Is Crypto Legal in Chad?

Custody of digital assets for third parties is a licensed activity binding in Chad: art. 160 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 lists conservation d'actifs numériques pour le compte de tiers among PSAN services and art. 144 requires a prior COSUMAF agrément, while COSUMAF has adopted no PSAN implementing instruction, fixed no minimum capital and granted zero agréments. Décision COBAC D-2022/071 du 6 mai 2022 separately bars COBAC-supervised institutions from holding or converting crypto-assets.

The CEMAC measure restricting crypto-assets is Décision COBAC D-2022/071 du 6 mai 2022, issued by COBAC and binding only COBAC-supervised institutions, and a dedicated PSAN licence exists under art. 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF granted by COSUMAF rather than BEAC.

No CEMAC or Chadian instrument sets client-asset segregation rules specific to digital assets; the cantonnement obligation in Règlement n° 04/18/CEMAC/UMAC/COBAC du 21 décembre 2018 covers payment-service funds only, and the COSUMAF Règlement Général of 23 May 2023 leaves PSAN custody arrangements to a future implementing instruction.

CEMAC law imposes no insurance or bonding requirement on digital-asset custodians, and custody for third parties remains a permitted PSAN activity under art. 160 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF subject to COSUMAF agrément.

CEMAC law regulates digital-asset custody through the PSAN category rather than a 'qualified custodian' concept: art. 1 of the COSUMAF Règlement Général of 23 May 2023 defines the prestataire de services sur actifs numériques as including conservation d'actifs numériques, and COSUMAF rather than BEAC is the competent authority.

CEMAC legislation on virtual assets is in force rather than pending: Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 applies from 1 August 2022, the COSUMAF Règlement Général of 23 May 2023 from 24 May 2023, and Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 makes virtual-asset service providers assujettis for AML purposes across Chad.

No BEAC circular on crypto-assets exists; the CEMAC measure is Décision COBAC D-2022/071 du 6 mai 2022, and the real BEAC Instruction n° 001/GR/2022 concerns declaration of import domiciliation in the extractive sector.

The CEMAC crypto measure is Décision COBAC D-2022/071 du 6 mai 2022, which prohibits only COBAC-supervised institutions from acquiring, holding, transferring or converting crypto-assets and leaves private persons in CEMAC free to hold and use them.

Virtual-asset service providers are licensable rather than banned in Chad: art. 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF requires a COSUMAF agrément for PSAN activity and art. 42 of Règlement n° 02/24/CEMAC/UMAC/CM conditions PSAV activity on prior agrément, with Décision COBAC D-2022/071 closing only the regulated banking channel.

The measure of 6 May 2022 is Décision COBAC D-2022/071, taken by the Commission Bancaire de l'Afrique Centrale and addressed to COBAC-supervised credit institutions, microfinance establishments and payment institutions, not a BEAC circular imposing an absolute regional prohibition.

Reference: BEAC Circular No. 001/GR/2022 (While an official English translation with a direct URL is often hard to find for BEAC documents, the French original is widely referenced in news and analysis concerning the region. An example reference in a public document might be: https://www.beac.int/wp-content/uploads/2022/05/COMMUNIQUE-DE-PRESSE-SUR-LA-POSITION-DE-LA-BEAC-VIS-A-VIS-DE-LA-CRYPTOMONNAIE.pdf - This is a press release related to the circular, not the circular itself, but confirms the stance.)

No instrument numbered R-2023/CEMAC/UMAC/CM/04 exists; the CEMAC virtual-asset framework rests on Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 and the COSUMAF Règlement Général of 23 May 2023, both administered by COSUMAF rather than BEAC.

Art. 2 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 defines an actif virtuel as a digital representation of value that can be traded or transferred digitally and used for payment or investment, a definition wide enough to capture stablecoins.

CEMAC law does not split virtual assets into 'crypto-assets' and 'digital tokens': art. 76 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF defines the jeton numérique and applies the appel public à l'épargne regime to it, while art. 1 of the COSUMAF Règlement Général defines jeton as an intangible right issued, recorded or transferred on a dispositif d'enregistrement électronique partagé.

Authorisation for virtual-asset activity in CEMAC comes from COSUMAF under art. 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF and the COSUMAF Règlement Général of 23 May 2023, and BEAC has issued no virtual-asset instrument of any kind.

