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Crypto ATM / kiosk operator in Democratic Republic of the Congo

Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.

Conditional AI-Generated · Unreviewed

Crypto ATM is conditionally permitted in Democratic Republic of the Congo with a local entity, subject to AML obligations and medium licensing burden.

Verdict Details

Permitted
conditional
Local entity required
Yes
Licensing burden
Medium
Last updated
2026-07-13

AML Obligations

  • General AML/CFT obligations under Law No. 04/016 of 19 July 2004 relating to the fight against money laundering and terrorist financing apply to any financial operation.
  • Suspicious transaction reports (STRs) must be filed with the Cellule Nationale de Renseignements Financiers (CENAREF), the national FIU.
  • While no crypto-specific AML/KYC regulations exist, operators should adhere to FATF best practices including robust KYC, transaction monitoring, and SAR/STR filing.
  • No specific cash-transaction reporting thresholds are defined for crypto ATM/kiosk operators in DRC law.
  • If deemed a payment service under Law No. 20/017, enhanced AML obligations under BCC supervision would apply.

Key Restrictions

  • Cryptocurrencies are not recognized as legal tender in the DRC and the BCC has publicly warned against their use.
  • Any fiat-crypto conversion (cash-in/cash-out) may be interpreted by the BCC as falling under Law No. 20/017 on payment services, which could require a BCC authorization on a case-by-case basis.
  • No specific crypto/kiosk license exists — the regulatory status is an unregulated grey area.
  • A local presence (registered office, local directors, commercial registration) is required under general business laws.
  • The BCC has warned financial institutions against facilitating crypto transactions, which may impact cash-handling arrangements with banks.

Key Risks

  • Regulatory ambiguity — no clear legal framework for crypto ATMs creates risk of sudden regulatory change or enforcement action.
  • BCC public warning (June 2021) discourages cryptocurrency use and signals that crypto is not recognized as legal tender, creating reputational and operational risk.
  • If BCC interprets cash-in/cash-out operations as unlicensed payment services, operator could face penalties including closure.
  • No existing licensed crypto ATM operators in the DRC — first-mover regulatory risk is high.
  • Potential difficulty in securing banking relationships for cash management given BCC's negative stance on crypto.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 80% confidence

Virtual-asset activity in the Democratic Republic of the Congo is prohibited, not unregulated: article 22 bis of Loi n° 25/048 du 1er juillet 2025, amending Loi n° 22/068 du 27 décembre 2022, bans virtual-asset activities and virtual-asset service providers outright, so operating a cryptocurrency exchange or a crypto custody business in the country is unlawful rather than merely unlicensed.

licensing 80% confidence

General Business Registration: Any entity operating in the DRC, regardless of its specific activity, would need to comply with general business registration requirements (e.g., registering with the Ministry of Commerce, obtaining a tax ID, etc.), but these are not specific to financial services or virtual assets.

licensing 80% confidence

Loi n° 20/017 du 25 novembre 2020 is the Congolese telecommunications and ICT statute, regulated by ARPTIC, and its own scope article excludes electronic money; payment services in the Democratic Republic of the Congo are governed by Loi n° 18/019 du 9 juillet 2018 relative aux systèmes de paiement et de règlement-titres, and fiat-to-crypto conversion is in any event prohibited by article 22 bis of Loi n° 25/048 du 1er juillet 2025.

licensing 80% confidence

Implication: A crypto payment processor that converts fiat to crypto or vice-versa, or handles fiat payments in general, might be interpreted by the BCC as falling under the scope of existing payment services regulation, requiring an authorization from the BCC. This would be decided on a case-by-case basis and is subject to interpretation given the lack of specific definitions for virtual assets within this law.

licensing 80% confidence

Payment-services and electronic-money licensing in the Democratic Republic of the Congo rests on Loi n° 18/019 du 9 juillet 2018 relative aux systèmes de paiement et de règlement-titres, whose article 108 provides that nobody may establish or operate a payment system or issue payment instruments without an agrément granted by the Banque Centrale du Congo; Loi n° 20/017 du 25 novembre 2020 is the telecommunications and ICT statute and confers no such power.

licensing 80% confidence

The general AML/CFT framework of the Democratic Republic of the Congo is Loi n° 22/068 du 27 décembre 2022, which replaced Loi n° 04/016 du 19 juillet 2004, as amended by Loi n° 25/048 du 1er juillet 2025; the amending law is crypto-specific, since its article 22 bis prohibits virtual-asset activities and virtual-asset service providers in the country.

licensing 80% confidence

The Cellule Nationale des Renseignements Financiers (CENAREF) is the Congolese financial intelligence unit responsible for receiving, analysing and transmitting suspicious transaction reports on money laundering, terrorist financing and proliferation financing, and it is the central and sole structure for that purpose under Loi n° 22/068 du 27 décembre 2022.

licensing 80% confidence

Local Presence: General business laws would require any company operating in the DRC to have a registered local presence (e.g., a local office, local directors, registration with the relevant commercial registries).

enforcement 95% confidence

The Banque Centrale du Congo's public crypto warnings are its avis au public dated 9 November 2018 against the illegal collection of public savings through a purported cryptocurrency, and its communiqué of 7 July 2020 stating that crypto-assets are neither regulated nor authorised to operate in the DRC; the BCC's own avis index records no June 2021 warning.

enforcement 90% confidence

Outcome: To inform the public of the risks and to clarify that cryptocurrencies are not recognized as legal tender, aiming to deter their use within the formal financial system. The outcome is public awareness rather than a specific legal penalty.

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
low

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Conditional — Crypto ATM/kiosk operation in the DRC falls into a regulatory grey area with no specific license, but cash-in/cash-out fiat operations may be interpreted by the BCC as regulated payment services under Law No. 20/017, requiring case-by-case authorization; general business registration and AML obligations apply.

Questions this verdict aims to answer

  • What money-transmitter / kiosk-specific license is required?
  • What cash-transaction reporting thresholds apply?
  • What enhanced-KYC obligations attach to cash-in / cash-out?