Centralized exchange in Cote d'Ivoire

There is no BCEAO licence category for virtual-asset service providers. BCEAO agrément as an établissement de monnaie électronique (Instruction n°008-05-2015 du 21 mai 2015, art. 8; minimum capital 300,000,000 FCFA, art. 11) or as a payment institution (Instruction n°001-01-2024 du 23 janvier 2024) is required only where the firm actually issues e-money or provides payment services; neither instrument mentions crypto-actifs or actifs virtuels. A crypto exchange as such cannot obtain, and is not required to hold, either licence.

No 'Directive n° 03/2018/CM/UEMOA on the harmonisation of payment services regulation' could be located in any BCEAO or UEMOA source; the BCEAO compendium chapter on payment systems and instruments lists no 2018 directive (its instruments are Règlement n°15/2002/CM/UEMOA, Directive n°08/2002/CM/UEMOA, Instruction n°01/2003/SP, Instruction n°008-05-2015 and related texts). Payment-institution regulation in the UMOA is set by Instruction n°001-01-2024 du 23 janvier 2024.

No 'Instruction n° 002/2019/RB/UEMOA' exists; the citation format ('/RB/UEMOA') is not BCEAO's, which numbers instructions n°00X-MM-YYYY. Approval of e-money issuers is governed by Instruction n°008-05-2015 du 21 mai 2015 (art. 8 agrément préalable, art. 11 capital 300 million FCFA) and of payment institutions by Instruction n°001-01-2024 du 23 janvier 2024.

Capital requirements (significant).

Local presence and management.

Required Registration: Registration with the commercial registry (RCCM - Registre du Commerce et du Crédit Mobilier) and relevant tax authorities in Cote d'Ivoire.

Côte d'Ivoire is not a FATF member; it is a GIABA member and is assessed by GIABA. Its second-round mutual evaluation was conducted by GIABA (on-site visit 6-24 June 2022, MER adopted 2023), not by an IMF-led team, and has been followed by three enhanced follow-up reports (2024, 2025, 2026). Côte d'Ivoire was under FATF increased monitoring during 2025 — it is on the EU high-risk third-country list from 5 August 2025 (Commission Delegated Regulation (EU) 2025/1184), which mirrors the FATF grey list, and it was not among the countries de-listed at the October 2025 plenary (Burkina Faso, Mozambique, Nigeria, South Africa). No evidence was found that its FATF action plan includes VASP regulation; the UEMOA-level VASP framework is still only in drafting (BCEAO C-CRYPTO committee, May 2026).

BCEAO's Cautious Stance: The BCEAO has historically adopted a cautious, and at times prohibitive, stance towards cryptocurrencies due to concerns about monetary stability, consumer protection, money laundering, and illicit financing. They have issued warnings to financial institutions and the public about the risks associated with cryptocurrencies.

The BCEAO's regulatory framework does not include specific rules for the segregation of cryptocurrency assets. While BCEAO regulations mandate segregation for fiduciaires in the traditional financial system (e.g., for securities maintained by investment service providers), these regulations explicitly exclude digital assets not recognized as financial instruments. Entities holding crypto assets may still be subject to general consumer protection or business contract laws at the national level in Côte d'Ivoire, but no specific segregation mandate from the BCEAO exists.

Evidence fact ci.custody.qualified-custodian-definitions not found (may have been renamed).

Evidence fact ci.custody.cold-storage-mandates not found (may have been renamed).

There are no specific BCEAO licensing requirements for crypto custody, as cryptocurrencies are not recognized or regulated by the BCEAO. However, entities engaged in activities that intersect with traditional financial services (e.g., handling fiat currency, money transfers, or operating as a bank or payment institution) are subject to existing WAEMU financial licensing requirements, including AML/KYC obligations under the BCEAO's regulatory framework. National-level business licensing (e.g., registration with the Commercial Court in Côte d'Ivoire) also applies.

No Ivorian AML/CFT instrument numbered 'Ordonnance n° 2019-1089 du 18 décembre 2019' or 'Loi n° 2014-393 du 20 juin 2014' exists. Côte d'Ivoire's AML/CFT statutory chain is: Loi n° 2005-554 du 2 décembre 2005 → Loi n° 2016-992 du 14 novembre 2016 relative à la lutte contre le blanchiment des capitaux et le financement du terrorisme → Ordonnance n° 2023-875 du 23 novembre 2023 relative à la lutte contre le blanchiment de capitaux, le financement du terrorisme et de la prolifération des armes de destruction massive, which is Côte d'Ivoire's transposition of the UMOA Loi uniforme LBC/FT/FP du 31 mars 2023.

Evidence fact ci.aml.identification-and-verification-of-identity not found (may have been renamed).

