Crypto-funded debit card in Congo

The prohibition applicable in the Republic of the Congo is Décision COBAC D-2022/071 du 6 mai 2022, issued by the Commission Bancaire de l'Afrique Centrale and not by BEAC; it bars COBAC-supervised institutions — credit institutions, microfinance establishments and payment institutions — from acquiring, holding, transferring, converting or booking crypto-assets, and requires them to detect such operations and report them to COBAC and BEAC, while leaving private holding of crypto by the public lawful and leaving the COSUMAF PSAN licensing regime in force.

No BEAC circular of 21 December 2022 bans crypto-assets; the cited PDF at beac.int returns HTTP 404, beac.int indexes no crypto content, and the real CEMAC measure is Décision COBAC D-2022/071 du 6 mai 2022 restricting COBAC-supervised institutions.

The prohibition binding financial institutions in the Republic of the Congo comes from Décision COBAC D-2022/071 du 6 mai 2022, which forbids COBAC-supervised establishments from acquiring, holding, transferring, converting or booking crypto-assets and obliges them to detect and report such operations to COBAC and BEAC; no BEAC circular of December 2022 exists.

Holding, buying, or selling cryptocurrencies.

Offering services related to cryptocurrencies.

Facilitating cryptocurrency transactions for clients.

Opening accounts for cryptocurrency service providers.

A community licensing route for crypto exchanges exists in the Republic of the Congo: Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 and the Règlement Général COSUMAF du 23 mai 2023 require COSUMAF agrément as prestataire de services sur actifs numériques, covering custody, buy-sell against legal tender, platform operation, reception-transmission of orders, portfolio management, advice and placement, although COSUMAF has granted no PSAN agrément to date.

Décision COBAC D-2022/071 du 6 mai 2022 bars COBAC-supervised institutions in the Republic of the Congo from every crypto-asset operation and obliges them to detect and report crypto-related flows to COBAC and BEAC, which closes banking relationships with crypto exchange platforms as a consequence of the general prohibition rather than through a separate account-opening clause.

COSUMAF is the designated competent authority for virtual-asset service providers in the Republic of the Congo and may grant PSAN agrément under the Règlement Général du 23 mai 2023, so an exchange platform can hold a lawful community licence, and articles 91 to 93 of that règlement place virtual-asset risks inside COSUMAF's risk-based AML/CFT supervision.

Décision COBAC D-2022/071 du 6 mai 2022 forbids credit institutions, microfinance establishments and payment institutions supervised by COBAC in the Republic of the Congo from acquiring, holding, transferring, converting or booking crypto-assets, and requires them to detect crypto-related operations and report them to COBAC and BEAC.

No BEAC circular restricts crypto-assets in the Republic of the Congo; the measure in force is décision COBAC D-2022/071 du 6 mai 2022, which binds COBAC-supervised institutions only, so residents of Congo-Brazzaville remain free to hold and trade crypto-assets peer-to-peer while conversion through a regulated bank, microfinance institution or payment institution is closed.

It is extremely difficult and risky for individuals to convert fiat currency into crypto or vice-versa through legitimate channels.

There is no consumer protection for individuals engaged in crypto trading.

Any trading activity occurs outside the regulated financial system, potentially exposing individuals to fraud, scams, and financial losses without recourse.

No Instruction n° 001/GRT/2022 exists; BEAC numbers its instructions n° 00X/GR/YYYY and has issued no virtual-asset instrument. Virtual-asset obligations in the CEMAC zone, including the Republic of the Congo, rest on Décision COBAC D-2022/071 du 6 mai 2022, Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022, the Règlement Général de la COSUMAF du 23 mai 2023 and Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, whose article 6(e) makes virtual-asset service providers assujettis.

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Evidence fact cg.aml.simplified-due-diligence-sdd not found (may have been renamed).

Reporting Obligation: Immediately report to the national Financial Intelligence Unit (FIU) any suspicious transactions, including attempted transactions, where they know, suspect, or have reasonable grounds to suspect that funds are the proceeds of a criminal activity, or are related to terrorist financing, regardless of the amount.

No Tipping-Off: VASPs and their employees are prohibited from disclosing to the customer or to third parties that a suspicious transaction report has been or will be submitted.

Article 39 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, directly applicable in the Republic of the Congo, requires assujettis including virtual-asset service providers to keep identification, account and transaction records for a minimum of ten years after the account is closed or the business relationship ends, not five years.

Article 39 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, directly applicable in the Republic of the Congo, requires assujettis including virtual-asset service providers to keep identification, account and transaction records for a minimum of ten years after the account is closed or the business relationship ends, not five years.

Availability: Records must be sufficient to permit the reconstruction of individual transactions and to provide evidence for prosecution of criminal activity. They must be made available promptly to the competent authorities upon request.