Centralized exchange in Central African Republic
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Central African Republic with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Customer Due Diligence (CDD) required under BEAC Regulation No. 01/17/CEMAC/UMAC/CM — collect full name, date of birth, nationality, physical address, and identification number for all customers (natural persons); for legal entities, verify legal form, name, address, directors, and beneficial owners.
- Enhanced Due Diligence (EDD) required for PEPs, cross-border relationships, and high-risk jurisdictions or products.
- Suspicious Transaction Reports (STRs) must be filed promptly with the national FIU (CENTIF) regardless of amount, whenever funds are suspected to be proceeds of crime or related to terrorist financing.
- Travel Rule obligations under CEMAC Regulation No. 04/22/CM/UMAC/CM: For any transfer exceeding EUR 1,000 (or equivalent in XAF), collect and transmit originator information (name, physical address, national identity number, date/place of birth, wallet address) and beneficiary information (name, physical address, wallet address) to the beneficiary VASP immediately and securely.
- Record-keeping: Maintain all CDD documents, transaction records, and copies of STRs for at least five (5) years.
- Risk-based procedures must be implemented to identify and verify customers, especially for higher-risk transactions or relationships.
- Tipping-off is strictly prohibited — VASPs must not inform customers or third parties that an STR has been filed.
- COBAC (Banking Commission of Central Africa) is the primary supervisor for financial institutions including VASPs in the CEMAC zone.
Key Restrictions
- Regional CEMAC/BEAC framework applies rather than standalone CAR national law — BEAC Regulation No. 04/22/CM/UMAC/CM and COBAC Instruction No. 001/GR/2023 govern VASPs in CAR.
- The operator must be compliant with both CAR national AML/CFT law (Law No. 00-010 of May 8, 2000) and the overarching CEMAC regional framework, which may create overlapping or conflicting requirements.
- No functional national VASP licensing regime has been established in CAR — the effective supervisory framework is regional (CEMAC/BEAC/COBAC) and its practical implementation in CAR is uncertain.
- The CAR 2022 crypto law (Law No. 22.006) has been described as embracing opaque, unregulated cryptocurrency schemes with risk of state asset capture; legitimate VASPs may face reputational and operational friction from this association.
- Central bank (BEAC) has actively opposed CAR's cryptocurrency initiatives and warned financial institutions against engaging with crypto within the CEMAC zone.
Key Risks
- Regulatory ambiguity: National transposition of CEMAC Regulation No. 04/22/CM/UMAC/CM into CAR-specific law may be incomplete or ongoing, creating legal uncertainty for VASPs operating in CAR.
- BEAC/CEMAC enforcement risk: BEAC has demonstrated willingness to pressure CAR over crypto initiatives, and COBAC can impose administrative sanctions including fines, license suspension/withdrawal, and referral for criminal prosecution.
- Political risk: CAR's Sango Coin project and Bitcoin legal tender history have drawn IMF criticism and created reputational risks; the government's approach to crypto is viewed as unorthodox by international financial institutions.
- Sanctions risk: Regulatory opacity and the government's past practices raise risk of inadvertent facilitation of illicit finance, with exposure under CEMAC AML/CFT penalties (imprisonment and monetary fines for individuals and legal entities).
- Infrastructure gaps: Lack of reliable local banking correspondent relationships and technical infrastructure for travel-rule compliance (e.g., no mandated technical protocol like TRISA) creates operational complexity.
- IMF and international pressure: Continued IMF surveillance and warnings could lead to further restrictions or reputational harm affecting correspondent banking and fiat on/off ramps.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
The Central African Republic's cryptocurrency statute is Loi n° 22.004 du 22 avril 2022 régissant la cryptomonnaie en République Centrafricaine, adopted by the National Assembly on 22 April 2022 and promulgated later that month; no Loi n° 22.006 of 27 April 2022 governs cryptocurrency.
The Central African Republic operates no national virtual-asset licensing or supervision and its land-tokenisation platform requires only an email address and a crypto payment with no identity verification, while Règlement n° 02/24/CEMAC/UMAC/CM art. 42 and the COSUMAF Règlement Général of 23 May 2023 impose prior authorisation duties that Bangui has not implemented.
No Règlement n° 01/17/CEMAC/UMAC/CM of 30 March 2017 exists; CEMAC AML/CFT law ran from Règlement n° 01/03-CEMAC-UMAC of 4 April 2003 through Règlement n° 02/10 of 2 October 2010 and Règlement n° 01/CEMAC/UMAC/CM of 11 April 2016 to Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024, each adopted by the UMAC Comité Ministériel rather than by BEAC.
