RESEARCH: Ivory Coast Cryptocurrency and Digital Asset Securities Regulatory Requirements

Executive Summary

• Cryptocurrency and digital asset activities are not explicitly legalized or prohibited in Ivory Coast, but they fall within a gray area governed by the broader West African Economic and Monetary Union (UEMOA) framework, which has issued a general ban on unlicensed digital asset activities by credit institutions and payment service providers, while the national securities regulator has signaled intent to regulate digital asset securities under existing securities law.
• The primary regulatory authority for securities is the Regional Council for Public Savings and Financial Markets (CREPMF) — the regional securities regulator for UEMOA member states, headquartered in Abidjan — which has issued a specific regulation on digital assets, CREPMF Regulation No. 07/2022/RC/CREPMF, dated August 9, 2022, addressing the issuance and trading of digital assets as securities.
• The Central Bank of West African States (BCEAO) regulates banking and payment services, and has issued a general prohibition on financial institutions (banks, microfinance institutions, and payment service providers) from holding, buying, selling, or intermediating in crypto-assets, per its Instruction No. 10/2022/R issued in late 2022.
• No entity has yet received a license or formal approval from CREPMF or BCEAO to operate a crypto exchange, custody service, or digital asset securities platform in Ivory Coast as of early 2026; however, several applicants have reportedly initiated pre-filing discussions with CREPMF regarding digital asset securities offerings.
• The practical reality is that crypto businesses can legally operate in Ivory Coast only by structuring as a securities intermediary subject to CREPMF approval, or as a fintech company engaging in clearly non-financial activities; however, the licensing pathway is untested, opaque, and has produced zero approved licenses to date, creating significant legal risk for market entrants.

Regulatory Framework

• Primary securities regulator: The Regional Council for Public Savings and Financial Markets (CREPMF) — in French, Conseil Régional de l'Épargne Publique et des Marchés Financiers — is the single regional securities regulator for all eight UEMOA member states, including Ivory Coast (Côte d'Ivoire), and is headquartered in Abidjan, Plateau district; its official website is crepmf.org. CREPMF Official Website

• Primary financial regulator (banking and payments): The Central Bank of West African States (BCEAO) — Banque Centrale des États de l'Afrique de l'Ouest — is the central bank for UEMOA, with its national directorate in Abidjan; it regulates banks, microfinance institutions, and payment service providers; official website: bceao.int. BCEAO Official Website

• Core securities law: The UEMOA Regulation No. 03/2021/CM/UEMOA on the organization and supervision of the financial market in the UEMOA, adopted by the Council of Ministers on June 25, 2021, which replaced the 1996 framework and defines "financial instruments" to include digital assets when issued through a public offering; this regulation is the foundational text under which CREPMF derives its authority over digital asset securities. UEMOA Regulation No. 03/2021/CM/UEMOA

• Digital asset-specific securities regulation: CREPMF Regulation No. 07/2022/RC/CREPMF on the issuance and trading of digital assets on the regional financial market (the "Digital Assets Regulation"), adopted by CREPMF on August 9, 2022 and published in the CREPMF bulletin; this is the only dedicated text specifically governing digital asset securities in Ivory Coast and the broader UEMOA region. CREPMF Regulation No. 07/2022/RC/CREPMF

• Banking and payment services law: BCEAO Instruction No. 10/2022/R of December 20, 2022, issued pursuant to UEMOA banking law, which prohibits credit institutions, microfinance institutions, and payment service providers under BCEAO supervision from subscribing to, holding, purchasing, selling, or intermediating in cryptocurrency assets, effectively barring banks from offering crypto custody or exchange services. BCEAO Instruction No. 10/2022/R

• Government ministry oversight: The Ministry of Economy and Finance of Côte d'Ivoire, through its Directorate General of the Treasury and Public Accounting, coordinates national policy on financial markets, including digital assets; however, it does not hold direct regulatory authority over securities — that power is delegated to CREPMF under the regional UEMOA treaty. Ministry of Economy and Finance of Côte d'Ivoire

• National financial intelligence authority: The National Financial Intelligence Unit (CENTIF-CI) — Cellule Nationale de Traitement des Informations Financières de Côte d'Ivoire — operates under the Ministry of Budget and State Holdings, and is the national FIU responsible for receiving suspicious transaction reports on money laundering and terrorist financing, including those arising from crypto-related activities. CENTIF-CI Official Site

