Centralized exchange in Equatorial Guinea
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is not permitted in Equatorial Guinea.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- General AML/CFT obligations exist under CEMAC regional law (Directive N° 01/03-UEAC-CM-300-CM-06) and national law (Law N° 4/2004), but these obligations cannot be fulfilled lawfully because the core activity of operating a centralized crypto exchange is prohibited under BEAC Circular No. 001/GR/2022.
- Customer due diligence (CDD), beneficial ownership identification, ongoing monitoring, and suspicious transaction reporting (STR) to CENTIF-GE would theoretically apply to VASPs, but the prohibition supersedes any licensing or registration pathway.
- Travel-rule obligations under BEAC Regulation N°01/CEMAC/UMAC/CM of 27 March 2022 apply in principle to CASPs (including exchanges, custody, transfers), requiring collection, verification, and transmission of sender/receiver information for transfers ≥ 1,000 USD/EUR (per FATF Recommendation 16). However, compliance is impossible because the underlying activity is banned.
- Record-keeping for at least 5 years post-relationship is required under regional AML rules.
Key Restrictions
- Centralized exchange operations (custody, order-matching, trading) are prohibited outright by BEAC Circular No. 001/GR/2022, which bans issuance, trading, holding, and any other activities related to crypto-assets by persons or entities subject to the CEMAC financial regulatory framework.
- Custody services for crypto-assets are specifically prohibited.
- No licensing or registration pathway exists — there is no application process or available license for crypto exchanges, custody providers, or VASPs.
- The prohibition applies broadly to any entity dealing with virtual assets in a professional capacity within the CEMAC zone, including Equatorial Guinea.
Key Risks
- Operating a centralized exchange would be a direct violation of BEAC Circular No. 001/GR/2022, exposing the operator to sanctions, asset seizure, and potential criminal penalties under CEMAC/BEAC enforcement.
- BEAC has taken a strongly precautionary stance citing financial stability, consumer protection, ML/TF, and capital flight concerns — no regulatory leniency or grandfathering is expected.
- No public enforcement precedents yet identified, but the prohibition is clear and categorical, making any operation high-risk.
- The regulatory contradiction between BEAC Circular No. 001/GR/2022 (prohibition) and BEAC Regulation N°01/CEMAC/UMAC/CM (which purports to regulate CASPs including exchanges) creates legal ambiguity about which instrument takes precedence, but the prohibition is the more restrictive and appears dominant.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
A licensing regime for digital-asset services applies in Equatorial Guinea through directly applicable community law: article 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 requires COSUMAF agrément as prestataire de services sur actifs numériques, and the Règlement Général COSUMAF du 23 mai 2023 supplies the framework, while no implementing instruction has been issued, no minimum capital is set and no agrément has been granted.
Licences for digital-asset services exist in CEMAC law and cover Equatorial Guinea: article 160 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF lists custody for third parties, purchase and sale against legal tender, platform operation, reception and transmission of orders, portfolio management, advice and placement, all subject to COSUMAF agrément, and no such agrément has yet been issued to any operator.
BEAC issued no Circular No. 001/GR/2022 of 29 June 2022 on the prohibition of crypto-assets; BEAC's register of Instructions, Circulaires et Règlements lists no 2022 crypto instrument, and the CEMAC measure of that period is Décision COBAC D-2022/071 du 6 mai 2022, binding supervised institutions only.
No CEMAC prohibition reaches the issuance, trading or holding of crypto-assets by any person: Décision COBAC D-2022/071 du 6 mai 2022 binds only institutions COBAC supervises, and Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 instead treats virtual-asset service providers in Equatorial Guinea as regulated obliged entities subject to authorisation and AML/CFT duties.
Exchanges: Prohibited from operating.
Custody of digital assets for third parties is a licensable activity rather than a prohibited one in Equatorial Guinea: it appears in the list of services requiring COSUMAF agrément under Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF, and the Règlement Général COSUMAF du 23 mai 2023 defines the PSAN as a professional providing purchase-sale, custody and platform services.
Payment institutions in Equatorial Guinea are barred from crypto-asset dealings by Décision COBAC D-2022/071 du 6 mai 2022 as COBAC-supervised entities, not by any prohibition on crypto payment processing as such; unsupervised persons face no equivalent bar and virtual-asset service provision is instead subject to authorisation under Règlement n° 02/24/CEMAC/UMAC/CM.
Other VASPs: Any entity dealing with virtual assets in a professional capacity.
Virtual-asset service providers operating in Equatorial Guinea carry AML/CFT obligations directly under Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024: article 6 lists them among the obliged entities, article 42 requires prior authorisation and the transmission of originator and beneficiary information above 500 000 FCFA for occasional transactions, and article 39 sets a ten-year record-retention period, while no CEMAC text fixes a minimum capital for PSAN.
No PSAN application process operates in Equatorial Guinea because COSUMAF has issued no implementing instruction and granted no agrément, while the licensing obligation itself exists in force under Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF and the Règlement Général COSUMAF du 23 mai 2023.
The foundational CEMAC AML/CFT text is a UMAC Ministerial Committee règlement, not a UEAC directive: Règlement n° 01/03-CEMAC-UMAC of 4 April 2003, revised by Règlement n° 02/10 of 2 October 2010 and Règlement n° 01/16/CEMAC/UMAC/CM of 11 April 2016, and superseded by Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024, which applies directly in Equatorial Guinea without national transposition.
Equatorial Guinea has no standalone national AML/CFT statute; the GABAC mutual evaluation adopted on 22 November 2024 records that the country relies entirely on the directly applicable CEMAC règlement, supplemented by the Criminal Code and the Code of Criminal Procedure, and no law numbered 4/2004 on money laundering appears in that report.
Obligation to Report: VASPs must establish systems to detect and report suspicious transactions.
A virtual-asset travel rule binds Equatorial Guinea through art. 42 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, which requires the originator's virtual-asset service provider to obtain and transmit accurate originator information and required beneficiary information, requires the beneficiary's provider to obtain, retain and disclose it to the authorities, and fixes the occasional-transaction threshold at 500 000 FCFA. The instrument was adopted by the Comité Ministériel de l'UMAC, not by BEAC, which has issued no virtual-asset instrument.
No BEAC regulation on crypto-asset activities dated 27 March 2022 exists. Règlement n° 01/CEMAC/UMAC/CM is the AML/CFT règlement of 11 April 2016, repealed and replaced by Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, and the CEMAC crypto-asset text is Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022, which subjects digital-asset service providers to a COSUMAF agrément.
Règlement n° 01/CEMAC/UMAC/CM was adopted on 11 April 2016 and concerns the prevention and suppression of money laundering, terrorist financing and proliferation, not crypto-asset activities; the 27 March 2022 date and the attribution to BEAC are fabricated, and the text was repealed by Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024.
Art. 42 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 sets the CEMAC virtual-asset transfer threshold at 500 000 FCFA for occasional transactions and imposes the originator and beneficiary information duties directly, rather than deferring to international standards; no CEMAC instrument contains the quoted phrase or a USD or EUR 1 000 threshold.
Evidence fact gq.travel-rule.which-vasps-are-covered not found (may have been renamed).
Exchange between crypto-assets and fiat currencies.
Transfer of crypto-assets.
Safekeeping and/or administration of crypto-assets or instruments enabling control over crypto-assets.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
No — centralized exchange operations (custody, order-matching, trading of crypto-assets) are prohibited outright in Equatorial Guinea under BEAC Circular No. 001/GR/2022, with no licensing or registration pathway available; while regional AML/CFT and travel-rule obligations exist on paper, they cannot be complied with because the underlying activity is banned.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?