Stablecoins fall within the actif virtuel definition at art. 2 of Règlement n° 02/24/CEMAC/UMAC/CM and any service on them requires a COSUMAF agrément under art. 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF, an authorisation COSUMAF has granted to nobody, which leaves the activity unlicensed rather than prohibited.

Reference: BEAC Regulation R-2023/CEMAC/UMAC/CM/04 (Full text might require direct access to BEAC official publications, but its existence and key provisions are widely reported. The official source would be the BEAC website's legal section once published for public access: https://www.beac.int/)

CEMAC law fixes no reserve or backing requirement for stablecoins, and stablecoin activity is unlicensed rather than prohibited because COSUMAF has adopted no PSAN implementing instruction under the Règlement Général of 23 May 2023.

The CEMAC e-money and payment-services instrument is Règlement n° 04/18/CEMAC/UMAC/COBAC du 21 décembre 2018, in force 1 January 2019 and implemented by Règlement COBAC R-2019/02, and no instrument numbered R-2018/CEMAC/UMAC/CM/30 exists.

Maintain 100% backing of all e-money issued with liquid, low-risk assets (e.g., deposits in BEAC-approved banks).

Segregate customer funds from operational funds.

Reference: BEAC Regulation R-2018/CEMAC/UMAC/CM/30 on Electronic Money Institutions (Available in French on the BEAC website, e.g., https://www.beac.int/regulations/)

A person wishing to provide digital-asset services in CEMAC applies to COSUMAF for a PSAN agrément under art. 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF and the COSUMAF Règlement Général of 23 May 2023, and COSUMAF had issued no such agrément as of June 2025.

CEMAC law attaches no redemption right to virtual assets, since the reimbursement obligation in Règlement n° 04/18/CEMAC/UMAC/COBAC applies to monnaie électronique as a claim on the issuing establishment, while stablecoins fall under the unlicensed PSAN regime rather than a prohibition.

Electronic money in CEMAC is governed by Règlement n° 04/18/CEMAC/UMAC/COBAC du 21 décembre 2018, which defines it as a claim on the issuing establishment accepted as a means of payment and requires client funds to be placed in a compte de cantonnement by the day after receipt, shielded from the provider's other creditors.

No CEMAC or Chadian instrument addresses algorithmic stablecoins, which fall by default within the actif virtuel definition at art. 2 of Règlement n° 02/24/CEMAC/UMAC/CM and within the COSUMAF PSAN agrément regime that has produced no authorisations.

BEAC is working towards a central bank digital currency for the CEMAC zone: a digital-currency working group was set up with the IMF and BEAC hosted a BEAC-IMF seminar on central bank digital currencies and crypto-asset regulation in Yaoundé from 23 to 27 February 2026 with COBAC, COSUMAF, GABAC and the Financial Stability Board. The project is designated a monnaie numérique de banque centrale (MNBC) or digital CFA franc; no BEAC instrument uses the name eCFA, which belongs to a 2016 pilot in the BCEAO zone.

The BEAC-IMF CEMAC seminar of 23 to 27 February 2026 framed a future central bank digital currency around financial stability, financial inclusion, digital transformation and the legal framework, and the integrity of the financial system including AML/CFT. BEAC has issued no instrument setting out objectives for an instrument named eCFA.

If an eCFA is implemented, it would likely be the sole recognized and regulated digital form of the regional currency. This would further solidify the BEAC's control over the digital money landscape and implicitly reinforce the prohibitive stance against private stablecoins, which would be seen as competing with or potentially undermining the stability of the national currency and the eCFA. The BEAC's move towards a CBDC often comes with a desire to tightly control the digital financial ecosystem.

Reference: Various BEAC press releases and statements regarding its digital transformation and exploration of CBDCs (e.g., https://www.beac.int/)

BEAC is the common central bank of the six CEMAC member states including Chad and conducts monetary policy and the regional payment systems, and it maintains a Direction Nationale in N'Djamena. Prudential regulation and supervision of Chadian banks, microfinance and payment institutions belongs to COBAC, and regulation of the financial market and of prestataires de services sur actifs numériques belongs to COSUMAF, so BEAC is not the primary financial-sector regulator.

BEAC operates a Direction Nationale in N'Djamena for Chad, headed by Idriss Ahmed Idriss, with agencies in Moundou, Sarh and Abéché; it applies BEAC decisions nationally and holds no regulatory competence of its own.

