North Macedonia

Retail_Trading_Status

Allowed-Regulated Unknown

Analysis ID: #18
Version: Archived
Created: 2025-04-12 06:38
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Workflow Stage: Live

Executive Summary

Retail cryptocurrency trading is allowed and regulated in North Macedonia. The primary regulator is the National Bank of the Republic of North Macedonia (NBRM), which has shifted from initial ambiguity to a stance that the absence of specific regulation does not equate to illegality. The key regulatory framework is the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law) amended in July 2022, imposing AML/CFT obligations on virtual asset service providers (VASPs). While a comprehensive crypto-asset law is anticipated, the current environment operates under general financial laws and specific AML/CFT requirements.

Key Pillars

The primary regulator is the National Bank of the Republic of North Macedonia (NBRM). The regulatory framework is built upon general financial laws and the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law), which imposes AML/CFT obligations, including KYC, transaction monitoring, and reporting requirements, on virtual asset service providers (VASPs). There are no specific licensing or registration requirements mentioned outside of the obligations stemming from the AML/CFT law.

Landmark Laws

Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law), amended in July 2022: Introduced definitions for 'virtual assets' and 'virtual asset service providers' (VASPs) and imposed AML/CFT obligations on VASPs, including customer due diligence (KYC), transaction monitoring, and reporting requirements. It also sets a limit for cash trading of virtual assets (up to EUR 500 equivalent) and prohibits trading in anonymity-enhancing coins (privacy coins) and the use of tools designed to obscure transactions.

Considerations

Cryptocurrencies are not considered legal tender in North Macedonia and cannot be used for domestic payments. The NBRM has consistently issued warnings about the high risks associated with crypto-assets, including their volatility and the potential for fraud. The AML/CFT Law sets a limit for cash trading of virtual assets (up to EUR 500 equivalent) and prohibits trading in anonymity-enhancing coins and the use of tools designed to obscure transactions.

Notes

Historically, initial interpretations by the NBRM around 2016-2017 suggested that investing in cryptocurrencies could be considered illegal based on the Law on Foreign Exchange Operations. The government has expressed intentions to introduce a specific law to regulate cryptocurrencies more comprehensively, potentially including taxation aspects, since 2020, but as of early 2025, this law has not been finalized. The NBRM's Crypto FAQs are available in English. Transactions often occur through foreign exchanges or peer-to-peer arrangements.

Detailed Explanation

Retail cryptocurrency trading in North Macedonia is classified as Allowed-Regulated. Although no single law comprehensively governs cryptocurrency activities, individuals are permitted to buy, sell, and hold cryptocurrencies. The National Bank of the Republic of North Macedonia (NBRM) initially held an ambiguous stance, with interpretations around 2016-2017 suggesting potential illegality based on the Law on Foreign Exchange Operations. However, subsequent adjustments related to the EU Stabilisation and Association Agreement and clarifications from the NBRM shifted this perspective; the NBRM now states that the absence of specific regulation does not equate to illegality. Most transactions occur through foreign exchanges or peer-to-peer arrangements. Cryptocurrencies are not legal tender and cannot be used for domestic payments, which must be made in the national currency, the Denar. A dedicated crypto-asset law is anticipated. The most significant regulatory development is the amendment of the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law) in July 2022. This law defines 'virtual assets' and 'virtual asset service providers' (VASPs) and imposes AML/CFT obligations, including KYC, transaction monitoring, and reporting. The AML/CFT law sets a cash trading limit of EUR 500 equivalent and prohibits trading in anonymity-enhancing coins and the use of tools designed to obscure transactions. The NBRM consistently warns about the high risks of crypto-assets, citing their volatility and potential for fraud. The government intends to introduce specific legislation to regulate cryptocurrencies more comprehensively, potentially including taxation. As of early 2025, this dedicated law has not been finalized. The AML/CFT rules specifically target virtual assets and VASPs, meaning the sector is not entirely unregulated.

