Stablecoin issuer / redeemer in Gabon

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.

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.

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.

For Securities (under COSUMAF): If classified as a security, there wouldn't be "reserve requirements" in the same sense as e-money. Instead, the issuer would be subject to capital adequacy requirements, disclosure obligations, and investor protection rules typical for securities offerings.

For Securities (under COSUMAF): If classified as a security, there wouldn't be "reserve requirements" in the same sense as e-money. Instead, the issuer would be subject to capital adequacy requirements, disclosure obligations, and investor protection rules typical for securities offerings.

COSUMAF, not BEAC, is the competent authority in Gabon: providing digital-asset services without a COSUMAF agrément as PSAN is unlawful under Règlement n° 01/22/CEMAC/UMAC/COSUMAF of 21 July 2022 and the Règlement Général COSUMAF of 23 May 2023. BEAC operates no authorisation regime for digital assets, and Décision COBAC D-2022/071 of 6 May 2022 restrains only COBAC-supervised institutions, so private holding and use of virtual assets remains lawful in Gabon.

Evidence fact ga.stablecoin.unregulatedprohibited-other-crypto-assets not found (may have been renamed).

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.

Likely Treatment: Given the BEAC's conservative stance and focus on financial stability, algorithmic stablecoins, which lack direct fiat or asset backing and rely on complex algorithms and market mechanisms to maintain their peg, would be viewed with extreme skepticism. They would almost certainly not qualify as e-money under BEAC regulations due to their inherent volatility and lack of full, tangible reserves. They would likely be considered highly speculative assets, and their issuance would probably be categorized as an unauthorized financial activity, potentially subject to prohibition.

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:

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.

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.

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

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.

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.

Keep customer identification data up-to-date.

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

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