Is Crypto Legal in Tanzania?

Tanzania has no virtual-asset licensing regime: as at 21 August 2026 there is no VASP licence class, no minimum-capital floor, no application process, no fee schedule, no register and no licensed firm. Tanzanian law does nevertheless define the terms — the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022, assented 23 February 2022, in force 8 March 2022) inserted definitions of "virtual asset" and "virtual asset service provider" into section 3 of the Anti-Money Laundering Act, Cap. 423, without attaching any obligation to them. The Bank of Tanzania's public notices of 12 and 29 November 2019, issued under sections 26 and 27 of the Bank of Tanzania Act, 2006 (Act No. 4 of 2006, Cap. 197) and the Foreign Exchange Act, 1992, remain the operative central-bank position, and ESAAMLG rated Tanzania Partially Compliant with Recommendation 15 in its 1st Enhanced Follow-Up Report of September 2022.

President Samia Suluhu Hassan's June 2021 remarks urging the Bank of Tanzania to prepare for cryptocurrency rest on wire reporting alone; no Bank of Tanzania or State House document records them, and BoT's own press-release index carries nothing on the subject. The Capital Markets and Securities Authority has published no crypto, virtual-asset or digital-asset notice, guidance or warning at any time, and its principal-legislation and press-release indexes carry none. The Bank of Tanzania's own account of where the work reached was given by Governor Emmanuel Tutuba on 30 July 2026: the Bank "completed the assessment and developed a concept on the regulation and supervision of virtual assets" which "has been submitted to the Ministry of Finance for further development" — a concept note held by the Ministry, not a bill and not a law.

Current Stance (Implied): While formal prohibition may not be explicit in specific crypto legislation, the lack of a regulatory framework and the BOT's historical cautious stance on unregulated financial activities mean that operating an unlicensed crypto business could face significant legal uncertainty and potential challenges under existing general financial laws.

Custody Providers: If a provider holds significant assets on behalf of clients, it could potentially be viewed through the lens of trust services or asset management, which are typically regulated.

The National Payment Systems Act, 2015 (Act No. 4 of 2015) licenses payment systems under section 7, payment instruments under section 17 and the issuance of electronic money under section 26, and its text contains no reference to virtual assets, cryptocurrency or digital currency. Its definition of electronic money requires "monetary value as represented by a claim on its issuer, that is electronically stored in an instrument or device, issued against receipt of funds of an amount not lesser in value than the monetary value issued" and redeemable in cash, which excludes virtual assets. A Bank of Tanzania payment-system, payment-instrument or electronic-money licence therefore reaches the fiat payment leg only and is not a virtual-asset licence, and the Bank of Tanzania has licensed no virtual-asset service provider under this or any other statute.

Currently Undefined: Since there is no specific regime, the distinction between registration and licensing for virtual assets is currently moot.

Future Outlook: If a regime were to be introduced, it would likely involve:

Licensing: For core VASP activities (exchanges, custody, issuance of certain tokens), implying a higher level of regulatory oversight, capital requirements, and ongoing compliance.

Registration: Potentially for less risky activities or for initial market entry, or as a component of a broader licensing framework.

Tanzania prescribes no minimum capital, paid-up share capital or liquid-capital requirement for virtual-asset business, because no virtual-asset licence class exists to attach one to. The Bank of Tanzania's dated press-release and public-notice index carries no virtual-asset licensing notice through 8 June 2026, and ESAAMLG's mutual evaluation of June 2021 records that Tanzania neither licenses nor registers virtual asset service providers and has designated no supervisor for them, rating Recommendation 15 Partially Compliant.

Future/Hypothetical: If regulated under existing laws (e.g., as a payment system provider or financial institution), then the capital requirements for those specific licenses would apply. These can vary significantly depending on the nature and scale of activities. A dedicated crypto license would almost certainly come with prescribed minimum capital.

