Is Crypto Legal in Benin?

Export Control Joint Unit (ECJU) – Department for Business and Trade, UK

The Department for International Trade (DIT) no longer exists: it merged with the Department for Business, Energy and Industrial Strategy in February 2023 to form the Department for Business and Trade (DBT), which now hosts the Export Control Joint Unit. In any event no UK department has any role in Benin's virtual-asset regulation.

Article 17 (not 'section 17') of the Export Control Order 2008 (SI 2008/3231) creates the transit/transhipment exception from the export prohibitions in articles 3, 4 and 8(1); the exception is disapplied for anti-personnel mines, Category A goods, certain military goods and goods destined for the embargoed destinations in Schedule 4. GOV.UK's Benin guidance confirms the practical consequence: 'This exception does not apply to certain military goods destined for Benin, meaning that a licence is required to transit goods through the UK.' Article 17 is not a general provision on 'export licensing for military goods', and it has no bearing on crypto or virtual-asset activity in Benin.

ECOWAS Convention on Small Arms and Light Weapons – Adopted 14 June 2006, bans SALW within member states.

Benin is a member of ECOWAS, which enforces the above arms ban but does not regulate cryptocurrencies.

The UK, through its ECJU, aligns with FATF recommendations indirectly via broader export controls.

Export of small arms, ammunition, or related SALW to ECOWAS members (including Benin).

CDD, EDD and STR reporting ARE specified for virtual-asset business in Benin. Loi n° 2024-01 du 20 février 2024 defines actif virtuel (art. 2, pt 2) and prestataire de services d'actifs virtuels (art. 2, pt 44), makes PSAV assujettis under art. 3(c) — thereby subjecting them to the law's customer due-diligence and enhanced due-diligence regime — and art. 60 requires suspicious-transaction declarations to the Cellule nationale de traitement des informations financières (CENTIF). What is missing is not the obligations but the supervisory machinery: no competent authority has been designated to implement the PSAV regime.

For Benin, beneficial-ownership identification and PEP screening are imposed by Loi n° 2024-01 du 20 février 2024, whose art. 3(c) makes prestataires de services d'actifs virtuels assujettis alongside financial institutions and DNFBPs. The UK Proceeds of Crime Act 2002 has no application in Benin and is not the source of any Beninese obligation; the UK's own crypto AML obligations sit in the Money Laundering Regulations 2017, not POCA.

A mandatory retention period is set. Article 23 of Loi n° 2024-01 du 20 février 2024 requires assujettis — which under art. 3(c) include prestataires de services d'actifs virtuels — to keep client identification documents and transaction records for ten (10) years after the closure of the account or the completion of the operation. This mirrors art. 23 of the UMOA loi uniforme of 31 March 2023. UK GDPR is irrelevant to Beninese firms.

Correct that Benin has no dedicated digital-asset statute or operational licensing framework, and correct that export controls do not touch crypto. But it is wrong that nothing addresses digital assets: Loi n° 2024-01 du 20 février 2024 defines actif virtuel (art. 2, pt 2) and PSAV (art. 2, pt 44), makes PSAV assujettis (art. 3(c)) and, at art. 58, provides that no one may carry on the professional activity of PSAV without having first obtained the agrément or prior authorisation of the competent authority. That authorisation requirement exists on paper but is inoperative because no competent authority has been designated, which is why GIABA's May 2025 follow-up report still rates Benin Non-Compliant on R.15.

Mandatory AML/KYC requirements are not absent. Under Loi n° 2024-01 du 20 février 2024, prestataires de services d'actifs virtuels are assujettis (art. 3(c)) and are therefore bound by the law's identification, due-diligence, record-keeping (art. 23, ten years) and suspicious-transaction reporting duties to CENTIF-Bénin (art. 60). The real exposure is supervisory, not normative: no competent authority has been designated under art. 58, so the obligations are unsupervised in practice.