The Central African Republic is bound by CEMAC community law, which prevails over conflicting national texts under article 44 of the CEMAC Treaty, and the AML/CFT and market règlements are adopted by the UMAC Comité Ministériel while BEAC holds the exclusive right of issue and COBAC supervises credit institutions.
The Central African Republic has no Loi n° 00-010 of 8 May 2000 on money laundering; GABAC's mutual evaluation records that money-laundering and terrorist-financing offences entered Central African law through the Penal Code revised in January 2010, with the CEMAC règlement applying directly alongside it.
No CEMAC instrument numbered 04/22/CM/UMAC/CM exists; the CEMAC text governing virtual asset service providers is Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 on the prevention and repression of money laundering, terrorist financing and proliferation financing, which defines actif virtuel and prestataire de services sur actifs virtuels at article 2 and lists PSAV among the assujettis at article 6.
COBAC has issued no instruction numbered 001/GR/2023 and none dated 31 January 2023; COBAC numbers its instructions in the form Instruction COBAC I-YYYY/NN, its published register ends at Instruction COBAC I-2018/01, and its only virtual-asset instrument is Décision COBAC D-2022/071 of 6 May 2022 on the holding, use, exchange and conversion of cryptocurrencies by COBAC-supervised institutions.
Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM sets the occasional-transaction threshold for virtual asset service providers at 500 000 FCFA, above which reinforced customer due diligence applies; the CEMAC framework states the threshold in FCFA and not as EUR 1 000.
Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM requires the originating virtual asset service provider to obtain and retain accurate information on the originator, to transmit it to the beneficiary PSAV, and to keep it under the article 39 retention rule; the regulation imposes the obligation by reference to the required accurate information rather than by listing date and place of birth as a distinct field.
Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM requires the beneficiary virtual asset service provider to obtain and retain accurate originator and beneficiary information and to make it available to the competent authorities on request.
Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM requires the originating virtual asset service provider to transmit the required originator information to the beneficiary virtual asset service provider immediately and in a secure manner.
Article 39 of Règlement n° 02/24/CEMAC/UMAC/CM requires assujettis, including virtual asset service providers, to retain customer identity documents, transaction records and related material for a minimum of ten years from account closure or the end of the business relationship, not five years.
Administrative sanctions: Fines, injunctions, public reprimands.
COSUMAF is the designated licensing authority for digital asset service providers throughout CEMAC under Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF of 21 July 2022 and the Règlement Général COSUMAF of 23 May 2023, and it holds the power to suspend or withdraw an agrément; no PSAN agrément has been granted in the Central African Republic and no PSAN implementing instruction or minimum-capital rule has been issued, so no CAR licence currently exists to suspend or withdraw.
Referral to national judicial authorities for criminal prosecution under national AML/CFT laws, which can lead to imprisonment and substantial monetary fines for individuals and legal entities.
BEAC is the central bank of the six CEMAC states and the Central African Republic is a member, and BEAC has issued no virtual-asset instrument of its own; COSUMAF is the designated competent authority for digital asset service providers in CEMAC, COBAC bars supervised credit, microfinance and payment institutions from acquiring, holding, transferring or converting crypto-assets under Décision COBAC D-2022/071 of 6 May 2022, and the Central African Republic's financial intelligence unit is an ANIF.
BEAC and COBAC directed their April and May 2022 response at the Central African Republic's Loi n° 22.004 du 22 avril 2022 régissant la cryptomonnaie, and the Republic repealed that law's legal-tender and guaranteed-convertibility provisions in March 2023 as a prior action for its IMF Extended Credit Facility.
The Central African Republic's National Assembly adopted a revised cryptocurrency law on 23 March 2023 that removed bitcoin's legal-tender status and turned the duty to accept crypto into a freedom to accept it, and IMF Country Report No. 23/155 records repeal of the legal-tender and guaranteed-convertibility provisions of Loi n° 22.004 as a met prior action.
IMF Country Report No. 23/155 of May 2023 records macro-fiscal, financial-stability and integrity risks from the April 2022 crypto legislation and from project Sango, holds that the legal-tender grant violated BEAC's exclusive right of issue in the monetary union, and conditions the 38-month Extended Credit Facility on repeal of the legal-tender and convertibility provisions.
Sango coin sold roughly 10 percent of its 210 million token target for under 2 million euros, its website went offline until April 2025, and the Central African Republic pivoted to the Solana-based $CAR memecoin launched on 9 February 2025, which lost more than 75 percent of its value within days.
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 — a centralized exchange can technically operate under the CEMAC regional VASP framework (Regulation No. 04/22/CM/UMAC/CM and COBAC Instruction No. 001/GR/2023) but faces severe regulatory ambiguity, an incomplete national transposition, active central-bank hostility toward crypto initiatives, and high political/reputational risk given CAR's Sango Coin and Bitcoin legal-tender history.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?