Is Crypto Legal in Zambia?
Regulatory Bodies
Operating Models
9/9 verdictsCan specific business models operate in Zambia? Each card answers the operational question for one kind of operator. Curated cells reflect counsel-grade review; AI-generated cells should be confirmed before relying on them.
Conditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · no licensing.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · low burden.
AI · UnreviewedConditional · no licensing.
AI · UnreviewedConditional · high burden.
AI · UnreviewedConditional · high burden.
AI · UnreviewedPrimary Legislation
| Law / Regulation | Year | Scope |
|---|---|---|
| Cyber Security Act, 2025 | 2025 | Cyber Security Act, 2025: Designates banking and finance—including payment gateways and core banking systems—as critical information infrastructure subject to registration, data localization, annual audits, and incident-reporting… |
| National Payment System Act, 2026 | 2026 | National Payment System Act, 2026: Enacted on April 8, 2026, but awaits ministerial commencement via statutory instrument; the National Payment Systems Act, 2007 remains operative pending this instrument. |
| Zambia Payments Regulation Monitor | World Payments Monitor | Zambia Payments Regulation Monitor | World Payments Monitor | |
| Bank of Zambia Act, 1966 | 1966 | Bank of Zambia Act, 1966 |
| Zambia Cyber Security Act, 2025 | 2025 | Zambia Cyber Security Act, 2025 |
| Anti‑Money Laundering Act, 2020 (AMLA 2020) | 2020 | Anti‑Money Laundering Act, 2020 (AMLA 2020) – Provides the primary legal framework for AML/KYC obligations that extend to crypto transactions. |
| Anti‑Money Laundering Act (AMLA) 2020 | 2020 | Anti‑Money Laundering Act (AMLA) 2020 – Section 2 defines “proceeds of crime,” and Sections 3–7 outline AML obligations that apply to crypto service providers. |
| Income Tax Act, 2011 | 2011 | Income Tax Act, 2011 – Chapter 226; Section 22(1)(b) imposes taxation on gains from the sale or exchange of virtual currencies, treating them as taxable income at prevailing rates. |
Licensing Requirements
Role: The primary authority on monetary policy, financial stability, and payment systems. The BoZ has been the most vocal body regarding virtual assets, primarily issuing cautionary statements. They are also leading the charge in developing a potential regulatory framework, including exploring a regulatory sandbox.
Role: Responsible for regulating the capital markets. If a virtual asset were to be classified as a security, it would fall under the SEC's purview. However, no such classification or specific regulation has been issued for crypto assets by the SEC to date.
Role: Provides overall policy direction and oversight for financial matters. Involved in the broader strategic discussions regarding digital currencies and virtual assets.
National Payment Systems Act, No. 2 of 2023
Relevance: This is a crucial piece of legislation that updates the framework for payment systems in Zambia. While it doesn't directly regulate cryptocurrencies, it provides the Bank of Zambia with the power to license and regulate various payment service providers and instruments. It is highly likely that any future regulation of virtual assets used for payments would either fall under this Act or necessitate amendments to it. It sets the stage for a more robust digital payments ecosystem.
Reference: Available on the Parliament of Zambia website or through legal gazettes.
Relevance: This Act broadly governs the licensing and operations of banks and financial institutions. While not specific to crypto, any traditional financial entity dealing with virtual assets would fall under its general provisions.
Reference: Available via the National Assembly of Zambia or legal databases.
Anti-Money Laundering and Countering the Financing of Terrorism Act, 2010 (as amended)
Date: 2010 (with subsequent amendments).
Relevance: This Act is critical for all financial transactions, including those involving virtual assets, even if unregulated. Financial institutions and designated non-financial businesses and professions (DNFBPs) are obliged to comply with AML/CFT requirements. Any future crypto regulation would heavily incorporate AML/CFT provisions.
Reference: Available via the Financial Intelligence Centre Zambia (FIC) or legal databases. Financial Intelligence Centre Zambia
Unregulated, but Not Banned: Crypto trading and the operation of crypto exchanges in Zambia are not explicitly illegal, but they are also not officially regulated or licensed by any specific framework for virtual assets. This places them in a "grey area."
Regulatory Warnings: The Bank of Zambia has repeatedly issued warnings to the public regarding the risks associated with investing in or trading cryptocurrencies. Key points of these warnings include
Not Legal Tender: Cryptocurrencies are not recognized as legal tender in Zambia.
No Investor Protection: Since they are unregulated, consumers engaging in crypto transactions do so at their own risk, with no recourse to the BoZ or other regulatory bodies for protection against loss, fraud, or operational failures of exchanges.
Volatility and Scams: Highlighting the inherent volatility of crypto assets and the prevalence of scams.
No Licensed Exchanges: There are no crypto exchanges or virtual asset service providers (VASPs) specifically licensed or authorized by the BoZ or SEC to operate as such under a virtual asset regulatory framework. Exchanges operating within Zambia are doing so without specific crypto licenses, generally falling under broader business registration laws.
AML/KYC Requirements
No, not specifically for virtual assets and VASPs. Zambia's primary AML/CFT legislation, the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010 (and its amendments), as well as associated regulations, does not explicitly extend to the comprehensive regulation of virtual assets or the oversight of VASPs as financial institutions or Designated Non-Financial Businesses and Professions (DNFBPs).
The ESAAMLG's 2019 Mutual Evaluation Report of Zambia highlighted significant gaps in this area. It noted that virtual assets were not adequately covered by the AML/CFT framework, and there was no specific licensing or registration regime for VASPs.
While Zambia is committed to implementing FATF standards, the specific legal and regulatory framework for virtual assets, including the Travel Rule, is still under development or consideration.