Tanzania's anti-money-laundering statute is the Anti-Money Laundering Act, originally Act No. 12 of 2006 and consolidated as Cap. 423 R.E. 2022, administered by the Financial Intelligence Unit established under it. Banks, financial institutions, cash dealers and the designated non-financial businesses and professions set out at section 3 paragraphs (a) to (i) are reporting persons and owe customer due diligence, record-keeping and suspicious-transaction reporting duties. Virtual asset service providers appear nowhere in that list, so the Tanzanian AML perimeter does not reach them, and the Anti-Money Laundering (Amendment) Regulations, 2023, G.N. No. 853E of 22 November 2023, made under section 29 of Cap. 423, contain no virtual-asset provision.

Virtual asset service providers are not reporting persons in Tanzania and owe no statutory customer due diligence, transaction-monitoring, record-keeping or suspicious-transaction reporting duty to the Financial Intelligence Unit. The Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022, assented 23 February 2022, in force 8 March 2022) inserted definitions of "virtual asset" and "virtual asset service provider" into section 3 of the Anti-Money Laundering Act, Cap. 423, but left the reporting-person list at paragraphs (a) to (i) unchanged, and the Minister has published no Gazette notice under paragraph (j) designating the category. The Anti-Money Laundering (Amendment) Regulations, 2023, G.N. No. 853E of 22 November 2023, carry no virtual-asset reference, and ESAAMLG rates Tanzania Partially Compliant with Recommendation 15. Tanzania has definitions without obligations.

Highly Likely: For any regulated financial service, a local presence (e.g., a locally incorporated entity, physical office, local management) is typically a prerequisite in Tanzania. This would almost certainly be a requirement for any future crypto licensing.

Future/Hypothetical: Should a framework emerge, the application process would likely involve:

Submission of a detailed application form.

Provision of business plans, operational policies, risk management frameworks, and AML/KYC policies.

Fit and proper assessment for directors, shareholders, and key personnel.

Demonstration of technical capabilities and cybersecurity measures.

Payment of application and licensing fees.

Role: The central bank responsible for monetary policy, financial sector regulation (including payment systems), and financial stability. Any future crypto framework is highly likely to involve the BOT, especially concerning stablecoins or payment-related virtual assets.

The National Payment Systems Act, 2015 is Act No. 4 of 2015, assented on 25 April 2015, and licenses payment system operators, payment service providers and electronic money issuers under the supervision of the Bank of Tanzania. Its text carries no reference to virtual assets, cryptocurrency or digital currency, and a payment system licence granted under it confers no authority to provide virtual asset services in Tanzania.

Relevant Publications (search for "National Payment Systems Act" or related regulations under Publications/Laws & Regulations): https://www.bot.go.tz/Publications

Role: Regulator of capital markets and securities in Tanzania. The CMSA would likely be involved if certain virtual assets are classified as securities (e.g., security tokens, investment contracts).

The Capital Markets and Securities Act is Chapter 79 R.E. 2002 of the Laws of Tanzania, originally Act No. 5 of 1994, commenced 1 October 1994 and amended by Act No. 4 of 1997 and by the Written Laws (Miscellaneous Amendments) (No. 3) Act, No. 12 of 2022. Its definition of securities reaches shares, debentures, bonds, notes, government loan instruments and collective investment scheme interests, and extends to no virtual asset, so the Capital Markets and Securities Authority licenses market intermediaries and no virtual asset business in Tanzania.

The Financial Intelligence Unit of Tanzania is established by section 4 of the Anti-Money Laundering Act, Cap. 423, and receives, analyses and disseminates financial intelligence on money laundering and terrorist financing. It draws that intelligence from the 'reporting persons' enumerated in section 3 of the same Act, and virtual asset service providers are absent from that enumeration, so no Tanzanian virtual asset service provider owes the Unit a reporting duty.

The Anti-Money Laundering Act, Cap. 423, originally Act No. 12 of 2006 and consolidated as R.E. 2022, binds the 'reporting persons' enumerated in section 3 paragraphs (a) to (i), covering banks and financial institutions, cash dealers, accountants, real estate agents, auditors, tax advisers, dealers in precious stones and metals, trust and company service providers, motor vehicle dealers, clearing and forwarding agents, advocates and notaries, pension fund managers, securities market intermediaries, financial leasing entities, microfinance service providers and auctioneers. The Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022, in force 8 March 2022) inserted definitions of 'virtual asset' and 'virtual asset service provider' into section 3 without adding virtual asset service providers to that list, so a Tanzanian virtual asset service provider carries no anti-money-laundering obligation unless the Minister designates the category by notice in the Gazette under paragraph (j).

