Centralized exchange in Tanzania
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is conditionally permitted in Tanzania with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Customer identification and verification (CDD) under the Anti-Money Laundering Act, 2006 — collect full legal name, date of birth, address, nationality, national ID/passport for natural persons; for legal entities collect registration number, address, directors, proof of incorporation, and beneficial ownership.
- Ongoing transaction monitoring for unusual or suspicious patterns consistent with customer risk profile.
- Enhanced Due Diligence (EDD) for higher-risk situations: PEPs, customers from high-risk FATF jurisdictions, complex/unusually large transactions, new anonymity-favoring technologies/products, cross-border virtual asset transfers.
- Suspicious Transaction Reporting (STR) to the Financial Intelligence Unit (FIU) Tanzania — any knowledge or suspicion of proceeds of crime, money laundering, or terrorism financing must be reported promptly via prescribed format.
- Record-keeping for a minimum of five (5) years after end of business relationship or transaction date — includes all CDD records, business correspondence, transaction records (dates, amounts, virtual asset types, sending/receiving addresses), and STR records.
- No tipping-off prohibition — VASPs and employees must not disclose to customers or third parties that an STR has been or will be submitted.
- Compliance with Anti-Money Laundering Regulations, 2012 (as amended) for detailed CDD, STR, and record-keeping procedures.
- Compliance with Anti-Terrorism Act, 2002 (as amended) for counter-terrorism financing obligations.
Key Restrictions
- Bank of Tanzania (BoT) maintains that cryptocurrencies are not recognized as legal tender and has prohibited financial institutions from facilitating crypto transactions.
- No specific crypto exchange/VASP licensing framework exists — the operating model would face significant legal uncertainty and potential enforcement.
- The BoT has issued public warnings against dealing in, facilitating, or operating businesses involving cryptocurrencies; operators risk being classified as unauthorized financial institutions.
- No specific rules exist for segregation of client digital assets from proprietary assets, creating structural ambiguity for custody.
- No specific mandates for cold storage or insurance/bonding requirements for custodial digital assets.
- Any entity facilitating fiat-to-crypto conversion may be viewed as engaging in money transmission/payment processing, potentially falling under the National Payment Systems Act, 2015.
Key Risks
- High enforcement risk — BoT and financial institutions have been warned not to facilitate crypto; operating an exchange could result in regulatory action or shutdown.
- Regulatory ambiguity — absence of a licensing framework means any exchange operation is legally grey; future regulation may impose retroactive compliance burdens.
- No legal recourse for customer disputes or insolvency scenarios involving crypto assets, given the lack of a recognized framework.
- Banking access risk — financial institutions are prohibited from facilitating crypto transactions, making fiat on/off ramps difficult or impossible through formal channels.
- Reputational risk — operating in a jurisdiction where the central bank has publicly warned against crypto could attract negative attention and media scrutiny.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
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.
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.
Exchanges: If an exchange facilitates the exchange of fiat currency for cryptocurrencies, or vice versa, it might be seen as engaging in money transmission or payment processing activities.
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.
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.
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.
Evidence fact tz.aml.identification-and-verification-of-customers not found (may have been renamed).
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.
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:
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.
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.
Regulator Name: Bank of Tanzania (BoT)
Entity Targeted: The general public, financial institutions, and any individuals or entities attempting to deal in, facilitate, or operate businesses involving cryptocurrencies. Violation Type: Dealing in, facilitating, or promoting instruments not recognized as legal tender; operating unauthorized financial services. Penalty Amount: Not a specific fine amount applied in a single action, but the outcome implies potential prosecution under existing financial laws for unauthorized activities.
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.
Entity Targeted: Any entity attempting to establish a cryptocurrency exchange, brokerage, or related service within Tanzania. Violation Type: Operating an unauthorized financial institution; providing financial services without a license. Penalty Amount: Not applicable as there are no known licensed entities to fine. The consequence would be prevention of operation or legal action. Outcome: Due to the regulatory stance, no formal licenses have been issued for cryptocurrency businesses. This means any entity attempting to operate such a business would be considered illegal from the outset. This "enforcement" is preventative and structural, rather than reactive with specific penalties.
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.
Conditional — a centralized exchange may technically operate in Tanzania but faces severe legal uncertainty, no licensing framework, a BoT prohibition on financial institutions facilitating crypto, and must comply with general AML/CFT obligations under the AMLA while operating outside any recognized regulatory regime.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?