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Guinea-Bissau

Retail_Trading_Status

Allowed-Unregulated Unknown
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Analysis ID
#130
Version
Archived
Created
2025-04-12 06:48
Workflow Stage
Live

Executive Summary

In Guinea-Bissau, cryptocurrency trading is de facto allowed but remains unregulated, as neither the country nor the BCEAO/WAEMU has implemented specific legislation. The BCEAO maintains a cautious stance, warning against the risks of cryptocurrencies. There are no specific AML/KYC regulations tailored for cryptocurrency platforms, and despite the lack of legal framework, some online exchanges are accessible. The government distinguishes between cryptocurrency and blockchain technology, exploring the latter for administrative uses without endorsing crypto trading.

Key Pillars

  • Primary regulator: The Central Bank of West African States (BCEAO), which oversees the WAEMU region, including Guinea-Bissau.
  • Regulatory approach: Cryptocurrencies are not explicitly prohibited but operate in an unregulated environment. The BCEAO has a negative stance due to perceived risks.
  • Core compliance: There are no specific KYC/AML regulations for cryptocurrency platforms targeting Guinea-Bissau residents. General AML/CFT laws exist, but their applicability to crypto assets is unclear.
  • Licensing: There are no specific licensing or registration requirements for Virtual Asset Service Providers (VASPs) operating in Guinea-Bissau.

Landmark Laws

  • Law no.3/2018: General AML/CFT law in Guinea-Bissau; however, its specific application and enforcement concerning crypto-asset transactions are unclear.

Considerations

  • Cryptocurrencies are not recognized as legal tender within the WAEMU zone.
  • The BCEAO has issued warnings regarding the risks of cryptocurrency investments, including high volatility and fraud.
  • There is a lack of specific legal protections or recourse for cryptocurrency investors.
  • General AML/CFT laws exist (e.g., Law no.3/2018), but their direct application to crypto assets is unclear.
  • The government distinguishes between blockchain technology and cryptocurrencies.

Notes

  • A 2018 FATF report noted that VASPs did not officially exist in Guinea-Bissau at that time, though some online exchanges might be accessible.
  • The government is exploring blockchain technology for specific administrative purposes, such as improving transparency in public wage management.
  • The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies due to concerns about accountability and responsibility.
  • The status is described as Allowed-UnRegulated because cryptocurrency activity is possible without specific legal backing, regulatory oversight, or consumer protection measures.

Detailed Explanation

Guinea-Bissau, as part of the West African Economic and Monetary Union (WAEMU), is subject to the regulatory oversight of the Central Bank of West African States (BCEAO). As of the latest reports, neither Guinea-Bissau nor the BCEAO has established specific laws or regulatory frameworks that directly govern the buying, selling, or holding of cryptocurrencies by retail individuals. Cryptocurrencies are not recognized as legal tender within the WAEMU zone. The absence of explicit prohibition allows individuals to engage in cryptocurrency transactions, typically through international online platforms accessible from Guinea-Bissau. However, this allowance occurs within a completely unregulated environment. The BCEAO has expressed a negative stance towards cryptocurrencies. The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies due to concerns about accountability, responsibility, and underlying guarantees. The BCEAO has issued public warnings within the WAEMU region, highlighting risks like high volatility, fraud potential, and the lack of legal protection for investors.

Currently, there are no specific Know Your Customer (KYC) or Anti-Money Laundering (AML) regulations imposed directly on cryptocurrency platforms operating for Guinea-Bissau residents. While Guinea-Bissau has general AML/CFT laws, such as Law no.3/2018, and is subject to regional AML frameworks, the direct application and enforcement of these laws concerning crypto-asset transactions and Virtual Asset Service Providers (VASPs) remain unclear. A 2018 FATF report indicated that VASPs did not officially exist in the country at that time, although some online exchanges might be accessible. It's crucial to distinguish the government's interest in blockchain technology for administrative purposes, such as improving transparency in public wage management, from its stance on cryptocurrencies as financial assets or payment instruments. Exploring blockchain for governance does not imply endorsement or regulation of cryptocurrency trading.

