The Comoros is not on the FATF List of Countries that have been identified as having strategic AML deficiencies
Compliance with FATF Recommendations
The last Mutual Evaluation Report relating to the implementation of anti-money laundering and counter-terrorist financing standards in Comoros was undertaken by the Financial Action Task Force (FATF) in 2011. According to that Evaluation, Comoros was deemed Compliant for 0 and Largely Compliant for 4 of the FATF 40 + 9 Recommendations. It was Partially Compliant or Non-Compliant for all 6 of the Core Recommendations.
US Department of State Money Laundering assessment (INCSR)
The Comoros was deemed a Jurisdiction of Concern by the US Department of State 2016 International Narcotics Control Strategy Report (INCSR). Key Findings from the report are as follows: -
The Union of the Comoros (Comoros) consists of three islands: Ngazidja (Grande Comore), Anjouan, and Moheli. It also claims a fourth (Mayotte), which France governs. Although Comoros lacks homegrown narcotics aside from the marijuana grown for domestic consumption, the islands are reportedly used for transshipment, mainly from Madagascar and continental Africa. Comoros is not a financial center for the region. The Comoran financial system is underdeveloped, and the risk of money laundering activities is relatively low. Electronic funds transfers (EFT) are now offered by two or three banks and credit cards are becoming available. Neither Union nor island government authorities have the means to estimate the volume of illegal proceeds generated by predicate offenses committed in the country. Nevertheless, due to the low level of development in Comoros, such proceeds appear to be limited and primarily involve migrant smuggling and corruption.
There are no international sanctions currently in force against this country.
The Arab League (comprising 22 Arab member states), of which this country is a member, has approved imposing sanctions on Syria. These include: -
Cutting off transactions with the Syrian central bank
Halting funding by Arab governments for projects in Syria
A ban on senior Syrian officials travelling to other Arab countries
A freeze on assets related to President Bashar al-Assad's government
The declaration also calls on Arab central banks to monitor transfers to Syria, with the exception of remittances from Syrians abroad.
The Arab League has also boycotted Israel in a systematic effort to isolate Israel economically in support of the Palestinians, however, the implementation of the boycott has varied over time among member states. There are three tiers to the boycott. The primary boycott prohibits the importation of Israeli-origin goods and services into boycotting countries. The secondary boycott prohibits individuals, as well as private and public sector firms and organizations, in member countries from engaging in business with any entity that does business in Israel. The Arab League maintains a blacklist of such firms. The tertiary boycott prohibits any entity in a member country from doing business with a company or individual that has business dealings with U.S. or other firms on the Arab League blacklist.
BRIBERY & CORRUPTION
Rating (100-Good / 0-Bad)
Transparency International Corruption Index 25
World Governance Indicator – Control of Corruption 23
One of the world's poorest countries, Comoros is made up of three islands that are hampered by inadequate transportation links, a young and rapidly increasing population, and few natural resources. The low educational level of the labor force contributes to a subsistence level of economic activity and a heavy dependence on foreign grants and technical assistance. Agriculture, including fishing, hunting, and forestry, accounts for 50% of GDP, employs 80% of the labor force, and provides most of the exports. Export income is heavily reliant on the three main crops of vanilla, cloves, and ylang-ylang; and Comoros' export earnings are easily disrupted by disasters such as fires and extreme weather. Despite agriculture’s importance to the economy, the country imports roughly 70% of its food; rice, the main staple, accounts for the bulk of imports.
Authorities are negotiating with the IMF for triennial program assistance. The government - which is racked by internal political disputes - is struggling to provide basic services, upgrade education and technical training, privatize commercial and industrial enterprises, improve health services, diversify exports, promote tourism, and reduce the high population growth rate. Recurring political instability, sometimes initiated from outside the country, has inhibited growth. Remittances from about 200,000 Comorans contribute about 25% of the country’s GDP. In December 2012, IMF and the World Bank's International Development Association supported $176 million in debt relief for Comoros, resulting in a 59% reduction of its future external debt service over a period of 40 years. In late 2013, a US-based investment company invested $200 million in a project to explore for hydrocarbons in Comoran territorial waters, the largest financial investment in the country’s history.
Agriculture - products:
vanilla, cloves, ylang-ylang (perfume essence), coconuts, bananas, cassava (manioc)
fishing, tourism, perfume distillation
Exports - commodities:
vanilla, ylang-ylang (perfume essence), cloves
Exports - partners:
India 28.7%, France 17%, Germany 8.7%, Saudi Arabia 7.1%, Singapore 6.6%, Netherlands 6.1%, Mauritius 5.3% (2015)
Imports - commodities:
rice and other foodstuffs, consumer goods, petroleum products, cement and construction materials, transport equipment
Imports - partners:
China 18.9%, Pakistan 16.2%, France 14.7%, UAE 11.3%, India 6.3% (2015)
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