Export licensing policy for Benin – GOV.UK

ECOWAS Convention on Small Arms and Light Weapons (SIPRI)

Benin Licensing Requirements for Professional Services – export.gov

Country Commercial Guide: Benin Standards & Trade – U.S. Trade Department

There is no dedicated crypto statute in Benin and no operational licensing regime, but the environment is not 'undefined': Loi n° 2024-01 du 20 février 2024 — Benin's transposition of the UMOA loi uniforme LBC/FT/FP of 31 March 2023 — defines actif virtuel (art. 2, pt 2) and PSAV (art. 2, pt 44), makes PSAV assujettis (art. 3(c)) and requires prior agrément or authorisation from the competent authority before carrying on PSAV activity (art. 58). No competent authority has yet been designated, so the requirement is not yet operable; holding or trading crypto is not prohibited. The trailing citation to export.gov's professional-services licensing page is irrelevant to this proposition.

The Export Control Joint Unit is not Benin's regulator of anything. ECJU is a UK body (within the Department for Business and Trade) administering UK strategic export controls; it has no jurisdiction in Benin. Benin's relevant authorities are CENTIF-Bénin (FIU, décret n° 2006-752 du 31 décembre 2006), which receives STRs under art. 60 of Loi n° 2024-01, and the BCEAO/UMOA layer for banking, e-money and payments; for virtual assets, art. 58 of Loi n° 2024-01 refers to a 'competent authority' that has not yet been designated. It is true, trivially, that ECJU does not oversee cryptocurrency activities.

No PSAV agrément can have been issued in Benin because art. 58 of Loi n° 2024-01 du 20 février 2024 conditions PSAV activity on prior agrément or authorisation from a 'competent authority' that Benin has not designated and for which no licensing procedure exists. So the outcome (no licences) is right, but the stated reason is wrong: the pathway is absent in implementation, not in law — a statutory authorisation requirement does exist and is unimplemented.

AML/KYC is mandatory for virtual-asset business in Benin: Loi n° 2024-01 du 20 février 2024 makes prestataires de services d'actifs virtuels assujettis (art. 3(c)), with identification and due-diligence duties, ten-year record retention (art. 23) and suspicious-transaction reporting to CENTIF (art. 60); art. 58 additionally requires prior agrément. Compliance is a legal duty, not 'voluntary'. The UK limb is also wrong: UK cryptoasset businesses must register with the FCA under the Money Laundering Regulations 2017. What is genuinely missing in Benin is supervision — no competent authority has been designated — and there is no virtual-asset travel rule, because the electronic-transfer duties in arts. 39 et seq. are addressed exclusively to institutions financières.

Tax guidance on cryptocurrency gains is absent, leaving operators to navigate potential income tax implications without clear direction. Benin - Licensing Requirements

Benin's AML/CFT cornerstone is Loi n° 2024-01 du 20 fevrier 2024 relative a la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la proliferation des armes de destruction massive, which transposes the UMOA uniform law of 31 March 2023. It replaced Loi n° 2018-17 du 25 juillet 2018, itself amended by Loi n° 2020-25 du 02 septembre 2020. No Beninese AML/CFT statute numbered 'Loi n° 2011-06' could be located, so the premise of the record is itself unsound.

Directive n° 02/2015/CM/UEMOA du 2 juillet 2015 has been superseded, not merely 'complemented', by the UMOA Loi uniforme LBC/FT/FP du 31 mars 2023. That uniform law - not any 2015 decision - is the current regional reference, and Benin transposed it by Loi n° 2024-01 du 20 fevrier 2024. UEMOA/UMOA instruments are not directly applicable: each state must transpose.

Decret n° 2025-678 du 29 octobre 2025 exists and does set the conditions for establishing personal identification documents and dispenses six of them (CIP, CIP afro-descendants, CIP etranger, CNI biometrique, passeport ordinaire biometrique, carte de resident) from mandatory legalisation/certification, with validity periods of 5 / 3 / 6 years. However it is a civil-identification instrument (RNPP / etat civil), not an AML/CFT instrument: Benin's AML identification and verification obligations remain those of Loi n° 2024-01 du 20 fevrier 2024, notably article 17 (verification from reliable and independent sources).