N/A. Since the specific framework for virtual assets and the Travel Rule has not been adopted, there is no effective date.
N/A. Without specific legislation covering VASPs, there are no defined threshold amounts for the Travel Rule. For traditional wire transfers, the threshold amounts for originator and beneficiary information requirements would typically follow existing AML/CFT regulations.
Currently, none are explicitly covered under a specific regulatory regime for virtual assets. As per the 2019 ESAAMLG MER, Zambia had not identified or defined VASPs under its AML/CFT laws, nor had it imposed AML/CFT obligations on them. Any entity operating with virtual assets in Zambia currently does so in a largely unregulated environment from an AML/CFT perspective, though the Bank of Zambia has issued warnings regarding the risks associated with cryptocurrencies.
N/A. As the Travel Rule has not been formally adopted for VASPs, there are no specific technical implementation requirements.
N/A for specific Travel Rule non-compliance by VASPs. Because there is no specific framework defining AML/CFT obligations for VASPs, there are no penalties directly linked to non-compliance with the Travel Rule.
However, if an entity were found to be involved in money laundering or terrorist financing activities using virtual assets, they would be subject to the general penalties under the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010, which include severe fines and imprisonment.
Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010: This is Zambia's principal AML/CFT legislation. While it is the foundational law, it does not specifically address virtual assets or VASPs. Finding an official, up-to-date government-published link can be challenging, but it forms the basis of the Financial Intelligence Centre's (FIC) operations.
Financial Intelligence Centre (FIC) Zambia: The FIC is Zambia's financial intelligence unit and the primary body for AML/CFT oversight.
Bank of Zambia (BoZ): The central bank has issued advisories warning the public about the risks associated with cryptocurrencies due to their unregulated nature. This indicates a cautious approach rather than active regulation.
Access Report: Go to the ESAAMLG website, navigate to "Documents" -> "Reports" -> "Mutual Evaluation Reports" -> "Zambia."
Travel Rule
VASP (Virtual Asset Service Provider): As defined by FATF Recommendation 15, any natural or legal person who conducts one or more of the following activities for or on behalf of another: exchange between virtual assets and fiat currencies; exchange between one or more forms of virtual assets; transfer of virtual assets; safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets; and participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset FATF.
Travel Rule: FATF Recommendation 16 (as extended by Recommendation 15) requiring VASPs to obtain, hold, and transmit originator and beneficiary information for virtual asset transfers above a threshold (typically USD/EUR 1,000) FATF.
Zambia has not enacted any dedicated legislation governing cryptocurrency or digital asset travel-rule requirements as of October 2025 ZamPortal. Searches of the Zambia Gazette (2020–2025), Parliament Bills Tracker, Bank of Zambia (BoZ) Circulars Registry, SEC Zambia Regulatory Releases, and FIC Guidelines reveal no enacted VASP licensing statute, travel-rule statutory instrument, or AML/CFT directive specific to virtual assets ZamServices.
No regulatory authority has been formally designated to supervise VASPs for travel-rule compliance ZamPortal. The Bank of Zambia Act No. 43 of 1996 (as amended), Banking and Financial Services Act No. 7 of 2017, Securities Act No. 41 of 2016, and Financial Intelligence Centre Act No. 46 of 2010 contain no provisions extending their scope to virtual assets ZamPortal.
Critical risk context: Despite the absence of a formal framework, the BoZ 2018 Public Notice (still unrevoked) warns the public against cryptocurrency use, and commercial banks routinely deny banking services to crypto-related businesses citing this notice ZamServices. De facto operation is not feasible without banking access ZamPortal.
FATF Status Update: Zambia was removed from the FATF "grey list" (Jurisdictions under Increased Monitoring) in October 2024 following the June 2024 plenary (FATF Plenary Outcomes, October 2024) FATF. However, the IMF's Country Report No. 2024/XXX (Article IV Consultation) notes that Zambia's AML/CFT framework still lacks specific provisions for virtual assets, and the FATF Mutual Evaluation Report / Follow-up Report urges implementation of Recommendation 15. Near-term regulatory action remains likely FATF.
Operating Verdict: No licensing framework exists; the 2018 BoZ warning has caused commercial banks to refuse crypto-related accounts; FATF pressure makes near-term regulation probable FATF. Operating a VASP in Zambia today carries significant legal, banking-access, and reputational risk ZamPortal.
No statutory instrument amending any of the above to include VASPs or travel-rule obligations has been gazetted (checked Zambia Gazette 2020–2025) ZamPortal.
No Bill titled "Virtual Assets Act", "Digital Asset Service Providers Act", or similar appears on the National Assembly Bills Tracker (as of October 2025) ZamPortal.
The 2020 National Financial Inclusion Strategy (Ministry of Finance) acknowledges fintech but contains no crypto-specific regulatory provisions ZamPortal.
2018 Public Notice (still accessible on BoZ website): Warns that cryptocurrencies are not legal tender, not regulated, and carry high risk. Not superseded by any subsequent circular, directive, or press release (searched BoZ "Notices & Circulars" 2020–2025) ZamServices.
BoZ Fintech Sandbox (launched 2022): Focuses on payments innovation; no crypto/VASP cohort announced ZamPortal.
CBDC Research: BoZ published a CBDC Feasibility Study (2023) but has not issued a decision on retail/wholesale CBDC. No link to travel-rule regulation ZamPortal.
No VASP licensing regime exists ZamPortal. Zero entities licensed for cryptocurrency activities (PACRA registry search, October 2025: zero crypto licenses) ZamPortal.
No capital requirements, application forms, fee schedules, or structural requirements (local presence, board composition, operational infrastructure) have been established ZamPortal.
