KM

KM schema world-payments-v1 trajectory: not yet assessed

Last updated · 14 modules · 56 sourced findings · 116 sources in the cumulative register

Jurisdiction brief

Latest update · 25 October 2026

Lead Signal

The Comoros government has escalated its market-access and authorisation dispute with the Anjouan-branded offshore licensing network, moving from unilateral disclaimers to a formal request for United Kingdom law-enforcement and financial-intelligence cooperation and stated preparation of domestic legal action. The Banque Centrale des Comores maintains that only it may authorise financial institutions nationally, and that the Anjouan network, including its separate forex and contract-for-difference licensing arm, the Anjouan Offshore Finance Authority, has no legal standing to issue such authorisations.

#

Comoros' Central Bank (BCC) remains the sole body empowered to authorise financial institutions nationally; the Comorian government has escalated to UK law-enforcement/financial-intelligence cooperation and prepared domestic legal action against the unrecognised Anjouan-branded licensing network.

Movement — CHANGEDComoros government requests UK law-enforcement cooperation and prepares legal action over the Anjouan licensing networkFirst-time cross-border cooperation request escalates the long-running market-access dispute
Key judgment — Probable · impact ELEVATEDComoros' escalation from unilateral disclaimers to a formal UK law-enforcement cooperation request over the Anjouan-branded licensing network represents a material shift in the market-access authorisation dispute, now extending into cross-border legal cooperation.claims: wpm-2026-W43-001
Standing sub-brief · as of 8 September 2026210 words · last cycle 2026-10-25

Licensing, Authorisation & Market Access

Banking and payments licensing in Comoros is a Union-exclusive competence: the Banque Centrale des Comores holds sole authority to authorise banks and financial institutions under Article 7 of Legislation No. 80-7 (1980). Non-bank e-money issuance runs through a separate, dedicated route: three non-bank Electronic Money Institutions are currently licensed under Regulation 01/2017, distinct from bank-issued payment products. In February 2026 the BCC extended this non-bank track further, issuing Axian Group a new 'IFDD' (decentralised digital financial institution) licence enabling a fully digital, centrally-supervised entity that offers nano and micro loans by mobile phone, alongside Axian's existing MVola mobile-money platform. Set against this Union-level licensing regime, island-level bodies calling themselves the Anjouan Offshore Finance Authority and the Mwali International Services Authority carry zero legal recognition: Organic Law 05-003/AU and Article 9 of the Constitution reserve licensing to the Union, and BCC, IMF, World Bank and FATF sources confirm the island bodies have no standing to authorise banks or financial institutions.

Periodic update · new data 2026-10-25

Licensing, Authorisation & Market Access

The Comoros government has escalated its dispute over market access and authorisation legitimacy concerning the Anjouan-branded offshore licensing network, moving from unilateral public disclaimers to a formal request for United Kingdom law-enforcement and financial-intelligence cooperation, alongside stated preparation of domestic legal action. The Banque Centrale des Comores maintains its established position that only it may authorise financial institutions nationally, and that the Anjouan network's authorisations carry no legal standing under that framework. This marks a material shift in posture: rather than confining itself to statements that the network lacks legal foundation, the government is now actively pursuing cross-border cooperation to investigate and potentially act against it.

Adjacent to the gambling-licensing dispute sits a separate forex and contract-for-difference licensing body, the Anjouan Offshore Finance Authority, which issues broker certificates distinct from but related to the gambling licences under scrutiny. The Central Bank's position extends equally to these certificates: only the Banque Centrale des Comores may authorise financial institutions nationwide, and AOFA certificates are not recognised as financial licences regardless of how they are marketed. For any payment service provider or financial institution assessing market-access risk connected to entities claiming authorisation via either the gambling-licensing network or the AOFA forex route, the operative baseline is that neither confers recognised authorisation under Comoros law.

Outlook

The trajectory to watch is the outcome of the Comoros government's cooperation request to the United Kingdom and whatever domestic legal action follows. Either development could clarify, or further undermine, the legal status of both the gambling-licensing network and its adjacent AOFA forex-licensing arm, with direct consequences for any entity relying on either as a basis for claimed authorisation.