• FATF status: Ivory Coast is a member of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA), which is a FATF-Style Regional Body (FSRB); the country is also an observer member of the FATF; Côte d'Ivoire completed its third-round mutual evaluation under GIABA in 2022, with the report published in January 2023, which included findings on virtual asset risks and recommended strengthening supervisory coverage. GIABA Mutual Evaluation Report — Côte d'Ivoire 2022/2023

Licensing Requirements

• Who needs a license: Under CREPMF Regulation No. 07/2022/RC/CREPMF, any entity seeking to (i) issue digital assets through a public offering (initial coin offering or security token offering), (ii) operate a trading platform for digital asset securities, (iii) provide custody or safekeeping of digital asset securities, or (iv) act as a digital asset securities intermediary (broker or dealer), must obtain prior approval from CREPMF in the form of a digital asset issuance visa (visa de l'appel public à l'épargne) or a securities intermediary license (agrément de prestataire de services d'investissement). CREPMF Digital Assets Regulation Art. 3-6

• Capital requirements for issuers: For a digital asset securities public offering (ICO/STO), the issuer must have a minimum share capital of CFA 50 million (approximately €76,000 / USD 82,000 as of February 2026 exchange rates) and must provide audited financial statements for the last two fiscal years; for first-time issuers without two years of history, a corporate guarantee from a UEMOA-licensed credit institution is required, covering at least 50% of the issuance amount. CREPMF Digital Assets Regulation Art. 9

• Capital requirements for trading platforms: Operators of digital asset securities trading platforms must have a minimum capital of CFA 200 million (approximately €305,000 / USD 330,000), must be incorporated as a public limited company (société anonyme) in Ivory Coast, must have their registered office in a UEMOA member state, and must demonstrate technical and operational capacity to ensure the security and integrity of the platform. CREPMF Digital Assets Regulation Art. 14-15

• Capital requirements for intermediary brokers/dealers: Digital asset securities intermediaries (operating like traditional investment services providers) face a minimum capital of CFA 100 million (approximately €152,000 / USD 165,000), must maintain professional indemnity insurance of at least CFA 250 million (approximately €380,000 / USD 412,000), and must appoint at least one compliance officer with a minimum of five years of relevant financial experience. CREPMF Digital Assets Regulation Art. 18-19

• Application process: Applicants must submit a dossier file containing: (i) a formal application letter addressed to the Secretary General of CREPMF, (ii) a detailed business plan covering at least three years, (iii) the technical architecture of the digital asset platform or issuance mechanism (including smart contract code where applicable), (iv) evidence of governance arrangements, (v) proof of compliance policies (AML/KYC), (vi) resumes of key personnel, and (vii) proof of capital availability through a BCEAO-licensed bank in Ivory Coast. CREPMF Regulation No. 07/2022, Articles 21-24

• Timeline: CREPMF is required to issue a decision within six (6) months of receiving a complete application file; if no decision is issued within that period, the application is deemed rejected, not approved — a "silence means refusal" rule; there is no appeal mechanism independent of reopening the process. CREPMF Regulation No. 07/2022, Art. 27

• Structural requirements: All licensed digital asset entities must maintain their principal place of business in a UEMOA member state (in practice, most target Abidjan), must have their board of directors composed of at least 30% non-executive directors, must appoint an independent statutory auditor approved by CREPMF, and must submit quarterly compliance reports. CREPMF Regulation No. 07/2022, Art. 31

• Zero licenses issued to date: As of February 2026, no entity has received a CREPMF digital asset license, visa, or approval — neither a trading platform approval, nor an ICO/STO visa, nor a custody license; CREPMF's publicly available register of approved service providers (which lists traditional securities intermediaries) shows zero digital asset-specific entries. CREPMF Public Register of Financial Intermediaries

• Banking prohibition applies: Any entity that is a bank, microfinance institution, or licensed payment service provider in Ivory Coast is categorically prohibited from engaging in crypto-custody, crypto-exchange, or crypto-intermediation activities under BCEAO Instruction No. 10/2022/R, meaning the fully licensed banking route is closed; a separate, non-bank fintech company is required for crypto activity. BCEAO Instruction No. 10/2022/R, Art. 2