FIU Website (Tanzania): https://www.fiu.go.tz/ (Note: Direct access to the full Act might be through the Attorney General's Chambers or legal databases, but the FIU site provides context and guidance.)

Assume AML/KYC obligations as per existing Tanzanian law and international standards (FATF).

Seek expert legal advice within Tanzania to assess any potential applicability of existing financial services laws to their specific activities and to stay informed on new regulations.

Tanzania's principal AML statute is the Anti-Money Laundering Act, Cap. 423 (Act No. 12 of 2006, R.E. 2023, commenced 1 July 2007), which imposes obligations on the class of 'reporting person' defined in section 3 paragraphs (a) to (j); the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022, in force 8 March 2022) inserted definitions of 'virtual asset' and 'virtual asset service provider' into section 3 but left virtual asset service providers outside that class, which only a notice published in the Gazette by the Minister under paragraph (j) can extend.

Tanzania's operative AML subsidiary legislation is the Anti-Money Laundering Regulations, 2022 (Government Notice No. 397 of 3 June 2022), amended by the Anti-Money Laundering (Amendment) Regulations, 2023 (Government Notice No. 853E of 22 November 2023); regulation 30 of GN No. 397 revoked the Anti-Money Laundering and Counter Terrorist Financing Regulations, 2012 (GN No. 289 of 2012), and neither the 2022 regulations nor the 2023 amendment mentions virtual assets or virtual asset service providers.

Tanzania's counter-terrorism statute is the Prevention of Terrorism Act, Act No. 21 of 2002, consolidated as Cap. 19 R.E. 2023 and in force from 15 June 2003, with terrorist financing offences at sections 16 and 17 and proliferation financing at section 13, supplemented by the POTA Regulations 2022; Tanzania has no statute titled the Anti-Terrorism Act, and the Prevention of Terrorism Act mentions no virtual assets.

Natural Persons: Collecting and verifying full legal name, date of birth, residential address, nationality, national identification number (e.g., National ID, passport, driver's license). Verification should be done using reliable, independent source documents, data, or information.

Legal Entities (Companies, Partnerships, etc.): Collecting and verifying official name, registration number, address of registered office, names of directors/partners, legal form, proof of existence (e.g., certificate of incorporation).

Beneficial Ownership: Identifying and verifying the identity of the ultimate beneficial owner(s) of the virtual assets or the entity, ensuring that the VASP knows who ultimately owns or controls the funds/assets.

Purpose and Intended Nature of the Business Relationship: Understanding the purpose and intended nature of the customer's virtual asset activities and the business relationship.

Ongoing Monitoring: Continuously monitoring the business relationship and transactions undertaken by the customer to ensure that they are consistent with the VASP's knowledge of the customer, their business, and risk profile. This includes monitoring for unusual or suspicious activities.

Enhanced Due Diligence (EDD): Applying EDD for higher-risk situations, which may include:

Transactions involving Politically Exposed Persons (PEPs).

Customers from high-risk jurisdictions (as identified by FATF or local authorities).

Complex, unusually large transactions, or unusual patterns of transactions that have no apparent economic or lawful purpose.

New technologies or products that favor anonymity, which is often a characteristic of some virtual asset transactions.

Tanzania imposes no suspicious-transaction reporting duty on virtual asset service providers: section 18 of the Anti-Money Laundering Act, Cap. 423 R.E. 2023 (section 17 in the R.E. 2022 numbering) binds only a "reporting person", and the section 3 definition of reporting person, at paragraphs (a) to (j), names banks and financial institutions, cash dealers, accountants, real estate agents, auditors, tax advisers, dealers in precious stones, works of art or metals, trust and company service providers, motor vehicle dealers, clearing and forwarding agents, advocates and notaries, pension fund managers, securities market intermediaries, financial leasing entities, microfinance service providers and auctioneers, but no virtual asset service provider, even though section 3 has defined both "virtual asset" and "virtual asset service provider" since the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022) came into force on 8 March 2022.