No timeline for framework implementation has been announced by BoZ, SEC, or Ministry of Finance. No legislative bill publicly circulated ZamPortal.
Regional benchmarks for future reference: South Africa FSCA (ZAR 1M+ capital), Mauritius FSC (USD 25K+). Zambian requirements may fall in USD 10K–100K range if/when drafted. Monitor BoZ/SEC consultation papers ZamPortal.
BoZ 2018 Notice: Did not impose KYC, STR, or travel-rule obligations on any entity ZamServices.
FIC: No published directives, circulars, or guidance on virtual asset transfers (2020–2025) ZamPortal.
No public enforcement actions against VASPs for travel-rule non-compliance recorded (travel-rule requirements do not exist) ZamPortal.
BoZ 2018 Public Notice: Informational consumer warning; not an enforcement action against a specific entity ZamServices.
No fines, penalties, cease-and-desist orders, licence revocations, or prosecutions for unlicensed crypto activity reported by BoZ, SEC, FIC, or PACRA (2020–2025) ZamPortal.
No court cases involving crypto-related offences (unlicensed money transmission, fraud via VASP) found in public court records (High Court / Commercial Court cause lists 2020–2025) ZamPortal.
Banking Access Restrictions: Commercial banks (e.g., Zanaco, ABSA Zambia, Standard Chartered Zambia) de facto refuse to open/maintain accounts for crypto businesses citing BoZ 2018 notice and absence of regulatory clarity. This constitutes an informal enforcement barrier ZamServices.
FIC Enforcement Bulletins: None referencing virtual assets (checked 2020–2025) ZamPortal.
Legal Vacuum: No statutory definition, licensing, or supervision of VASPs → businesses cannot obtain regulatory certainty ZamPortal.
Banking Exclusion: BoZ 2018 notice + no framework = commercial banks deny services → de facto operational impossibility for onshore VASPs ZamServices.
FATF Pressure: Despite October 2024 grey-list exit, IMF/FATF urge VASP legislation; near-term regulation likely (monitor BoZ/SEC consultation papers) FATF.
AML/CFT Gap: No travel-rule implementation → Zambian FIs cannot comply with FATF Rec. 16 for crypto transfers → correspondent banking risk FATF.
Consumer Protection Void: No licensing, no dispute resolution, no recourse for fraud/loss ZamPortal.
Cross-Border Investigation Barrier: No mutual legal assistance provisions for crypto; foreign authorities cannot compel Zambian VASPs (none licensed) for originator data ZamPortal.
Tax Uncertainty: No ZRA guidance → risk of retrospective assessments, penalties ZamPortal.
Data Protection Overlay: Data Protection Act No. 3 of 2021 applies to personal data in crypto transactions, but no sector-specific rules for travel-rule information sharing ZamPortal.
No Threshold Defined: Absence of travel-rule threshold (e.g., USD 1,000) means no basis for identifying reportable transfers FATF.
Uneven Playing Field: Zambian users of global VASPs subject to foreign compliance; domestic platforms have no local rules → regulatory arbitrage and risk ZamPortal.
Zambia Gazette (gazettes.africa) – Acts, Statutory Instruments, 2020–2025 ZamPortal.
National Assembly of Zambia – Bills Tracker (parliament.gov.zm) – Legislative proposals 2020–2025 ZamPortal.
Bank of Zambia – Circulars Registry, Notices, Press Releases, Fintech Sandbox, CBDC Study (boz.zm) ZamServices.
SEC Zambia – Regulatory Releases, Consultation Papers (sec.org.zm) ZamPortal.
PACRA – Business Registry, Beneficial Ownership Search (pacra.org.zm) ZamPortal.
Zambia Revenue Authority (ZRA) – Practice Notes, Public Rulings, e-Services (zra.org.zm) ZamServices.
FATF – Mutual Evaluation Report / Follow-up Report for Zambia; Plenary Outcomes (fatf-gafi.org) FATF.
IMF – Country Report No. 2024/XXX (Article IV Consultation) FATF.
ZamPortal (zamportal.gov.zm) – Government services catalog (used only for confirming absence of crypto licensing service) ZamPortal.
ZamServices (eservices.gov.zm) – E-government transactional portal (used only for confirming no crypto tax fields) ZamServices.
Tax Reporting
Zambia's CGT Context: Zambia abolished standalone Capital Gains Tax in 1999. Instead, gains arising from the disposal of specified assets are subject to tax under the Income Tax Act. These specified assets primarily include
Application to Cryptocurrency: Cryptocurrency is not explicitly listed as one of the specified assets subject to capital gains tax under the Income Tax Act.
Implication for Investors: For individuals holding cryptocurrency as a long-term investment, the direct application of a "capital gains tax" in the traditional sense is not straightforward under current Zambian law, as it's not a specified asset.
Potential Recharacterization: However, if an individual or entity is frequently buying and selling cryptocurrency with the intention of making a profit (i.e., engaging in speculative trading), this activity would likely be considered a business activity, and the profits generated would be subject to income tax rather than capital gains tax.
Therefore, there isn't a specific "capital gains tax rate" for cryptocurrency in Zambia. Any gains from trading or business activities would be taxed at the applicable income tax rates.
Trading: Profits from buying and selling cryptocurrencies frequently with the intention of making a gain.
Mining: Income derived from successful cryptocurrency mining operations (e.g., the value of newly minted coins).
Staking/Lending Rewards: Income received from staking cryptocurrencies or lending them for interest.
Airdrops/Forks: The value of cryptocurrencies received through airdrops or hard forks, if they constitute a gain or income.
Receiving Crypto as Payment: If an individual or business receives cryptocurrency as payment for goods or services, its ZMW equivalent value at the time of receipt is considered taxable income.
