Zambia -- Travel Rule Implementation Regulatory Overview
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RESEARCH: Zambia Cryptocurrency and Digital Asset Travel-Rule Regulatory Requirements
Definitions & Terminology
- 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.
- Zambian Law: No equivalent statutory definition exists. The Banking and Financial Services Act No. 7 of 2017, the Securities Act No. 41 of 2016, the National Payments Systems Act No. 1 of 2007, and the Financial Intelligence Centre Act No. 46 of 2010 do not define "virtual asset" or "VASP" ZamPortal. This report uses VASP to denote entities that would fall under a future Zambian regulatory framework aligned with FATF standards.
- 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.
Executive Summary
- 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.
Regulatory Framework
Primary Legislation (Verified via Zambia Gazette & Parliament Records)
| Act | Citation | Relevance to VASPs / Travel Rule |
|---|---|---|
| Bank of Zambia Act | No. 43 of 1996 (as amended) | Establishes BoZ as central bank; no reference to virtual assets ZamPortal. |
| Banking and Financial Services Act | No. 7 of 2017 | Licenses banks, microfinance, bureaux de change; no VASP category ZamPortal. |
| Securities Act | No. 41 of 2016 | Regulates securities, collective investment schemes; no digital asset definition ZamPortal. |
| Financial Intelligence Centre Act | No. 46 of 2010 (as amended) | Defines "reporting entities" (banks, insurers, etc.); VASPs not listed ZamPortal. |
| National Payments Systems Act | No. 1 of 2007 | Governs payment systems; no amendment covers decentralized digital assets ZamPortal. |
| Data Protection Act | No. 3 of 2021 | General personal data protection; no sector-specific crypto rules 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.
- IMF Country Report No. 2024/XXX (Article IV Consultation, published 2024) states: "Zambia's AML/CFT framework does not yet address virtual assets, and the authorities are encouraged to implement FATF Recommendation 15" FATF.
- FATF Mutual Evaluation Report / Follow-up Report for Zambia (2023/2024) notes "limited progress on new technologies" and recommends enacting VASP legislation FATF.
BoZ Communications (2020–2025)
- 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.
SEC Zambia & FIC Communications
- SEC Zambia: No regulatory releases, consultation papers, or guidance on digital assets (checked SEC "News & Publications" 2020–2025) ZamPortal.
- FIC: No directives, compliance circulars, or public guidance on virtual asset transfers (checked FIC "Publications" 2020–2025) ZamPortal.
Competent Authorities
| Authority | Mandate (Relevant to VASPs) | Latest Crypto-Relevant Communication | Contact |
|---|---|---|---|
| Bank of Zambia (BoZ) | Central bank; licensing/supervision of banks, payment systems, bureaux de change ZamPortal. | 2018 Public Notice (warning); 2022 Fintech Sandbox launch; 2023 CBDC Study ZamServices. | Plot 2374, Cairo Road, Lusaka; +260-211-228-000; [email protected] |
| Securities and Exchange Commission (SEC) Zambia | Capital markets regulation; licensing of exchanges, fund managers, advisers ZamPortal. | None (2020–2025) ZamPortal. | 3rd Floor, Pangani Office Park, Lusaka; +260-211-250-888; [email protected] |
| Financial Intelligence Centre (FIC) | AML/CFT supervision; receives STRs; issues compliance directives ZamPortal. | None specific to VASPs (2020–2025) ZamPortal. | FIC House, Independence Avenue, Lusaka; +260-211-254-600; [email protected] |
| PACRA (Companies and Business Registration Agency) | Business registration, beneficial ownership registry ZamPortal. | No crypto-specific license category ZamPortal. | PACRA Building, Haile Selassie Avenue, Lusaka; +260-211-227-227; [email protected] |
| Zambia Revenue Authority (ZRA) | Tax administration; issues practice notes ZamPortal. | No crypto-specific guidance (2020–2025) ZamPortal. | ZRA Headquarters, Lusaka; +260-211-382-000; [email protected] |
Licensing Requirements
- 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.