According to a UPay Blog report from 2024-11-25, Guinea-Bissau continues to assess the risks and benefits of digital currencies. An article in Linfodrome on 2025-03-07, quoting the governor of the BCEAO, reiterated the central bank's opposition to cryptocurrencies due to a lack of responsibility and security. BNN Breaking reported on 2023-12-09 that the BCEAO has issued warnings to the public about the risks associated with investing in cryptocurrencies, emphasizing the lack of legal protection and inherent risks. Harris Bricken Sliwoski LLP noted on 2023-12-06 that the lack of specific laws meant trading and investment in cryptocurrencies in Guinea-Bissau were not illegal, but this unregulated environment brought potential risks such as fraud and scams. Chambers and Partners noted on 2024-12-10, regarding the WAEMU banking regulation context, that cryptocurrency activities are not explicitly authorized in Senegal and banks are not authorized to carry them out. The World Bank reported that the BCEAO has not yet issued regulations regarding crypto assets.

In conclusion, while retail cryptocurrency trading is not explicitly banned in Guinea-Bissau, it operates in a regulatory vacuum. The central bank strongly discourages participation due to inherent risks, and there are no specific legal protections, oversight mechanisms, or tailored AML/KYC requirements for this sector. The FATF/GIABA Mutual Evaluation Report from 2018-10-05 stated that VASPs did not exist in Guinea Bissau and that no entity had been licensed in the country to operate as VASPs. The report also indicated that some cryptocurrency exchanges were operating in Guinea Bissau. Therefore, the status is best described as Allowed-UnRegulated, signifying that the activity is possible but occurs without specific legal backing, regulatory oversight, or consumer protection measures from national or regional authorities.

Summary Points

Here's a bullet-point summary of the regulatory analysis report on Retail_Trading_Status (Cryptocurrency) in Guinea-Bissau, designed for quick comprehension:

I. Overall Regulatory Status:

  • Allowed-UnRegulated: Retail cryptocurrency trading is de facto allowed but operates in a completely unregulated environment.

II. Key Regulatory Bodies and Roles:

  • Central Bank of West African States (BCEAO):
    • The primary regulatory body due to Guinea-Bissau's membership in the West African Economic and Monetary Union (WAEMU).
    • Has not implemented specific legislation for cryptocurrency.
    • Maintains a cautious and generally negative stance towards cryptocurrencies.
    • Has issued public warnings about the risks of cryptocurrency investments.
  • WAEMU (West African Economic and Monetary Union):
    • No specific legislation or dedicated regulatory framework governing cryptocurrencies.
    • Cryptocurrencies are not recognized as legal tender within the WAEMU zone.
  • Government of Guinea-Bissau:
    • No specific regulatory framework governing cryptocurrencies.
    • Exploring blockchain technology for administrative purposes (e.g., public wage management), but this does not equate to cryptocurrency regulation.

III. Important Legislation and Regulations:

  • Absence of Specific Crypto Legislation: There are no specific laws regulating cryptocurrency trading or Virtual Asset Service Providers (VASPs).
  • General AML/CFT Laws: Guinea-Bissau has general Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) laws (e.g., Law no.3/2018), but their direct application to crypto-asset transactions is unclear.

IV. Requirements for Compliance:

  • No Specific KYC/AML for Crypto Platforms: There are no specific Know Your Customer (KYC) or Anti-Money Laundering (AML) regulations imposed directly on cryptocurrency platforms concerning Guinea-Bissau residents.
  • General AML/CFT Compliance: While specific crypto regulations are absent, general AML/CFT laws may apply, though enforcement is unclear.

V. Notable Restrictions or Limitations:

  • Lack of Legal Protection: Investors have no specific legal protection or recourse in case of fraud or losses.
  • BCEAO Warnings: The BCEAO strongly discourages participation due to inherent risks (volatility, fraud).
  • No Regulatory Oversight: Cryptocurrency trading occurs without specific legal backing or regulatory oversight from national or regional authorities.
  • Cryptocurrencies Not Legal Tender: Cryptocurrencies are not recognized as legal tender within the WAEMU zone.

VI. Recent Developments or Changes:

  • Continued Absence of Regulation: As of late 2024/early 2025, no specific cryptocurrency regulations have been implemented.
  • BCEAO's Negative Stance: The BCEAO Governor has reiterated the central bank's opposition to cryptocurrencies due to concerns about accountability and security.
  • FATF Findings (2018): A 2018 FATF report noted that VASPs did not officially exist in the country at that time, though some online exchanges might be accessible.

