Mozambique

Okay, here is the comprehensive report on the current status of retail cryptocurrency trading in Mozambique.
## Report on the Current Status of Retail Cryptocurrency Trading in Mozambique

**Topic:** Retail_Trading_Status
**Description:** Assess whether individual citizens and residents in the country 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. Identified Status:** **Allowed-UnRegulated**

**2. Narrative Explanation:**

The status of retail cryptocurrency trading in Mozambique is best described as **Allowed-UnRegulated**. Currently (as of April 2025), there is no specific, comprehensive legislation in Mozambique that explicitly permits, prohibits, or regulates the buying, selling, and holding of cryptocurrencies like Bitcoin by individual citizens and residents. While not explicitly illegal for individuals to engage in, the activity exists in a regulatory vacuum specifically concerning crypto-assets themselves.

The Banco de Moçambique (Central Bank of Mozambique) has publicly addressed cryptocurrencies, primarily through warnings. In early 2018, the Bank issued statements clarifying that cryptocurrencies are not legal tender in Mozambique, are not issued or guaranteed by the central monetary authority, and are not supervised or regulated by the Bank. It explicitly warned citizens about the risks associated with cryptocurrencies, citing their volatility, lack of security guarantees, and potential use in illicit activities such as money laundering and terrorist financing. These communications serve as discouragement and risk advisories rather than legal prohibitions on individual ownership or trading.

While there's no crypto-specific regulatory framework covering aspects like exchange licensing (for crypto exchanges *as* crypto exchanges), specific tax rules for crypto gains (though general income tax rules may apply), or consumer protection specifically tailored to crypto investors, recent developments indicate a move towards regulating service providers for AML/CFT purposes.

Law No. 14/2023 (AML/CFT Law) and subsequent Notice No. 4/GBM/2023 (September 2023) now classify Virtual Asset Service Providers (VASPs) as financial institutions for AML/CFT compliance purposes. These VASPs are required to register with the Banco de Moçambique to operate legally. This regulation focuses on the *service providers* and their obligations regarding anti-money laundering and terrorism financing, rather than regulating the *assets* themselves or the act of *individual trading and holding*.

Therefore, individuals are generally able to acquire and hold cryptocurrencies, often through international platforms (as there are no known major regulated exchanges based *in* Mozambique specifically for retail crypto trading), but they do so without specific regulatory protections or prohibitions governing the assets themselves. Trading occurs at the individual's own risk, as highlighted by the Central Bank. Existing general laws, such as those concerning electronic transactions (Law on Electronic Transactions, 2017), cybercrimes, and potentially general income tax principles for any realized gains, might apply, but these are not crypto-specific regulations.

**3. Supporting Excerpts:**

*   **On Lack of Specific Regulation & Central Bank Stance (2018):**
    *   "The Central Bank of Mozambique issued a statement in January 2018 describing cryptocurrency use in illicit activities and advised citizens to stay away from cryptocurrency. The Bank stated that it neither regulates nor monitors transactions using Bitcoin because cryptocurrency is not issued by its central authority and has no legal standing in the country." (Source: Freeman Law)
    *   "The central bank therefore warns that it does not regulate, supervise or monitor activities and transactions carried out using Bitcoin, and is therefore not liable for any effects resulting from transactions related to it, as the crypto-currency has no legal standing and is not issued by the national monetary authority." (Source: Club of Mozambique, reporting on Banco de Moçambique statement)
    *   "In Mozambique, the Central Bank has not provided a view on crypto assets in general, but has openly discouraged the use of Bitcoins in the jurisdiction... companies transacting with Bitcoin are not regulated under Mozambican law, and the Bitcoin does not offer security and is prone to frauds and other crimes." (Source: LEX Africa, quoting Célia Francisco, partner at CGA Maputo)
    *   "In early 2018, the Banco de Moçambique (BM) warned Mozambicans of the dangers of using Bitcoin, in a press release. They stressed that virtual currencies are unregulated and are therefore used outside of the law." (Source: Crowdfund Insider / Ecobank Research)