Sources and findings (6)
  1. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved
  2. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved
  3. T1https://2009-2017.state.gov/documents/organization/82217.pdfretrieved
  4. T2https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comorosretrieved
  5. T2https://legasset.com/anjouan-forex-licence-explained/retrieved
  6. T2https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/retrieved

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Comoros has no distinct codified conduct-of-business or safeguarding rulebook comparable to CASS/PSRs; the primary conduct mechanism observed is BCC's direct public-communiqué enforcement against fraudulent/unlicensed promotional activity (AOFA/MISA) rather than a formal promotions regime. E-money issuer safeguarding presumably derives from Regulation 01/2017's authorisation conditions, but the specific segregation/trust mechanics of that regulation could not be independently verified from public sources in this run.

Standing sub-brief · as of 8 September 2026112 words · last cycle 2026-09-08

Conduct, Safeguarding & Promotions

Comoros has no codified conduct or promotions rulebook comparable to a CASS-style safeguarding regime. The observed enforcement mechanism is direct: the Banque Centrale des Comores publishes public communiqués, most recently in 2022-2023, warning that no island entity is authorised to issue banking or financial licences. This positions BCC's public messaging, rather than a formal codified rulebook, as the operative conduct-and-promotions control for the non-bank e-money sector.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T2https://legasset.com/anjouan-forex-licence-explained/retrieved
  2. T2https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/retrieved
  3. T2https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/retrieved

#

Comoros has no standalone crypto/stablecoin licensing framework. Virtual asset activity involving client funds, settlement, or custody is captured only via the general financial-institution authorisation mechanism ('agrément') under BCC supervision; the BCC had not issued dedicated crypto guidance as of 2026 and crypto adoption remains low, funded mainly via P2P using mobile money on-ramps.

Standing sub-brief · as of 8 September 202681 words · last cycle 2026-09-08

Stablecoins & Digital Money

Comoros has no standalone crypto or stablecoin licensing framework. Virtual-asset activity is captured only via the general financial-institution 'agrément' authorisation route, the same route used for other financial-institution licensing; the BCC had issued no dedicated crypto guidance as of 2026, and adoption remains low, with peer-to-peer activity funded via mobile-money on-ramps.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T3https://ybcase.com/en/fintech/polucit-kriptolicenziu-na-komorahretrieved
  2. T3https://startpolymarket.com/countries/comoros/retrieved
  3. T3https://startpolymarket.com/countries/comoros/retrieved

#

Comoros' legacy critical infrastructure is SYCOCO, a manual cheque-clearing house that is the country's only interbank clearing mechanism. The BCC is modernising this via an ATS+ (RTGS+ACH+instant funds transfer) project and, as of August 2025, a live National Interoperable Payment Switch (built by PayLogic under the World Bank-backed PADSF programme) connecting banks, MFIs and mobile-money operators. A 2026 BCC-Banque Centrale de Tunisie cooperation accord explicitly covers payment-system modernisation and cybersecurity strengthening.

Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. Open its jurisdiction pages on Dataprotection.gi →

Standing sub-brief · as of 8 September 2026140 words · last cycle 2026-09-08

Operational Resilience & Critical Infrastructure

Manual cheque-clearing through the SYCOCO system, processing around 5,000 cheques a month worth KMF 19.7 billion, remains the sole formal interbank clearing mechanism, pending absorption into a planned ATS+ (RTGS/ACH/instant funds transfer) system with no confirmed go-live date. That legacy mechanism now sits alongside a new layer of interoperability: a National Interoperable Payment Switch went live on 25 August 2025, connecting banks, microfinance institutions and mobile-money operators under the World Bank-backed PADSF programme, replacing historically closed-loop ATM and POS networks. Separately, the BCC and the Central Bank of Tunisia signed an institutional cooperation agreement in April 2026 covering payment-system modernisation and cybersecurity strengthening.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved
  2. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved
  3. T3https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switchretrieved
  4. T2https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/retrieved
  5. T3https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/retrieved

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Card-scheme infrastructure in Comoros remains nascent: retail card/POS penetration is extremely low, ATM/POS networks have historically been closed-loop and non-interoperable, and international cards route through partner banks (e.g., Exim Bank Comoros issuing Visa cards) rather than through any domestic scheme rulebook. No evidence of a Comoros-specific interchange regulation, surcharging rule, or PCI DSS mandate was found; the National Payment Switch (2025) is the first material step toward standardised domestic scheme rules.