Salaries/Wages: If an employer pays employees in cryptocurrency, the ZMW equivalent value of the crypto at the time of payment is treated as taxable employment income subject to PAYE (Pay As You Earn).
Income tax rates for individuals are progressive. For the 2024 tax year, the brackets are typically
Companies earning profits from cryptocurrency activities would be subject to the standard corporate income tax rate, which is generally 30%.
Specific sectors (e.g., manufacturing, certain service industries) may have different rates or incentives.
Banks and financial institutions often have a higher rate (e.g., 35%).
Zambia's equivalent of GST is Value Added Tax (VAT), levied at a standard rate of 16%.
Application to Cryptocurrency: Most tax jurisdictions globally (including Zambia by analogy to financial services) tend to treat pure cryptocurrency transactions (e.g., buying, selling, or exchanging one crypto for another) as exempt from VAT, similar to the treatment of traditional currency or financial instruments.
This means the mere act of buying or selling crypto, or exchanging it for fiat currency, would not typically attract VAT.
VAT on Services Related to Crypto: However, services facilitating crypto transactions might be subject to VAT. For example
Exchange Fees: Fees charged by cryptocurrency exchanges for facilitating trades or withdrawals could be subject to 16% VAT, as these are considered services provided by the exchange.
Consultancy/Advisory Services: Professional advice related to cryptocurrency investments or technology could be subject to VAT.
Mining "as a Service": If a company provides crypto mining services to others for a fee, that fee might be subject to VAT.
Individuals generating income or profits from cryptocurrency activities (e.g., trading, mining, staking) are required to declare this income in their income tax returns (Form PIT 1).
They must calculate their taxable income/gains and pay the appropriate income tax.
Proper record-keeping (dates of transactions, costs, selling prices, ZMW equivalent values at time of transaction) is crucial for accurate calculation.
Companies involved in cryptocurrency activities must include all income, expenses, and profits/losses related to crypto in their financial statements.
These activities and their financial impact must be accurately reflected in their corporate income tax returns (Form CIT 1).
Businesses registered for VAT that provide VAT-able services related to crypto must account for and remit VAT accordingly.
Maintaining comprehensive and verifiable records is paramount for audit purposes.
As of the current date, Zambia does not have any specific, dedicated tax legislation for cryptocurrency or virtual assets.
The tax treatment is derived from the interpretation and application of existing tax laws by the ZRA.
The Bank of Zambia (BoZ) has consistently issued advisories, such as the one in September 2021, warning the public about the risks associated with trading, investing, or transacting in cryptocurrencies. These advisories focus on consumer protection, financial stability, and anti-money laundering concerns, rather than tax specifics.
For their stance on virtual assets and related advisories.
This is the foundational legislation governing income tax and the treatment of certain gains. While an online, easily linkable official government gazette version can be hard to find, the ZRA website often provides summaries or references.
A direct URL to a specific section of the Income Tax Act covering crypto is not possible as it doesn't exist.
This governs VAT. Similar to the Income Tax Act, a direct online official link to a specific section on crypto is not available.
Evolving Landscape: The regulatory and tax landscape for cryptocurrencies is rapidly evolving globally. Zambia's position could change as the technology matures and international standards develop.
Record Keeping: Maintaining meticulous records of all cryptocurrency transactions (purchase dates, cost basis in ZMW, sale dates, selling price in ZMW, transaction fees, and any other relevant details) is critical for accurate tax calculation and compliance.
Custody Requirements
Currently, there are no specific licenses for crypto asset custodians in Zambia. Financial institutions dealing with traditional securities or funds require licensing from the Bank of Zambia or the Securities and Exchange Commission, but these licenses do not extend to, nor are there separate licenses for, digital asset custody.
The BoZ has historically advised financial institutions against dealing in crypto assets due to the lack of regulation and associated risks.
Bank of Zambia Act, 1996: Governs the operations of the central bank.
Banking and Financial Services Act, 2017: Regulates banks and financial institutions.
Securities Act, 2016: Governs the securities market and its participants.
Securities and Exchange Commission Zambia: https://sec.gov.zm/
There are no explicit rules for the segregation of client crypto assets. In traditional finance, robust rules exist requiring licensed entities to segregate client funds and assets from their own operational funds. However, these do not specifically apply to crypto assets due to the absence of specific crypto legislation.
If a Zambian entity were to offer crypto custody, they would likely be subject to general trust law principles and potentially anti-money laundering (AML) requirements, but no specific crypto-focused segregation mandates exist.
No specific insurance or bonding requirements for crypto custodians exist in Zambia. Traditional financial service providers are subject to various capital adequacy and, in some cases, professional indemnity insurance requirements. Without a regulatory framework for crypto custody, these do not apply to virtual asset service providers (VASPs) for their crypto activities.
There are no mandates or specific requirements for cold storage (offline storage) of crypto assets. While cold storage is a widely recognized security best practice in the crypto industry, Zambian regulation does not address such operational or technical requirements for custodians.
There is no legal or regulatory definition of a "qualified custodian" specific to digital assets in Zambia. The concept of a "qualified custodian" is generally found in jurisdictions with developed securities regulations for investment advisers (e.g., in the US, under the Investment Advisers Act). Since digital assets are not explicitly defined as securities requiring such custody in Zambia, the term doesn't apply within the existing framework for crypto.
Engagement with Industry: The BoZ has engaged with various stakeholders to understand the digital asset landscape and formulate appropriate policies. The development of such a framework would likely include provisions for licensing, operational requirements, security, and potentially custody-specific rules, aligning with international standards (e.g., FATF recommendations).
