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 The statement that beneficial ownership is not obtainable through ordinary company searches is now out of date: Benin established a beneficial ownership registry by Decret n° 2024-917 du 24 avril 2024.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

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.

To date, there is no specific legislation or regulatory framework in Benin or by the BCEAO that explicitly classifies stablecoins as e-money, payment tokens, or securities.

The BCEAO has consistently stated that these assets are not legal tender in the UEMOA zone and are not regulated by the central bank.

The most significant regulatory pronouncement is the BCEAO Communiqué N° 004/2020/RB du 29 janvier 2020 sur les monnaies virtuelles et crypto-actifs.

Correct that an e-money issuer must be licensed (agréé) by the BCEAO before operating, and that a decentralised privately issued stablecoin would not qualify without restructuring to fit the monnaie électronique definition — but the legal basis is art. 8 of Instruction n° 008-05-2015 du 21 mai 2015, not the non-existent « Instruction N° 002/2018/RB ». Art. 8: « aucune structure ou établissement ne peut exercer des activités d'émission de monnaie électronique, sans avoir été dûment agréé ou autorisé préalablement par la Banque Centrale. »

No specific licensing regime for stablecoin issuers. As with reserve requirements, there is no framework for licensing an entity whose primary business is the issuance of stablecoins.

Evidence fact bj.enforcement.developing-frameworks not found (may have been renamed).

Evidence fact bj.enforcement.focus-on-fraud not found (may have been renamed).

Evidence fact bj.enforcement.limited-public-reporting not found (may have been renamed).

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.

No Crypto-Specific Rate: There are no specific capital gains tax rates for cryptocurrencies in Benin.

Potential Interpretation: If the DGI were to view cryptocurrencies as a "movable asset" or a "financial instrument," any profits derived from their sale or exchange could theoretically be subject to general capital gains provisions.