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