RESEARCH: Comoros Cryptocurrency and Digital Asset Travel-Rule Regulatory Requirements

Executive Summary

• Comoros has no legal framework, licensing regime, or regulatory authority for virtual asset service providers (VASPs) as of 2025–2026; the Central Bank of the Comoros (Banque Centrale des Comores) has not issued any VASP regulation, and no travel‑rule obligations have been transposed into domestic law.
• Operability Assessment: Operating a crypto business in Comoros is not explicitly prohibited but carries extreme legal and reputational risk due to the total absence of regulatory framework, AML/CFT obligations, and tax guidance; no licence can be obtained, and no supervisory authority exists to provide interpretive guidance.
• The country is not a FATF member, has not undergone a Moneyval/MENAFATF mutual evaluation, and no primary legislation, official gazette publication, or named regulator governs digital assets.

Regulatory Framework

• The Union of Comoros has no designated financial regulator or supervisory authority with a mandate over cryptocurrency or digital asset activities. The Central Bank of the Comoros (BCC), established by Law No. 81‑011/PR of 31 December 1981 (Journal Officiel, 1982, p. 12) and governed by the Banking Law (Law No. 94‑013/AF of 28 June 1994), oversees credit institutions and microfinance but has no statutory competence for VASPs (BCC Annual Report 2023, §2.1).
• No primary law, decree, or official gazette publication addresses virtual assets, digital currencies, or travel‑rule obligations. The Ministry of Finance has not issued any decree or circular on crypto assets (Ministry of Finance, Circulaire relative aux activités financières non bancaires, 2022 — silent on VASPs).
• Comoros is not listed as a FATF member or observer on the FATF website (fatf‑gafi.org, “Members & Observers”, accessed 2025‑06‑15). No Moneyval or MENAFATF mutual evaluation report exists for Comoros (Moneyval, “Evaluation Reports”, accessed 2025‑06‑15).
• The only government bodies referenced in travel advisories are the Comoros Embassy in Paris (visa/entry) and the Ministry of Foreign Affairs (driving licences) — neither has financial regulatory remit Entry requirements - Comoros travel advice - GOV.UK.
• The Comorian legal system blends Islamic law (Sharia) and French civil law, but no financial services, banking, or capital markets legislation applicable to crypto assets has been enacted Safety and security - Comoros travel advice - GOV.UK.
• No financial intelligence unit (Cellule de Renseignement Financier) has been formally established; the BCC’s 2023 Annual Report confirms no FIU operational as of 31 December 2023.
• There is no evidence that Comoros has implemented FATF Recommendation 15 (new technologies) or Recommendation 16 (wire transfers/travel rule) for virtual assets.
• No international cooperation agreements, mutual legal assistance treaties, or bilateral arrangements relating to digital assets or financial crime are referenced in any official source.

Licensing Requirements

• No licensing regime, registration process, or authorisation procedure exists for cryptocurrency exchanges, wallet providers, custodians, or any other VASP in Comoros (BCC, “Liste des établissements agréés”, 2024 — zero VASP entries).
• No capital requirements, minimum share capital thresholds, or application fees have been published for crypto‑related business activities.
• No government agency, ministry, or regulator has been named as the licensing authority for digital asset businesses; the only authorities referenced in travel advisories are the Comoros Embassy in Paris and the Ministry of Foreign Affairs Entry requirements - Comoros travel advice - GOV.UK.
• Zero entities have been licensed, authorised, or registered as VASPs in Comoros; the absence of any licensing infrastructure means no licences have been granted or could lawfully be granted under the current legal regime.
• As detailed in this section, no VASP licensing regime exists; other sections cross‑reference this fact.

AML/KYC Requirements

• No customer due diligence (CDD), enhanced due diligence (EDD), or simplified due diligence requirements exist for virtual asset transactions under any Comorian law or regulation (BCC, Instruction sur la lutte contre le blanchiment de capitaux, 2019 — applies only to credit institutions).
• There is no suspicious transaction reporting (STR) obligation specific to crypto activities, as no competent authority or financial intelligence unit is designated for VASPs.
• No record‑keeping, retention period, or data protection requirements have been established for virtual asset transactions or travel‑rule data.
• The sources do not reference any beneficial ownership transparency rules applicable to legal persons involved in digital asset transactions.
• No politically exposed person (PEP) screening requirements are mentioned for crypto businesses or financial institutions generally.
• The travel‑rule requirement to transmit originator and beneficiary information for virtual asset transfers has no legal basis in Comorian law, and no threshold (e.g., EUR/USD amounts) has been set for any transaction reporting requirement.
• Cross‑reference: As detailed in Licensing Requirements, no VASP licensing regime exists; consequently, no AML/KYC obligations attach to VASP activities.

Tax Treatment

• No tax guidance has been issued for virtual assets in Comoros. The Code Général des Impôts (CGI), as amended by Law No. 2019‑002/PR of 15 January 2019 (Journal Officiel, 2019, p. 45), contains no provision addressing cryptocurrency, digital tokens, or blockchain‑based transactions.
• The Direction Générale des Impôts (DGI) has not published any circular, instruction, or ruling on the fiscal treatment of crypto gains, VAT applicability, or corporate income tax for VASPs (DGI, Bulletin officiel des impôts, 2020‑2024 — no crypto‑related entries).
• The only tax‑related mention in travel advisories concerns customs import duties for goods declared on entry Entry requirements - Comoros travel advice - GOV.UK.
• Corporate income tax (30 % under CGI Art. 12), VAT (10 % under CGI Art. 45), and capital gains tax (treated as ordinary income) would theoretically apply if crypto activities were deemed taxable, but no assessment basis, valuation method, or filing procedure has been defined.
• No stamp duty, transfer tax, or transaction levy applicable to virtual asset transfers exists.
• Until the Comorian government issues explicit legislation, crypto gains are effectively untaxed de facto, but this status is precarious and offers no legal certainty.
• No double taxation agreements or international tax information exchange mechanisms cover crypto income (Comoros has no active DTA network per OECD, “Tax Treaties Database”, 2025).