Article 17 of Loi n° 2024-01 du 20 fevrier 2024 requires reporting entities to identify the customer and to verify identity by means of documents, data or information from reliable and INDEPENDENT sources. Customer self-certification does not satisfy verification. The risk-based approach modulates the extent of measures, not the requirement of an independent source. The only material carve-out identified by GIABA is article 86 (certain online payment transactions where the account is held in Benin, another WAEMU state, or an equivalent third country).

Identification of legal-entity customers and of their beneficial owners is required under Loi n° 2024-01 du 20 fevrier 2024. The statement that beneficial ownership is not obtainable through ordinary company searches is now out of date: Benin established a beneficial ownership registry by Decret n° 2024-917 du 24 avril 2024.

Beneficial Ownership: Identify and take reasonable measures to verify the identity of the beneficial owner(s) of the customer.

Purpose and Intended Nature of Business: Understand the purpose and intended nature of the business relationship.

Ongoing Monitoring: Conduct ongoing due diligence on the business relationship and scrutinize transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Risk-Based Approach: Apply a risk-based approach, meaning enhanced due diligence (EDD) for higher-risk situations (e.g., customers from high-risk jurisdictions, politically exposed persons - PEPs, complex transactions) and simplified due diligence (SDD) for lower-risk situations.

No travel rule applies to virtual asset transfers in Benin. The originator/beneficiary information rules of the UMOA uniform law (arts. 39-47), carried into Loi n° 2024-01, are drafted for 'institutions financieres', which the law defines separately from prestataires de services d'actifs virtuels. GIABA's May 2025 follow-up report rates Benin Non-Compliant on Recommendation 15 ('no legal instrument has been adopted by Benin designed to regulate VA and VASP activities') and Partially Compliant on Recommendation 16 with no virtual-asset coverage at all.

Article 60 al. 1 of Loi n° 2024-01 du 20 fevrier 2024 requires reporting entities (assujettis) to report immediately to CENTIF sums, transactions or attempted transactions suspected of being proceeds of money laundering, terrorist financing, proliferation financing or a predicate offence. GIABA rates Benin Compliant on R.20. However it is not established that PSAV/VASPs are operative reporting entities in Benin: GIABA rates R.15 Non-Compliant and records that no legal instrument regulating VA/VASP activity has been adopted.

No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or third parties that an STR is being or has been filed.

The retention period in Benin is TEN (10) years, not five. Article 23 of Loi n° 2024-01 du 20 fevrier 2024 requires reporting entities to keep, for ten years from the closure of accounts or the termination of the relationship, documents on customer identity, customer knowledge and risk profile, due diligence analyses and transactions. This mirrors art. 23 of the UMOA uniform law of 31 March 2023 ('dix ans, a compter de la cloture de leurs comptes').

Type of Records: This includes all customer identification data (e.g., copies of identification documents), account files, business correspondence, and transaction data (e.g., amounts, dates, types of transactions, involved parties).

Availability: Records must be sufficient to permit the reconstruction of individual transactions and be made available to competent authorities upon request.

Benin’s Financial Intelligence Unit (FIU) is the Cellule Nationale de Traitement des Informations Financières (CENTIF). CENTIF is an administrative financial intelligence unit under the Minister of Finance, with financial and decision-making autonomy, responsible for receiving, analyzing, enriching and transmitting suspicious transaction reports and other relevant financial information to competent authorities for the purposes of combating money laundering and terrorist financing, and for coordinating and supporting national AML/CFT policy and strategy.

Central Bank of West African States (BCEAO): While the BCEAO is the central bank for UEMOA member states and regulates traditional financial institutions, it has issued warnings and statements regarding cryptocurrencies. It would likely be involved in any future licensing or specific regulatory framework for VASPs in the region.

