“Prior to this training, we thought we knew it all,” said a participant of an ICAR Financial Investigations and Asset Recovery training workshop in Comoros on 24–28 February. “But we have now realised that there is a lot we can improve on.”

Another senior participant stated that he will call a meeting of all officers under his supervision to apply the new knowledge of money laundering offences and financial investigation processes immediately to the team’s work.

This is common feedback after ICAR training workshops, which feature a complex simulated investigation that multi-disciplinary teams of anti-corruption practitioners have to solve together.

In this case, the teams were made up of 24 judges and prosecutors from Grande Comore, Anjouan and Mohéli, plus representatives from law enforcement agencies, the Financial Intelligence Unit of Comoros and other relevant agencies. Through this investigation, they learned the benefits of working as a team to tackle serious financial crimes and recover the illicit proceeds.

Picking up on this aspect at the closing ceremony, Elizabeth Mutunga, Head of Governance, Peace and Security of COMESA, emphasised the importance of inter-agency cooperation and collaboration in the fight against money laundering and terrorist financing. The weaknesses of one or other stakeholder will impact the whole chain, she said, and undermine the efforts made.

A timely training intervention

The workshop was an opportunity for the participants to discover and discuss novel asset confiscation mechanisms in Comoros such as extended confiscation or non-conviction-based confiscation. These are provided for in the Comorian anti-money laundering law but not utilised.

Will we see greater use of these mechanisms in the future? Judging from the participants’ enthusiasm, we expect so.

As one prosecutor mentioned, the training workshop came at the right time as Comoros is currently considering amending some of its laws to align better with international standards. The Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), which is the regional body of the Financial Action Task Force (FATF), will conduct its Mutual Evaluation of Comoros in 2022. 

COMESA-supported workshops in Comoros, Ethiopia and Djibouti

The workshop was delivered in partnership with COMESA through the EU-funded Maritime Security Programme (MASE). We are delighted to partner with COMESA once again for the provision of national training workshops in Comoros, Ethiopia and Djibouti, following two COMESA-supported regional training workshops conducted in Seychelles and Zambia in 2017.

As usual, the workshop was specifically tailored to Comoros’ legal system and framework for anti-money laundering, anti-corruption and asset recovery. Two members of the ICAR training team conducted a scoping mission in 2019 to speak to relevant stakeholders and gather this information.