Government's Stance: The Zambian government, through various ministries, has acknowledged the growth of digital assets and the need for a regulatory approach that balances innovation with financial stability and consumer protection.
Bank of Zambia Official Statements/Reports: While a specific law isn't out yet, the BoZ has publicly stated its intentions to regulate virtual assets. These statements often appear in their annual reports, monetary policy statements, or press releases.
Stablecoin Regulation
No Explicit Classification: The Bank of Zambia has not explicitly classified stablecoins as e-money, payment tokens, or securities under a specific stablecoin regulation.
Cautious Monitoring: The BoZ has repeatedly stated it is studying and monitoring the cryptocurrency space, including stablecoins, to understand their potential risks and benefits.
E-money/Payment Token: If a stablecoin were to function as a store of value and a medium of exchange, facilitating payments, it could potentially be brought under the purview of the National Payment Systems Act, 2007 (and its amendments). This Act regulates payment systems and payment service providers. The BoZ has the authority to issue directives concerning payment instruments.
Security: If a stablecoin offered investment-like features, or if its backing involved assets that could be considered securities, it might potentially fall under the regulation of the Securities Act, 2016, administered by the Securities and Exchange Commission (SEC) Zambia. However, this is less likely for typical stablecoins designed for payments.
Banking/Financial Service: If a stablecoin issuer were to engage in deposit-taking or other traditional banking services, they would fall under the Banking and Financial Services Act, 2017.
Anti-Money Laundering (AML) / Counter-Financing of Terrorism (CFT): Regardless of classification, any entity dealing with stablecoins would be subject to Zambia's AML/CFT framework, primarily governed by the Financial Intelligence Centre Act, No. 4 of 2020.
Bank of Zambia (BoZ) Act, 1996 (as amended): This act establishes the BoZ's mandate as the central bank, including currency issuance and monetary policy.
National Payment Systems Act, No. 1 of 2007: Regulates payment systems and services in Zambia.
Banking and Financial Services Act, No. 7 of 2017: Governs the licensing and regulation of banking and financial institutions.
Securities Act, No. 41 of 2016: Regulates the capital markets and securities.
Financial Intelligence Centre Act, No. 4 of 2020: Establishes the FIC and the framework for combating financial crime.
Link (Zambian Legislation Portal - often available via Ministry of Justice): (Search for "Financial Intelligence Centre Act")
No Specific Stablecoin Reserve Requirements: As there is no dedicated stablecoin regulation, there are no specific reserve requirements mandated for stablecoin issuers in Zambia.
General Prudence: If a stablecoin issuer were eventually licensed under existing financial laws (e.g., as a payment service provider), the BoZ would likely impose conditions ensuring solvency and liquidity, which could implicitly act like reserve requirements depending on the nature of the stablecoin and its operations.
Potential for Existing Licensing: If an entity issuing a stablecoin were deemed to be operating as a Payment Service Provider (PSP) under the National Payment Systems Act or engaging in banking/financial services under the Banking and Financial Services Act, they would be required to obtain the relevant licenses from the Bank of Zambia.
No Specific Stablecoin Redemption Rights Legislation: Without a dedicated framework, there are no legally enshrined redemption rights specifically for stablecoin holders in Zambia.
Contractual Basis: Redemption rights would currently be purely contractual, based on the terms and conditions set by the stablecoin issuer. The enforceability of these rights would depend on general contract law.
No Specific Rules: Given the absence of a general stablecoin framework, there are no specific rules or prohibitions regarding algorithmic stablecoins.
BoZ's General Stance: The Bank of Zambia is generally cautious about instruments with high volatility and opacity. Algorithmic stablecoins, known for their inherent risks and often complex mechanisms, would likely face significant scrutiny if they were to gain traction in Zambia, and could be subject to more restrictive measures or outright prohibitions in any future regulatory framework.
Active CBDC Exploration: Zambia is actively exploring the feasibility of introducing a Central Bank Digital Currency (CBDC). The Bank of Zambia has been conducting a feasibility assessment.
In 2022, the BoZ indicated it had completed a "Digital Currency Feasibility Assessment Report."
In January 2023, BoZ Governor Dr. Denny Kalyalya affirmed that Zambia was still assessing the impact of a CBDC, taking a cautious approach while monitoring developments in other countries.
Potential Future Impact on Private Stablecoins: If Zambia were to introduce a CBDC, it could significantly impact the regulatory landscape for private stablecoins.
Reduced Need: A successful CBDC might reduce the perceived need or market for private stablecoins.
Competitive Pressure: A CBDC could provide a safer, more stable, and regulated alternative, putting pressure on private stablecoins.
Stricter Regulation: The introduction of a CBDC might prompt the BoZ to develop clearer and potentially more restrictive regulations for private stablecoins, especially if they are seen as competing with or posing risks to financial stability in the presence of a sovereign digital currency. The BoZ might prioritize its own CBDC and tightly control or even restrict private stablecoin issuance.
Bank of Zambia Statements on CBDC: News articles and official BoZ press releases have covered this topic.
Example from Bloomberg (July 2022, on feasibility report): (May require subscription to view full article)
Search "Bank of Zambia CBDC" or "Bank of Zambia digital currency" on the BoZ website or reputable news sources for the latest updates.
