Crypto-funded debit card in Gabon

BEAC Instruction n° 001/GR/2021 defines the operating procedures of the Centrale des Incidents de Paiement and carries no crypto-asset provision, and BEAC has issued no instruction banning crypto-assets in the CEMAC zone; the CEMAC measure on crypto-assets is Décision COBAC D-2022/071 du 6 mai 2022, which binds only institutions supervised by COBAC.

Décision COBAC D-2022/071 du 6 mai 2022 bars every COBAC-supervised institution operating in Gabon, including credit institutions, microfinance establishments and payment institutions, from acquiring, holding, transferring or converting crypto-assets and from booking them on their balance sheets, which forecloses bank-provided crypto custody; the décision binds supervised institutions only and leaves holding of crypto by private persons lawful.

Custody of digital assets for third parties is a licensed activity in Gabon: article 160 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 places prestation de services sur actifs numériques under the COSUMAF regime, article 1 of the Règlement Général COSUMAF du 23 mai 2023 defines the prestataire de services sur actifs numériques by reference to conservation d'actifs numériques, and article 42 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 forbids carrying on virtual-asset service activity without prior agrément; COSUMAF has issued no PSAN agrément to date.

The instrument closing the crypto channel for Gabonese banks is Décision COBAC D-2022/071 du 6 mai 2022, taken by COBAC and not by BEAC, and non-bank operators are not in an unregulated space: the Règlement Général COSUMAF du 23 mai 2023 subjects prestataires de services sur actifs numériques to a COSUMAF agrément at articles 336 and following, and article 42 of Règlement n° 02/24/CEMAC/UMAC/CM requires prior agrément before any virtual-asset service activity is carried on.

The absence of specific regulations, leading to a legal grey area.

The potential for future regulatory changes, which could include outright bans, strict licensing, or a more facilitative framework.

No CEMAC or Gabonese instrument addresses stablecoins by name. A fiat-pegged token used in Gabon falls within the actif virtuel definition at art. 2 of Règlement n° 02/24/CEMAC/UMAC/CM, so its issuer or service provider is an assujetti requiring prior agrément, while the monnaie électronique regime sits in Règlement n° 04/18/CEMAC/UMAC/COBAC of 21 December 2018 and is administered by COBAC rather than by BEAC. The CFA franc is pegged to the euro and issued by BEAC, and no CEMAC digital currency is in issue.

Règlement n° 02/18/CEMAC/UMAC/CM of 21 December 2018 is the CEMAC foreign-exchange regulation, portant réglementation des changes dans la CEMAC, in force from 1 March 2019 and published on BEAC's exchange-policy register. The instrument governing electronic money and payment services in CEMAC is Règlement n° 04/18/CEMAC/UMAC/COBAC of 21 December 2018 on payment services, implemented by COBAC R-2019/02.

Règlement n° 02/18/CEMAC/UMAC/CM of 21 December 2018, in force 1 March 2019, is the CEMAC foreign-exchange regulation and contains no rule on electronic money, reserves or segregated accounts; the words monnaie électronique, crypto and actif virtuel do not appear in it. Electronic money and payment services in CEMAC are governed by Règlement n° 04/18/CEMAC/UMAC/COBAC of 21 December 2018, whose licensing conditions are set by Règlement COBAC R-2019/01 of 23 September 2019.

Virtual assets are not legal tender in Gabon, where the franc CFA BEAC alone has legal-tender status, but they are regulated: Règlement n° 01/22/CEMAC/UMAC/COSUMAF of 21 July 2022 brings jetons numériques into the appel public à l'épargne regime, the Règlement Général COSUMAF of 23 May 2023 defines jeton and PSAN at article 1, and Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 makes virtual-asset service providers obliged entities. The restrictive measure in force is Décision COBAC D-2022/071 of 6 May 2022, which binds COBAC-supervised institutions only, and BEAC has published no crypto warning of its own.

BEAC opened a reflection on a monnaie numérique de banque centrale for the CEMAC zone in September 2023, and no CEMAC central bank digital currency has been issued as of August 2026. BEAC designates the project a monnaie numérique de banque centrale rather than an e-CFA, and its own website publishes no CBDC or crypto content.

Impact on Private Stablecoins: If the BEAC proceeds with its e-CFA, it is highly probable that the regulatory environment for private stablecoins would become significantly stricter. The introduction of an official digital currency would likely lead to:

Règlement n° 01/16-CEMAC-UMAC-CM du 11 avril 2016 governed AML/CFT in Gabon until the UMAC Ministerial Committee adopted Règlement n° 02/24/CEMAC/UMAC/CM at Libreville on 20 December 2024; the 2024 règlement supersedes it, defines actif virtuel and PSAV at article 2, lists PSAV among the assujettis at article 6 and requires prior agrément plus a virtual-asset travel rule at article 42.

Individuals: Obtain and verify identity using reliable, independent source documents (e.g., national ID cards, passports, driver's licenses) for name, date of birth, place of birth, address, and nationality.

Legal Entities (Companies): Obtain and verify information such as the company's name, legal form, address of registered office, names of directors, and provisions governing the power to bind the company. Identify and verify the identity of the beneficial owners (individuals who ultimately own or control the company) and persons acting on behalf of the company.

Conduct ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Enhanced Due Diligence (EDD): Apply EDD in situations identified as higher risk, including:

For virtual assets, this could involve deeper scrutiny of the source of funds/wealth, understanding the origin and destination of virtual assets, and the underlying purpose of transactions.

Relationships with Politically Exposed Persons (PEPs).

Transactions involving high-risk jurisdictions.

Complex, unusually large transactions, or unusual patterns of transactions that have no apparent economic or visible lawful purpose.

Obligation to Report: Any VASP that suspects or has reasonable grounds to suspect that funds (fiat or virtual assets) are the proceeds of a criminal activity, or are related to terrorist financing, must report its suspicions.

Suspicious transaction reports in Gabon are filed with the Agence Nationale d'Investigation Financière (ANIF), the administrative financial intelligence unit attached to the Ministry of the Economy, which receives, analyses and transmits them to the competent judicial authorities under Règlement n° 02/24/CEMAC/UMAC/CM.

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

Article 39 of Règlement n° 02/24/CEMAC/UMAC/CM requires obliged entities in Gabon, including virtual-asset service providers, to keep customer identification documents and transaction records for a minimum of ten years after the account is closed or the business relationship ends, not five years.

Copies of documents used for identification and verification of customers and beneficial owners.

Account files and business correspondence.

Records of transactions, including the amount, currency (fiat and/or virtual asset type and quantity), date, and the identity of the parties involved.

Records of suspicious transaction reports filed.

Gabon has enacted no tax legislation on crypto-assets. The Code Général des Impôts in force, Loi n° 027/2008 as updated by the loi de finances n° 033/2024 of 30 December 2024, carries no occurrence of crypto, cryptomonnaie, actif virtuel, actif numérique, monnaie virtuelle or jeton, and the Direction Générale des Impôts has published no doctrine or circular on the subject, so crypto income is reached only by the general rules on business profits at 30 %, on capital gains from movable assets taxed by a 20 % prélèvement libératoire, and on TVA at 18 %.

Gabon taxes capital gains realised by individuals at a liberatory rate of 20 per cent, applied to the net annual gain after a 15 per cent abattement, under the Code Général des Impôts enacted by Loi n° 027/2008 of 22 January 2009. The 15 per cent figure is the abattement on the taxable base, not the rate, and the Code Général des Impôts contains no provision on cryptocurrency or virtual assets.