Stablecoin issuer / redeemer in Equatorial Guinea
Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.
Stablecoin issuer is not permitted in Equatorial Guinea.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Not applicable — the issuance of stablecoins is prohibited under BEAC Circular No. 001/GR/2022, which bans all crypto-asset activities. General AML obligations under Law N° 4/2004 and CEMAC/GABAC directives (CDD, STR filing to CENTIF-GE, 5-year record retention) would apply only if the prohibition were lifted, but currently they cannot be operationalized for stablecoin issuance.
- If hypothetically permitted, stablecoin issuers would face CDD/EDD obligations (gq.aml.identification-and-verification, gq.aml.beneficial-ownership, gq.aml.risk-based-approach-rba-apply-cdd), STR filing to CENTIF-GE (gq.aml.obligation-to-report-vasps-must, gq.aml.reporting-authority-reports-are-submitted), and 5-year record retention (gq.aml.retention-period-vasps-must-maintain).
Key Restrictions
- Stablecoin issuance, trading, holding, and related activities are prohibited by BEAC Circular No. 001/GR/2022 for all persons/entities subject to the CEMAC financial regulatory framework.
- There is no licensing or registration pathway available — the prohibition is blanket, with no opt-in or exemption mechanism.
- Foreign-issued stablecoins are not permitted for use locally; the prohibition covers any dealing with crypto-assets in a professional capacity.
- BEAC Regulation N°02/18/CEMAC/UMAC/CM on electronic money could theoretically classify fiat-pegged stablecoins as electronic money, but the BEAC crypto-asset circular supersedes this for crypto-assets, effectively blocking issuance.
- No local entity can lawfully engage in stablecoin issuance, so localEntityRequired is moot.
Key Risks
- Criminal/regulatory enforcement exposure: any stablecoin issuance or redemption in or targeting Equatorial Guinea would violate the BEAC Circular, exposing the operator to potential sanctions under CEMAC financial law.
- Regulatory ambiguity: BEAC Regulation 02/18 on electronic money could be interpreted to cover stablecoins, but the BEAC Circular 001/GR/2022 explicitly prohibits crypto-asset activities, creating interpretive tension.
- Tax non-compliance risk: even if the operation is prohibited, any income or gains derived from prohibited crypto activities would still technically be taxable under PIT (2-35%) or CIT (35%), creating a double-exposure scenario.
- No legal pathway for reserve segregation, custody, or audit exists for stablecoin reserves in this jurisdiction.
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.
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.
Règlement n° 02/18/CEMAC/UMAC/CM governs foreign exchange and cannot classify a stablecoin as electronic money; electronic money in the CEMAC is governed by Règlement n° 04/18/CEMAC/UMAC/COBAC du 21 décembre 2018 on payment services, and a digitally issued token in Equatorial Guinea otherwise falls to the jeton numérique regime of COSUMAF rather than to the e-money regime.
Article 27 of Règlement n° 02/18/CEMAC/UMAC/CM concerns non-resident CFA franc accounts and the duty of a domiciling intermediary to report doubts under CEMAC AML/CFT rules, and imposes no backing obligation on electronic money; the segregation of funds received against electronic money is required by COBAC Règlement R-2019/02, article 10, implementing Règlement n° 04/18/CEMAC/UMAC/COBAC.
Evidence fact gq.aml.regional-legislation-cemacgabac not found (may have been renamed).
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.
Evidence fact gq.aml.identification-and-verification not found (may have been renamed).
Obligation to Report: VASPs must establish systems to detect and report suspicious transactions.
Reporting Authority: Reports are submitted to the national Financial Intelligence Unit (FIU).
Article 39 of Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 requires assujettis in Equatorial Guinea, including virtual-asset service providers, to keep identity and transaction records for a minimum of ten years after the account is closed or the business relationship ends, not five years.
Evidence fact gq.aml.primary-financial-intelligence-unit-fiu not found (may have been renamed).
Equatorial Guinea taxes company capital gains as part of taxable profits subject to corporate income tax at 25%, and no Equatorial Guinean instrument classifies virtual assets as property or as an asset for tax purposes.
Equatorial Guinea's corporate income tax rate is 25% of taxable profits, with a minimum income tax of 1.5% of the year's turnover for fiscal year 2025, following the Tax Code enacted by Law n° 1/2024 of 19 November 2024.
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.
Prohibited — BEAC Circular No. 001/GR/2022 bans all crypto-asset issuance, trading, and custody in Equatorial Guinea (CEMAC zone), making stablecoin issuance unlawful with no licensing or registration pathway available.
Questions this verdict aims to answer
- What e-money or banking license is required to issue?
- What reserve composition, segregation, and audit rules apply?
- What redemption rights must be granted to holders?
- Are foreign-issued stablecoins permitted for use locally?