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OO RUEHBZ RUEHDU RUEHGI RUEHJO RUEHMA RUEHMR RUEHPA RUEHRN RUEHTRO
DE RUEHAN #1202 3321250
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O 281250Z NOV 07
FM AMEMBASSY ANTANANARIVO
TO RUEHC/SECSTATE WASHDC IMMEDIATE 0720
INFO RUEHRC/DEPT OF AGRICULTURE WASHINGTON DC IMMEDIATE
RUEATRS/DEPT OF TREASURY WASHDC IMMEDIATE
RUEHC/DEPT OF LABOR WASHDC IMMEDIATE
RUCPDOC/DEPT OF COMMERCE WASHDC IMMEDIATE
RUEHZO/AFRICAN UNION COLLECTIVE
RHHMUNA/HQ USPACOM HONOLULU HI
RHMFIUU/CJTF HOA
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UNCLAS ANTANANARIVO 001202 
 
SIPDIS 
 
SENSITIVE 
SIPDIS 
 
DEPT FOR AF/E AND AF/FO 
DEPT PASS TO USTR FOR FLISER 
 
E.O. 12958: N/A 
TAGS: EFIN ECON PREL CN
SUBJECT:  COMOROS SHELL BANKS ILLEGAL AND UNAUTHORIZED 
 
¶1. (SBU)  SUMMARY.  "Just as the United States is not responsible 
for the criminals who manufacture counterfeit dollars, so the 
Comoros should not be blamed for criminals who market banking 
licenses when they lack the legal authority to issue them."  With 
this argument, Vice Governor of the Central Bank of the Union of the 
Comoros, Abdou Mohamed Chanfou, reiterated his request for any 
possible assistance to shut down these illicit entities wherever 
they may exist.  He pointed out the difficulty they face given that 
these banks are all "virtual" with neither the operators nor the 
internet servers resident on Comoran soil.  END SUMMARY. 
 
¶2.  (U)  In a meeting with Poloff November 21, Central Bank Vice 
Governor Chanfou and Director of the Union Ministry of Finance, 
Soilih Mohamed Soilih, went over Union Government policies and 
efforts with regard to shell banking.  Both officials, with several 
staff from both institutions in attendance, emphasized the shell 
banking issue was a criminal, not a national, problem.  The Vice 
Governor reported on his efforts to communicate to the public on 
illicit banking taking place outside the Comoros in the name of 
"Anjouan," noting shell banking entities have no legal standing in 
the Comoros. 
 
¶3. (SBU)  In January 2008, Chanfou will launch another public 
relations campaign, again issuing circulars indicating the small 
number of commercial banks with approved licenses to operate in the 
Comoros, and the long list of illicit entities, with licenses issued 
by criminal individuals in Anjouan (and Moheli).  Individuals who 
sold licensing authority, use such ill-gotten authority, or profit 
from shell banks are in violation of Comoran law. 
 
¶4. (SBU)  Cabinet Director Soilih, with a polite tone of 
frustration, stated the Union Government does not condone or 
facilitate license issuance or operation of shell banking entities. 
He added his concern that Union statements and actions were so far 
insufficient to address Western government condemnation of the 
Comoros.  Soilih repeated his government's request for technical 
assistance and international cooperation to resolve the shell bank 
issue. 
 
¶5. (SBU)  Vice Governor Chanfou likened his country's punishment for 
shell banks to the global problem of counterfeit U.S. dollars.  Like 
criminals who produce fraudulent U.S. currency, the individuals who 
sold "Anjouan licensing rights" acted privately for private gain 
without any legal authority.  The sole governing authorities for 
finance in the Union of the Comoros are the Union Central Bank and 
Union Minister of Finance.  These legitimate Union institutions have 
long sought to educate the banking public, discredit the likes of 
"anjouan.net," and dissuade international financial institutions 
from doing business with these entities.  In addition to public 
awareness via official circulars on sanctioned and non-sanctioned 
banks, the Union Government has filed legal proceedings against 
individuals in France for illegally operating shell banks in the 
name of Comoros or Anjouan. 
 
¶6. (SBU)  To further make his point about the unfair nature of 
punishing the Comoros, Vice Governor Chanfou reiterated his 
government's request for international assistance to shut down shell 
bank internet sites.  Neither servers nor individuals are reported 
to operate within Comoran jurisdiction.  The Union Government lacks 
the resources or technical expertise to tackle this international 
financial crime alone.  Chanfou candidly asked what percentage of 
global money laundering is facilitated by Comoran criminals, what 
steps were taken in other countries where shell banking existed, and 
why did it seem the Comoros had been singled out as a pariah? 
 
SIBLEY