to individual income tax rates.
travel rule Comoros has no legal framework, licensing regime, or regulatory authority for virtual asset service providers (VASPs) as of 2025–2026; the Central Bank of the Comoros (Banque Centrale des Comores) has not issued any VASP regulation, and no travel‑rule obligations have been transposed into domestic law. Operability Assessment: Operating a crypto business in Comoros is not explicitly prohibited but carries extreme legal and reputational risk due to the total absence of regulatory framework, AML/CFT obligations, and tax guidance; no licence can be obtained, and no supervisory authority exists to provide interpretive guidance. The country is not a FATF member, has not undergone a Moneyval/MENAFATF mutual evaluation, and no primary legislation, official gazette publication, or named regulator governs digital assets. The Union of Comoros has no designated financial regulator or supervisory authority with a mandate over cryptocurrency or digital asset activities. The Central Bank of the Comoros (BCC), established by Law No. 81‑011/PR of 31 December 1981 (Journal Officiel, 1982, p. 12) and governed by the Banking Law (Law No. 94‑013/AF of 28 June 1994), oversees credit institutions and microfinance but has no statutory competence for VASPs (BCC Annual Report 2023, §2.1). No primary law, decree, or official gazette publication addresses virtual assets, digital currencies, or travel‑rule obligations. The Ministry of Finance has not issued any decree or circular on crypto assets (Ministry of Finance, Circulaire relative aux activités financières non bancaires, 2022 — silent on VASPs). Comoros is not listed as a FATF member or observer on the FATF website (fatf‑gafi.org, “Members & Observers”, accessed 2025‑06‑15). No Moneyval or MENAFATF mutual evaluation report exists for Comoros (Moneyval, “Evaluation Reports”, accessed 2025‑06‑15). The only government bodies referenced in travel advisories are the Comoros Embassy in Paris (visa/entry) and the Ministry of Foreign Affairs (driving licences) — neither has financial regulatory remit Entry requirements - Comoros travel advice - GOV.UK. The Comorian legal system blends Islamic law (Sharia) and French civil law, but no financial services, banking, or capital markets legislation applicable to crypto assets has been enacted Safety and security - Comoros travel advice - GOV.UK.

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-22. View full profile