Tanzania -- Licensing Requirements Regulatory Overview

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.