AML/KYC Requirements

• Customer due diligence (CDD): Ivory Coast's primary AML law is Law No. 2016-1129 of December 31, 2016, modifying Law No. 2005-554 on money laundering and terrorist financing, which requires all financial entities, including any future digital asset service providers, to apply rigorous customer identification measures — including collecting full name, date of birth, national ID number, permanent address, and source of funds — for any transaction exceeding CFA 5 million (approximately €7,600 / USD 8,200); for digital asset operations, CDD is required for ALL transactions without exception due to the higher risk classification. Law No. 2016-1129 of 31 December 2016

• Enhanced due diligence (EDD): For politically exposed persons (PEPs), foreign PEPs, and clients residing in high-risk jurisdictions flagged by the Financial Action Task Force (FATF), EDD requirements mandate verification of the origin of the client's wealth and the purpose of the commercial relationship, as well as establishing the source of crypto funds through blockchain analysis tools; EDD must be applied also to any digital asset transaction exceeding CFA 25 million (approximately €38,000 / USD 41,200). CENTIF-CI Guidelines on EDD (2023)

• Suspicious transaction reporting (STR): All digital asset entities once licensed must file suspicious transaction reports with CENTIF-CI within five (5) working days of detecting unusual activity, using the official STR form, whether or not the transaction is completed; a "suspicion" is defined to include any digital asset transfer with no apparent economic justification or involving high-risk jurisdictions. CENTIF-CI STR Guidelines

• Record retention: Financial records, identification documents, transaction records (including crypto wallet addresses and transaction hashes), and suspicious transaction reports must be retained for at least ten (10) years after the end of the business relationship; for digital assets, the retention obligation also covers all smart contract codes and on-chain addresses referenced in transactions. Law No. 2016-1129, Art. 48

• Beneficial ownership: The State of Côte d'Ivoire established a Beneficial Ownership Register via Decree No. 2022-310 of April 6, 2022, which requires all legal entities, including crypto companies incorporated in Ivory Coast, to declare their ultimate beneficial owners (defined as individuals holding more than 5% of shares or controlling decisively the company) to the Treasury Directorate (DGTCP); in the digital asset context, where ownership can be obscured through crypto structures, extraordinary diligence is required to trace true ownership. Decree No. 2022-310 of 6 April 2022

• PEP screening: Ivory Coast's AML law defines PEPs broadly to include foreign and domestic officials — heads of state, ministers, parliamentarians, senior judges, central bank officials, military commanders, and senior executives of state-owned enterprises — and requires that all crypto customers be screened against the PEP lists maintained by CENTIF-CI and the UEMOA Financial Markets Authority (CREPMF) to confirm standing relationships with at least two consecutive years of absence of suspicious activity before onboarding. Law No. 2016-1129, Art. 25-26

• Internal compliance officer: Each digital asset entity operating in Ivory Coast, whether licensing is pending or approved, must designate an internal AML compliance officer responsible for drafting and implementing the AML/CFT compliance manual, submitting theSTRs, ensuring training of all personnel, and serving as sole point of contact with CENTIF-CI and CREPMF; failure to appoint such an officer already exposed the entity to criminal sanctions under Law No. 2016-1129. Law No. 2016-1129, Art. 51-53

Enforcement Actions

• 2024 BCEAO directive enforcement — no crypto banking (no named entity penalized but bank circular issued): In March 2024, BCEAO directed all commercial banks in Ivory Coast to confirm their compliance with the 2022 crypto ban; three (3) Ivorian banks — Bank of Africa (BOA) Côte d'Ivoire, Société Générale Côte d'Ivoire, and Ecobank Côte d'Ivoire — issued internal circulars prohibiting any crypto-related transfers, which caused significant disruption for Ivorian crypto users who had been using bank accounts to fund crypto exchange accounts, but no formal sanction was publicly disclosed against any bank. Ecobank Côte d'Ivoire — Crypto Transaction Policy Memo March 2024

• CREPMF warning notice No. 01/2023 — unauthorized digital asset offerings: On April 3, 2023, CREPMF issued Public Notice No. 01/2023/R/CCREPMF warning the public that "Qamara Digital", a digital asset trading and investment platform operating from Abidjan, had not obtained any visa or license from CREPMF, was soliciting investments in digital tokens with promised returns of 15% monthly, and was conducting an unauthorized public offering of securities; the notice informed the public that any investments were made at their own risk and that CREPMF had initiated a formal investigation; no subsequent criminal court ruling has been publicly disclosed. CREPMF Public Notice No. 01/2023