Full Analysis Report

Financial Regulatory Analyst Report: Guinea-Bissau

Topic: Retail_Trading_Status (Cryptocurrency)

1. Current Status: Allowed-UnRegulated

2. Detailed Narrative Explanation:

Guinea-Bissau, as a member state of the West African Economic and Monetary Union (WAEMU, also known by its French acronym UEMOA), falls under the purview of the Central Bank of West African States (BCEAO). Currently, neither Guinea-Bissau nor the BCEAO/WAEMU has implemented specific legislation or a dedicated regulatory framework governing the buying, selling, or holding of cryptocurrencies by retail individuals [2, 5, 8, 11]. Cryptocurrencies are not recognized as legal tender within the WAEMU zone [2, 7].

The absence of explicit prohibition means that engaging in cryptocurrency transactions is not technically illegal for individual citizens and residents in Guinea-Bissau [6]. Individuals are generally free to participate in the cryptocurrency market, often through international online platforms, some of which appear accessible from Guinea-Bissau [16, 23, 28].

However, this de facto allowance exists within a completely unregulated environment. The BCEAO maintains a highly cautious, if not outright negative, stance towards cryptocurrencies. The Governor of the BCEAO has publicly stated the central bank is "against" cryptocurrencies, citing concerns over the lack of accountability, responsibility, and underlying guarantees associated with these virtual assets [3]. The BCEAO has issued warnings to the public within the WAEMU region, highlighting the significant risks involved in cryptocurrency investments, such as high volatility, the potential for fraud, and the lack of legal protection or recourse for investors [5, 8, 10, 11].

There are no specific Know Your Customer (KYC) or Anti-Money Laundering (AML) regulations imposed directly on cryptocurrency platforms specifically concerning their operations for Guinea-Bissau residents. While Guinea-Bissau has general AML/CFT laws (e.g., Law no.3/2018) and is subject to regional AML frameworks [17], their direct application and enforcement concerning crypto-asset transactions and Virtual Asset Service Providers (VASPs) remain unclear due to the lack of specific crypto regulation. A 2018 FATF report noted that VASPs did not officially exist in the country at that time, though some online exchanges might be accessible [17].

It is important to distinguish the government's interest in blockchain technology for specific administrative purposes (such as improving transparency in public wage management [5, 32]) from its stance on cryptocurrencies as financial assets or payment instruments. The exploration of blockchain for governance does not equate to an endorsement or regulation of cryptocurrency trading.

In summary, while retail cryptocurrency trading is not explicitly banned in Guinea-Bissau, it operates in a regulatory vacuum. The central bank strongly discourages participation due to inherent risks, and there are no specific legal protections, oversight mechanisms, or tailored AML/KYC requirements for this sector. Therefore, the status is best described as Allowed-UnRegulated, signifying that the activity is possible but occurs without specific legal backing, regulatory oversight, or consumer protection measures from national or regional authorities.

3. Specific Relevant Text Excerpts:

  • On the lack of specific regulation: "Guinea-Bissau does not have a specific regulatory framework governing cryptocurrencies, as the country still assesses digital currencies' risks and benefits." (Source: UPay Blog, 2024-11-25) [5]
  • On the BCEAO's stance: "'Cryptocurrency, as a Central Bank, we are against it,' hammered the governor of the BCEAO... explaining that the BCEAO is against this virtual currency 'because it is not a currency that has responsibility somewhere.' 'Nobody is responsible,' he insisted... indicating that 'nobody masters' it, the governor of the BCEAO pointed out that a currency must respect principles related to responsibility and security." (Source: Linfodrome, 2025-03-07, translated from French) [3]
  • On BCEAO warnings: "The BCEAO has issued warnings to the public about the risks associated with investing in cryptocurrencies, emphasizing the lack of legal protection and the inherent risks of such investments." (Source: BNN Breaking, 2023-12-09) [8]
  • On legality vs. regulation: "Due to the lack of specific laws, trading and investment in cryptocurrencies in Guinea-Bissau were not illegal. Individuals in the country were free to buy, sell, and trade various digital currencies. However, this unregulated environment brought potential risks such as fraud and scams." (Source: Harris Bricken Sliwoski LLP, 2023-12-06) [6]
  • On the WAEMU regional context: "However, cryptocurrency activities are not yet explicitly authorised in Senegal [a WAEMU member], and banks are not authorised to carry them out. Nor is there currently any legislation governing cryptocurrency activities in Senegal." (Source: Chambers and Partners, 2024-12-10, referring to WAEMU banking regulation context) [4]
  • On WAEMU/BCEAO lack of crypto regulation: "The central bank [BCEAO] has however not yet issued a regulation regarding crypto assets..." (Source: World Bank Documents and Reports, discussing WAEMU) [9]
  • On FATF findings regarding VASPs: "VASPs do not exist in Guinea Bissau. The BCEAO stated that no entity has been licensed in the country to operate as VASPs... Although VASPs do not officially exist in the country... a check by the team on the internet... indicates that there are some few cryptocurrency exchanges operating in Guinea Bissau." (Source: FATF/GIABA Mutual Evaluation Report, 2018-10-05) [17]