Correct in substance: prudential regulation and supervision of Beninese financial institutions rests with regional bodies - BCEAO and the Commission Bancaire de l'UMOA (banks, e-money, payment institutions), AMF-UMOA (ex-CREPMF) for securities, CIMA for insurance - while the Ministere de l'Economie et des Finances holds national policy and coordination roles, houses CENTIF and supervises parts of the DNFBP sector. GIABA's May 2025 report nonetheless records that several DNFBP sectors in Benin still have no designated AML/CFT supervisor.

Direct link to the legislative text in English is often hard to find publicly for Beninese national laws. It's usually available via official government gazettes or legal databases in French.

The date is right - Directive n° 02/2015/CM/UEMOA relative a la lutte contre le blanchiment de capitaux et le financement du terrorisme dans les Etats membres de l'UEMOA was adopted on 2 July 2015 (the record's own id slug, '29 September 2015', is wrong). But it is no longer current: it has been superseded by the UMOA Loi uniforme LBC/FT/FP du 31 mars 2023, transposed in Benin by Loi n° 2024-01 du 20 fevrier 2024. It should be described as the former, not a live, regional reference.

Article 147 of the Constitution of 11 December 1990 does provide that 'les traites ou accords regulierement ratifies ont, des leur publication, une autorite superieure a celle des lois'. But that rule governs ratified treaties, not derived UEMOA/UMOA secondary legislation. A UEMOA directive is by definition binding as to result and requires national transposition; the UMOA uniform law is a model text that each member state must enact. Benin in fact transposed - Loi n° 2018-17 du 25 juillet 2018, then Loi n° 2024-01 du 20 fevrier 2024 - which would have been unnecessary if the record's inference were correct.

Website: While a direct, frequently updated public website with specific legal texts in English for CENAREF can be elusive, their contact information and general mission are usually available through government portals. An official presence often exists within the Ministry of Economy and Finance.

A more reliable reference is often through GIABA's documentation.

GIABA provides reports and information on AML/CFT frameworks for its member states, including Benin.

Financial Action Task Force (FATF):

Relevant documents include "Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers."

While not the direct regulator for VASPs, it's a key financial authority in the region.

Consult local legal counsel specializing in financial technology and AML/CFT to ensure full compliance with the most current interpretation and application of laws.

There is no body called 'CENAREF' in Benin — CENAREF is the FIU of the Democratic Republic of the Congo. Benin's financial intelligence unit is the CENTIF-Bénin (Cellule Nationale de Traitement des Informations Financières), created by décret n° 2006-752 du 31 décembre 2006. No public sanction against a virtual-asset business exists in Benin: the GIABA/FATF follow-up report of May 2025 rates Benin Non-Compliant on FATF Recommendation 15 and records that 'no legal instrument has been adopted by Benin designed to regulate VA and VASP activities', so no supervisory or enforcement regime exists to sanction under. Loi n° 2024-01 du 20 février 2024 art. 58 does state that no one may professionally act as a PSAV without the agrément or prior authorisation of the competent authority, but Benin has not designated that competent authority, so the requirement is not operational.

Monitor official announcements from the Beninese government, CENAREF, and BCEAO for any new legislation or directives regarding virtual assets.

Benin, through its GIABA/FATF-aligned AML/CFT framework, is expected to implement current FATF standards, but the Travel Rule is not automatically or implicitly adopted in Benin merely by GIABA membership; any Travel Rule obligations depend on Benin’s specific domestic implementation and sectoral rules.

