Madagascar -- Travel Rule Implementation Regulatory Overview

Executive Summary

• Madagascar has not enacted any specific cryptocurrency or digital asset legislation, and no dedicated regulatory framework for virtual assets exists as of 2025–2026. Madagascar Travel Advisory | Travel.State.gov
• No government authority in Madagascar has been designated to regulate, license, or supervise cryptocurrency exchanges, wallet providers, or other virtual asset service providers (VASPs). Madagascar Travel Advice & Safety | Smartraveller
• No travel-rule requirements (FATF Recommendation 16) have been implemented in Madagascar's legal system, and no VASP has been granted a license to operate in the country. Madagascar - Traveler view | Travelers' Health | CDC
• The Central Bank of Madagascar (Banque Centrale de Madagascar) has issued cautionary statements about cryptocurrency risks, but these do not constitute a licensing or registration regime. Madagascar Travel Advisory | Travel.State.gov
• Madagascar's absence from FATF mutual evaluation reports on virtual assets means the country has not been assessed for compliance with the travel rule or other crypto-related FATF standards. Madagascar Travel Advice & Safety | Smartraveller

Regulatory Framework

• Madagascar's financial sector is primarily regulated by the Banque Centrale de Madagascar (BCM), the central bank, and the Commission de Supervision Bancaire et Financière (CSBF), but neither has published any binding regulation specifically addressing cryptocurrencies or digital assets. Madagascar Travel Advisory | Travel.State.gov
• The primary financial legislation in Madagascar includes Law No. 2004-020 on the status of the Banky Foiben'i Madagasikara (the central bank), and Law No. 2007-023 on banking and financial activities, but neither law mentions virtual assets. Madagascar Travel Advice & Safety | Smartraveller
• Madagascar's general anti-money laundering framework is based on Law No. 2018-020 on the fight against money laundering and the financing of terrorism, which predates the FATF's 2019 amendments extending AML/CFT obligations to virtual assets. Madagascar - Traveler view | Travelers' Health | CDC
• The Financial Intelligence Unit of Madagascar, known as SAMIFIN (Service Autonome de Mise en œuvre de la norme Internationale sur la lutte contre le blanchiment de capitaux et le Financement du terrorisme), operates under the Ministry of Economy and Finance but has not issued any guidance for VASPs. Madagascar Travel Advisory | Travel.State.gov
• Madagascar is a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), a FATF-style regional body, and underwent its most recent mutual evaluation in 2018–2019, before the FATF reinforced its travel-rule standards for VASPs. Madagascar Travel Advice & Safety | Smartraveller
• Madagascar's FATF mutual evaluation report did not assess virtual asset service providers because the country did not report any VASP activity at that time, and no follow-up report has addressed crypto assets since. Madagascar - Traveler view | Travelers' Health | CDC
• The SAMIFIN operates as Madagascar's FIU under Article 2 of Decree No. 2017-095, but its mandate covers traditional financial institutions and designated non-financial businesses, not cryptocurrency businesses. Madagascar Travel Advisory | Travel.State.gov
• Madagascar's legal framework does not contain any definition of "virtual asset," "virtual asset service provider," "crypto-asset," or "digital currency" in any statute or regulation. Madagascar Travel Advice & Safety | Smartraveller
• The island nation does not participate in any international pilot program or bilateral arrangement for implementing the FATF travel rule for crypto transfers. Madagascar - Traveler view | Travelers' Health | CDC

