Crypto ATM / kiosk operator in Benin

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 The statement that beneficial ownership is not obtainable through ordinary company searches is now out of date: Benin established a beneficial ownership registry by Decret n° 2024-917 du 24 avril 2024.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').

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.

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.

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.