Stablecoin issuer / redeemer in Rwanda

Article 19 of Law n° 023/2026 of 25/05/2026 regulating virtual asset business governs stablecoin issuance in Rwanda, and Article 4(3) excludes central-bank-regulated payment instruments, securities and capital-market instruments, central bank digital currencies and algorithm-based stablecoins from the definition of virtual asset.

Rwanda's payment-system statute is Law n° 061/2021 of 14/10/2021 governing the payment system, published in Official Gazette n° 41 bis of 01/11/2021, which repealed Law n° 03/2010 except its Article 23 and requires a licence for the provision of payment services at Article 16.

E-money Issuer/Payment Service Provider License (if regulated for payments): Any entity wishing to issue electronic money or provide payment services in Rwanda must obtain a license from the National Bank of Rwanda under the National Payment Systems Act and related instructions. This would be the most relevant licensing regime if stablecoins were to be integrated into the payment system. The requirements are rigorous, including:

Electronic money issuers in Rwanda are governed by Regulation n° 54/2022 of the National Bank of Rwanda, a 46-article instrument whose Article 45 repealed Regulation n° 08/2016 of 01/12/2016 governing the electronic money issuers.

Article 35 of National Bank of Rwanda Regulation n° 54/2022 requires electronic money issuers to issue e-money at par value on receipt of funds, and Article 23 requires them to keep at least one hundred per cent of the e-money float in liquid assets, reconciled daily by 4.00 p.m.

Article 24 of National Bank of Rwanda Regulation n° 54/2022 requires all monies received to be held in a trust or special account, bars commingling with the funds of any person other than e-money holders, and requires trust funds to be placed in a financial institution authorised by the Central Bank.

Safeguarding: Measures to safeguard customer funds are paramount in e-money regulations.

Minimum capital requirements.

Robust governance, risk management, and internal control frameworks.

Fit and proper criteria for management and shareholders.

E-money Analogy (if regulated): If stablecoins were to be regulated as e-money, the NBR's instructions for Electronic Money Issuers would likely be applied. These typically require:

Article 35 of National Bank of Rwanda Regulation n° 54/2022 requires an electronic money issuer, on request by the holder, to redeem at any moment and at par value the monetary value of e-money held, with a redemption fee permitted only where it is clearly stated in the contract between issuer and holder.

Securities Classification (Less Likely for most stablecoins, but possible): If a stablecoin were structured to offer investment rights, interest, or represent a share in an underlying asset pool in a way that qualifies as an investment, it could potentially fall under securities law, regulated by the Capital Market Authority (CMA).

Rwanda's capital market statute is Law N°01/2011 of 10/02/2011 regulating capital market in Rwanda, Official Gazette n° 13bis of 28/03/2011, as modified by Law N°45/2018 of 13/08/2018.

Securities License (if classified as security): If a stablecoin were to be classified as a security, the issuer would need to comply with the licensing and disclosure requirements of the Capital Market Authority.

High Risk: Algorithmic stablecoins, by their nature, carry higher risks of volatility and de-pegging compared to fully fiat-backed stablecoins. It is highly probable that such models would be deemed too risky and would not be permitted under any future regulatory framework without significant adaptations and stringent oversight.

Article 19 of Law n° 023/2026 of 25/05/2026 governs stablecoin issuance in Rwanda, and the Capital Market Authority of Rwanda has made no implementing regulation under that law, so no stablecoin reserve requirement is yet in operation.

Article 19 of Law n° 023/2026 of 25/05/2026 governs stablecoin issuance in Rwanda, and the redemption right at par under Article 35 of National Bank of Rwanda Regulation n° 54/2022 binds electronic money issuers only.

Rwanda's anti-money-laundering statute is Law nº 001/2025 of 22/01/2025 on the prevention and punishment of money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction, Official Gazette nº Special Bis of 22/01/2025, which superseded Law nº 028/2023 of 19/05/2023, itself the successor to Law nº 75/2019. No Rwandan anti-money-laundering statute carries the number 060/2021. Reporting persons on the Financial Intelligence Centre's published list are 435 financial institutions and 3,128 designated non-financial businesses and professions, a class that excludes virtual asset service providers, whose anti-money-laundering duty arises instead as a licensing condition under Article 10(2)(g) of Law nº 023/2026 of 25/05/2026, supervised by the Capital Market Authority of Rwanda under Article 6.

Evidence fact rw.licensing.identification-and-verification-of-customers not found (may have been renamed).

For Individuals: Obtaining and verifying name, address, date of birth, nationality, national identification number (e.g., Rwandan ID card, passport number), and any other unique identifiers. This typically involves documentary verification (e.g., valid ID document) and, where appropriate, non-documentary methods.