What Constitutes Suspicion: Suspicion can arise from various factors, including unusual transaction patterns, inconsistent customer information, lack of clear economic purpose, or involvement of high-risk jurisdictions.

Suspicious transaction reports in Tanzania are submitted to the Financial Intelligence Unit under section 18 of the Anti-Money Laundering Act, Cap. 423 R.E. 2023 by any secure means the Unit specifies, and the Unit operates a goAML portal for that purpose, but the duty falls only on a "reporting person" as defined in section 3, and virtual asset service providers are outside that definition, so no Tanzanian virtual asset service provider owes a reporting obligation to the Unit.

Tanzania's tipping-off prohibition in section 22 of the Anti-Money Laundering Act, Cap. 423 R.E. 2023 (section 20 in the R.E. 2022 numbering) is drafted to bind "a person" rather than only a reporting person, so it reaches anyone, including the staff of a virtual asset business, who discloses or warns a person involved in a transaction, or an unauthorised third party, that a suspicious transaction report under section 18 may be prepared, is being prepared or has been sent to the Financial Intelligence Unit; the prohibition attaches to reports made by reporting persons, and virtual asset service providers owe no reporting duty of their own because section 3 omits them from the reporting-person list.

Tanzania's anti-money-laundering record-retention period is ten years, not five: section 17(1)(b) of the Anti-Money Laundering Act, Cap. 423 R.E. 2023 (section 16 in the R.E. 2022 numbering) requires every reporting person to retain records for a minimum period of ten years from the date the transaction is completed, the business relationship ends or the risk assessment is completed, and the duty binds only the reporting persons listed at paragraphs (a) to (j) of section 3, a list that omits virtual asset service providers.

All customer identification and verification data.

Business correspondence related to the customer relationship.

Records of all virtual asset transactions, including transaction dates, amounts, types of virtual assets, sending and receiving addresses (if applicable), and originating/beneficiary information.

Records of all suspicious transaction reports filed.

Records of internal policies and procedures for AML/CFT compliance.

Accessibility: Records must be maintained in a manner that allows for easy retrieval by competent authorities upon request.

The Financial Intelligence Unit of Tanzania is established as an extra-ministerial department under the Ministry responsible for finance by section 4 of the Anti-Money Laundering Act, Cap. 423 R.E. 2023, and section 6 gives it power to receive suspicious transaction reports, currency transaction reports, cross-border currency reports and electronic funds transfer reports from reporting persons, to analyse them and disseminate the results to law enforcement agencies, supervisory authorities and other competent authorities, and to supervise reporting persons for compliance with anti-money-laundering, counter-terrorist-financing and counter-proliferation-financing obligations.

The Bank of Tanzania supervises banks and financial institutions under the Bank of Tanzania Act, 2006 (Act No. 4 of 2006, Cap. 197) and has issued the only Tanzanian official positions on cryptocurrency, the public notice of 12 November 2019 and the press release of 29 November 2019, both invoking sections 26 and 27 of that Act and the Foreign Exchange Act, 1992, yet it licenses and supervises no virtual asset service provider; on 30 July 2026 Governor Emmanuel Tutuba said the Bank had "completed the assessment and developed a concept on the regulation and supervision of virtual assets" and had submitted that concept to the Ministry of Finance, which is a policy document awaiting legislation rather than a supervisory perimeter.

Evolving Landscape: The regulatory environment for virtual assets is dynamic globally and locally. VASPs should continuously monitor for new laws, regulations, or guidance from Tanzanian authorities.

Risk-Based Approach: VASPs are expected to implement a risk-based approach to AML/CFT, meaning they should assess their specific risks (customer type, products, services, delivery channels, geographical areas) and apply controls commensurate with those risks.

FATF Standards: Tanzania is expected to align with the recommendations of the Financial Action Task Force (FATF), particularly FATF Recommendation 15 on New Technologies and its Interpretive Note on Virtual Assets and VASPs. This means adhering to the "travel rule" (which requires VASPs to obtain and transmit originator and beneficiary information for virtual asset transfers) and having a robust internal compliance program.