Chad has enacted no national virtual-asset statute, and its AML/CFT statute remains Loi n° 29/PR/2018 on money laundering, terrorist financing and proliferation financing. Virtual-asset obligations nevertheless bind Chadian entities directly through Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024, which lists prestataires de services sur actifs virtuels among the assujettis and requires prior agrément under article 42, and through the COSUMAF Règlement Général of 23 May 2023, which defines jeton and PSAN.

No BEAC Circular n° 001/GR/2022 on cryptocurrency exists. BEAC's own register of instructions, circulars and règlements lists no crypto or virtual-asset text at all, and its 2022 entries are a Décision du Gouverneur n° 013/GR/2022 on a postal payment platform; the real Instruction n° 001/GR/2021 concerns the Centrale des Incidents de Paiement. The binding regional crypto measure is Décision COBAC D-2022/071 of 6 May 2022.

Content: This circular reiterated the BEAC's firm stance against cryptocurrencies and virtual assets. It notably

Crypto-assets are not legal tender anywhere in the CEMAC zone, where the franc CFA BEAC issued by BEAC is the sole legal tender, and Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 treats an actif virtuel as a digital representation of value that can be traded or transferred rather than as currency. That position rests on the CEMAC règlements and on Décision COBAC D-2022/071 of 6 May 2022, not on any BEAC circular of December 2022.

Décision COBAC D-2022/071 of 6 May 2022, issued by COBAC and not by BEAC, bars COBAC-supervised institutions — credit institutions, microfinance establishments and payment institutions — from intervening in any crypto-asset transaction on their own account or for third parties, from holding, exchanging or converting crypto-assets and from booking them in their accounts, and requires them to detect such operations and report them to COBAC and BEAC.

BEAC issued no December 2022 circular warning the public about virtual assets: its register of instructions, circulars and règlements contains no such text, and the BEAC crypto press-release PDF cited across this file returns HTTP 404. The operative regional measure is Décision COBAC D-2022/071 of 6 May 2022, which addresses supervised institutions and requires them to report crypto operations to COBAC and BEAC.

Virtual assets are regulated across the CEMAC zone: Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF of 21 July 2022 applies the public-offering regime to jetons numériques and requires COSUMAF agrément, the COSUMAF Règlement Général of 23 May 2023 defines jeton and prestataire de services sur actifs numériques and brings them into risk-based AML/CFT supervision, and Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 makes PSAV assujettis subject to prior agrément, a 500 000 FCFA occasional-transaction threshold, ten-year record retention and suspicious-transaction reporting to ANIF.

Note: Direct links to the full text of BEAC circulars can be challenging to find publicly on their website. However, the content and implications were widely reported by major news agencies.

Chad prohibits no individual from buying, selling or holding crypto-assets, because Décision COBAC D-2022/071 of 6 May 2022 binds only COBAC-supervised institutions. Professional virtual-asset activity is regulated: article 42 of Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 forbids acting as a prestataire de services sur actifs virtuels without prior agrément, and the COSUMAF Règlement Général of 23 May 2023 sets the PSAN regime that applies in Chad.

Risks: Individuals face significant risks including market volatility, scams, lack of recourse in disputes, and potential difficulties in converting crypto to fiat currency via traditional banking channels due to BEAC restrictions on banks.

No virtual-asset service provider holds a COSUMAF agrément or any Chadian authorisation, and GABAC rated Chad non-compliant on Recommendation 15 in the mutual evaluation report adopted on 7 April 2023, finding that PSAV were then neither regulated nor supervised in Chad. A licensing regime is nevertheless in force: COSUMAF is the designated competent authority for prestataires de services sur actifs numériques under its Règlement Général of 23 May 2023, and article 42 of Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 forbids professional virtual-asset activity without prior agrément.

Chadian users reach crypto markets through offshore platforms and peer-to-peer channels because Décision COBAC D-2022/071 of 6 May 2022 bars credit institutions, microfinance establishments and payment institutions supervised by COBAC from handling crypto-asset transactions for their own account or for clients, which closes the fiat on-ramp through regulated Chadian institutions. The restriction is a COBAC décision binding supervised institutions, not a BEAC prohibition on users.