Correct in substance but imprecise on the threshold: Ordonnance n° 2023-875, art. 2(12), defines the bénéficiaire effectif as the natural person who ultimately owns or controls the client, and for companies as a person holding, directly or indirectly, 'plus de vingt-cinq pour cent du capital' — i.e. *more than* 25%, not '25% or more'. Côte d'Ivoire additionally created a beneficial-ownership register by Loi n° 2024-362 du 11 juin 2024, with access rules set by Décret n° 2024-583 du 26 juin 2024.

Ongoing Monitoring: Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the obliged entity's knowledge of the customer, their business, and risk profile.

Enhanced Due Diligence (EDD): Applying EDD measures in higher-risk situations, including:

Obligation to Report: Obliged entities must report any transaction (or attempted transaction) that they suspect is linked to money laundering or terrorist financing to the Financial Intelligence Unit (FIU).

No Tipping-Off: Obliged entities and their employees are prohibited from disclosing to the customer or to third parties that an STR has been filed or that an investigation is underway.

All customer identification data (e.g., copies of identification documents).

'BCEAO Instruction n° 003/2022/RB du 17 novembre 2022' does not exist. BCEAO instructions are numbered nnn-mm-yyyy (e.g. 008-05-2015, 001-03-2021); the '/RB' form is never used, and the BCEAO instrument index contains no instrument of that number or of that date. No BCEAO instruction brings PSAV into the scope of supervised entities: PSAV are made assujettis by art. 3(c) of the Loi uniforme du 31 mars 2023, transposed in Côte d'Ivoire by Ordonnance n° 2023-875 du 23 novembre 2023, and art. 59 leaves PSAV-specific requirements to a competent authority that has not been designated.

There is no EUR 1,000 virtual-asset travel-rule threshold in force in Cote d'Ivoire. Ordonnance n° 2023-875 du 23 novembre 2023 places the originator/beneficiary information duties in arts. 39-47 on institutions financieres only; art. 2 defines PSAV as a distinct category, and art. 59 defers all PSAV-specific requirements to a competent authority that Cote d'Ivoire has not designated. The threshold figure is also denominated in the wrong currency — UEMOA thresholds are set in FCFA (see Decision n° 021 du 21/12/2023/CM/UMOA on seuils). The EUR 1,000 figure is FATF Recommendation 16 boilerplate, not Ivorian law.

Collect and retain accurate and meaningful originator and beneficiary information for all virtual asset transfers. This information typically includes:

Originator Information: Name, account number (or unique transaction identifier), physical address, national identity number (or customer identification number), date and place of birth (for natural persons), or place of registration (for legal entities).

Beneficiary Information: Name, account number (or unique transaction identifier), and where applicable, physical address or national identity number (or customer identification number).

Transmit this information to the beneficiary VASP immediately and securely, along with the virtual asset transfer itself, or through a secure messaging system that ensures the information is received before or at the time of the transfer.

Administrative sanctions in Cote d'Ivoire are not imposed by CENTIF-CI. CENTIF-CI is the financial intelligence unit and receives declarations de soupcon (Ordonnance n° 2023-875, art. 60); it has no sanctioning power. Administrative and disciplinary sanctions are imposed by the autorite de controle — for banks, compagnies financieres, SFD and etablissements de monnaie electronique this is the Commission Bancaire de l'UMOA, acting through its College de supervision ('sanctions disciplinaires et pecuniaires prononcees par le College de Supervision de la Commission Bancaire de l'UMOA') — and, for other assujettis, by the Commission Nationale des Sanctions LBC/FT established by Ordonnance n° 2022-237 du 30 mars 2022 and Decret n° 2024-58 du 14 fevrier 2024. The BCEAO itself is the central bank, not the sanctioning organ. Critically, no autorite de controle has been designated for PSAV, so none of these ladders is applicable to virtual-asset service providers in practice.

Criminal Sanctions: For severe or repeated breaches, especially those involving intentional facilitation of money laundering or terrorist financing, criminal charges can be brought against individuals (directors, employees) and the entity itself. These can include imprisonment and heavier fines, as defined in the national penal code and AML/CFT law.

Entity Targeted: General public and financial institutions operating within the UEMOA zone (including Côte d'Ivoire). Violation Type: While not a "violation" in the traditional sense, the BCEAO's consistent stance warns against the use, holding, or facilitation of transactions involving cryptocurrencies, emphasizing their speculative nature, lack of regulatory oversight, and potential for fraud and money laundering. It effectively "enforces" a non-recognition policy. Penalty Amount: Not applicable, as this is a general regulatory stance and warning, not a specific penalty against an entity. Outcome: A clear declaration that cryptocurrencies are not legal tender, are not regulated, and pose significant risks. Financial institutions are generally dissuaded from engaging with them. This discourages formal crypto operations.

Outcome: A clear declaration that cryptocurrencies are not legal tender, are not regulated, and pose significant risks. Financial institutions are generally dissuaded from engaging with them. This discourages formal crypto operations.