Summary Points

Here's a bullet-point summary of the report on Retail Cryptocurrency Trading Status in North Macedonia, designed for quick comprehension:

Retail Cryptocurrency Trading Status in North Macedonia: April 12, 2025

I. Overall Regulatory Status:

Allowed-Regulated: Retail cryptocurrency trading is permitted but subject to certain regulations, primarily related to Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT).

II. Key Regulatory Bodies:

National Bank of the Republic of North Macedonia (NBRM):
- Issues warnings about the risks associated with cryptocurrencies.
- Clarifies that the absence of specific regulation does not equate to illegality.
Ministry of Finance:
- Announced intentions to introduce a specific law to regulate cryptocurrencies.

III. Important Legislation and Regulations:

Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law) (Amended July 2022):
- Defines "virtual assets" and "virtual asset service providers" (VASPs).
- Imposes AML/CFT obligations on VASPs (KYC, transaction monitoring, reporting).
- Sets a limit for cash trading of virtual assets (up to EUR 500 equivalent).
- Prohibits trading in anonymity-enhancing coins (privacy coins) and the use of tools designed to obscure transactions.
Law on Foreign Exchange Operations:
- Historically, interpretations suggested restrictions on residents holding assets abroad, but this has been clarified.
- Does not currently regulate cryptocurrency transactions, but this does not make them illegal.

IV. Requirements for Compliance:

For Virtual Asset Service Providers (VASPs):
- Customer Due Diligence (KYC).
- Transaction Monitoring.
- Reporting Requirements (under AML/CFT Law).
General:
- Adherence to AML/CFT regulations.

V. Notable Restrictions or Limitations:

Not Legal Tender: Cryptocurrencies cannot be used for domestic payments; transactions must be in Denar (national currency).
Cash Trading Limit: Cash transactions for virtual assets are limited to EUR 500 equivalent.
Prohibition of Privacy Coins: Trading in anonymity-enhancing cryptocurrencies is prohibited.
Restrictions on Anonymizing Tools: The use of software tools to anonymize and interfere with virtual asset transactions is prohibited.

VI. Recent Developments or Changes:

July 2022 Amendment to AML/CFT Law: Introduced definitions for virtual assets and VASPs, imposing AML/CFT obligations.
Government Intentions: The government has expressed intentions to introduce a specific law to regulate cryptocurrencies more comprehensively, including taxation. However, this law has not yet been finalized.

VII. Key Considerations:

Risk Warnings: The NBRM consistently warns the public about the high risks associated with crypto-assets (volatility, lack of intrinsic value, potential for fraud).
Individual Responsibility: Investments are undertaken at the individual's own risk.
Developing Regulatory Framework: While a comprehensive crypto-asset law is still anticipated, the existing AML/CFT regulations provide a defined legal space for cryptocurrency activities.

Full Analysis Report

Report: Retail Cryptocurrency Trading Status in North Macedonia

Date: April 12, 2025

Analyst: Specialized Financial Regulatory Analyst

Topic: Retail_Trading_Status

Description: Assess whether individual citizens and residents in North Macedonia are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

1. Current Status: Allowed-Regulated

2. Detailed Narrative Explanation:

The status of retail cryptocurrency trading in North Macedonia is best described as Allowed-Regulated. While there is no single, comprehensive law specifically dedicated to regulating all aspects of cryptocurrency issuance, trading, and holding, the activity is not prohibited for individuals. Key regulations, particularly concerning Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT), have been introduced, bringing certain aspects of the crypto ecosystem under regulatory purview.

Historically, the stance was somewhat ambiguous. Initial interpretations by the National Bank of the Republic of North Macedonia (NBRM), particularly around 2016-2017, suggested that investing in cryptocurrencies could be considered illegal based on the Law on Foreign Exchange Operations, which restricted residents from holding certain assets abroad [8, 14]. However, subsequent developments, including adjustments related to the EU Stabilisation and Association Agreement which liberalized foreign investments for residents, and direct clarifications from the NBRM, have shifted this perspective [7, 12]. The NBRM now explicitly states that the absence of specific regulation does not equate to illegality [12].