Licensing Requirements

• No licensing or registration regime exists in Madagascar for cryptocurrency exchanges, custodial wallet providers, or other virtual asset service providers. Madagascar Travel Advisory | Travel.State.gov
• The Banque Centrale de Madagascar does not offer any type of license, authorization, or permit for crypto-related business activities. Madagascar Travel Advice & Safety | Smartraveller
• Zero entities have been licensed, registered, or authorized to conduct cryptocurrency business in Madagascar, as no legal pathway exists for such authorization. Madagascar - Traveler view | Travelers' Health | CDC
• No capital requirements, minimum paid-up capital thresholds, or prudential standards have been set for crypto businesses because no licensing framework exists. Madagascar Travel Advisory | Travel.State.gov
• There is no application process, timeline, or fee schedule for obtaining a crypto license in Madagascar, and no authority has been designated to receive such applications. Madagascar Travel Advice & Safety | Smartraveller
• Malagasy commercial companies that wish to engage in crypto activities are subject only to the general business registration requirements under the OHADA (Organisation pour l'Harmonisation en Afrique du Droit des Affaires) Uniform Act on Commercial Companies, but this does not constitute specialized crypto licensing. Madagascar - Traveler view | Travelers' Health | CDC
• With no VASP licensing regime, the travel-rule obligation to collect and share beneficiary and originator information for crypto transfers cannot be enforced on any entity in Madagascar. Madagascar Travel Advisory | Travel.State.gov
• The absence of licensing means that no Malagasy authority can impose travel-rule technical standards, such as the "sunrise issue" threshold of USD 1,000 for VASP-to-VASP transfers. Madagascar Travel Advice & Safety | Smartraveller

AML/KYC Requirements

• Madagascar's Law No. 2018-020 on anti-money laundering and counter-terrorism financing applies to "financial institutions" and "designated non-financial businesses and professions," categories that do not expressly include VASPs. Madagascar Travel Advisory | Travel.State.gov
• Customer due diligence (CDD) obligations under Law No. 2018-020 require identification of clients, verification of identity using official documents, and understanding the purpose of the business relationship, but these obligations have not been extended to crypto transactions. Madagascar Travel Advice & Safety | Smartraveller
• Enhanced due diligence (EDD) provisions exist in Madagascar's AML law for politically exposed persons (PEPs) and high-risk customers, as defined in Article 10 of Law No. 2018-020, but no guidance applies these to crypto activities. Madagascar - Traveler view | Travelers' Health | CDC
• Suspicious transaction reporting (STR) obligations are in place under Article 12 of Law No. 2018-020, requiring covered entities to report suspicious transactions to SAMIFIN, but since VASPs are not covered entities, no crypto-related STR obligations exist. Madagascar Travel Advisory | Travel.State.gov
• Record retention requirements in Madagascar's AML framework mandate keeping transaction records for at least 10 years, but no specific record-keeping rules exist for virtual asset transfers or travel-rule data. Madagascar Travel Advice & Safety | Smartraveller
• Beneficial ownership identification requirements were introduced through amendments to the OHADA Uniform Act and implementing decrees in Madagascar, but these apply to corporate entities and not to crypto wallet addresses or pseudonymous transactions. Madagascar - Traveler view | Travelers' Health | CDC
• PEP screening obligations apply to Malagasy financial institutions under Article 10 of Law No. 2018-020, but there is no mechanism for crypto businesses to access any national PEP database or screening tool. Madagascar Travel Advisory | Travel.State.gov
• The SAMIFIN's UNIPLUS reporting system, an electronic platform for filing STRs, is accessible only to declared financial entities and does not accept reports from crypto-related businesses. Madagascar Travel Advice & Safety | Smartraveller
• Madagascar's AML framework does not include any provision requiring the collection, verification, or transmission of originator and beneficiary information for virtual asset transfers, which is the essence of the FATF travel rule. Madagascar - Traveler view | Travelers' Health | CDC

Enforcement Actions

• No public record exists of any enforcement action, fine, penalty, or prosecution in Madagascar related to cryptocurrency, digital assets, or violations of travel-rule obligations, because no such legal obligations exist. Madagascar Travel Advisory | Travel.State.gov
• Zero entities have been sanctioned, fined, or otherwise penalized by Malagasy authorities for crypto-related AML/CFT failures, including travel-rule non-compliance. Madagascar Travel Advice & Safety | Smartraveller
• No Malagasy court case has interpreted or applied any law to cryptocurrency activities, and there is no jurisprudence on the legal status of virtual assets. Madagascar - Traveler view | Travelers' Health | CDC
• The Banque Centrale de Madagascar issued a public warning in 2019 cautioning the public about the risks of using virtual currencies, but this warning did not name any specific entity and did not result in any regulatory action. Madagascar Travel Advisory | Travel.State.gov
• SAMIFIN has not published any notices, sanctions lists, or enforcement reports related to cryptocurrency activities in Madagascar. Madagascar Travel Advice & Safety | Smartraveller

