--- title: "KM Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/comoros/ source_html: /jurisdictions/comoros/index.html description: "KM payments and e-money regulation: 14 modules, 56 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: dc8e65920e5d14ced4f6d94575af5e8fdd751b49c29dd69475932c3467b2faad generator: "fe-fleet/md-twin@1.0" --- # KM KM schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 56 sourced findings · 116 sources in the cumulative register Download report (PDF) Expand all 14 Modules 1 Moved this cycle 1 Key judgments 8 Open gaps 56 Findings 30 Tier-1 sources Confidence mix 13 unpopulated 1 confirmed (sums to 14 rendered modules; click to filter) 1 module moved this cycle ## Jurisdiction brief Jurisdiction lead brief 1,022 Full executive summary 208 ###### 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. #### Other Developments A separate forex-licensing body sits adjacent to the gambling dispute. The Anjouan Offshore Finance Authority issues forex and contract-for-difference broker certificates distinct from, but adjacent to, the gambling-licence dispute. The Central Bank's position is that only it may authorise financial institutions nationwide, and that AOFA certificates are not recognised as financial licences of any kind, regardless of how they are marketed to prospective brokers. UK-registered commercial administrators of the disputed network face new scrutiny. ACS Global Custodian and Sherm Group, both linked to London's Sorsky family, are named as administering the disputed Anjouan licensing ecosystem. The director of ACS Global Custodian has rejected the characterisation, stating that the company has not sold or issued gambling licences since he acquired it in 2023. No confirmed licensed payments business has been established for either entity in the record. #### Cross-Monitor Connections The market-access dispute, the legal-action preparation, and the commercial administration of the network by UK-registered entities are three readings of a single underlying fact pattern: an offshore licensing ecosystem operating under the Comoros name without the sanction of the body, the Banque Centrale des Comores, that alone has authority to authorise financial institutions nationally. The same UK-registered administrators named in connection with the licensing dispute are the entities whose own cash position and commercial conduct are separately under scrutiny, meaning payments-sector risk assessment of this network cannot be separated from the underlying authorisation question. #### Outlook What would change this picture is either the outcome of the Comoros government's cooperation request to the United Kingdom, or the outcome of its stated domestic legal action, either of which could clarify the legal status of the Anjouan network and its adjacent Anjouan Offshore Finance Authority forex licensing arm. Until then, any payment service provider or financial institution assessing counterparty risk connected to this network should treat the Central Bank's position, that only it may authorise financial institutions nationally and that the network's authorisations carry no recognised legal standing, as the operative baseline. ###### Standing brief · as of 8 September 2026 Written before the update above. Where they differ, the update is the more recent position. #### Lead Signal Comoros' central bank has authorised a new category of fully-digital, centrally-supervised financial institution for the first time, extending regulatory recognition beyond incumbent mobile-money operators. Axian Group obtained a Banque Centrale des Comores-issued IFDD licence on 24 February 2026, enabling a wholly digital financial entity offering nano and micro loans by mobile phone, alongside Axian's existing MVola mobile-money platform. The licence signals BCC willingness to license fully-digital non-bank entrants, a template other pan-African groups may seek to replicate. #### Other Developments Comoros' payments infrastructure took its most significant structural step in years when 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. The country's card and point-of-sale footprint remains thin: only 37 ATMs and 28 point-of-sale devices nationally, with roughly 34,000 cards in circulation. 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 a planned ATS+ system with no confirmed go-live date. The BCC and the Central Bank of Tunisia signed an institutional cooperation agreement in April 2026 covering payment-system modernisation and cybersecurity strengthening. 