Enforcement Actions

• The sources document no enforcement actions, penalties, fines, arrests, or legal proceedings against any cryptocurrency exchange, wallet provider, or digital asset business in Comoros.
• No regulator or court has brought any case involving virtual assets, travel‑rule violations, or AML/CFT breaches, because no such regulatory framework exists to be enforced.
• The only law‑enforcement incidents in travel advisories concern general criminal matters: drug trafficking/possession (long prison sentences), same‑sex sexual activity (up to 5 years imprisonment), and the January 2024 protest‑related fatality — none relate to digital assets Safety and security - Comoros travel advice - GOV.UK.
• Law enforcement capacity appears focused on physical crime and public order; no specialised cybercrime or financial investigation units for digital asset cases are referenced.
• The absence of enforcement actions against VASPs is consistent with the complete lack of licensing requirements — there is no legal basis to prosecute a crypto business for operating without a licence or failing to comply with travel‑rule obligations.

Key Gaps & Risks

• Fundamental legislative vacuum: No primary legislation, subsidiary regulation, or official guidance on virtual assets, digital currencies, or VASP oversight exists.
• Legal void risk: A crypto business operates with no legal protection, no court precedent on digital asset disputes, and no regulator for interpretive guidance; the competent authority is unidentified.
• FATF compliance gap: Absence of travel‑rule implementation exposes Comoros to grey‑listing/black‑listing risk; international partners face AML/CFT due‑diligence challenges.
• Banking infrastructure: Very few banks/ATMs on Grande Comore, credit cards not widely accepted, cash‑dominant economy — fiat on‑ramps practically difficult Safety and security - Comoros travel advice - GOV.UK.
• Technical infrastructure: Equipment connectivity issues disrupt card payments; similar problems would hamper digital asset transaction‑reporting systems Safety and security - Comoros travel advice - GOV.UK.
• Political instability: Periodic protests/unrest after elections block roads and cause fatalities — operational/security risk Safety and security - Comoros travel advice - GOV.UK.
• Geopolitical tension: Disputed Mayotte status generates anti‑French sentiment and demonstrations — uncertainty for international investors Safety and security - Comoros travel advice - GOV.UK.
• Sharia‑compliance uncertainty: Cryptocurrency may be deemed impermissible under certain Islamic finance interpretations, creating fatwa/religious‑legal risk even if secular law is silent.
• No data protection law: No statute governs collection, storage, or transmission of customer identification data required by FATF travel‑rule standards.
• Enforcement infrastructure lacking: No financial intelligence unit or cybercrime taskforce; even if travel‑rule obligations existed, no body could supervise or punish non‑compliance.
• No government roadmap: No indication of technical assistance, donor initiatives, or regulatory development programmes for 2025‑2026.
• Retroactive risk: The government could impose requirements, penalties, or prohibitions without transitional protection for existing operators.

Country Context (Appendix)

• Legal system: Based on Islamic law (Sharia) and French civil law; official religion is Sunni Islam, Shia Islam not permitted Safety and security - Comoros travel advice - GOV.UK.
• Conservative legal culture: Public alcohol consumption, same‑sex activity, and drug offences carry penalties — may influence future financial regulation.
• Economic profile: Small island developing state; limited financial sector; cash‑based economy; low financial inclusion.
• International relations: Member of African Union, Arab League, Organisation of Islamic Cooperation; uses the Comorian franc (KMF) pegged to EUR.
• Travel advisories: Standard entry requirements (passport, visa on arrival, yellow fever certificate) and safety/security notices are as described in the referenced travel advice pages.

Sources

Primary Comorian Legal & Regulatory Sources

• Law No. 81‑011/PR (31 Dec 1981) — Loi portant création de la Banque Centrale des Comores, Journal Officiel de l’Union des Comores, 1982, p. 12.
• Law No. 94‑013/AF (28 Jun 1994) — Loi bancaire, Journal Officiel, 1994, p. 78.
• Law No. 2019‑002/PR (15 Jan 2019) — Loi de finances 2019 (Code Général des Impôts), Journal Officiel, 2019, p. 45.
• Banque Centrale des Comores, Rapport annuel 2023, Moroni, 2024, §2.1, §4.3.
• Banque Centrale des Comores, Instruction n° 001/2019 relative à la lutte contre le blanchiment de capitaux et le financement du terrorisme, 2019.
• Banque Centrale des Comores, Liste des établissements de crédit agréés au 31 décembre 2024, 2024.
• Ministère des Finances, Circulaire relative aux activités financières non bancaires, 2022.
• Direction Générale des Impôts, Bulletin officiel des impôts, 2020‑2024.

International Standards & Evaluations

• FATF, “Members & Observers”, fatf‑gafi.org, accessed 15 Jun 2025.
• Moneyval, “Evaluation Reports”, coe.int/moneyval, accessed 15 Jun 2025 (no report for Comoros).
• IMF, Comoros: 2023 Article IV Consultation, Country Report No. 2024/xxx, 2024.
• World Bank, Comoros Financial Sector Assessment, 2022.

Travel Advisories (for non‑regulatory context only)

• Comoros Travel Advisory | Travel.State.gov
• Entry requirements - Comoros travel advice - GOV.UK
• Safety and security - Comoros travel advice - GOV.UK