Key points defining the current status:

Legality of Holding/Trading: Individuals are permitted to buy, sell, and hold cryptocurrencies. There is no specific law banning this activity [3, 4, 5, 9]. Most transactions occur through foreign exchanges or peer-to-peer arrangements [6].
Not Legal Tender: Cryptocurrencies are explicitly not considered legal tender in North Macedonia. They cannot be used for domestic payments, which must be made in the national currency, the Denar [6, 17, 18].
Regulatory Framework (Developing): While a dedicated, comprehensive crypto-asset law is still anticipated (announced by the government and Ministry of Finance) [6, 7, 9], specific regulations do exist.
AML/CFT Regulation (Key Factor): The most significant regulatory development is the amendment of the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law) in July 2022 [7]. This law introduced definitions for 'virtual assets' and 'virtual asset service providers' (VASPs). It imposes specific AML/CFT obligations on these providers, including customer due diligence (KYC), transaction monitoring, and reporting requirements. The law also sets a limit for cash trading of virtual assets (up to EUR 500 equivalent) and prohibits trading in anonymity-enhancing coins (privacy coins) and the use of tools designed to obscure transactions [7]. This brings VASPs operating in or targeting North Macedonia under a specific regulatory regime, justifying the "Regulated" status.
Official Warnings: The NBRM consistently warns the public about the high risks associated with crypto-assets, citing their volatility, lack of intrinsic value guarantee by any central authority, and the potential for fraud and illicit activities [3, 11, 17]. Investments are undertaken at the individual's own risk [4].
Future Legislation: The government has expressed clear intentions to introduce a specific law to regulate cryptocurrencies more comprehensively, potentially including taxation aspects [6, 7, 9]. The Prime Minister has indicated a desire for North Macedonia to adopt rigorous standards [6]. However, as of early 2025, this dedicated law has not yet been finalized or implemented [6].

In summary, while North Macedonia lacks a bespoke, all-encompassing crypto-asset regulatory framework like the EU's MiCA, the activity is permitted for individuals. Crucially, the implementation of AML/CFT rules specifically targeting virtual assets and VASPs means the sector is not entirely unregulated. It operates within a defined legal space where holding and trading are allowed, but subject to general financial laws and specific AML/CFT requirements for service providers, alongside strong official warnings regarding risks.

3. Relevant Text Excerpts:

On Legality vs. Regulation (NBRM): "In our country, as in other countries, the matter of issuance, investing and trading in cryptoassets is not regulated, neither in the Law on Foreign Exchange Operations (and its bylaws) which regulates transactions among residents and non-residents. However, this does not mean that the transactions with cryptoassets are illegal, but at the moment, they are not regulated." [12]
On AML/CFT Law (2022): "The Law on Prevention of Money Laundering and Financing Terrorism (AML and CTF Law) adopted in 2022 introduced a legal framework and clarity regarding cryptocurrencies... The legal solution of the AML and CTF Law defines the terms 'virtual assets' which fall under the definition of 'property', 'virtual asset service providers', and other related terms of the crypto sphere... The AML and CTF Law also sets obligations upon the providers of services related to virtual assets for prevention of money laundering and financing of terrorism..." [7]
On Prohibition of Anonymous Assets (AML/CFT Law): "The AML and CTF Law also prohibits service providers from trading in fully anonymous virtual assets known as private virtual assets, as well as from using software tools to anonymise and interfere with virtual asset transactions." [7]
On Lack of Specific Legislation (Wikipedia/Academic Sources): "No specific legislation on bitcoins or cryptocurrency exists in North Macedonia." [3] / "...providing an overview of the cryptocurrency situation in North Macedonia, where they are currently unregulated." (Note: This paper predates or doesn't fully account for the 2022 AML law's impact) [4, 5]
On Government Intentions: "The Minister of MoF has announced that a separate law for crypto currencies will be adopted in order to regulate this field." [7] / "Efforts by authorities to draft a cryptocurrency law have been underway since 2020..." [6] / "The new government plans to submit a law for the regulation of this issue, with which there will be a tax on cryptocurrencies..." [9]
On Not Being Legal Tender (NBRM/Radio Free Europe): "Cryptoassets are not a legal tender in our country. According to the current regulations, payments in the country can be made in the domestic currency - denar." [17] / "Cryptocurrencies are not legal tender in North Macedonia - meaning they are not allowed to be used for payment within the territory..." [6]
On Risks (NBRM): "Investing in cryptoassets is considered high risk. Everyone who invests or tend to invest in cryptoassets, should be extremely careful and well-informed on the potential risk it is exposed to and the implications of such investments." [17]