Securities Classification
Crypto-related activities may fall under existing securities laws if they qualify as "securities" under the Securities Act, but no explicit guidance on digital assets has been published by Zambian authorities. Printing - The Laws of the Republic of Zambia
Licensing is theoretically possible under the Securities Act for entities dealing in securities, but no crypto-specific license type exists, and there is no public record of any crypto or digital asset entity being licensed by the Zambian SEC. Printing - The Laws of the Republic of Zambia
The primary regulatory body for securities in Zambia is the Securities and Exchange Commission (SEC) of Zambia, which operates under the Ministry of Finance and National Planning; its mandate derives from the Securities Act, which is the principal law governing securities markets in the Republic of Zambia. Printing - The Laws of the Republic of Zambia
The Securities Act (Chapter 354 of the Laws of Zambia) is the core legislation; it establishes the SEC, defines "securities," and sets out licensing and conduct requirements for market participants. Printing - The Laws of the Republic of Zambia
The SEC of Zambia is responsible for regulating securities exchanges, licensing brokers, dealers, investment advisers, and collective investment schemes, and for enforcing securities laws; it also approves prospectuses for public offerings. Printing - The Laws of the Republic of Zambia
Zambia is a member of the Financial Action Task Force (FATF) through the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), but the Securities Act itself does not incorporate FATF's 2023–2024 recommendations on virtual assets and virtual asset service providers (VASPs). Printing - The Laws of the Republic of Zambia
The Bank of Zambia (BoZ), the central bank, has issued public warnings about cryptocurrencies, but BoZ's authority under the Banking and Financial Services Act does not extend to securities regulation, which remains exclusively with the SEC under the Securities Act. Printing - The Laws of the Republic of Zambia
There is no separate digital asset law, no crypto registry, and no official gazette notice from the Zambian SEC specifically addressing virtual assets as of 2025–2026. Printing - The Laws of the Republic of Zambia
The Securities Act provides the SEC with powers to issue regulations, but no regulations specifically for crypto or digital assets have been promulgated; the only operational rules are the Securities (Licensing) Rules and related instruments, which are general in nature. Printing - The Laws of the Republic of Zambia
The Zambian government has a digital transformation agenda promoted through ZamPortal, which consolidates public e-services, but this portal contains no crypto-specific regulatory services or licensing pathways for digital asset businesses. ZamPortal
The Zambia Qualifications Authority (ZAQA) manages the National Qualifications Framework for educational certificates, not financial regulation, confirming that no specialized body has been assigned crypto oversight outside the SEC and BoZ. ZAQA Qualification Verification Portal
The Act requires applicants for a securities license to submit a formal application to the SEC, including constitutional documents, business plan, details of directors and key personnel, and evidence of compliance with fit-and-proper requirements; the SEC has discretion to grant or refuse a license. Printing - The Laws of the Republic of Zambia
Capital requirements under the Securities Act are set by the SEC in subsidiary rules; however, there are no capital thresholds published for crypto-related activities because no crypto license exists. Printing - The Laws of the Republic of Zambia
Applicants must be incorporated in Zambia or registered as a foreign company under the Companies Act, and must have a physical place of business in Zambia to be eligible for a securities license under the Securities Act. Printing - The Laws of the Republic of Zambia
The Securities Act requires that a licensed securities exchange must have governance structures, surveillance mechanisms, and clearing/settlement arrangements approved by the SEC; digital asset exchanges cannot meet these requirements without a regulatory determination that their tokens are "securities." Printing - The Laws of the Republic of Zambia
The Securities Act prohibits any person from operating an unlicensed securities business, with penalties including fines and imprisonment; this means a crypto exchange dealing in tokenized securities without a license would face criminal sanctions. Printing - The Laws of the Republic of Zambia
Zero entities have been licensed to conduct crypto asset activities in Zambia; no press releases, gazette notices, or SEC announcements indicate any existing license for a digital asset exchange, broker, or custodian. Printing - The Laws of the Republic of Zambia
Licensed brokers and dealers under the Securities Act must conduct customer due diligence (CDD) on their clients, including verifying identity, understanding the nature of transactions, and assessing the source of funds, in line with the Financial Intelligence Centre Act of Zambia. Printing - The Laws of the Republic of Zambia
The Securities Act requires licensees to report suspicious transactions to the Financial Intelligence Centre (FIC) and to maintain transaction records for a minimum period, but the Act does not specify the exact retention duration, which is left to the FIC Act and its regulations. Printing - The Laws of the Republic of Zambia
Enhanced due diligence (EDD) is required for politically exposed persons (PEPs) and high-risk customers under Zambia's AML framework, and the Securities Act obliges licensees to apply these standards in their securities dealings. Printing - The Laws of the Republic of Zambia
Beneficial ownership identification is mandatory for corporate clients under the Companies Act and the AML framework; securities licensees must identify ultimate beneficial owners of client entities before transacting. Printing - The Laws of the Republic of Zambia
The Securities Act empowers the SEC to inspect licensees' records and demand the production of documents for AML compliance reviews, and violations can lead to license suspension or revocation. Printing - The Laws of the Republic of Zambia
Record retention under the Securities Act requires licensees to keep all client transaction records, communications, and identification documents for a period set by the SEC, which is generally five years under Zambian practice, but no crypto-specific rule exists. Printing - The Laws of the Republic of Zambia
The Securities Act authorizes the SEC to investigate suspected violations, impose administrative fines, and prosecute offenders in court, but there is no public record on the SEC's website of any enforcement action taken against a cryptocurrency or digital asset entity. Printing - The Laws of the Republic of Zambia
The Bank of Zambia has issued public warnings against the use of cryptocurrencies, but the central bank does not have enforcement powers over securities firms, and no penalty has been reported against crypto businesses by the SEC. Printing - The Laws of the Republic of Zambia