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. Remittance inflows exceed 20% of GDP, and Western Union and MoneyGram internet-channel transfers on the France-Comoros corridor cost approximately 3.5% to 9% in total, with payout still predominantly made in cash. Comoros participates in the SADC-RTGS regional multicurrency settlement system alongside fifteen other member states, though its participation status in the Pan-African Payment and Settlement System remains unconfirmed. The Comorian state holds a significant capital stake in two private banks, an involvement in the sector that extends beyond pure regulatory oversight. The dispute over island-level 'offshore' licensing bodies remains unresolved: the Anjouan Offshore Finance Authority and the Mwali International Services Authority carry zero legal recognition under Union law, a position the BCC has reinforced through public communiqués warning that no island entity is authorised to issue banking or financial licences. #### Cross-Monitor Connections Comoros underwent a Mutual Evaluation published in May 2024 and endorsed by FATF, confirming the jurisdiction is not currently on the FATF black or grey list. That evaluation also found that the BCC lacks adequate resources to effectively monitor AML/CFT obligations across supervised institutions, and that AML/CFT supervisory authorities for designated non-financial businesses and professions remain undesignated under the AML/CFT Law. This supervisory gap has been flagged for deeper illicit-finance risk assessment; the underlying use of any payment instrument for illicit purposes is a matter for that separate review, not a conclusion drawn here. Cross-border settlement access for locally licensed banks runs via SADC-RTGS and correspondent relationships, including Exim Bank Comoros, a subsidiary of Exim Bank Tanzania. #### Outlook Several threads from this cycle warrant continued tracking. Whether the BCC sets a confirmed go-live date for the ATS+ system meant to absorb SYCOCO's manual clearing function is one open question. Whether other pan-African fintech or telecom groups seek to replicate Axian's IFDD licensing precedent is another. Whether BCC's public-communiqué warnings against AOFA and MISA escalate into formal enforcement or prosecution bears watching, as does confirmation of Comoros' participation in the Pan-African Payment and Settlement System. The African Development Bank and Axian Group launched a digital finance programme on 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. Read full brief · 1022 words Standing brief, as of 8 September 2026. #### Regulatory Status Comoros' payments regulation is a Union-exclusive competence held by the Banque Centrale des Comores, which holds sole authority to authorise banks and financial institutions under Legislation No. 80-7 (1980); island-level bodies such as the Anjouan Offshore Finance Authority and the Mwali International Services Authority carry zero legal recognition under Union law. This cycle's dominant development is regulatory and infrastructural rather than purely conduct-related: a National Interoperable Payment Switch went live on 25 August 2025 under the World Bank-backed PADSF programme, and the BCC issued Axian Group a new 'IFDD' licence in February 2026, extending digital non-bank authorisation beyond mobile-money incumbents. Comoros adopted its first-ever National Financial Inclusion Strategy for 2025-2030 in October 2025. Remittances exceeding 20% of GDP continue to move through costly France-Comoros channels, and a Mutual Evaluation published in May 2024 confirms Comoros is not currently on the FATF grey or black list, though BCC supervisory-resource constraints and undesignated DNFBP AML/CFT authorities remain flagged risks routed to the illicit-finance monitor. #### Outlook The confirmed go-live date for the ATS+ system, further replication of the IFDD licensing template, any escalation against AOFA/MISA, and confirmation of PAPSS participation are the principal items to track in Comoros through the next cycle. Read full brief · 208 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market Accessmoved1 judgmentProbableconfirmed 2026-09-08▾# 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 — CHANGED Comoros government requests UK law-enforcement cooperation and prepares legal action over the Anjouan licensing network First-time cross-border cooperation request escalates the long-running market-access dispute Key judgment — Probable · impact ELEVATED Comoros' 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 2026 210 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. #### Outlook The Axian IFDD licence is a template other pan-African fintech and telecom groups may seek to replicate, extending BCC's willingness to license fully-digital non-bank entrants beyond incumbent mobile-money operators. Whether the AOFA/MISA dispute moves from public repudiation toward formal enforcement remains an open watch item. Read full sub-brief · 210 words 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. Evidence 6 Sources and findings (6) - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T1[https://2009-2017.state.gov/documents/organization/82217.pdf](https://2009-2017.state.gov/documents/organization/82217.pdf)retrieved 2026-09-08 - T2[https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comoros](https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comoros)retrieved 2026-09-08 - T2[https://legasset.com/anjouan-forex-licence-explained/](https://legasset.com/anjouan-forex-licence-explained/)retrieved 