Loi n° 2018-17 du 25 juillet 2018 (as amended by Loi n° 2020-25 du 2 septembre 2020) was Benin's AML/CFT law, but it is no longer 'currently referenced'. It has been superseded by Loi n° 2024-01 du 20 février 2024 relative à la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la prolifération des armes de destruction massive en République du Bénin — Benin's transposition of the UMOA loi uniforme LBC/FT/FP du 31 mars 2023, adopted by the Assemblée nationale on 12 January 2024 and promulgated 20 February 2024. It is a 207-article text that, unlike the 2018 law, expressly covers actifs virtuels and prestataires de services d'actifs virtuels.

sgg.gouv.bj does host a page for Loi n° 2017-15 du 10 août 2017, but that law is 'modifiant et complétant la loi n° 2013-01 du 14 août 2013 portant code foncier et domanial en République du Bénin' — a land-tenure statute with nothing to do with money laundering. Benin's AML/CFT instrument on the same portal is Loi n° 2024-01 du 20 février 2024 (sgg.gouv.bj/doc/loi-2024-01/), preceded by Loi n° 2018-17 du 25 juillet 2018 as amended by Loi n° 2020-25 du 2 septembre 2020. The full text of Loi n° 2024-01 is also published by the Assemblée nationale.

Loi n° 2017-15 is dated 10 août 2017, not 19 June 2017, and is the amendment to Benin's code foncier et domanial, not an AML/CFT law. Benin's AML/CFT statute in force is Loi n° 2024-01 du 20 février 2024 (promulgated 20 February 2024, adopted 12 January 2024), which replaced Loi n° 2018-17 du 25 juillet 2018. The surrounding proposition — that no Travel Rule effective date exists for Benin — is correct: Loi n° 2024-01 makes PSAV assujettis (art. 3) and requires prior agrément/autorisation (art. 58), but no competent authority has been designated and no VA transfer information obligation has been brought into force; GIABA's May 2025 follow-up report rates Benin NC on R.15.

FATF Recommendation 16 (for wire transfers, which the Travel Rule mirrors for VA transfers) specifies that financial institutions (and by extension, VASPs) should obtain and transmit required originator and beneficiary information for transactions equal to or above USD/EUR 1,000.

In the absence of specific domestic guidance for Benin's VASP Travel Rule, the expectation is that the FATF standard of USD/EUR 1,000 (or equivalent in local currency) would apply to inter-VASP virtual asset transfers. Lower thresholds may apply for suspicious transaction reporting.

The FATF defines VASPs broadly to include any natural or legal person who, as a business, conducts one or more of the following activities or operations for or on behalf of another natural or legal person:

Exchange between virtual assets and fiat currencies.

Exchange between one or more forms of virtual assets.

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

Participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset.

Benin's AML/CFT law is not 'Law N°2017-15' (that is the 10 August 2017 amendment to the code foncier et domanial). Under the law actually in force, Loi n° 2024-01 du 20 février 2024, prestataires de services d'actifs virtuels are not covered by mere interpretation — they are defined at art. 2(44) and expressly listed as assujettis at art. 3, alongside institutions financières and EPNFD. The claim's premise that VASPs are captured only implicitly, 'even if not explicitly named', is therefore obsolete as well as attached to the wrong statute.

GIABA Guidance: GIABA actively encourages its member states to regulate and supervise VASPs for AML/CFT purposes. Their mutual evaluation reports and guidance documents clarify these expectations.

Reference: GIABA Official Website – Look for publications, mutual evaluation reports for Benin or general guidance on virtual assets.

VASPs operating in Benin would generally be expected to collect the required originator and beneficiary information (name, address, account number/VA wallet address, transaction hash, etc.) for transfers exceeding the threshold, in line with the FATF Travel Rule.

Transmit this information to the beneficiary VASP during or before the transaction.

Be able to make this information available to competent authorities (e.g., Benin's Financial Intelligence Unit – Cellule Nationale de Traitement des Informations Financières du Bénin - CENTIF-Bénin) upon request.

Common industry solutions (e.g., TRISA, Shyft Network, Sygna, Travel Rule Protocol) are typically used for this purpose, but no specific protocol is mandated by Benin.