Under the Securities Act, persons operating an unlicensed securities business are liable on conviction to a fine or imprisonment, or both; however, no such prosecution of any crypto entity has been publicly documented. Printing - The Laws of the Republic of Zambia
The Securities Act allows the SEC to seek court orders to restrain unlawful activities, freeze assets, and appoint receivers, but these powers have not been deployed against any digital asset business in Zambia as of 2025. Printing - The Laws of the Republic of Zambia
No fines, penalties, or administrative sanctions have been imposed by the SEC on any entity for crypto-related securities violations, since no crypto business has been formally classified as a securities entity under the Act. Printing - The Laws of the Republic of Zambia
The Zambia Revenue Authority (ZRA) administers the Income Tax Act and Value Added Tax Act, but neither of these statutes nor any administrative guidance from ZRA addresses cryptocurrency, digital assets, or tokenized securities as of 2025–2026. Printing - The Laws of the Republic of Zambia
Under the Income Tax Act, gains from the sale of "securities" as defined in the Securities Act could theoretically be taxed as income or capital gains, but since crypto is not classified as a security, no tax treatment is determinable. Printing - The Laws of the Republic of Zambia
No tax guidance has been issued for virtual assets; consequently, crypto businesses and individuals in Zambia have no legal certainty on how to file or pay taxes on digital asset transactions. Printing - The Laws of the Republic of Zambia
The absence of a legal definition for "cryptocurrency," "digital asset," or "virtual asset" in the Securities Act creates interpretive uncertainty; a crypto token could be deemed a "security" only through case-by-case SEC determination, but no guidance or safe harbor has been published. Printing - The Laws of the Republic of Zambia
There is no registration or licensing pathway for crypto exchanges, custodians, or wallet providers unless they choose to be regulated as securities intermediaries, which most crypto businesses cannot do because their offerings do not clearly qualify as "securities." Printing - The Laws of the Republic of Zambia
Cross-border crypto businesses face significant risk: the Securities Act applies extraterritorially to activities targeting Zambian residents, meaning an offshore crypto exchange offering tokens to Zambians could be deemed to be carrying on unlicensed securities business without any clear legal test. Printing - The Laws of the Republic of Zambia
Zambia's AML framework does not yet include virtual asset service providers (VASPs) as "obliged entities," meaning crypto businesses are not required to submit suspicious transaction reports, but they also do not have legal recognition to operate safely; this gap aligns with FATF's observation of Zambia's partial compliance with Recommendation 15. Printing - The Laws of the Republic of Zambia
The practical reality is that crypto businesses in Zambia operate on a "no objection" basis—no one has been shut down, but no one has been licensed, creating chilling effects on legitimate innovation and opening the door to fraudulent schemes with no regulator jurisdiction. Printing - The Laws of the Republic of Zambia
The SEC has not issued any guidance, no-action letters, or public statements on digital assets, leaving market participants without predictability; in contrast, the regulator's silence is itself a major compliance risk for any entity contemplating a Zambian crypto venture. Printing - The Laws of the Republic of Zambia
The Securities Act's penalties for unlicensed activity include criminal liability for directors and officers personally, meaning individuals involved in a crypto business that is later classified as a securities business face personal fines and imprisonment. Printing - The Laws of the Republic of Zambia
The Securities Act does not address insolvency of crypto intermediaries, market manipulation in digital asset trading, or disclosure requirements for token issuers, leaving major gaps that no other Zambian law fills. Printing - The Laws of the Republic of Zambia
Unlike countries that have enacted bespoke crypto legislation, Zambia's failure to amend the Securities Act or pass new legislation means the country is falling behind regional peers, and businesses face higher legal risk in Zambia than in jurisdictions with clear frameworks. Printing - The Laws of the Republic of Zambia
Printing - The Laws of the Republic of Zambia
Sanctions & Restrictions
Sanctions data collection in progress.
Enforcement Actions
Entity Targeted: General public and unregulated entities. Violation Type: Engaging in unregulated financial activities, potential for fraud, money laundering, and lack of consumer protection. Not recognizing virtual assets as legal tender. Penalty Amount: Not applicable (as these are warnings, not specific fines).
Date: Ongoing, with multiple statements issued over the years. A significant recent statement was in May 2022.
Outcome: Public awareness campaigns, repeated advisories that virtual assets are not legal tender, and that individuals engage with them at their own risk. The BoZ has emphasized that virtual assets are not regulated in Zambia and has warned against the risks involved, including fraud, price volatility, and lack of consumer protection. They have also indicated that they are exploring the possibility of a Central Bank Digital Currency (CBDC).
Bank of Zambia Statement on Virtual Assets (May 2022): https://www.boz.zm/media/media_releases/2022/STATEMENT%20ON%20VIRTUAL%20ASSETS.pdf
Note: This is a policy statement and warning, not an enforcement action against a specific entity.
Regulator Name: Financial Intelligence Centre (FIC) Zambia
Entity Targeted: General public, financial institutions (regarding their reporting obligations). Violation Type: Potential for money laundering and terrorist financing using virtual assets. Penalty Amount: Not applicable (as these are general advisories/reports).
Date: FIC annual reports consistently highlight emerging trends in financial crime, which often include the use of virtual assets as a medium, though not usually specific enforcement actions against crypto entities themselves.
Outcome: Increased awareness among reporting entities and the public about the risks of financial crimes, including those facilitated by virtual assets. FIC focuses on intelligence gathering and dissemination to aid law enforcement.
FIC Zambia Website (for Annual Reports): https://www.fic.gov.zm/
Note: FIC reports cover broader financial crime trends, and while virtual assets may be mentioned as a method, specific regulatory enforcement actions against crypto businesses are not typically the focus of these public reports.
Caution and Warnings: The Bank of Zambia consistently advises against the use of cryptocurrencies due to risks and their unregulated status.
No Legal Tender Status: Cryptocurrencies are explicitly not recognized as legal tender in Zambia.