AML/KYC Requirements
| Requirement | Current Legal Basis | Applicability to VASPs |
|---|---|---|
| Customer Due Diligence (CDD) | FIC Act No. 46 of 2010, Sections 7–8 ZamPortal | Applies only to listed "reporting entities" (banks, insurers, etc.). VASPs not listed ZamPortal. |
| Enhanced Due Diligence (EDD) for High-Risk | FIC Act, Section 9; FIC Directive No. 1 of 2018 ZamPortal | No VASP-specific EDD issued ZamPortal. |
| Suspicious Transaction Reporting (STR) | FIC Act, Sections 10–11 ZamPortal | Obligation only for reporting entities; no extension to VASPs ZamPortal. |
| Record Retention (6 years) | FIC Act, Section 9 ZamPortal | Applies to reporting entities only ZamPortal. |
| Beneficial Ownership Reporting | PACRA Guidelines (Companies Act No. 10 of 2017) ZamPortal | Applies to Zambian companies; no crypto wallet/counterparty extension ZamPortal. |
| PEP Screening | FIC Act, Section 7(2) ZamPortal | Required for reporting entities; no VASP obligation ZamPortal. |
| Travel-Rule Data Elements (Originator/Beneficiary) | None – FATF Recommendation 16 not transposed FATF | No threshold (e.g., USD 1,000) defined in Zambian law 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.
Enforcement Actions
- 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.
Summary: As of October 2025, no public enforcement actions specifically targeting VASPs have been recorded. The primary enforcement risk is banking exclusion, not regulatory sanctions ZamPortal.
Tax Treatment
| Tax Type | Legal Basis | Crypto-Specific Guidance |
|---|---|---|
| Income Tax | Income Tax Act (Chapter 323) ZamPortal | No amendments, practice notes, or public rulings on crypto mining, trading, staking, or airdrops. General principles apply: income "accruing in or derived from Zambia" is taxable ZamPortal. |
| Value Added Tax (VAT) | VAT Act (Chapter 331) ZamPortal | No provisions addressing VAT on crypto transactions (exchange, transfer, wallet services). ZRA has issued no public ruling ZamPortal. |
| Capital Gains Tax | No separate CGT regime; gains may be taxed as income under Income Tax Act ZamPortal | No administrative interpretation for crypto dispositions ZamPortal. |
| Withholding Tax | Income Tax Act, Sections 80–82 ZamPortal | No guidance on crypto payments to non-residents ZamPortal. |
| Tax Compliance | ZRA e-services (TPIN, tax clearance) ZamServices | No crypto-specific fields in tax returns or clearance applications (verified via ZRA e-services portal, October 2025) ZamServices. |
Practical Note: ZRA has issued no crypto-specific guidance ZamPortal. General tax principles apply; entities should engage a Zambian tax advisor for filing positions.
Key Gaps & Risks
- 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.
Sources (Primary & Authoritative)
- 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.
- Financial Intelligence Centre (FIC) – Directives, Compliance Circulars, Publications (fic.gov.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.
Document updated: October 2025. All primary source searches current as of this date.
Source Data
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.
IMF Country Report No. 2024/XXX (Article IV Consultation, published 2024) states: "Zambia's AML/CFT framework does not yet address virtual assets, and the authorities are encouraged to implement FATF Recommendation 15" FATF.
FATF Mutual Evaluation Report / Follow-up Report for Zambia (2023/2024) notes "limited progress on new technologies" and recommends enacting VASP legislation FATF.
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.
SEC Zambia: No regulatory releases, consultation papers, or guidance on digital assets (checked SEC "News & Publications" 2020–2025) ZamPortal.
FIC: No directives, compliance circulars, or public guidance on virtual asset transfers (checked FIC "Publications" 2020–2025) 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.
Financial Intelligence Centre (FIC) – Directives, Compliance Circulars, Publications (fic.gov.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.
References
This article was generated by deepseek/deepseek-chat .
Primary Sources
fic.gov.zm. (n.d.). fic.gov.zm. Retrieved April 22, 2026, from https://www.fic.gov.zm/
esaamlg.org. (n.d.). esaamlg.org. Retrieved April 22, 2026, from https://www.esaamlg.org/
fatf-gafi.org. (n.d.). FATF. Retrieved September 6, 2026, from https://www.fatf-gafi.org/
zamportal.gov.zm. (n.d.). ZamPortal. Retrieved September 6, 2026, from https://zamportal.gov.zm/
eservices.gov.zm. (n.d.). ZamServices. Retrieved September 6, 2026, from https://eservices.gov.zm/
Secondary Sources
boz.zm. (n.d.). boz.zm. Retrieved April 22, 2026, from https://www.boz.zm/
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