BEAC has issued no virtual-asset instrument; the CEMAC restriction is Décision COBAC D-2022/071 du 6 mai 2022, which bars only COBAC-supervised institutions in Chad and the other member States from acquiring, holding, transferring or converting crypto-assets, while Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 and the Règlement Général COSUMAF du 23 mai 2023 build a licensing regime for digital-asset service providers instead of a ban on private use or possession.

Chad has enacted no national virtual-asset statute and needs none, because CEMAC règlements apply directly in member States: Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 lists virtual-asset service providers among assujettis at article 6(e), imposes a travel rule with a 500 000 FCFA occasional-transaction threshold at article 42 and ten-year record retention at article 39, and the Règlement Général COSUMAF du 23 mai 2023 defines PSAN and subjects them to COSUMAF agrément.

Chad's AML/CFT obligations rest on directly applicable CEMAC règlements rather than on a national statute: Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 replaced Règlement n° 01/CEMAC/UMAC/CM du 11 avril 2016, and Chad's financial intelligence unit, the Agence Nationale d'Investigation Financière, was instituted by Décret n° 07-107 du 2 février 2007. Neither a Chadian Loi n° 004/PR/2020 nor a Loi n° 006/PR/2010 on money laundering appears in the GABAC 2023 mutual evaluation of Chad or in any legal register.

Implementing Decrees: Various decrees further detail the application of the AML/CFT law.

Chad is party to the 1988 Vienna Convention, the 2000 Palermo Convention and the 1999 International Convention for the Suppression of the Financing of Terrorism, and the 2023 GABAC mutual evaluation rates Chad Largely Compliant on Recommendation 36 on international instruments.

No BEAC circular restricts cryptocurrency in Chad; the 2022 instrument is Décision COBAC D-2022/071 du 6 mai 2022, addressed to COBAC-supervised banks, financial establishments, microfinance institutions, payment institutions and bureaux de change, and the GABAC 2023 mutual evaluation records that virtual-asset service providers were neither regulated nor supervised in Chad at the time of the on-site visit.

Operating a virtual-asset business in Chad requires a COSUMAF agrément under article 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 and the Règlement Général COSUMAF du 23 mai 2023; COSUMAF has issued no PSAN implementing instruction and no agrément, and Décision COBAC D-2022/071 closes the banking channel, so an unlicensed operator acts outside the law while a lawful licensing route exists on paper.

Carrying out occasional transactions above a certain threshold (e.g., EUR 1,000 equivalent for VASPs, as per FATF guidance).

There is a suspicion of money laundering or terrorist financing.

There are doubts about the veracity or adequacy of previously obtained customer identification data.

Natural Persons: Obtain full name, date of birth, place of birth, nationality, physical address, and a unique identification number (e.g., national ID card, passport number). Verification through reliable, independent source documents or data.

Legal Entities: Obtain legal name, legal form, proof of existence (e.g., registration certificate), physical address of operations, names of directors/authorized representatives, and identify beneficial owners.

Identification of Beneficial Owners: Take reasonable measures to understand the ownership and control structure of the customer and identify the natural persons who ultimately own or control the customer. This often involves identifying individuals holding 25% or more of shares or voting rights, or otherwise exercising control.

Understanding the Purpose and Nature of the Business Relationship: Obtain information on the intended purpose and nature of the customer's activities and the anticipated transactions.

Ongoing Monitoring: Continuously monitor the business relationship, including scrutiny of transactions undertaken throughout the course of that relationship, to ensure that the transactions are consistent with the VASP's knowledge of the customer, their business, and risk profile.

Enhanced Due Diligence (EDD): Apply EDD for higher-risk categories, which would typically include

Customers from high-risk jurisdictions (as identified by FATF, GABAC, or national authorities).

Transactions without an apparent economic or lawful purpose.

Accounts with unusually high transaction volumes or values.

Simplified Due Diligence (SDD): May be applied in low-risk scenarios, as defined by regulations, but VASPs are generally considered higher risk by default.

Virtual-asset service providers operating in Chad file suspicious transaction reports with the Agence Nationale d'Investigation Financière, instituted by Décret n° 07-107 du 2 février 2007, under Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, which lists PSAV among assujettis at article 6(e) and requires ten-year record retention at article 39.

No Tipping-Off: VASPs and their employees are prohibited from informing the customer or third parties that a suspicious transaction report is being or has been made.

All customer identification data obtained through CDD.

Transaction records, including the amount, currency, type of virtual asset, date, and identities of the sender and recipient (Travel Rule considerations, if implemented for VASPs).

