Stablecoin issuer / redeemer in Cameroon

This was true when written but is no longer. A legal framework exists: Reglement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 (in force 1 August 2022) introduced 'jetons numeriques' and 'actifs numeriques' into CEMAC market law (arts. 76 and 160), and the COSUMAF Reglement general du 23 mai 2023 (in force 24 May 2023) created the PSAN regime — exploitation d'une plateforme de negociation d'actifs numeriques is an enumerated service requiring COSUMAF agrement. Reglement n° 02/24/CEMAC/UMAC/CM du 20 decembre 2024, art. 42(1), separately forbids exercising VASP activity without prior approval. What remains true is the practical conclusion: no implementing instructions have been issued, no licensed PSAN is publicly known, and COBAC D-2022/071 still denies exchanges access to banking services.

Second half is correct: COBAC-supervised institutions (banks, microfinance, payment institutions, bureaux de change) are prohibited by Decision COBAC D-2022/071 from holding, exchanging or converting crypto-assets, so regulated-sector custody is indeed impossible. First half is wrong as of 2026: 'conservation d'actifs numeriques pour le compte de tiers' is an enumerated PSAN service under the COSUMAF Reglement general du 23 mai 2023 and requires COSUMAF agrement, and the CEMAC VASP definition in Reglement n° 02/24/CEMAC/UMAC/CM expressly covers safekeeping of virtual assets.

Substantially right, with the issuer mis-stated. Payment services and e-money in CEMAC are governed by Reglement n° 04/18/CEMAC/UMAC/COBAC du 21 decembre 2018 relatif aux services de paiement dans la CEMAC (with COBAC prudential norms, e.g. Reglement COBAC R-2019/02 for etablissements de paiement); the licensing/prudential authority is COBAC, not BEAC alone. Etablissements de paiement are among the assujettis covered by COBAC D-2022/071 and so may not handle crypto-assets, and there is indeed no crypto-specific payment licence at the COBAC layer.

A VASP/PSAN authorisation regime does exist and covers Cameroon, at CEMAC level. (i) The COSUMAF Reglement general du 23 mai 2023 (in force 24 May 2023) creates the prestataire de services sur actifs numeriques status, defines jetons numeriques functionally (art. 336: 'tout bien incorporel representant, sous forme numerique, un ou plusieurs droits'), reserves digital-token placement to PSAN, and requires COSUMAF agrement for buying/selling digital assets against legal currency, third-party custody, operating a trading platform, order reception/transmission, portfolio management, advice and placement. (ii) Reglement n° 02/24/CEMAC/UMAC/CM du 20 decembre 2024 defines 'actifs virtuels' and 'prestataires de services d'actifs virtuels', makes them assujettis, and at art. 42(1) provides that no one may carry on VASP activity professionally without prior approval or authorisation from the competent authority (art. 39: 10-year record retention; art. 42(5)(a): originator/beneficiary travel-rule information). The record's practical conclusion is nevertheless close to reality: no implementing instructions have been published, no PSAN agrement is publicly known, and COBAC D-2022/071 continues to prohibit supervised institutions from any crypto dealing. The accurate framing is 'a regime exists in law but is not operational', not 'no regime exists'.

Entities seeking to operate in the crypto space would likely face a lack of legal recognition and significant operational hurdles, particularly concerning banking relationships.

Evidence fact cm.licensing.beac-communiqu-on-cryptocurrencies-december not found (may have been renamed).

Lack of Legal Tender Status: Cryptocurrencies are not recognized as legal tender within the CEMAC zone.

Local Presence: For most regulated financial activities in Cameroon, a local corporate entity and physical presence are mandatory. This would likely extend to any future crypto licensing.

Capital Requirements: For financial institutions, BEAC and COBAC impose strict capital requirements (e.g., minimum capital for banks, microfinance institutions, payment institutions). Any future VASP license would likely have similar prudential requirements.

The substantive claim is right but the instrument identity is wrong. There is no "Regulation No. 02/CEMAC/UMAC/CM/22" and no 2022 CEMAC AML regulation. The instrument is Reglement n° 02/24/CEMAC/UMAC/CM, signed at Libreville on 20 December 2024 (CEMAC/UMAC Ministerial Committee, extraordinary session), effective on signature and abrogating all contrary provisions of Reglement n° 01/CEMAC/UMAC/CM du 11 avril 2016. It does define virtual assets - art. 2(72): "Digital representation of a value that can be digitally traded, transferred or used for payment or investment purposes... does not include digital representations of fiat currencies, securities and other financial assets already covered by specific regulatory provisions" - and defines prestataires de services d'actifs virtuels; art. 6(e) lists "virtual or digital asset service providers" among the assujettis, so VASPs carry the same AML/CFT obligations as financial institutions. It is a FATF-aligned revision (approved by GABAC Plenary Resolution No. 10 of 28 September 2024). The 2022 CEMAC instrument that touches digital assets is a different one: Reglement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 on the regional financial market.

Loi n° 2016/007 du 12 juillet 2016 is Cameroon's Code Penal, not an AML/CFT law, and it did not create ANIF. Cameroon has no standalone national AML/CFT statute: the framework is the directly applicable CEMAC regulation - today Reglement n° 02/24/CEMAC/UMAC/CM du 20 decembre 2024, previously Reglement n° 01/CEMAC/UMAC/CM du 11 avril 2016 and before that Reglement n° 01/03-CEMAC-UMAC-CM du 4 avril 2003 - supplemented for supervised financial institutions by Reglement COBAC R-2023/01 on LBC/FT diligences (in force 1 July 2024). ANIF was created by Decret n° 2005/187 du 31 mai 2005 (organisation and functioning of the Agence Nationale d'Investigation Financiere), operational since January 2006 and attached to the Ministere des Finances; its regional legal basis is art. 25 of Reglement n° 01/03-CEMAC-UMAC-CM, which instituted an ANIF in every Central African state.

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

Evidence fact cm.aml.identification-of-beneficial-owners not found (may have been renamed).

Reporting Obligation: VASPs must report any transaction (or attempted transaction) that they suspect, or have reasonable grounds to suspect, is related to money laundering or terrorist financing, regardless of the amount.

Reporting Body: Reports must be made to the Agence Nationale d'Investigation Financière (ANIF), Cameroon's FIU.

Timing: Reports must be submitted "without delay" once suspicion is formed.

Continuously monitoring business relationships and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and their risk profile, including, where necessary, the source of funds.

No Specific Crypto Capital Gains Tax: Cameroon does not have a dedicated capital gains tax on virtual assets.

Wrong on both the existence and the number. Cameroon has no separate capital gains tax on cryptocurrency at all — crypto is absent from the CGI. Where Cameroonian law does tax gains, it does so *inside* the IRPP as a category, not as a separate tax: plus-values on the cession of shares and securities are taxed as revenus de capitaux mobiliers at 16.5% (15% IRCM base + 10% CAC = 16.5%), rising to a 33% liberatory rate where the beneficiary is established in a tax haven (CGI arts. 70-71); plus-values on immovable property are taxed at 5%. There is no 15% headline rate: 15% is the IRCM *base* rate before the mandatory 10% centimes additionnels communaux.