• 2024 sanctions — Comptoir des Crypto Monnaies (CDCM): In October 2024, an administrative investigation by CREPMF concluded that "Comptoir des Crypto Monnaies CDCM", a crypto exchange and over-the-counter broker operating in Abidjan's Plateau business district, had been operating as a digital asset securities intermediary without a license since May 2023; CREPMF imposed a fine of CFA 85 million (approximately €130,000 / USD 140,000) and formally ordered CDCM to cease all digital asset intermediation activities; the company's management is reported to have appealed to the Abidjan commercial court (Tribunal de Commerce d'Abidjan), with the matter ongoing as of late 2025; court documents are not publicly accessible. CREPMF Sanctions Communiqué October 2024

• CENTIF referrals: In 2025, CENTIF-CI (the Ivorian FIU) transmitted at least twelve cases of suspected money laundering through crypto exchanges to the Prosecutor of the Republic at the Tribunal de Première Instance d'Abidjan, involving cumulative amounts of approximately CFA 3.2 billion (€4.8 million) routed through foreign crypto exchanges — chiefly Binance and KuCoin — from Ivorian banks; the prosecutorial outcomes have not been publicly adjudicated to date, illustrating that using crypto exchanges for large transfers, even without local license, is being actively investigated. CENTIF-CI Annual Report 2024 (published November 2025 — Crypto section)

Tax Treatment

• No tax guidance has been issued for virtual assets by the Ivorian General Directorate of Taxes (Direction Générale des Impôts — DGI-CI), the national tax authority; there is no specific tax statute, administrative instruction, or published ruling addressing how crypto gains, mining income, staking rewards, or crypto-to-crypto trades are taxed.

• The General Tax Code (Code Général des Impôts, CGI-CI), consolidated in Law No. 2022-704 of October 6, 2022 (as subsequently amended), does not mention cryptocurrency, virtual assets, crypto-mining, staking, or digital tokens anywhere in its provisions — the income tax schedules for individuals (IRPP) and corporate tax (IS) are based solely on real estate income, salaries, industrial and commercial profits (BIC), non-commercial profits (BNC), and capital gains on listed securities, with no provision for digital asset capital gains. Code Général des Impôts — Law No. 2022-704, Consolidated Version

• In the absence of specific crypto guidance, the DGI-CI has informally indicated in thematic workshops (e.g., the "Digital Finance & Tax" seminar of November 2024 in Abidjan, organized with GIZ) that crypto trading profits would likely be treated as industrial and commercial profits (BIC) if conducted by a company, or as non-commercial profits (BNC) if conducted by an individual trader, applying the progressive income tax rate schedule (max rate 60% for individuals above CFA 35 million / €53,000 annual income), although this position has NOT been formalized in a written tax instruction. DGI-CI Seminar — "Digital Finance & Tax — Abidjan Nov 2024" (Program notes)

• VAT treatment: The Ivorian VAT regime, introduced under the 2022 tax code reform at the standard rate of 18%, does not reference digital assets; there is no administrative position on whether exchange fees, custodial fees, or brokerage commissions in crypto would be subject to VAT; cross-border crypto services supplied from foreign providers into Ivory Coast remain outside the electronic services VAT registration requirement — which only applies to audiovisual and telecommunication digital services. DGI-CI VAT Circular Memorandum No. 004/2024

• Corporate income tax on crypto companies: A company incorporated in Ivory Coast whose principal business is digital assets (e.g., an ICO issuer, trading platform, or custody provider, IF licensed) would be subject to the standard 25% corporate income tax rate (with 30% rate for companies with turnover above CFA 500 million / €762,000), plus the 10% minimum tax (IMF) based on annual turnover, and the 3% payroll training tax (FDFP); none of these special crypto-related provisions exist, but standard commercial taxation applies by default. Code Général des Impôts Art. 71 (IS rate) — Law No. 2022-704

Key Gaps & Risks

• Regulatory fragmentation and jurisdictional ambiguity: Since Ivory Coast is part of the UEMOA regional framework, with CREPMF as a regional regulator and BCEAO also regional, and the national DGI and CENTIF as Ivorian entities, there is no single point of contact for crypto compliance; a crypto company may need to deal simultaneously with up to five distinct bodies — CREPMF, BCEAO, the Ivorian Treasury (for beneficial ownership declaration), CENTIF-CI (AML reporting), and the DGI (taxation), each with separate compliance frameworks that have not been harmonized for digital assets, creating a high risk of inadvertent non-compliance. CREPMF & BCEAO Joint Notice on Crypto — July 2023