Legal Counsel: Given the evolving nature and the lack of highly specific VASP legislation, it is highly advisable for any VASP operating or intending to operate in Tanzania to seek local legal counsel specializing in financial regulation and AML/CFT to ensure full compliance.

Tanzania's principal anti-money-laundering statute is the Anti-Money Laundering Act, Act No. 12 of 2006, consolidated as Cap. 423 and now in Revised Edition 2023, which imposes customer due diligence (section 16), record-keeping for a minimum of ten years (section 17), suspicious transaction reporting to the Financial Intelligence Unit (section 18) and internal compliance programmes (sections 19 and 20) on "reporting persons" as defined in section 3; the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022), in force 8 March 2022, inserted definitions of "virtual asset" and "virtual asset service provider" into section 3 but did not add virtual asset service providers to the reporting-person list at paragraphs (a) to (j), so a Tanzanian virtual asset service provider falls inside the perimeter only if the Minister specifies the category by notice published in the Gazette under paragraph (j), and no such notice has been made.

Tanzania's counter-terrorism statute is the Prevention of Terrorism Act, Act No. 21 of 2002, consolidated as Cap. 19 in Revised Edition 2023 and amended most recently by the Anti-Money Laundering (Amendment) Act, 2022; the Minister declares suspected international terrorists and international terrorist groups under section 14 and designates suspected domestic terrorists under section 15, property used in the commission of terrorist acts is seized under section 38, and seizure, restraint and forfeiture orders are made under sections 48 and 49; the Act makes no reference to virtual assets, cryptocurrency or digital assets, so targeted financial sanctions in Tanzania reach virtual assets only through the general definition of property.

The Bank of Tanzania issued two cryptocurrency warnings in November 2019, the Public Notice on Cryptocurrencies of 12 November 2019 and the press release "Bank of Tanzania Not Involved in Cryptocurrency" of 29 November 2019, each citing sections 26 and 27 of the Bank of Tanzania Act, 2006 and the Foreign Exchange Act, 1992, and each stating that the Tanzanian shilling is the only legal tender and that the foreign exchange regulatory framework does not extend to trading or use of any virtual currency; the Bank's only subsequent published work on the subject is central bank digital currency research, described in its public notice of 14 January 2023 as a "phased, cautious and risk-based approach" with a way forward to be announced on conclusion of the research phase, which is neither a pilot nor a decision against issuance.

The Bank of Tanzania's published position rests on the two November 2019 warnings and on a central bank digital currency research notice of 14 January 2023 that adopts a "phased, cautious and risk-based approach" and promises information on the way forward once research concludes; President Samia Suluhu Hassan's June 2021 remarks urging the Bank to prepare for cryptocurrency are recorded in press reporting and in no Bank of Tanzania or State House document, and Tanzania as at 21 August 2026 still has no virtual asset service provider licence, register or designated supervisor, the Bank having submitted a regulation-and-supervision concept to the Ministry of Finance on 30 July 2026.

Tanzania has no crypto-custodian licence and no virtual-asset service provider authorisation of any kind: the Bank of Tanzania Act, Cap. 197 creates no such category, the Bank of Tanzania's published Regulations and Guidelines registers carry no virtual-asset instrument, and the Capital Markets and Securities Authority has issued no crypto circular, so a crypto custodian in Tanzania is unlicensed and unsupervised rather than caught by general financial-service rules.

Tanzanian law imposes no duty to segregate client digital assets from a custodian's proprietary assets: no Tanzanian virtual-asset instrument exists, the Bank of Tanzania's Regulations and Guidelines registers carry no digital-asset client-asset rule, and the Bank of Tanzania (Fintech Regulatory Sandbox) Regulations, 2024 (GN No. 540 of 5 July 2024) make no reference to virtual assets or to safekeeping of client assets.