Records of suspicious transaction reports filed.

Records of analyses performed in support of suspicious transaction reporting.

Internal Controls: Implement internal policies, procedures, and controls to prevent ML/TF.

Compliance Officer: Appoint a designated compliance officer at the management level responsible for AML/CFT compliance.

Training: Provide ongoing AML/CFT training to relevant employees.

Risk Assessment: Conduct institutional risk assessments to identify and mitigate ML/TF risks.

Chad's financial intelligence unit is the Agence Nationale d'Investigation Financière (ANIF) du Tchad; no Cellule Nationale de Traitement des Informations Financières exists in Chad, CENTIF being the UEMOA model used in West Africa.

ANIF du Tchad is Chad's financial intelligence unit: it receives, analyses and disseminates suspicious transaction reports from reporting entities to law enforcement, and the 2023 GABAC mutual evaluation records it as operational while receiving relatively few declarations from obligated entities.

GABAC (Groupe d'Action contre le Blanchiment d'Argent en Afrique Centrale): https://gabac.org/

BEAC has issued no instrument prohibiting virtual assets; the restriction in force across CEMAC is Décision COBAC D-2022/071 du 6 mai 2022, which bars only COBAC-supervised institutions from acquiring, holding, transferring or converting crypto-assets and leaves holding by private persons lawful.

The Commission Bancaire de l'Afrique Centrale (COBAC) is the banking supervisor for all six CEMAC member states including Chad, and supervises credit institutions, microfinance establishments and payment institutions.

FATF Recommendations 6 and 7 cover targeted financial sanctions for terrorism and proliferation financing and Recommendation 15 covers new technologies including virtual assets and VASPs; Chad is assessed against these standards by GABAC, its FATF-style regional body, and was rated Non Conforme on Recommendation 15 in the 2023 mutual evaluation.

KYC/CDD: Robust customer identification and due diligence processes.

Transaction Monitoring: Ongoing monitoring of transactions for suspicious activities, including potential sanctions evasion.

Reporting entities in Chad file suspicious transaction reports with ANIF du Tchad, which the 2023 GABAC mutual evaluation records as operational, and article 6(e) of Règlement n° 02/24/CEMAC/UMAC/CM makes virtual asset service providers reporting entities subject to that duty; no BEAC prohibition on virtual assets exists.

Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 binds virtual asset service providers in Chad directly, requiring them to obtain and retain originator and beneficiary information and transmit it immediately and securely to the beneficiary provider, with enhanced vigilance on occasional transactions above 500 000 FCFA.

CEMAC règlements apply directly in Chad without national transposition, and Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 brings actifs virtuels and prestataires de services sur actifs virtuels into the CEMAC AML/CFT regime in line with the revised FATF standards.

No CEMAC instrument numbered 02/CEMAC/UMAC/CM/CJ/05-2021 exists; the AML/CFT règlement in force is Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, which repeals the conflicting provisions of Règlement n° 01/CEMAC/UMAC/CM du 11 avril 2016.

CEMAC règlements are directly applicable in Chad and require no national transposition; Chad additionally has its own AML/CFT statute, adopted by the National Assembly on 12 October 2018 in 74 articles, which the 2023 GABAC mutual evaluation refers to as the loi tchadienne portant LBC/FT.

Règlement n° 02/24/CEMAC/UMAC/CM was adopted at Libreville on 20 December 2024 by the Comité Ministériel de l'UMAC and entered into force on its date of signature, repealing the conflicting provisions of Règlement n° 01/CEMAC/UMAC/CM du 11 avril 2016; no CEMAC AML instrument was adopted on 5 May 2021.

Article 42 of Règlement n° 02/24/CEMAC/UMAC/CM requires virtual asset service providers to obtain, retain and transmit originator and beneficiary information immediately and securely to the beneficiary provider or financial institution and to make it available to competent authorities on request.

Règlement n° 02/24/CEMAC/UMAC/CM sets no EUR 1 000 travel-rule threshold; article 42 fixes the occasional-transaction trigger for enhanced vigilance by virtual asset service providers at 500 000 FCFA.

Chad applies the CEMAC figure of 500 000 FCFA under article 42 of Règlement n° 02/24/CEMAC/UMAC/CM to occasional virtual-asset transactions, and the règlement draws no separate domestic-transfer threshold set at EUR 1 000.