Focus on Monitoring: Regulators are monitoring global developments and exploring potential frameworks, including a CBDC.
General Fraud vs. Regulatory Enforcement: While there might be instances of law enforcement (police) dealing with fraud cases where cryptocurrencies were used, these are distinct from regulatory enforcement actions by financial regulators against crypto businesses for operating without a license or violating financial laws.
Research & Articles
Regulatory Forecast
high confidenceLikely enforcement action expected around 2026-04-22
Based on 53 historical regulatory events for Zambia, with increasing regulatory activity.
Recent Updates
Bank of Zambia's Fintech Regulatory Sandbox and Virtual Assets Framework: In recent years, the Bank of Zambia has...
Bank of Zambia's Fintech Regulatory Sandbox and Virtual Assets Framework: In recent years, the Bank of Zambia has indicated its intention to develop a comprehensive framework for virtual assets. This includes exploring the possibility of a regulatory sandbox for fintech innovations, which could eventually lead to specific regulations for digital asset service providers, including custodians.
Bank of Zambia Official Statements/Reports: While a specific law isn't out yet, the BoZ has publicly stated its...
Bank of Zambia Official Statements/Reports: While a specific law isn't out yet, the BoZ has publicly stated its intentions to regulate virtual assets. These statements often appear in their annual reports, monetary policy statements, or press releases.
Outcome: Public awareness campaigns, repeated advisories that virtual assets are not legal tender, and that indiv...
Outcome: Public awareness campaigns, repeated advisories that virtual assets are not legal tender, and that individuals engage with them at their own risk. The BoZ has emphasized that virtual assets are not regulated in Zambia and has warned against the risks involved, including fraud, price volatility, and lack of consumer protection. They have also indicated that they are exploring the possibility of a Central Bank Digital Currency (CBDC).
Caution and Warnings: The Bank of Zambia consistently advises against the use of cryptocurrencies due to risks an...
Caution and Warnings: The Bank of Zambia consistently advises against the use of cryptocurrencies due to risks and their unregulated status.
No Explicit Classification: The Bank of Zambia has not explicitly classified stablecoins as e-money, payment toke...
No Explicit Classification: The Bank of Zambia has not explicitly classified stablecoins as e-money, payment tokens, or securities under a specific stablecoin regulation.
Bank of Zambia (BoZ) Act, 1996 (as amended): This act establishes the BoZ's mandate as the central bank, includin...
Bank of Zambia (BoZ) Act, 1996 (as amended): This act establishes the BoZ's mandate as the central bank, including currency issuance and monetary policy.
No Specific Stablecoin Issuer Licensing: There is no dedicated licensing regime specifically for stablecoin issuers.
No Specific Stablecoin Issuer Licensing: There is no dedicated licensing regime specifically for stablecoin issuers.
Potential for Existing Licensing: If an entity issuing a stablecoin were deemed to be operating as a Payment Serv...
Potential for Existing Licensing: If an entity issuing a stablecoin were deemed to be operating as a Payment Service Provider (PSP) under the National Payment Systems Act or engaging in banking/financial services under the Banking and Financial Services Act, they would be required to obtain the relevant licenses from the Bank of Zambia.
BoZ's General Stance: The Bank of Zambia is generally cautious about instruments with high volatility and opacity...
BoZ's General Stance: The Bank of Zambia is generally cautious about instruments with high volatility and opacity. Algorithmic stablecoins, known for their inherent risks and often complex mechanisms, would likely face significant scrutiny if they were to gain traction in Zambia, and could be subject to more restrictive measures or outright prohibitions in any future regulatory framework.
Active CBDC Exploration: Zambia is actively exploring the feasibility of introducing a Central Bank Digital Curre...
Active CBDC Exploration: Zambia is actively exploring the feasibility of introducing a Central Bank Digital Currency (CBDC). The Bank of Zambia has been conducting a feasibility assessment.
Bank of Zambia Statements on CBDC: News articles and official BoZ press releases have covered this topic.
Bank of Zambia Statements on CBDC: News articles and official BoZ press releases have covered this topic.
Unregulated, but Not Banned: Crypto trading and the operation of crypto exchanges in Zambia are not explicitly ...
Unregulated, but Not Banned: Crypto trading and the operation of crypto exchanges in Zambia are not explicitly illegal, but they are also not officially regulated or licensed by any specific framework for virtual assets. This places them in a "grey area."
No Licensed Exchanges: There are no crypto exchanges or virtual asset service providers (VASPs) specifically lice...
No Licensed Exchanges: There are no crypto exchanges or virtual asset service providers (VASPs) specifically licensed or authorized by the BoZ or SEC to operate as such under a virtual asset regulatory framework. Exchanges operating within Zambia are doing so without specific crypto licenses, generally falling under broader business registration laws.
The Bank of Zambia (BoZ) has consistently issued advisories, such as the one in September 2021, warning the public ab...
The Bank of Zambia (BoZ) has consistently issued advisories, such as the one in September 2021, warning the public about the risks associated with trading, investing, or transacting in cryptocurrencies. These advisories focus on consumer protection, financial stability, and anti-money laundering concerns, rather than tax specifics.
Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010: This is Zambia's principal AML/CFT legisla...
Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010: This is Zambia's principal AML/CFT legislation. While it is the foundational law, it does not specifically address virtual assets or VASPs. Finding an official, up-to-date government-published link can be challenging, but it forms the basis of the Financial Intelligence Centre's (FIC) operations.
Bank of Zambia (BoZ): The central bank has issued advisories warning the public about the risks associated with c...
Bank of Zambia (BoZ): The central bank has issued advisories warning the public about the risks associated with cryptocurrencies due to their unregulated nature. This indicates a cautious approach rather than active regulation.
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