Open gap — wpm-int-3No Comoros-specific interchange regulation, surcharging rule, or PCI DSS mandate was located.no under-indexing note recorded
Standing sub-brief · as of 8 September 202681 words · last cycle 2026-09-08

Scheme & Network Compliance

Comoros' retail card infrastructure remains nascent: only 37 ATMs and 28 point-of-sale devices operate nationally, with roughly 34,000 cards in circulation, and networks have historically been closed-loop and non-interoperable. No Comoros-specific interchange regulation, surcharging rule, or PCI DSS mandate has been identified; the 2025 Payment Switch is the first material step toward domestic scheme standardisation.

no periodic updates on record for this sub-brief

Sources and findings (3)
  1. T1https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf Applies beyond this jurisdiction (World Bank)retrieved
  2. T3https://en.wikipedia.org/wiki/Exim_Bank_Comorosretrieved
  3. T3https://www.einpresswire.com/article/786074855/paylogic-awarded-project-for-the-national-interoperable-digital-payment-switch-in-the-union-of-comorosretrieved

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Comoros is a heavily remittance-dependent corridor economy: diaspora inflows exceed 20% of GDP as of 2025 (up from 12.1% in 2018), paid out predominantly in cash via Western Union/MoneyGram at total costs typically 5-9% on the France-Comoros corridor. Comoros is a member of SADC and participates in the SADC-RTGS regional multicurrency settlement system alongside 15 other member states, though it is not yet confirmed as a PAPSS participant.

Open gap — wpm-int-1No KM-specific payment-corridor change has been identified since the 2026-09-08 anchor run.no under-indexing note recorded
Standing sub-brief · as of 8 September 2026104 words · last cycle 2026-09-08

Payment Corridor Dynamics

Remittance inflows exceed 20% of GDP, up from 12.1% of GDP in 2018, and Western Union and MoneyGram internet-channel transfers on the France-Comoros corridor cost approximately 3.5% to 9% in total, with payout still made predominantly in cash. Comoros participates in the SADC-RTGS regional multicurrency settlement system alongside fifteen other SADC member states; its participation status in the Pan-African Payment and Settlement System remains unconfirmed from available public sources.

no periodic updates on record for this sub-brief

Sources and findings (5)
  1. T3https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/retrieved
  2. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved
  3. T1https://remittanceprices.worldbank.org/corridor/FR/KM Applies beyond this jurisdiction (World Bank)retrieved
  4. T2https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008retrieved
  5. T1https://www.elibrary.imf.org/view/journals/087/2025/004/article-A001-en.xml Applies beyond this jurisdiction (IMF)retrieved

#

The Comorian financial sector is small and bank/microfinance-dominated (no stock exchange), with four commercial banks, a postal bank, microfinance institutions, and a growing mobile-money/digital-finance segment led by Axian (MVola/Mixx/IFDD), BDC's Holo Money, and Comores Telecom's Huri Money. The 2025 BCC Annual Report shows a strengthening banking sector with rising assets, deposits and profits, alongside expanding digital/agent-based financial inclusion infrastructure.

Standing sub-brief · as of 8 September 202671 words · last cycle 2026-09-08

Industry Structure & Commercial Dynamics

The Comorian state holds a significant capital stake in two private banks, keeping it involved in the financial sector beyond pure regulatory oversight. The sector remains small and bank/microfinance-dominated, with no stock exchange, while the competitive mobile-money segment, including MVola, Holo Money and Huri Money, continues to grow.

Outlook

Continued growth in mobile-money competition alongside a still-concentrated, state-linked banking sector is the structural dynamic to track.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://www.mfw4a.org/country/comorosretrieved
  2. T2https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/retrieved
  3. T2https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comorosretrieved
  4. T1https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf Applies beyond this jurisdiction (World Bank)retrieved

The dominant payments-relevant legal contest in Comoros is not court litigation but a jurisdictional/regulatory-legitimacy dispute: island-level bodies (AOFA on Anjouan, MISA on Mwali) have issued 'offshore' financial licences that the BCC, backed by the Union Constitution and Organic Law 05-003/AU, has repeatedly and publicly declared to have zero legal standing. Enforcement capacity constraints have historically limited prosecutions (e.g., an unprosecuted BCC-filed complaint noted in the 2010 IMF assessment). The judiciary is a mixed civil/Islamic/customary system with the Supreme Court as apex authority.