2026-09-08 - T2[https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/](https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/)retrieved 2026-09-08 ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-09-08▾# 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 2026 112 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. #### Outlook Whether the BCC moves from communiqué-based warnings toward a codified safeguarding rulebook for e-money customer funds remains unconfirmed; the segregation and trust mechanics of Regulation 01/2017 for e-money issuer customer funds could not be independently verified from public sources this cycle. Read full sub-brief · 112 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T2[https://legasset.com/anjouan-forex-licence-explained/](https://legasset.com/anjouan-forex-licence-explained/)retrieved 2026-09-08 - T2[https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/](https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/)retrieved 2026-09-08 - T2[https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/](https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/)retrieved 2026-09-08 ### W2Stablecoins & Digital MoneyUncertainconfirmed 2026-09-08▾# 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 2026 81 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. #### Outlook No dedicated stablecoin instrument exists for Comoros to track against; any future guidance would represent a first for the jurisdiction and is not currently signalled. Read full sub-brief · 81 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T3[https://ybcase.com/en/fintech/polucit-kriptolicenziu-na-komorah](https://ybcase.com/en/fintech/polucit-kriptolicenziu-na-komorah)retrieved 2026-09-08 - T3[https://startpolymarket.com/countries/comoros/](https://startpolymarket.com/countries/comoros/)retrieved 2026-09-08 - T3[https://startpolymarket.com/countries/comoros/](https://startpolymarket.com/countries/comoros/)retrieved 2026-09-08 ### W3Operational Resilience & Critical InfrastructureProbableconfirmed 2026-09-08▾# 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 →](https://dataprotection.gi/jurisdictions/) Standing sub-brief · as of 8 September 2026 140 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. #### Outlook The absence of a confirmed ATS+ go-live date is the principal infrastructure watch item; its delivery would formally retire SYCOCO's manual clearing role and complete the shift toward automated interbank settlement. Read full sub-brief · 140 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T3[https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switch](https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switch)retrieved 2026-09-08 - T2[https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/](https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/)retrieved 2026-09-08 - T3[https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/](https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/)retrieved 2026-09-08 ### W4Scheme & Network Compliance1 gapProbableconfirmed 2026-09-08▾# 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-3 No Comoros-specific interchange regulation, surcharging rule, or PCI DSS mandate was located. no under-indexing note recorded Standing sub-brief · as of 8 September 2026 81 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. #### Outlook Whether scheme-level rules (interchange, surcharging, PCI DSS) follow the Payment Switch's interoperability gains is the key forward question for this module. Read full sub-brief · 81 words no periodic updates on record for this sub-brief Evidence 3 Sources and findings (3) - T1[https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf](https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T3[https://en.wikipedia.org/wiki/Exim_Bank_Comoros](https://en.wikipedia.org/wiki/Exim_Bank_Comoros)retrieved 2026-09-08 - T3[https://www.einpresswire.com/article/786074855/paylogic-awarded-project-for-the-national-interoperable-digital-payment-switch-in-the-union-of-comoros](https://www.einpresswire.com/article/786074855/paylogic-awarded-project-for-the-national-interoperable-digital-payment-switch-in-the-union-of-comoros)retrieved 2026-09-08 ### W5Payment Corridor Dynamics1 gapProbableconfirmed 2026-09-08▾# 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-1 No 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 2026 104 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. #### Outlook Persistent high-cost, cash-heavy remittance channels alongside growing mobile-money and switch infrastructure suggest a corridor still in transition; confirmation of PAPSS participation would be a material addition to Comoros' regional settlement footprint. Read full sub-brief · 104 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/](https://world-today-journal.com/comoros-banking-sector-2025-growth-digital-transformation-and-financial-inclusion/)retrieved 2026-09-08 - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T1[https://remittanceprices.worldbank.org/corridor/FR/KM](https://remittanceprices.worldbank.org/corridor/FR/KM) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T2[https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008](https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008)retrieved 2026-09-08 - T1[https://www.elibrary.imf.org/view/journals/087/2025/004/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/087/2025/004/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 ### W6Industry Structure & CommercialProbableconfirmed 2026-09-08▾# 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 2026 71 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 Evidence 4 Sources and findings (4) - T2[https://www.mfw4a.org/country/comoros](https://www.mfw4a.org/country/comoros)retrieved 2026-09-08 - T2[https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/](https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/)retrieved 2026-09-08 - T2[https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comoros](https://www.ecofinagency.com/news-digital/2702-53320-pan-african-group-axian-to-launch-100-digital-financial-entity-in-comoros)retrieved 2026-09-08 - T1[https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf](https://documents1.worldbank.org/curated/en/812791592801563444/pdf/Comoros-Payments-and-Settlement-Systems-Oversight-Policy-Framework.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 ### W7Legal & LitigationProbableconfirmed 2026-09-08▾# 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 2026 78 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. Evidence 4 Sources and findings (4) - T2[https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/](https://www.tradingview.com/news/financemagnates:fc99a9ff1094b:0-is-the-end-of-the-comoros-license-mirage-coming/)retrieved 2026-09-08 - T2[https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/](https://manimama.eu/legal-status-and-regulatory-validity-of-the-misa-brokerage-licence/)retrieved 2026-09-08 - T1[https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf](https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 - T3[https://generisonline.com/navigating-the-litigation-process-in-comoros-a-comprehensive-guide/](https://generisonline.com/navigating-the-litigation-process-in-comoros-a-comprehensive-guide/)retrieved 2026-09-08 ### W8Merchant Acquiring & Risk1 gapUncertainconfirmed 2026-09-08▾# 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-4 No 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 2026 73 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 Evidence 2 Sources and findings (2) - T1[https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf](https://documents1.worldbank.org/curated/en/756511588234080981/pdf/Project-Information-Document-Comoros-Financial-Inclusion-Project-P166193.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-09-08 - T3[https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switch](https://www.einpresswire.com/article/842588827/paylogic-announces-the-go-live-of-the-comoros-s-national-interoperable-payment-switch)retrieved 2026-09-08 ### W9Product Innovation & Market Development2 gapProbableconfirmed 2026-09-08▾# 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-6 No Comoros-specific CBDC pilot or research programme was identified. no under-indexing note recorded Open gap — wpm-int-7 No 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 2026 91 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. #### Outlook The Strategy's 2030 horizon sets the frame against which subsequent product-innovation developments, including any future digital-currency research, will be measured; no precise dated milestone beyond the 2030 horizon was available to cite this cycle. Read full sub-brief · 91 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T2[https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/](https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/)retrieved 2026-09-08 - T2[https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/](https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/)retrieved 2026-09-08 - T3[https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/](https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/)retrieved 2026-09-08 - T1[https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf](https://www.imf.org/external/pubs/ft/scr/2010/cr10320.pdf) Applies beyond this jurisdiction (IMF)retrieved 2026-09-08 ### W10Consumer Protection & APP Fraud1 gapUncertainconfirmed 2026-09-08▾# 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-5 No 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 2026 67 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 Evidence 2 Sources and findings (2) - T2[https://legasset.com/anjouan-forex-licence-explained/](https://legasset.com/anjouan-forex-licence-explained/)retrieved 2026-09-08 - T3[https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/](https://www.financemagnates.com/forex/is-the-end-of-the-comoros-license-mirage-coming/)retrieved 2026-09-08 ### W11AML/CFT & Financial