For Legal Entities (Companies, Corporations, Trusts): Obtaining and verifying the entity's name, legal form, address, registration number, articles of incorporation, bylaws, and proof of existence. Identifying and verifying the identity of beneficial owners (individuals who ultimately own or control the entity, typically 25% ownership threshold or control through other means), as well as persons acting on behalf of the entity (e.g., directors, authorized signatories).

Risk-Based Approach: Applying CDD measures based on a risk assessment. This means applying enhanced due diligence (EDD) for higher-risk customers (e.g., Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, complex or unusually large transactions) and simplified due diligence (SDD) for lower-risk customers (if permitted and justified). Due to the inherent risks of virtual assets, most VASP activities would generally require standard or enhanced CDD.

Ongoing Monitoring: Continuously monitoring the business relationship and transactions undertaken by customers to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile. This includes keeping customer information up-to-date.

Reporting Threshold: There is no minimum monetary threshold for reporting suspicious transactions. Any transaction, regardless of amount, where there are reasonable grounds to suspect that it may be related to money laundering or terrorist financing, must be reported.

Timing: Reports must be made promptly, typically within a specified number of business days (e.g., 2-5 working days) of forming the suspicion.

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

Duration: Records must generally be kept for a period of at least five (5) years after the end of the business relationship or the date of the transaction.

Customer Identification Records: All documents and information obtained during the CDD process (e.g., copies of identification documents, beneficial ownership information).

Transaction Records: Records of all transactions undertaken, sufficient to permit reconstruction of individual transactions (e.g., sender and receiver details, amounts, type of virtual asset, transaction hash/ID, date and time).

Business Relationship Records: Records pertaining to the business relationship, correspondence, and decisions made regarding the customer's risk profile.

Suspicious Transaction Reports (STRs): Copies of all STRs filed and any internal documentation supporting the decision to file (or not to file).

Financial Intelligence Centre (FIC) of Rwanda

The National Bank of Rwanda has published no virtual-asset circular or guideline; ESAAMLG's July 2024 mutual evaluation of Rwanda records that the central bank issued a public notice in 2023 warning against crypto-asset activity until a regulatory framework was in place, and since Law nº 023/2026 of 25/05/2026 regulating virtual asset business the licensing of virtual asset service providers belongs to the Capital Market Authority of Rwanda, with the National Bank of Rwanda confined by Article 8 to cooperation with that Authority and to directives on matters falling under its own purview.

Rwanda's operative anti-money-laundering statute is Law nº 001/2025 of 22/01/2025 on the prevention and punishment of money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction, which replaced Law nº 028/2023 of 19/05/2023, itself the repeal of Law nº 75/2019 of 29/01/2020; no Rwandan anti-money-laundering law is numbered 008/2020, and the Financial Intelligence Centre is governed by Law nº 045/2021 of 18/08/2021 as amended by Law nº 002/2025 of 22/01/2025.

Law nº 008/2021 of 16/02/2021 governs partnerships, not payment systems; Rwanda's payment-system statute is Law nº 061/2021 of 14/10/2021, which makes no reference to virtual assets, and virtual asset business is licensed by the Capital Market Authority of Rwanda under Law nº 023/2026 of 25/05/2026, the National Bank of Rwanda being confined to monetary and financial-stability oversight and cooperation rather than licensing.

Screen all customers, beneficial owners, and counterparties against the UN Security Council Consolidated List and other specific UN sanctions lists (e.g., for specific countries or individuals/entities designated for terrorism financing, proliferation, etc.).

Immediately freeze funds and other assets of designated individuals and entities.

Articles 6 and 7 of Rwanda's Regulations on Targeted Financial Sanctions of 26/08/2021 require a reporting person to report to the Financial Intelligence Centre without delay whether funds or other assets of a designated person were identified and to notify attempted dealings with frozen assets, but virtual asset service providers are not among Rwanda's reporting persons, their obligations arising instead under Law nº 023/2026.

Requirements for VASPs: Due to the risk of secondary sanctions and disruption of international financial services, prudent VASPs operating in Rwanda should:

Rwanda taxes company profit under Law n° 027/2022 of 20/10/2022 establishing taxes on income, which carries no virtual asset, cryptocurrency or digital asset provision, and neither Law n° 051/2023 of 05/09/2023 nor Law n° 014/2025 of 27/05/2025 added one.

Services Related to Crypto: Services that are not the mere exchange of crypto, but rather services facilitating crypto transactions (e.g., fees charged by a crypto exchange for providing its platform, wallet services, advisory services, software development for crypto projects) would likely be considered taxable services and subject to the 18% VAT.