Tanzania imposes no insurance, bonding or proof-of-reserves duty on crypto custodians: the Bank of Tanzania Act, Cap. 197 is silent on virtual assets and on custody of client assets, the Bank's published Regulations and Guidelines registers carry no virtual-asset instrument, and the Bank of Tanzania (Fintech Regulatory Sandbox) Regulations, 2024 create no custodian insurance or reserve obligation.

No Tanzanian instrument mandates cold storage or any other technical custody standard for client digital assets: the Bank of Tanzania Act, Cap. 197 is silent on virtual assets, and the Bank of Tanzania's published Regulations and Guidelines registers contain no digital-asset custody or storage standard.

Tanzanian law contains no definition of a qualified crypto custodian and no custodian authorisation category for virtual assets: 'qualified custodian' is United States Securities and Exchange Commission vocabulary with no standing in Tanzania, and neither the Bank of Tanzania Act, Cap. 197 nor the Anti-Money Laundering Act, Cap. 423 creates such a status.

The Bank of Tanzania is Tanzania's central bank under the Bank of Tanzania Act, Cap. 197 and holds the sole right to issue notes and coins under section 26, but it supervises no virtual-asset activity; Governor Emmanuel Tutuba said on 30 July 2026 that the Bank had completed its assessment and submitted a concept on the regulation and supervision of virtual assets to the Ministry of Finance, so the drafting now sits with the Ministry and no framework is in force.

Tanzanian virtual-asset custodians carry no AML/CFT obligations: the Anti-Money Laundering (Amendment) Act, 2022 (Act No. 2 of 2022) inserted definitions of 'virtual asset' and 'virtual asset service provider' into section 3 of the Anti-Money Laundering Act, Cap. 423 but did not add virtual-asset service providers to the section 3 'reporting person' list, whose paragraphs (a) to (i) name no virtual-asset business, and the Minister has published no Gazette notice under paragraph (j) designating them.

Tanzania implements United Nations Security Council targeted financial sanctions domestically through sections 12A, 14(5) and 54 of the Prevention of Terrorism Act, Cap. 19 R.E. 2023 (Act No. 21 of 2002) and the Prevention of Terrorism (General) Regulations 2022, GN No. 379 of 2022, regulations 4, 19, 20, 25 and 26; the Financial Intelligence Unit's Guidelines on Targeted Financial Sanctions revised November 2023 require screening against the Domestic List and the UNSCR List and freezing or blocking within twenty-four hours of designation, covering UNSCRs 1267, 1373, 1988, 1989, 2253, 1718 and 2231. Those duties bind only the 'reporting persons' enumerated in section 3 of the Anti-Money Laundering Act, Cap. 423, a class that excludes virtual asset service providers, and no United Nations sanctions regime targets Tanzania itself.

Obligations: Financial institutions (and by extension, any entity deemed a "reporting person" under Tanzanian AML law, which could include VASPs if they were formally regulated) must:

Screen against the UN Consolidated List: Check customers, beneficial owners, and transaction parties against the UN Security Council Consolidated List, which identifies individuals and entities subject to asset freezes, travel bans, and arms embargoes.

Freeze Assets: Immediately freeze funds or other economic resources of designated individuals and entities.

Prohibit Transactions: Refrain from making funds or economic resources available, directly or indirectly, to or for the benefit of designated individuals and entities.

Report: Report any hits or frozen assets to the relevant authorities (e.g., Financial Intelligence Unit - FIU).

Relevance to Crypto: If crypto assets are recognized as "funds" or "economic resources" under Tanzanian law, these obligations would directly apply to VASPs. Even if not explicitly recognized, best practice dictates treating them as such to avoid facilitating sanctioned activity.

UN Security Council Sanctions Committees: https://www.un.org/securitycouncil/sanctions/committees

Legal Basis: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces U.S. sanctions programs. While U.S. law, OFAC sanctions have significant extraterritorial reach.

US Dollar Nexus: Transactions involving the U.S. dollar, even if initiated and completed outside the U.S., often clear through the U.S. financial system, making them subject to OFAC jurisdiction.

U.S. Persons Involvement: Any transaction involving a U.S. person (citizen, resident, entity, or branch abroad) or U.S.-origin goods/services (including software or cloud services) makes it subject to OFAC.