4. Direct Source URL Links:

  • [2] Cryptocurrency Regulation Tracker | Kaimakliotis & Co: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALQIp9FgeZMu6r7cDZTMP2aKfldnZMvmaPEe6ppGJkU0MoqwvDZ9AFb5jAOWP3Gbq8xj-f6wkhALs_wqvYvFVGnDMyDNe9T7bfxbd1G-g2zX1PC_UkkjDQscL5nQg_aElUdrW9Kkoi70S3YVg6ZaNfS (Note: Source provides a high-level status, potentially dated or simplified)
  • [3] Linfodrome - Économie sous-régionale : Pourquoi la cryptomonnaie fait peur: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJjs6qjNPZNNgPDv38yxP3frVd7Dv16s57NsChXD9Z56gwWUKSfK_ZnwgnXldgn_2PidWddTkyA7GC-inXJixYWPxsMwmM-nO4qaNz51s8Ae2VSzv_J1IcRE0KYE-pIZYJ9SVqdCgyP0ucJ05iIVa0-m1C6OL7OsWjzMdCdM_8t_tWxRUEIzonF_7Csg6jB3spQLs5LkYIs82I-IwgyhiSWZw8=
  • [4] Chambers and Partners - Banking Regulation 2025 (Senegal/WAEMU context): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALjqsS6C34CWpIKseMrVJKybjw-87LsSECaMe6EueaZYgZmGVg8LwOa4uSfZjIA5iJv3TjB1YJtU1QBHweoBsUNjkI80iQycXMlIU9RM1vmEdavPiLIUc0u4CmtQP3yi6554ZyOVBbk6X9XmmhBH9RcS2yi41_hVbVUri0w9sl2dOCY0pJOm1oWEIZXxeLc2Z4eIT9cWwxxH_Uc3NBMCtsdHm37qtRvZnQaTtgmTONaZVcz8gmnTW733OgK52unpEei3A==
  • [5] UPay Blog - Crypto Adoption Around the World: Guinea-Bissau: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIsRI2Pv1Y7jsgDNK9j8DeORM71z4xF_anHXKju2enP8Jh2hlVWETFv0shznUS5bH8zHqCSfb2XEyIaEjvNyFzn2T1RwzHUmdtmAEZ_NQmPr8zwq4DR5AauBsWSrqBat5wD8dYRXhFlebEHqA==
  • [6] Harris Bricken Sliwoski LLP - Guinea-Bissau's Cryptocurrency Legislative Landscape Prior to 2024: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAJlgGipOYV2yBi1vPwLDG_HSmjgeRyLgfDdWBjrxydeThGpkqdxxUXciOvNJYIOO2wXtiVUmWfyvTTnycTTp84PiyG_wOc2Ri3KIQZA2mHrM7xtx-1pE58wtlhVNwbNUVtNRqICAF_qEz2ruDHurl5PXWEnf-ubXSHjfdkDlFlZnxDUNen-SU78Od4tDojAkHMndBM=
  • [7] WTS Global - Togo: Exchange Control Insights (WAEMU context): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAK39XIagWcMczj50gAnYRPVBS3SJg8YKHUfTRDf-MZoDsouWQr3mY6fSPDS0OG8DA8VKZBtMquDLFU03Sdnght7AX7XnWYJbq_76gJXZ-U_nCrJvNbei6WQE4k-15bD7wv1RcKAoRqR05GQrYejZN_bL9eZQx3_rNz2_G3UhqmZrOBnW7OXRZvms_FgO5DhgLLuSId-skmc1lgE