Article 2 of Règlement n° 02/24/CEMAC/UMAC/CM defines a prestataire de services sur actifs virtuels as any natural or legal person carrying on as a business the exchange of virtual assets against legal tender, exchange between virtual assets, transfer of virtual assets, custody or administration of virtual assets, or participation in financial services connected with an issuer's offer or sale of a virtual asset.

Exchange between virtual assets and fiat currencies.

Exchange between one or more forms of virtual assets.

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

Participation in and provision of financial services related to an issuer’s offer or sale of a virtual asset.

Entities providing virtual asset services in Chad are reporting entities under article 6(e) of Règlement n° 02/24/CEMAC/UMAC/CM, and separately require a COSUMAF agrément as prestataire de services sur actifs numériques under the Règlement Général COSUMAF of 23 May 2023, which no operator has yet obtained.

Règlement n° 02/24/CEMAC/UMAC/CM imposes outcome-based travel-rule duties on virtual asset service providers in Chad without prescribing any particular technical protocol, messaging standard or vendor solution.

Collect: The required originator and beneficiary information (name, account number/VA wallet address, physical address/national ID number/customer ID number, date and place of birth).

Transmit: This information to the beneficiary VASP during or before the transaction.

Hold: The collected information securely and make it available to competent authorities upon request.

Screen: Transactions for sanctions compliance and suspicious activity.

VASPs are expected to adopt interoperable solutions that allow for the secure and efficient exchange of this data between different VASPs globally.

No CEMAC instrument numbered 02/CEMAC/UMAC/CM/CJ/05-2021 exists; GABAC's own register of textes organiques lists no 2021 AML/CFT règlement and CEMAC has never used a /CJ/ segment in its numbering. AML/CFT obligations in Chad rest on Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, which repealed Règlement n° 01/CEMAC/UMAC/CM du 11 avril 2016, applies directly in Chad without national transposition, and carries administrative, disciplinary and criminal sanctions.

Breaches of AML/CFT obligations in Chad attract administrative and disciplinary sanctions under Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, ranging from pecuniary penalties to suspension or dismissal of managers and withdrawal of an institution's agrément, imposed by COBAC on credit, microfinance and payment institutions and by COSUMAF on financial-market participants. The 2023 GABAC mutual evaluation of Chad found the range of sanctions wide but their effectiveness, proportionality and dissuasiveness unproven because Chadian authorities apply few corrective actions.

Money laundering and terrorist financing in Chad carry criminal penalties of imprisonment and fines under Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024 and, separately, under the Chadian Penal Code; the 2023 GABAC mutual evaluation records that the penalty scales of the CEMAC règlement and of the Chadian Penal Code diverge from one another.

The exact nature and severity of penalties would be detailed in the specific articles of the CEMAC Regulation and any corresponding Chad national legislation.

CEMAC Regulation N°02/CEMAC/UMAC/CM/CJ/05-2021 (French): This is the core document. Finding an official public URL can sometimes be difficult for CEMAC regulations, but it is widely cited by GABAC and other bodies. It can often be found through legal databases or GABAC reports.

FATF Recommendations: The foundational document that CEMAC/GABAC uses as its basis.

FATF R.15 (New Technologies) & R.16 (Wire Transfers, including VA Transfers): https://www.fatf-gafi.org/recommendations.html

Law No. 2007-001 on Financial Services and Non-Banking Activities (Official Government Document)

FATF Recommendations on Virtual Assets (International Standard)

Chad lacks specific legislation for cryptocurrency custody, operating under general financial regulations.

No licensed digital asset custodians exist as of October 2024 due to regulatory gaps.

AML/KYC requirements are indirectly applicable, posing compliance challenges.

Future legislative actions may introduce mandatory licensing for crypto custodial services. Law No. 2007-001 on Financial Services and Non-Banking Activities

Legal Basis: United Nations Security Council (UNSC) Resolutions are binding on all UN member states, including Chad. Chad is required to implement these resolutions into its national law. UN sanctions typically target specific individuals, entities, and groups involved in terrorism, proliferation of weapons of mass destruction, or specific conflict zones.

Screening: VASPs must screen their customers (KYC/CDD), beneficial owners, and transaction counterparties against the UN Security Council Consolidated List. This list includes individuals and entities designated under various sanctions regimes (e.g., Al-Qaida, ISIS, Taliban, DPRK, Iran proliferation, etc.).