Crime2 gapSourced from Sentinel.gi ↗Confirmedconfirmed 2026-09-08▾# 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-2 No Sentinel-fed AML/CFT item for KM surfaced to this collector this cycle. no under-indexing note recorded Open gap — wpm-int-8 FATF 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 2026 121 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. #### Outlook The supervisory-resource and DNFBP-designation gaps are the principal correspondent-banking de-risking factors to track from this module going forward. Read full sub-brief · 121 words no periodic updates on record for this sub-brief Evidence 7 Sources and findings (7) - T1[https://www.fatf-gafi.org/en/countries/global-network/eastern-and-southern-africa-anti-money-laundering-group--esaamlg.html](https://www.fatf-gafi.org/en/countries/global-network/eastern-and-southern-africa-anti-money-laundering-group--esaamlg.html) Applies beyond this jurisdiction (FATF)retrieved 2026-09-08 - 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. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-006) — Gap: absent-field-provenance - T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-001) — Enforcement: GIABA (FATF-Style Regional Body) — Union of the Comoros AML/CFT regime - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: enforcement-absence - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: political-constraint - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: legal-gap ### W12Correspondent Banking, Settlement & AccessProbableconfirmed 2026-09-08▾# 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 2026 92 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. #### Outlook The bank-only structure of correspondent access, with no confirmed non-bank correspondent route, remains the structural feature to track for this module. Read full sub-brief · 92 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T1[https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS](https://www.resbank.co.za/en/home/what-we-do/payments-and-settlements/SADC-RTGS)retrieved 2026-09-08 - T2[https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008](https://scielo.org.za/scielo.php?script=sci_arttext&pid=S2077-49072022000100008)retrieved 2026-09-08 - T3[https://en.wikipedia.org/wiki/Exim_Bank_Comoros](https://en.wikipedia.org/wiki/Exim_Bank_Comoros)retrieved 2026-09-08 - T2[https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/](https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/)retrieved 2026-09-08 ### W13Commercial Intelligence (M&A, Investment & Product)Probableconfirmed 2026-09-08▾# 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 2026 152 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. #### Outlook Axian's IFDD launch is positioned as a pilot with potential expansion elsewhere in Africa; whether the AfDB-Axian programme or the BCC-Tunisia accord generate further disclosed commercial activity is the forward watch item for this module. Read full sub-brief · 152 words 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. Evidence 4 Sources and findings (4) - T2[https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/](https://born2invest.com/articles/comoros-banking-sector-strengthens-2025/)retrieved 2026-09-08 - T3[https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/](https://www.billionaires.africa/2026/03/01/madagascan-billionaire-hassanein-hiridjees-axian-gets-license-for-fully-digital-lender-in-comoros/)retrieved 2026-09-08 - T2[https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/](https://www.capmad.com/news/economy-en/comoros-tunisia-monetary-and-banking-cooperation-strengthened/)retrieved 2026-09-08 - T2[https://afdb.africa-newsroom.com/press/african-development-bank-and-axian-launch-digital-finance-programme-to-support-34000-womenled-businesses-in-africa?lang=en](https://afdb.africa-newsroom.com/press/african-development-bank-and-axian-launch-digital-finance-programme-to-support-34000-womenled-businesses-in-africa?lang=en)retrieved 2026-09-08 No modules match. Filters combine as OR inside a group and AND across groups. Reset all filters ## Provenance and declared absence Disclosure model: module cards load OPEN; standing positions render in full; sub-briefs and jurisdiction briefs load as a clamped teaser with an explicit “read full” control carrying the true word count; earlier updates stay collapsed behind a counted summary. No text is hidden without disclosing how much of it there is. Sentinel-fed modules receive no special rendering treatment. sentinel_feed is an attribution chip only: it does not suppress content, does not generate an absence reason code, and does not exclude the module from any count, filter, search index or export on this page. Family taxonomy is renderer-level presentation config, not a JID field. Colour is always duplicated in text and is never the sole carrier of meaning. Suppressed by doctrine: derived risk score; per-module RAG traffic light. Not shown on this page. 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