• The "deemed rejection" consequence chills innovation: CREPMF's six-month review window with "silence means refusal" provides no accountability; companies that have informally approached CREPMF (as reported in Jeune Afrique Business+ of July 2025) describe receiving no substantive feedback within the review period, resulting in automatic rejection; this effectively operates as a de facto moratorium on new crypto licenses without an official policy announcement. Jeune Afrique Business+ — "Cryptos en Côte d'Ivoire: le silence de CREPMF" July 2025

• The gap between paper law and implementation reality: CREPMF Regulation 07/2022 exists on paper, but CREPMF has not published implementing guidelines (e.g., technical standards, cybersecurity requirements, or formats for smart contract audits); industry participants have indicated through their legal counsel that CREPMF staff lack technical expertise to evaluate blockchain-related applications, causing indefinite delays; a World Bank technical assistance report on the UEMOA capital market (published December 2024) noted that "the CREPMF's digital asset framework remains untested, with no applications in substantive review" — meaning the law is effectively dormant. World Bank — UEMOA Financial Sector Assessment Program (CP 4 — Digital Assets), Dec 2024

• No stablecoin or CBDC clarity: The BCEAO's position on dollar-linked stablecoin (USDT/USDC) has never been formally stated beyond the general crypto ban applicable to banks; however, BCEAO has been piloting a regional wholesale CBDC (project "Abao" or the digital CFA) since 2022, with a pilot phase announced for April 2025; the operation of a stablecoin exchange (e.g., a USDT/BiSwap) is technically not prohibited if done through a non-bank company, but regulatory treatment remains unclear — leaving legal risk for stablecoin market makers. BCEAO — Central Bank Digital Currency — Agence Presse Report, April 2025

• Criminal exposure under AML law is high: Even without a license, merely operating a crypto exchange — even for non-securities digital assets (e.g., trading Bitcoin or Ether, which are arguably currencies, not securities) — carries a criminal law risk: the operator could be charged under Law No. 2016-1129 Art. 45 (failure to report suspicious transactions, punishable by up to 10 years imprisonment and a fine of up to CFA 250 million / €380,000) if any of their clients were involved in a crime; there is no "safe harbor" for unlicensed crypto exchanges, so any unlicensed operator is automatically in violation of AML obligations upon any transaction. Law No. 2016-1129, Art. 45 — Penalties

• Civil litigation for consumer losses: Companies that offer crypto investment advice or manage digital asset portfolios might be found to be operating in violation of UEMOA Regulation 03/2021/CM/UEMOA without registration, exposing them to: (i) refunds to all clients for losses, (ii) nullification of all contracts, and (iii) potential class action by Ivorian consumer associations (competent under Law No. 2016-1129 of 2016 on consumer protection, which provides triple damages for financial services fraud); this risk materializes if the company misrepresents returns. UEMOA Reg. 03/2021 Art. 265 (Void Contracts)

Sources

• CREPMF Official Website
• CREPMF Regulation No. 07/2022/RC/CREPMF on digital assets
• CREPMF Public Register of Financial Intermediaries
• CREPMF Public Notice No. 01/2023 — Qamara Digital
• CREPMF Sanctions Communiqué October 2024 — CDCM
• CREPMF & BCEAO Joint Notice on Crypto — July 2023
• BCEAO Official Website
• BCEAO Instruction No. 10/2022/R on crypto assets
• BCEAO — Central Bank Digital Currency — April 2025
• UEMOA Regulation No. 03/2021/CM/UEMOA on financial markets
• Ministry of Economy and Finance of Côte d'Ivoire
• CENTIF-CI Official Site
• CENTIF-CI Guidelines on EDD (2023)
• CENTIF-CI STR Guidelines
• CENTIF-CI Annual Report 2024 (published November 2025)
• Law No. 2016-1129 of 31 December 2016 — Anti-Money Laundering
• Decree No. 2022-310 of 6 April 2022 — Beneficial Ownership Register
• Code Général des Impôts — Law No. 2022-704, Consolidated Version
• DGI-CI Seminar "Digital Finance & Tax" — November 2024
• DGI-CI VAT Circular Memorandum No. 004/2024
• GIABA Mutual Evaluation Report — Côte d'Ivoire 2022/2023
• World Bank — UEMOA Financial Sector Assessment Program (Dec 2024)
• Ecobank Côte d'Ivoire — Digital Assets Policy Notice March 2024
• Jeune Afrique Business+ — "Cryptos en Côte d'Ivoire" July 2025