Secondary Sanctions: Certain OFAC programs include "secondary sanctions" which target non-U.S. persons for engaging in specific activities with sanctioned countries or entities, even if no direct U.S. nexus exists.

Obligations: VASPs dealing with any U.S. nexus (customers, funds, technology) must:

Screen against OFAC Sanctions Lists: Primarily the Specially Designated Nationals and Blocked Persons (SDN) List, but also other lists like the Non-SDN Palestinian Legislative Council List, Sectoral Sanctions Identifications (SSI) List, etc.

Block/Reject Transactions: Block property and interests in property of SDNs and reject prohibited transactions involving sanctioned jurisdictions or entities.

Report: Report blocked property and rejected transactions to OFAC.

Relevance to Crypto: OFAC has explicitly stated that its sanctions apply to virtual currency transactions and has designated cryptocurrency addresses associated with sanctioned entities.

OFAC Guidance on Virtual Currency: https://home.treasury.gov/system/files/126/virtual_currency_guidance_final.pdf

Legal Basis: The European Union imposes sanctions (restrictive measures) based on common foreign and security policy decisions.

EU Persons/Entities: Transactions involving EU citizens, residents, or entities (including subsidiaries or branches of EU companies).

EU Financial System Nexus: Transactions routed through the EU financial system.

EU-Origin Technology: Use of EU-origin technology or services.

Obligations: VASPs with an EU nexus must:

Screen against EU Sanctions Lists: Check against the EU Consolidated Financial Sanctions List.

Freeze Assets: Freeze funds and economic resources of designated individuals and entities.

Report: Report any hits to relevant EU member state authorities.

Relevance to Crypto: The EU's 6th AML Directive and upcoming MiCA (Markets in Crypto-Assets) regulation explicitly bring VASPs under AML/CFT and sanctions compliance obligations.

EU Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions: While not a single direct public list like OFAC's SDN, the EU Sanctions Map provides access to relevant regulations.

Tanzania implements United Nations Security Council designations through the Prevention of Terrorism Act, Chapter 19 Revised Edition 2023, whose section 15 empowers the Minister to designate a person or entity pursuant to United Nations Security Council Resolutions and whose section 14(5) carries the power to make freezing regulations; the Financial Intelligence Unit's Targeted Financial Sanctions Guide of November 2023 defines the Domestic List as names declared by the Minister of Home Affairs under that Act, directs users to the UNSC Sanctions Committee lists, and requires a freeze and a report to the Minister, the Police and the FIU within twenty-four hours of designation, and no Tanzanian list targets virtual assets.

Cryptocurrencies are not legal tender in Tanzania - section 26 of the Bank of Tanzania Act, Cap. 197 gives the Bank the sole right of issue and makes its notes and coins the only legal tender, and the Bank's notices of 12 and 29 November 2019 restate this - but no Tanzanian instrument prohibits financial institutions from facilitating crypto transactions, and the High Court held in Yellow Card Tanzania Limited v Nyamwero Michael Nyamwero, Commercial Case No. 12171 of 2024 (13 December 2024) that crypto trading is not illegal in Tanzania.

Tanzania has taken no cryptocurrency enforcement action: the Bank of Tanzania's dated press-release index carries no crypto or virtual-asset item between the notices of 12 and 29 November 2019 and the central bank digital currency notice of 14 January 2023, and no fine, licence revocation or sanction against a virtual-asset entity appears on it through August 2026; no Tanzanian instrument bans financial institutions from dealing in crypto, and the November 2019 notices are public warnings that create no offence, licence or supervised perimeter.

Legal Basis: As a UN member state, Tanzania is legally bound to implement sanctions imposed by the UN Security Council. These sanctions are primarily aimed at combating terrorism, proliferation of weapons of mass destruction, and addressing specific threats to international peace and security.

Legal Basis: The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces U.S. sanctions programs. While U.S. law, OFAC sanctions have significant extraterritorial reach.

Legal Basis: The European Union imposes sanctions (restrictive measures) based on common foreign and security policy decisions.