No 'Loi n° 2017-15 du 19 juin 2017' exists; Loi n° 2017-15 is dated 10 août 2017 and amends the code foncier et domanial. Sanctions for AML/CFT non-compliance in Benin are set out in Loi n° 2024-01 du 20 février 2024, the transposition of the UMOA loi uniforme du 31 mars 2023, whose sanctions title follows the uniform law (administrative sanctions imposed by the autorité de contrôle, not by the CENTIF, plus criminal penalties). The predecessor was Loi n° 2018-17 du 25 juillet 2018 as amended by Loi n° 2020-25 du 2 septembre 2020.

Administrative Sanctions: Fines, warnings, temporary suspension, or permanent revocation of operating licenses (if applicable).

Criminal Penalties: Imprisonment and substantial fines for individuals found responsible for money laundering or terrorist financing, or for wilfully failing to comply with reporting obligations.

Specific penalty amounts would depend on the severity and nature of the non-compliance (e.g., failure to report suspicious transactions, failure to implement due diligence, or actual involvement in illicit activities).

Not Legal Tender: Cryptocurrencies are not recognized as legal tender within the UEMOA zone.

Virtual assets are not recognised or regulated as financial instruments in Benin, and BCEAO has publicly flagged unregulated crypto-actifs as a financial-stability risk. However, Benin is not 'tightening oversight' through any crypto-specific instrument: Loi n° 2024-01 du 20 février 2024 makes prestataires de services d'actifs virtuels assujettis to AML/CFT obligations (art. 3(c)) and bars professional PSAV activity without prior agrément or authorisation of the 'autorité compétente' (art. 58), but no competent authority has been designated (art. 59 defers everything to future regulation). GIABA's May 2025 enhanced follow-up report rates Benin Non-Compliant on R.15, finding that 'no legal instrument has been adopted by Benin designed to regulate VA and VASP activities'.

BCEAO's published position treats 'l'essor de crypto-actifs non régulés' as a risk to monetary and financial stability, and the UEMOA framework offers no consumer protection or clear legal framework for virtual assets. The specific itemised warning attributed here to a UEMOA Financial Stability Committee communiqué cannot be verified: the cited communiqué URL 404s, and no equivalent BCEAO risk communiqué was retrievable.

No BCEAO or Beninese instrument prohibits banks, microfinance institutions or payment service providers from crypto-related activity. GIABA's May 2025 report states that 'no legal instrument has been adopted by Benin designed to regulate VA and VASP activities' and rates R.15 Non-Compliant. What exists is (a) BCEAO public warnings about unregulated crypto-actifs, and (b) Loi n° 2024-01 art. 58, a generally applicable prior-authorisation requirement for professional PSAV activity that is inoperative because no competent authority has been designated.

There is no operational licensing regime for crypto custody in Benin, but it is wrong to say custody falls outside the regulated perimeter altogether. Loi n° 2024-01 art. 2(44)(d) expressly includes 'la conservation et l'administration d'actifs virtuels' in the PSAV definition, art. 3(c) makes PSAV assujettis, and art. 58 forbids professional PSAV activity without prior agrément or authorisation from the competent authority. Because no competent authority has been designated (art. 59), no custody licence can in fact be applied for or granted.

Segregation of Client Assets Rules: No specific rules exist mandating the segregation of client digital assets from the custodian's operational assets.

Insurance/Bonding Requirements: There are no specific insurance or bonding requirements for crypto custodians.

Cold Storage Mandates: No specific mandates dictate the use of cold storage or other security protocols for digital assets held in custody.

Qualified Custodian Definitions: There is no legal definition of a "qualified custodian" specifically for digital assets.

Regulatory work has been publicly announced since this claim was written, though none of it is custody-specific. BCEAO created the Comité chargé de l'élaboration de la réglementation relative aux crypto-monnaies dans l'UMOA (C-CRYPTO) and convened an international conference on crypto-actifs in Dakar on 8 May 2026, stating that 'l'enjeu n'est pas de freiner l'innovation, mais d'en assurer une intégration maîtrisée'. In Benin, a colloquium on 'Droit africain et cryptomonnaies' was held on 18 December 2025. The claim's second half remains right: the only crypto obligations actually enacted are AML/CFT ones, via Loi n° 2024-01, with no dedicated custody licence.