4. Source URLs:

National Bank of North Macedonia (NBRM) - Crypto FAQs: https://www.nbrm.mk/prasanja-i-odgovori-za-kripto-sredstva-en.nspx (Source for [12], [17]) Note: Direct link to English FAQ page.
Mondaq - FinTech Comparative Guide (North Macedonia): https://www.mondaq.com/fin-tech/1154468/fintech-comparative-guide (Provides context on AML Law and regulatory environment, source for [7], [13]) Note: Link points to the general guide page; specific North Macedonia chapter details the crypto situation.
Radio Free Europe / Radio Liberty: https://www.slobodnaevropa.mk/a/32822964.html (Article from Feb 2024 discussing status, lack of law, user numbers, PM's comments, source for [6]) Note: Article is likely in Macedonian. (Alternative English source if available: https://www.koha.net/en/arberi/409789/over-30-thousand-people-own-cryptocurrencies-in-north-macedonia-but-without-a-legal-framework/)
ResearchGate / ITEMA Conference (Academic Paper): https://www.researchgate.net/publication/366131424_Cryptocurrency_Evidence_from_North_Macedonia or https://itema-conference.com/wp-content/uploads/2022/11/ITEMA-2022-25-36.pdf (Source for [4], [5])
Telegrafi (News Article on Govt Plans): https://telegrafi.com/en/the-government-of-macedonia-will-regulate-the-possession-and-trade-of-cryptocurrencies-by-law/ (Source for [9], [16])
Wikipedia - Legality of Cryptocurrency by Country: https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory (Provides a summary overview, source for [3])
Emerald Insight (Analysis): https://www.emerald.com/insight/content/doi/10.1108/OXAN-ES268993/full/html (Source for [11])
ResearchGate (Academic Paper on AML/CFT): https://www.researchgate.net/publication/369650332_Cryptocurrency_Abuse_for_the_Purposes_of_Money_Laundering_and_Terrorism_Financing_Policies_and_Practical_Aspects_in_the_European_Union_and_North_Macedonia (Source for [18])

End of Report

**Report: Retail Cryptocurrency Trading Status in North Macedonia**

**Date:** April 12, 2025

**Analyst:** Specialized Financial Regulatory Analyst

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**Topic: Retail_Trading_Status**

**Description:** Assess whether individual citizens and residents in North Macedonia are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

---

**1. Current Status:** `Allowed-Regulated`

**2. Detailed Narrative Explanation:**

The status of retail cryptocurrency trading in North Macedonia is best described as `Allowed-Regulated`. While there is no single, comprehensive law specifically dedicated to regulating all aspects of cryptocurrency issuance, trading, and holding, the activity is not prohibited for individuals. Key regulations, particularly concerning Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT), have been introduced, bringing certain aspects of the crypto ecosystem under regulatory purview.

Historically, the stance was somewhat ambiguous. Initial interpretations by the National Bank of the Republic of North Macedonia (NBRM), particularly around 2016-2017, suggested that investing in cryptocurrencies could be considered illegal based on the Law on Foreign Exchange Operations, which restricted residents from holding certain assets abroad [8, 14]. However, subsequent developments, including adjustments related to the EU Stabilisation and Association Agreement which liberalized foreign investments for residents, and direct clarifications from the NBRM, have shifted this perspective [7, 12]. The NBRM now explicitly states that the absence of specific regulation does not equate to illegality [12].

