Custodial wallet / SaaS in Central African Republic

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.

Loi n° 22.004 du 22 avril 2022 made crypto-assets legal tender alongside the CFA franc, the National Assembly stripped that status on 23 March 2023 under IMF and BEAC pressure, and a tokenisation law passed in 2023 opened land and natural resources to blockchain tokens.

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.

While it creates the framework, it generally defers to further decrees or existing AML/CFT laws for specific requirements.

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.

Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 names virtual-asset service providers as assujettis in article 6 and requires prior agrément under article 42, so CEMAC AML/CFT law now covers virtual-asset businesses expressly rather than by analogy with FATF Recommendation 15.

Règlement n° 02/24/CEMAC/UMAC/CM requires customer and beneficial-owner identification under article 20, ongoing monitoring under article 21, enhanced measures for politically exposed persons under article 23, ten-year record retention under article 39 and suspicious-transaction reporting to ANIF under article 105.

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.

This regulation is further complemented by an instructional circular from the Banking Commission of Central Africa (COBAC), which is the primary supervisor for financial institutions in CEMAC:

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.

The CEMAC AML/CFT regulation covering virtual assets was adopted by the UMAC Ministerial Committee in extraordinary session at Libreville on 20 December 2024 as Règlement n° 02/24/CEMAC/UMAC/CM; no CEMAC regulation on virtual asset service providers was published on 21 December 2022.

No COBAC implementing instruction on virtual assets took effect on 31 January 2023; the COBAC instruction register ends at Instruction COBAC I-2018/01 and contains no virtual-asset text, and the COBAC sectoral AML/CFT instrument is Règlement COBAC R-2023/01, in force 1 July 2024.

CEMAC règlements are directly applicable in the Central African Republic without national transposition under article 44 of the CEMAC Treaty, so Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 binds virtual asset service providers in CAR from its entry into force; no COBAC implementing instruction on virtual assets exists, and Décision COBAC D-2022/071 of 6 May 2022 binds only COBAC-supervised institutions rather than VASPs.

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.

This threshold applies to both single transactions and linked transactions.

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

Evidence fact cf.aml.collect-and-retain-the-following not found (may have been renamed).

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.

Implement risk-based procedures to identify and verify the identity of customers, especially for higher-risk transactions or relationships.

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 faces downside financing risks related to BEAC and has previously shown practices challenging regional monetary policy uniformity, suggesting potential for financial instability risks. While robust Anti-Money Laundering and Combating the Financing of Terrorism (AML-CFT) legal frameworks were noted in 2006, the provided evidence does not directly confirm that BEAC specifically argued a CAR law violated CEMAC conventions concerning unified monetary policy.

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.

The International Monetary Fund holds no regulatory authority over the Central African Republic and acted through programme conditionality, making repeal of the crypto legal-tender and convertibility provisions a prior action for the 38-month Extended Credit Facility arrangement.

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.