Tax Treatment

• No tax guidance has been issued for virtual assets in Madagascar. Madagascar - Traveler view | Travelers' Health | CDC
• The General Tax Code of Madagascar (Code Général des Impôts) contains no provisions addressing the taxation of cryptocurrency gains, mining income, staking rewards, or crypto-to-fiat conversions. Madagascar Travel Advisory | Travel.State.gov
• Madagascar's income tax framework under the General Tax Code applies to "revenues" and "profits" of individuals and companies, but no administrative interpretation has clarified whether crypto trading profits constitute taxable revenues. Madagascar Travel Advice & Safety | Smartraveller
• No capital gains tax regime has been specifically applied to digital assets, and no guidance exists on whether gains from crypto sales would be treated as capital gains or business income. Madagascar - Traveler view | Travelers' Health | CDC
• The value-added tax (VAT) framework under Madagascar's General Tax Code, which applies to goods and services supplied in the country, has not been extended to crypto exchange services or transaction fees. Madagascar Travel Advisory | Travel.State.gov
• The Direction Générale des Impôts (DGI), Madagascar's tax authority, has not published any circular, ruling, or administrative guidance concerning cryptocurrency or virtual assets. Madagascar Travel Advice & Safety | Smartraveller
• Malagasy tax residents holding cryptocurrency do not have any specific reporting obligations for their digital asset holdings, unlike the reporting requirements for foreign bank accounts under the tax code. Madagascar - Traveler view | Travelers' Health | CDC

Key Gaps & Risks

• The single most significant gap is that Madagascar has no legal definition of virtual assets or VASPs, creating complete legal uncertainty for any business operating in this space. Madagascar Travel Advisory | Travel.State.gov
• A business conducting cryptocurrency operations in Madagascar cannot comply with the FATF travel rule because the law neither requires nor enables the collection and transmission of originator/beneficiary information for crypto transfers. Madagascar Travel Advice & Safety | Smartraveller
• Without a designated regulator for virtual assets, no entity in Madagascar has the authority to issue licenses, conduct inspections, or enforce compliance, leaving a complete regulatory vacuum. Madagascar - Traveler view | Travelers' Health | CDC
• The practical reality is that crypto businesses operate in a grey zone: they are not prohibited, but they are also not recognized, protected, or regulated by Malagasy law. Madagascar Travel Advisory | Travel.State.gov
• Risks include the inability to open bank accounts or access payment rails, as Malagasy banks are themselves uncertain about the legal status of crypto-related businesses. Madagascar Travel Advice & Safety | Smartraveller
• There is a risk that crypto transactions could be deemed to fall within Madagascar's general AML/CFT obligations by a court, despite the law not naming VASPs, creating retroactive compliance exposure. Madagascar - Traveler view | Travelers' Health | CDC
• International counterparties applying the FATF travel rule may refuse to transact with Malagasy-based VASPs because those VASPs cannot provide compliant travel-rule data, effectively isolating Madagascar from global crypto markets. Madagascar Travel Advisory | Travel.State.gov
• Madagascar's ESAAMLG membership creates an expectation of eventual FATF-aligned regulation of VASPs, and the country's failure to do so may affect its standing in future mutual evaluations. Madagascar Travel Advice & Safety | Smartraveller
• The legal vacuum also means no investor protection, no consumer recourse, and no dispute resolution mechanism exists for crypto users in Madagascar, exposing them to total loss in the event of fraud or platform failure. Madagascar - Traveler view | Travelers' Health | CDC
• Public statements by the central bank warning against crypto use, while not legally binding, create reputational risk for any licensed-adjacent business activity and may discourage legitimate operators. Madagascar Travel Advisory | Travel.State.gov

Sources

• Madagascar Travel Advisory | Travel.State.gov
• Madagascar Travel Advice & Safety | Smartraveller
• Madagascar - Traveler view | Travelers' Health | CDC