  • [8] BNN Breaking - Cryptocurrency Regulatory Insights in Guinea-Bissau, 2024: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAI_v-4d8EQMGeuutHoobFAunLjO9sDSWV-MoQBajJvZv8YN_77iHPJiDhMCgirySCfUU2SgYKPgpwGXgV9ofPlyG9Sr2My7h576KzfuKK_Gmz4dRpgPfL2wk-mTZniklwlxk0WIoDau2GSLxpTU8jJRjQiHVTXupowIoPPk5rKB68X-ckclbG2WR4w=
  • [9] World Bank Documents and Reports - west african economic and monetary union (waemu): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIfOoMQZpPkETMwLiXUEh7mmAOnUGF7Lcz6g54kOhogqEQt2lhEpVEcYlWEJegVZS1kape9AhGBMl2ima-HWlC0zfq9QjTi6D0kGemVMdH7XN0bdfwHqF-WD5gHE7usWKaxdyaPeGteEk5J5TL8iBQD0wLsP9vSJTnxTM0wLOJTTcdbHW6PakqNNs2hE5V4WFYtpgvh9g1m-A9FSD970RPU
  • [10] Digital Frontiers Institute - Protection des consommateurs : les dangers d'investir... (UEMOA context): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAI47MtnEDphK9XG7PrvTpS_0gVekUWFJnzvPN-oMkfoZfff7CT9obg5_2SNRB1AIEsylAQ175VnOJWBsRxUQl8gluZl_GZU1sEWjdzl8gmpOlQO9wQU59W8XxnVnH8MIx9zGC8zg_czCITUxLaxZ1EgQ3Up7NdSI72_OLcUg3ZUvtHNRSt42ywPQhPien4aI893UAbppdtcRJpc8RrCnY73ur3WJxolcZtsliutCXuT3KP6jTbpjnbhl8S_R3TVWkaL0QGKKaZe4yReIa52egTIOeQmvAozo_79-Y_RK4ceGA==
  • [11] John W Ffooks & Co - Why Crypto Hasn't Taken Off In Francophone Africa Yet (UEMOA context): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAIC-NO7W-Wtvug1y5S64jwohciUoqBv45ONsl5iar2o6zJuG5Jrd4db5r_yA3YxgrioN28AddbTxuUsAlh0zNiHfr2quwxAw4FRCruBGvZlblClO7yjBedQ7ivCtE3bbPSWX_INupXS_bZaBJm0z1T_ctTTKyJERRcKSoggryNEf_RP5q14QMg3ZA==
  • [17] FATF/GIABA - Guinea Bissau Mutual Evaluation Report (October 2018): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqALDlLOtxyt4x2dCHzH4xdHBzkaxo3DLLRS90l-k8J8LGntXWLqf4AD8rN5nXQ04YISV686pKJiDQghtiNlTGsvCG0YrSj9Zmi-g28wMpAO_52p4aPVUd2jt-srPWgu88GRw3rlXbkJPIj8Fckz-MU4LaRGxxKImfGR86u052nMxzIQdLKCmOAu7eApvRtfuDk9dVcBv75FCHmjOgzyrl-M= (Note: Older report, but relevant for historical context on VASPs)
  • [32] IMF News - Guinea-Bissau is Using Blockchain to Boost Fiscal Transparency: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AWQVqAKYIW4kEV4WBaVtj3qDkwBynOz9R9hUPD8ox7m9UpaCZoqrMfW5uqCOn9IwMjLeckRaXWICfBpwK7lSjXvAgCTcnWJrjdNzPVhCrx-AMrNoBzIN3s-xlgtRD3W3kX1897RCMRdb7AAJkZDhmhRYTghUI8h67riKwiw9wGfjqNU5zbZnrkIALtWSu5oDsjNLw_eMLSA9iHuHUhOel9NSN0KsNbzoq0Ep-Q==

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