Standing sub-brief · as of 8 September 202678 words · last cycle 2026-10-25

Legal & Litigation

A 2010 IMF/ESAAMLG assessment found that a BCC-filed complaint against unknown parties remained unprosecuted, and that the offshore legal framework created in Anjouan remained legally in effect absent formal invalidation. That historical enforcement-capacity gap continues to contextualise the ongoing AOFA/MISA legitimacy dispute, the dominant payments-relevant legal contest in the jurisdiction.

Outlook

Whether the AOFA/MISA dispute produces a formal judicial or administrative invalidation, rather than continued reliance on public communiqués, remains the central legal watch item.

Periodic update · new data 2026-10-25

Legal & Litigation

The Comoros government has stated that it is preparing domestic legal action over the Anjouan-branded licensing network, having first requested United Kingdom law-enforcement and financial-intelligence cooperation. This represents an escalation from the government's prior unilateral disclaimers disputing the network's legitimacy to active preparation of a formal legal response, naming the licensing network's commercial administrators as relevant subjects. The litigation risk here attaches not only to the network's gambling-licensing activity but, given the Anjouan Offshore Finance Authority's adjacent forex and contract-for-difference certificates, to that parallel authorisation claim as well, since the Central Bank's underlying legal position, that only it may authorise financial institutions nationally, applies equally to both.

Separately, the commercial administrators named in connection with the network, ACS Global Custodian and Sherm Group, face their own contested characterisation. The director of ACS Global Custodian has rejected the reporting's interpretation of the evidence, stating that the company has not sold or issued gambling licences since he acquired it in 2023. No court or regulatory finding has resolved this dispute, and the underlying facts, including the source of a reported increase in the company's cash holdings, remain contested.

Outlook

The clearest indicator of litigation risk going forward is whether the Comoros government's stated domestic legal action is actually filed, and against which parties. Any filing naming ACS Global Custodian or Sherm Group directly would materially sharpen the currently contested characterisation of their role in the network.

Sources and findings (4)
  1. T2https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/retrieved
  2. T2https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/retrieved
  3. T1https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf Applies beyond this jurisdiction (IMF)retrieved
  4. T3https://generisonline.com/navigating-the-litigation-process-in-comoros-a-comprehensive-guide/retrieved

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Merchant acquiring in Comoros is constrained by very low POS penetration and non-interoperable legacy networks. No dedicated acquiring regulation, chargeback/dispute framework, or high-risk-MCC treatment regime specific to Comoros was located in this run (searched BCC policy-framework documentation and payments-infrastructure press); the 2025 National Payment Switch go-live is the primary structural development expected to improve merchant settlement speed and reach.

Open gap — wpm-int-4No dedicated chargeback/dispute framework or high-risk-MCC treatment regime specific to Comoros was located.no under-indexing note recorded
Standing sub-brief · as of 8 September 202673 words · last cycle 2026-09-08

Merchant Acquiring & Risk

The National Payment Switch is positioned to provide faster merchant settlement and expand rural payment access, an expected improvement against a backdrop of low point-of-sale penetration. No dedicated acquiring regulation, chargeback or dispute framework, or high-risk-MCC treatment regime has been identified for Comoros.

Outlook

Whether merchant-facing rules follow the Switch's infrastructure gains, in the same way scheme compliance may eventually follow it, is the open question for this module.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T1https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf Applies beyond this jurisdiction (World Bank)retrieved
  2. T3https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switchretrieved

#

Comoros adopted its first-ever National Financial Inclusion Strategy (NFIS) 2025-2030 on October 8, 2025, chaired by the BCC via a new National Financial Inclusion Council. Concrete infrastructure delivered under this push includes KomorPay (automated cheque/transfer clearing), the Komor Switch interbank platform, a National Payment Hub, the Mali Ya Wakazi banking-agent network, and a live (Aug 2025) National Interoperable Payment Switch. Axian's new IFDD digital-lending licence (2026) extends mobile nano/micro-loan products. No confirmed CBDC pilot exists for Comoros specifically.