Legal Uncertainty: Activities are conducted in a regulatory grey area.

No Consumer Protection: There are no specific regulatory safeguards for clients using such services.

Operational Risk: Without clear guidelines, security, operational, and financial risks are heightened.

Correct that no crypto-custody-specific law exists, but it understates the AML position: Beninese AML/CFT law does not merely 'apply generally' to crypto — Loi n° 2024-01 art. 3(c) expressly lists prestataires de services d'actifs virtuels as assujettis, art. 2(44) covers exchange, transfer, custody/administration and issuance-related services, art. 23 imposes 10-year record retention, and art. 58 requires prior agrément. Suspicious transaction reports go to CENTIF-Bénin (the FIU; note that 'CENAREF' is the DRC's FIU, not Benin's). In practice supervision is absent: GIABA rates Benin Non-Compliant on R.15.

For regulatory research on financial stability concerns or unregulated financial products, you would now typically consult the dedicated press-release and notice sections of the relevant financial authorities (eg, ACPR, AMF, SEC, CFTC) and any issue‑specific warning or policy pages they maintain, rather than generically looking for “communiqués de presse.”

A colloquium was indeed held and reported on the Benin government portal on 18 December 2025 — 'Droit africain et cryptomonnaies : Les professionnels de la justice africains en réflexion sur les enjeux juridiques' — but it was a reflection by African justice professionals on the legal issues raised by cryptocurrencies, not a government initiative to develop a Beninese legal framework for cryptocurrencies. No Beninese crypto legal framework has followed: GIABA (May 2025) records that no legal instrument regulating VA/VASP activity has been adopted, and the drafting work is regional (BCEAO's C-CRYPTO committee, 2026).

Benin is a UEMOA/UMOA member and BCEAO is the common central bank and the banking/e-money/payments regulator. But BCEAO is not 'the primary financial regulator' across the board and does not issue directives: UEMOA directives and règlements are adopted by the Conseil des Ministres de l'UEMOA (BCEAO issues instructions, avis and circulaires), securities are regulated by AMF-UMOA (the former CREPMF, renamed 2022), and AML/CFT obligations bind through national transposition — for Benin, Loi n° 2024-01 du 20 février 2024, which transposes the UMOA Loi uniforme of 31 March 2023. AML supervision and STR receipt sit with CENTIF-Bénin.

Developing Frameworks: Many African nations, including Benin, are still in the early stages of developing comprehensive regulatory frameworks specifically for cryptocurrencies. Enforcement often takes the form of general warnings or actions against broad financial fraud rather than specific crypto licensing violations.

Limited Public Reporting: Unlike jurisdictions with mature financial markets (e.g., USA, EU), individual enforcement actions, especially those involving relatively smaller sums or entities, are often not widely publicized by regulators in Benin or the wider UEMOA region.

Focus on Fraud: When actions occur, they are often initiated by law enforcement (police, judicial authorities) against individuals or groups involved in pyramid schemes or investment fraud using cryptocurrencies, rather than by a financial regulator against a crypto service provider for regulatory non-compliance.

The BCEAO’s regulatory stance on crypto‑actifs in Benin has been updated; the earlier communiqué no longer reflects current enforcement deadlines.

BCEAO's own published register of electronic-money issuers in the UMOA, situation au 28 février 2026, lists eight authorised arrangements for Benin — the Trésor Public du Bénin (prepaid card), three établissements de monnaie électronique (MTN Mobile Money Benin, Moov Money, ID Money Benin) and four bank/telecom partnerships (BESTCASH, CORIS-MONEY, and two CELTIS CASH arrangements). Not two. The claim is in any event unrelated to virtual assets: no crypto or VASP authorisation exists in Benin at all.

Police or judicial actions against individuals for fraud or Ponzi schemes where cryptocurrency was the means rather than the specific regulatory violation.

Formal legal enforcement against refusal of BCEAO banknotes and coins is now in place, superseding informal warnings.