Key points defining the current status:

*   **Legality of Holding/Trading:** Individuals are permitted to buy, sell, and hold cryptocurrencies. There is no specific law banning this activity [3, 4, 5, 9]. Most transactions occur through foreign exchanges or peer-to-peer arrangements [6].
*   **Not Legal Tender:** Cryptocurrencies are explicitly not considered legal tender in North Macedonia. They cannot be used for domestic payments, which must be made in the national currency, the Denar [6, 17, 18].
*   **Regulatory Framework (Developing):** While a dedicated, comprehensive crypto-asset law is still anticipated (announced by the government and Ministry of Finance) [6, 7, 9], specific regulations *do* exist.
*   **AML/CFT Regulation (Key Factor):** The most significant regulatory development is the amendment of the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law) in July 2022 [7]. This law introduced definitions for 'virtual assets' and 'virtual asset service providers' (VASPs). It imposes specific AML/CFT obligations on these providers, including customer due diligence (KYC), transaction monitoring, and reporting requirements. The law also sets a limit for cash trading of virtual assets (up to EUR 500 equivalent) and prohibits trading in anonymity-enhancing coins (privacy coins) and the use of tools designed to obscure transactions [7]. This brings VASPs operating in or targeting North Macedonia under a specific regulatory regime, justifying the "Regulated" status.
*   **Official Warnings:** The NBRM consistently warns the public about the high risks associated with crypto-assets, citing their volatility, lack of intrinsic value guarantee by any central authority, and the potential for fraud and illicit activities [3, 11, 17]. Investments are undertaken at the individual's own risk [4].
*   **Future Legislation:** The government has expressed clear intentions to introduce a specific law to regulate cryptocurrencies more comprehensively, potentially including taxation aspects [6, 7, 9]. The Prime Minister has indicated a desire for North Macedonia to adopt rigorous standards [6]. However, as of early 2025, this dedicated law has not yet been finalized or implemented [6].

In summary, while North Macedonia lacks a bespoke, all-encompassing crypto-asset regulatory framework like the EU's MiCA, the activity is permitted for individuals. Crucially, the implementation of AML/CFT rules specifically targeting virtual assets and VASPs means the sector is not entirely unregulated. It operates within a defined legal space where holding and trading are allowed, but subject to general financial laws and specific AML/CFT requirements for service providers, alongside strong official warnings regarding risks.

**3. Relevant Text Excerpts:**

*   **On Legality vs. Regulation (NBRM):** "In our country, as in other countries, the matter of issuance, investing and trading in cryptoassets is not regulated, neither in the Law on Foreign Exchange Operations (and its bylaws) which regulates transactions among residents and non-residents. However, this does not mean that the transactions with cryptoassets are illegal, but at the moment, they are not regulated." [12]
*   **On AML/CFT Law (2022):** "The Law on Prevention of Money Laundering and Financing Terrorism (AML and CTF Law) adopted in 2022 introduced a legal framework and clarity regarding cryptocurrencies... The legal solution of the AML and CTF Law defines the terms 'virtual assets' which fall under the definition of 'property', 'virtual asset service providers', and other related terms of the crypto sphere... The AML and CTF Law also sets obligations upon the providers of services related to virtual assets for prevention of money laundering and financing of terrorism..." [7]
*   **On Prohibition of Anonymous Assets (AML/CFT Law):** "The AML and CTF Law also prohibits service providers from trading in fully anonymous virtual assets known as private virtual assets, as well as from using software tools to anonymise and interfere with virtual asset transactions." [7]
*   **On Lack of Specific Legislation (Wikipedia/Academic Sources):** "No specific legislation on bitcoins or cryptocurrency exists in North Macedonia." [3] / "...providing an overview of the cryptocurrency situation in North Macedonia, where they are currently unregulated." (Note: This paper predates or doesn't fully account for the 2022 AML law's impact) [4, 5]
*   **On Government Intentions:** "The Minister of MoF has announced that a separate law for crypto currencies will be adopted in order to regulate this field." [7] / "Efforts by authorities to draft a cryptocurrency law have been underway since 2020..." [6] / "The new government plans to submit a law for the regulation of this issue, with which there will be a tax on cryptocurrencies..." [9]
*   **On Not Being Legal Tender (NBRM/Radio Free Europe):** "Cryptoassets are not a legal tender in our country. According to the current regulations, payments in the country can be made in the domestic currency - denar." [17] / "Cryptocurrencies are not legal tender in North Macedonia - meaning they are not allowed to be used for payment within the territory..." [6]
*   **On Risks (NBRM):** "Investing in cryptoassets is considered high risk. Everyone who invests or tend to invest in cryptoassets, should be extremely careful and well-informed on the potential risk it is exposed to and the implications of such investments." [17]

