Remote VASP serving residents in Chad
Foreign-incorporated entity that offers exchange, custody, or transfer services to residents of a jurisdiction without establishing a local entity or office.
Remote VASP is not permitted in Chad.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- CDD required when establishing a business relationship (Law N°004/PR/2020).
- CDD required for occasional transactions above ~EUR 1,000 equivalent.
- Customer identification: natural persons — full name, date of birth, place of birth, nationality, physical address, unique ID number; legal entities — legal name, legal form, registration certificate, physical address, directors, beneficial owners.
- Beneficial ownership identification required (25%+ threshold).
- Ongoing monitoring of business relationship and transaction scrutiny.
- Enhanced Due Diligence (EDD) required for PEPs, high-risk jurisdictions, complex/unusual large transactions, and customers from FATF/GABAC-listed high-risk countries.
- Reporting of suspicious transactions to Chad's Financial Intelligence Unit (FIU) required.
- Record-keeping obligations for customer data and transaction records.
Key Restrictions
- BEAC Circular No. 001/GR/2022 of March 28, 2022 prohibits financial institutions and all economic agents in the CEMAC zone from engaging in crypto-asset activities, including holding, exchanging, selling, or purchasing crypto-assets.
- Regulation R-2023/CEMAC/UMAC/CM/04 of April 2023 states that any activity relating to virtual assets is prohibited unless expressly authorized by the BEAC — no authorization regime for foreign VASPs is established.
- No specific licensing pathway exists for foreign VASPs to serve Chadian residents remotely.
- Regulated financial institutions in Chad are warned against or prohibited from engaging with crypto assets, so no local banking/on-ramp partners are available.
Key Risks
- Direct enforcement risk: any remote VASP serving Chadian residents would be operating in violation of BEAC Circular No. 001/GR/2022, which applies to all economic agents in the CEMAC zone.
- No legal pathway to obtain authorization, meaning unlicensed operation is the only option — but that carries potential criminal/regulatory liability.
- Chad is subject to UN Security Council sanctions regimes (terrorism financing, proliferation) which could expose VASPs transacting with sanctioned entities.
- OFAC and EU sanctions have extraterritorial reach where US or EU nexus exists, creating compound risk for non-compliant VASPs.
- Reputational and correspondent-banking risk: any detected crypto activity could lead to de-risking by regional banks.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
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.
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.
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.
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.
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.
Establishing a business relationship.
Carrying out occasional transactions above a certain threshold (e.g., EUR 1,000 equivalent for VASPs, as per FATF guidance).
Evidence fact td.aml.identification-and-verification-of-customer not found (may have been renamed).
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.
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:
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.
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.
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.
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.
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.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
No — a foreign-incorporated remote VASP cannot lawfully serve Chadian residents under current BEAC/CEMAC regulations, which (via Circular No. 001/GR/2022 and Regulation R-2023) prohibit all crypto-asset activities unless expressly authorized by the BEAC, and no authorization pathway exists for non-resident operators. AML/KYC obligations under Law N°004/PR/2020 would technically apply if operation were attempted, but operation itself is prohibited.
Questions this verdict aims to answer
- May a non-resident provider serve residents from abroad?
- Does cross-border service trigger licensing, registration, or AML obligations?
- What enforcement risk exists for unlicensed remote operators?