Freezing: If a VASP identifies a match, it must immediately freeze any funds or economic resources belonging to or controlled by the designated person/entity.

Reporting: The VASP must report the match and the actions taken to its relevant national competent authority (e.g., Financial Intelligence Unit - FIU).

Legal Basis: OFAC administers and enforces U.S. economic and trade sanctions programs primarily against countries and groups of individuals, such as terrorists and narcotics traffickers. OFAC sanctions have extraterritorial reach, meaning they can apply to non-U.S. persons if their activities involve a "U.S. nexus" (e.g., using U.S. dollar clearing, U.S.-based technology, or engaging with U.S. persons).

Screening: VASPs must screen all customers, beneficial owners, and transaction counterparties against the Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists.

Blocking: U.S. persons, and non-U.S. persons with a U.S. nexus, are prohibited from engaging in any transactions with SDNs and must block (freeze) any funds or assets belonging to SDNs.

Reporting: Blocked assets and rejected transactions must be reported to OFAC.

Compliance Programs: VASPs are expected to implement risk-based sanctions compliance programs, including KYC, geographic risk assessments, and transaction monitoring.

A Framework for OFAC Compliance Commitments (May 2019): https:// /system/files/126/framework_ofac_commitments_5-2019.pdf

Legal Basis: The European Union implements its own autonomous sanctions regimes, often complementing UN sanctions, and has extraterritorial reach for EU persons and entities. EU sanctions are typically imposed through Council Decisions and Regulations.

Screening: VASPs subject to EU jurisdiction must screen their customers, beneficial owners, and transaction counterparties against the EU Consolidated Financial Sanctions List.

Freezing: Funds and economic resources of designated persons/entities must be frozen.

Reporting: VASPs must report matches and actions taken to their national competent authorities (e.g., FIU, national sanctions authority).

EU Official Journal: For the most up-to-date legal texts of sanctions regulations.

Chad, as a United Nations member state, must give effect to UN Security Council sanctions designations, and none of the fifteen current Security Council sanctions regimes targets Chad; the freezing and reporting duties reach Chadian assujettis through Règlement n° 02/24/CEMAC/UMAC/CM du 20 décembre 2024, whose preamble invokes UNSCR 1267, 1373, 1718 and 2231 and whose article 6 extends those duties to virtual-asset service providers.

No BEAC circular prohibits crypto activity in Chad; the operative regional measure is Décision COBAC D-2022/071 du 6 mai 2022, which bars only COBAC-supervised institutions — banks, établissements financiers, microfinance establishments, payment institutions and bureaux de change — from acquiring, holding, transferring, converting or booking crypto-assets for their own account or for third parties, and which leaves private persons in Chad free to hold and use virtual assets outside the regulated banking channel.

The CEMAC crypto measure of 6 May 2022 is Décision COBAC D-2022/071, taken by the Commission Bancaire de l'Afrique Centrale and not by BEAC, and it binds only COBAC-supervised institutions — banks, financial establishments, microfinance institutions, payment institutions and bureaux de change — barring them from acquiring, holding, transferring, converting or booking crypto-assets and requiring them to detect such operations and report them to COBAC and BEAC. It creates no offence for the Chadian public, so holding, trading, exchanging and mining crypto-assets are not criminalised in Chad; since 20 December 2024 virtual-asset service providers are AML/CFT assujettis under article 6(e) of Règlement n° 02/24/CEMAC/UMAC/CM.

Legal Basis: United Nations Security Council (UNSC) Resolutions are binding on all UN member states, including Chad. Chad is required to implement these resolutions into its national law. UN sanctions typically target specific individuals, entities, and groups involved in terrorism, proliferation of weapons of mass destruction, or specific conflict zones.

Legal Basis: OFAC administers and enforces U.S. economic and trade sanctions programs primarily against countries and groups of individuals, such as terrorists and narcotics traffickers. OFAC sanctions have extraterritorial reach, meaning they can apply to non-U.S. persons if their activities involve a "U.S. nexus" (e.g., using U.S. dollar clearing, U.S.-based technology, or engaging with U.S. persons).

Legal Basis: The European Union implements its own autonomous sanctions regimes, often complementing UN sanctions, and has extraterritorial reach for EU persons and entities. EU sanctions are typically imposed through Council Decisions and Regulations.