Open gap — wpm-int-6No Comoros-specific CBDC pilot or research programme was identified.no under-indexing note recorded
Open gap — wpm-int-7No forward-dated regulatory deadlines were extracted into regulatory_horizon this cycle; the NFIS 2025-2030 sets a 2030 target horizon but no precise dated milestone was available to cite without fabricating precision.ATS+ (RTGS/ACH/IFT) rollout timeline should be tracked as a lead-signal watch item for a future confirmed go-live date.
Standing sub-brief · as of 8 September 202691 words · last cycle 2026-09-08

Product Innovation & Market Development

Comoros adopted its first-ever National Financial Inclusion Strategy for 2025-2030 on 8 October 2025, chaired by the BCC through a newly created National Financial Inclusion Council. The strategy sets financial-inclusion targets through 2030 and provides the strategic backdrop for payment-switch and agent-network rollouts; no CBDC pilot has been confirmed for Comoros.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T2https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/retrieved
  2. T2https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/retrieved
  3. T3https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/retrieved
  4. T1https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf Applies beyond this jurisdiction (IMF)retrieved

#

No dedicated financial consumer-protection agency, ombudsman scheme, or APP-fraud reimbursement regime specific to Comoros was located (searched BCC's public communications and generic ombudsman registries). The de facto consumer-protection mechanism observed is the BCC's direct public-communiqué warnings against fraudulent island-level 'licence' schemes (AOFA/MISA), functioning as anti-fraud messaging rather than a formal complaints/redress framework.

Open gap — wpm-int-5No dedicated financial consumer-protection agency, ombudsman scheme, or APP-fraud reimbursement regime specific to Comoros was located.no under-indexing note recorded
Standing sub-brief · as of 8 September 202667 words · last cycle 2026-09-08

Consumer Protection & APP Fraud

BCC public communiqués warn that AOFA paperwork triggers enhanced due diligence and is commonly declined by banks and payment service providers, functioning as a de facto consumer-protection mechanism in the absence of a dedicated ombudsman scheme or APP-fraud reimbursement regime.

Outlook

Whether Comoros develops a dedicated financial ombudsman or APP-fraud reimbursement framework, rather than continuing to rely on communiqué-based warnings, remains unconfirmed.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T2https://legasset.com/anjouan-forex-licence-explained/retrieved
  2. T3https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/retrieved

#

Sentinel.gi payments-context position: Comoros is a member of ESAAMLG and underwent a Mutual Evaluation (MER published May 2024, endorsed by FATF) assessing compliance with the FATF 40 Recommendations. Comoros is not currently on the FATF black or grey list. The BCC supervises AML/CFT for all financial institutions except insurance, but the MER flags resource constraints limiting effective supervision, and DNFBP AML/CFT supervisory authorities remain undesignated under Law n°12-008/AU.

Open gap — wpm-int-2No Sentinel-fed AML/CFT item for KM surfaced to this collector this cycle.no under-indexing note recorded
Open gap — wpm-int-8FATF primary MER/country pages returned HTTP 403 (blocked); W11 sentinel content relies on the ESAAMLG mirror PDF and secondary compliance summaries rather than the FATF page directly.no under-indexing note recorded
Standing sub-brief · as of 8 September 2026121 words · last cycle 2026-09-08

AML/CFT & Financial Crime

This module is sourced from the Sentinel.gi feed; the analysis below reflects Sentinel's payments-context summary rather than independent WPM illicit-finance analysis. Comoros underwent a Mutual Evaluation, published May 2024 and endorsed by FATF, confirming the jurisdiction is not currently on the FATF black or grey list. The same evaluation found that the BCC lacks adequate resources to effectively monitor AML/CFT obligations across supervised institutions, and that DNFBP AML/CFT supervisory authorities remain undesignated under AML/CFT Law No. 12-008/AU, Article 24(1). For deeper illicit-finance risk assessment of the DNFBP supervisory gap, see the linked Sentinel.gi feed and the FIM cross-reference.

no periodic updates on record for this sub-brief

Sources and findings (7)
  1. T1https://www.fatf-gafi.org/en/countries/global-network/eastern-and-southern-africa-anti-money-laundering-group--esaamlg.html Applies beyond this jurisdiction (FATF)retrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — Comoros — AML/CFT governed by Law N°20-005/AU, implemented via Decision n°12-2023/BCC/DSBR and TFS Decree N°23-074/PR. Supervisor: Banque Centrale des Comores (BCC); FIU: Service de Renseignements Financiers (SRF), est. Décret N°03-025/PR (2003), reinforced Ordinance N°09-002/PR (2009). Assessed by GIABA (FSRB) under 2012 FATF Recommendations/2013 Methodology; 2nd round MER adopted May 2024 found mixed technical compliance and very low effectiveness, placing Comoros under enhanced follow-up. Not on FATF or EU high-risk lists.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-006) — Gap: absent-field-provenance
  4. T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: GIABA (FATF-Style Regional Body) — Union of the Comoros AML/CFT regime
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: enforcement-absence
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: political-constraint
  7. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap

#

Comoros' cross-border settlement access runs primarily through SADC-RTGS (operated by the South African Reserve Bank on behalf of participating SADC central banks) and through correspondent relationships held by locally licensed banks, some of which (Exim Bank Comoros) are subsidiaries of larger regional banking groups (Exim Bank Tanzania). Generic de-risking pressures documented globally for small/frontier markets are relevant context but no Comoros-specific de-risking incident was independently confirmed in this run. A 2026 BCC-Tunisia cooperation accord also touches banking supervision and financial stability, which is adjacent to correspondent-access themes.

Standing sub-brief · as of 8 September 202692 words · last cycle 2026-09-08

Correspondent Banking, Settlement & Access

Access to correspondent banking in Comoros runs through locally licensed banks rather than through any dedicated non-bank correspondent channel, the asymmetry that defines this module: cross-border settlement access runs via SADC-RTGS and correspondent relationships held by those banks, including Exim Bank Comoros, a subsidiary of Exim Bank Tanzania. No Comoros-specific de-risking incident was independently confirmed this cycle; generic frontier-market de-risking pressure is relevant context only.

no periodic updates on record for this sub-brief

Sources and findings (4)
  1. T1https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGSretrieved
  2. T2https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008retrieved
  3. T3https://en.wikipedia.org/wiki/Exim_Bank_Comorosretrieved
  4. T2https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/retrieved

#

Trailing-12-month (Sept 2025-Sept 2026) commercial activity in Comoros payments is dominated by BCC-driven infrastructure milestones and Axian Group product/licensing moves, plus one pan-African development-finance partnership explicitly covering Comoros.

Standing sub-brief · as of 8 September 2026152 words · last cycle 2026-10-25

Commercial Intelligence

Axian Group secured a Banque Centrale des Comores IFDD licence (24 February 2026) to launch a branchless digital financial institution offering nano and micro loans via mobile phone; deal value was not publicly disclosed. The Banque Centrale des Comores and the Central Bank of Tunisia signed an institutional cooperation agreement (7 April 2026) covering monetary policy, financial stability, supervision, payment-system modernisation, fintech and cybersecurity; deal value was not publicly disclosed. The African Development Bank and Axian Group launched a digital finance programme (announced 2 September 2026) leveraging Mixx and MVola to support 34,000 women-led businesses across five countries including Comoros, building on AfDB's earlier financing to Axian Telecom; deal value was not publicly disclosed.

Periodic update · new data 2026-10-25

Commercial Intelligence & Fintech

UK-registered entities ACS Global Custodian, trading as Anjouan Corporate Services, and Sherm Group, both linked to London's Sorsky family, are reported as administering the disputed Anjouan licensing ecosystem commercially. ACS Global Custodian's cash holdings reportedly rose from thirteen thousand one hundred and thirty pounds to six hundred and fourteen thousand eight hundred and twenty-six pounds in 2025, though the source of that increase is not publicly disclosed and remains unestablished in the reporting. The director of ACS Global Custodian has rejected the newspaper's interpretation of the evidence, stating that the company has not sold or issued gambling licences since he acquired it in 2023, a direct dispute between the reported commercial narrative and the company's own account of its activity.

No confirmed licensed payments business has been established for either ACS Global Custodian or Sherm Group in the record this period; their role as reported is one of commercial administration of the broader licensing ecosystem rather than of any specific payments product or service. This is a discrete commercial event concerning named entities rather than a structural market-wide trend, and it sits alongside, but distinct from, the authorisation dispute between the Comoros government and the Anjouan network itself.

Outlook

What would clarify this picture is independent confirmation of the source of ACS Global Custodian's reported cash-holding increase, and whether any regulatory or law-enforcement body, in the United Kingdom or Comoros, examines the company's role in the licensing ecosystem directly in light of the director's denial.

Sources and findings (4)
  1. T2https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/retrieved
  2. T3https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/retrieved
  3. T2https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/retrieved
  4. T2https://afdb.africa-newsroom.com/press/african-development-bank-and-axian-launch-digital-finance-programme-to-support-34000-womenled-businesses-in-africa?lang=enretrieved
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