Overview: Comoran government security forces had limited resources and training in counterterrorism and maritime security, so the country remained vulnerable to terrorist transit. In April, a Comoran Coast Guard unit was created and received an ArchAngel patrol boat from the United States to help with maritime surveillance. Training to Comoran Coast Guard officials on its proper operation and maintenance was also provided.

Countering Terrorist Finance: Comoros has introduced a number of measures to establish an anti-money laundering/countering terrorist finance (AML/CTF) regime, including a 2009 law providing for the establishment of a financial intelligence unit, expanding the scope of preventative measures, and covering terrorism financing. However, the legal framework has many shortcomings and the government has not effectively implemented it. The Financial Action Task Force (FATF) mutual evaluation assessors found Comoros "largely compliant" (the FATF's second highest rating) for four of the FATF 40+9 recommendations, and it received ratings of partially compliant or noncompliant on the rest. An inadequate budget, dysfunctional ministries, and a nonfunctioning judiciary limit effectiveness of Comorian AML/CTF efforts, despite apparent high-level political support. Thus far, most institutions subject to the law have not yet put AML/CTF policies and procedures in place. Although the central bank has begun to monitor implementation of the AML/CTF preventive measures, limited resources hampered the government's ability to enforce the AML regulations, and local institutions and personnel lacked the training and capacity to enforce the law fully.

There have been no investigations or convictions for money laundering to date. The criminalization of terrorist financing does not comply with the 1999 UN Convention for the Suppression of the Financing of Terrorism. There were no provisions allowing the Comorian authorities to freeze the assets of terrorists and other persons designated by the UNSCRs 1267 and 1373.

As of December, Comoros was a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), a FATF-style regional body. ESAAMLG became an Associate Member of the FATF in June.

Regional and International Cooperation: Comoros acted as Chair of the East African Standby Brigade (an AU body for peacekeeping and intervention missions) in 2010.

Countering Radicalization and Violent Extremism: President Sambi, democratically elected in 2006, with Comoran religious leaders, has publicly rejected religious extremism. President Sambi has also sought close partnership with the United States to develop Comoros economically and to create opportunities for the country's youth. To this end, he has requested that the Peace Corps return to Comoros as soon as possible.


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