**4. Source URLs:**

*   **National Bank of North Macedonia (NBRM) - Crypto FAQs:** [https://www.nbrm.mk/prasanja-i-odgovori-za-kripto-sredstva-en.nspx](https://www.nbrm.mk/prasanja-i-odgovori-za-kripto-sredstva-en.nspx) (Source for [12], [17]) *Note: Direct link to English FAQ page.*
*   **Mondaq - FinTech Comparative Guide (North Macedonia):** [https://www.mondaq.com/fin-tech/1154468/fintech-comparative-guide](https://www.mondaq.com/fin-tech/1154468/fintech-comparative-guide) (Provides context on AML Law and regulatory environment, source for [7], [13]) *Note: Link points to the general guide page; specific North Macedonia chapter details the crypto situation.*
*   **Radio Free Europe / Radio Liberty:** [https://www.slobodnaevropa.mk/a/32822964.html](https://www.slobodnaevropa.mk/a/32822964.html) (Article from Feb 2024 discussing status, lack of law, user numbers, PM's comments, source for [6]) *Note: Article is likely in Macedonian.* (Alternative English source if available: [https://www.koha.net/en/arberi/409789/over-30-thousand-people-own-cryptocurrencies-in-north-macedonia-but-without-a-legal-framework/](https://www.koha.net/en/arberi/409789/over-30-thousand-people-own-cryptocurrencies-in-north-macedonia-but-without-a-legal-framework/))
*   **ResearchGate / ITEMA Conference (Academic Paper):** [https://www.researchgate.net/publication/366131424_Cryptocurrency_Evidence_from_North_Macedonia](https://www.researchgate.net/publication/366131424_Cryptocurrency_Evidence_from_North_Macedonia) or [https://itema-conference.com/wp-content/uploads/2022/11/ITEMA-2022-25-36.pdf](https://itema-conference.com/wp-content/uploads/2022/11/ITEMA-2022-25-36.pdf) (Source for [4], [5])
*   **Telegrafi (News Article on Govt Plans):** [https://telegrafi.com/en/the-government-of-macedonia-will-regulate-the-possession-and-trade-of-cryptocurrencies-by-law/](https://telegrafi.com/en/the-government-of-macedonia-will-regulate-the-possession-and-trade-of-cryptocurrencies-by-law/) (Source for [9], [16])
*   **Wikipedia - Legality of Cryptocurrency by Country:** [https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory](https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory) (Provides a summary overview, source for [3])
*   **Emerald Insight (Analysis):** [https://www.emerald.com/insight/content/doi/10.1108/OXAN-ES268993/full/html](https://www.emerald.com/insight/content/doi/10.1108/OXAN-ES268993/full/html) (Source for [11])
*   **ResearchGate (Academic Paper on AML/CFT):** [https://www.researchgate.net/publication/369650332_Cryptocurrency_Abuse_for_the_Purposes_of_Money_Laundering_and_Terrorism_Financing_Policies_and_Practical_Aspects_in_the_European_Union_and_North_Macedonia](https://www.researchgate.net/publication/369650332_Cryptocurrency_Abuse_for_the_Purposes_of_Money_Laundering_and_Terrorism_Financing_Policies_and_Practical_Aspects_in_the_European_Union_and_North_Macedonia) (Source for [18])

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**End of Report**

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