*   **On Lack of Specific Crypto Legislation (Recent):**
    *   "(2024-06-12) There is no special legislation on crypto-assets in Mozambique. Under the terms of the general legislation, any gain on such exchanges is subject to Corporate Income Tax or Personal Income Tax." (Source: CMS Law)
    *   "(2024-06-12) As Mozambique has no specific legislation on cryptocurrency, no specific treatment is given in law to either crypto-assets or NFTs." (Source: CMS Law)
    *   "(2024-12-10) Mozambique currently lacks specific legislation directly governing cryptocurrencies. Therefore, the legal status of cryptocurrencies and their associated transactions remains somewhat ambiguous." (Source: UPay Blog)
    *   "(2025-01-17) The regulatory environment for cryptocurrencies in Mozambique is unclear, posing potential legal risks." (Source: OneSafe Blog)

*   **On Trading via International Platforms & Risk:**
    *   "The real-time trading of foreign currencies, cryptocurrencies and other assets on virtual platforms, whose domains are not registered in Mozambique, is at the risk of those who practice it." (Source: Banco de Moçambique - Foreign Exchange Licensing page)
    *   "There are no exchanges based in Mozambique." (Source: Freeman Law, as of their publication date, corroborating use of external platforms)

*   **On Recent VASP Registration for AML/CFT:**
    *   "Law no. 14/2023, of 28 August, which approves the Law on Preventing and Combating Money Laundering and Terrorist Financing, considers virtual asset service providers to be financial institutions for the purposes of complying with their duties in terms of preventing and combating ML/TF." (Source: VdA Law Firm analysis of Notice 4/GBM/2023)
    *   "In particular, Law no. 14/2023 regulates the exercise of activities with virtual assets, determining that these activities can only be carried out by entities that are registered for this purpose with the Bank of Mozambique." (Source: VdA Law Firm analysis of Notice 4/GBM/2023)
    *   "Notice No. 4/GBM/2023, of September 14 – Minimum requirements for registering virtual asset service providers." (Source: Banco de Moçambique - AML/CFT Legislation page)

**4. Source Links:**

*   **Banco de Moçambique - AML/CFT Legislation:** [https://www.bancomoc.mz/en/financial-stability/anti-money-laundering-and-countering-the-financing-of-terrorism-and-proliferation/](https://www.bancomoc.mz/en/financial-stability/anti-money-laundering-and-countering-the-financing-of-terrorism-and-proliferation/) (Provides access to relevant laws and notices like Notice 4/GBM/2023)
*   **Banco de Moçambique - Foreign Exchange Licensing (mentions crypto trading risk):** [https://www.bancomoc.mz/en/financial-stability/foreign-exchange-licensing-and-control/](https://www.bancomoc.mz/en/financial-stability/foreign-exchange-licensing-and-control/)
*   **VdA Law Firm Analysis of Notice 4/GBM/2023:** [https://www.vda.pt/en/publications/articles/MZ-Approval-of-the-legal-framework-for-the-registration-of-virtual-asset-service-providers/](https://www.vda.pt/en/publications/articles/MZ-Approval-of-the-legal-framework-for-the-registration-of-virtual-asset-service-providers/)
*   **CMS Law - Crypto Tax in Mozambique (June 2024):** [https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-tax/mozambique](https://cms.law/en/int/expert-guides/cms-expert-guide-to-crypto-tax/mozambique)
*   **Freeman Law - Mozambique and Cryptocurrency:** [https://freemanlaw.com/mozambique-and-cryptocurrency/](https://freemanlaw.com/mozambique-and-cryptocurrency/)
*   **Club of Mozambique - Report on 2018 Central Bank Warning:** [https://clubofmozambique.com/news/mozambiques-central-bank-warns-against-using-bitcoin/](https://clubofmozambique.com/news/mozambiques-central-bank-warns-against-using-bitcoin/)
*   **LEX Africa - Digital Currencies Article (mentions Mozambique):** [https://www.lexafrica.com/digital-currencies-and-services-gaining-momentum-across-the-continent/](https://www.lexafrica.com/digital-currencies-and-services-gaining-momentum-across-the-continent/)
*   **Crowdfund Insider - Report on African Crypto Regulation (2018, mentions Mozambique):** [https://www.crowdfundinsider.com/wp-content/uploads/2018/08/Cryptocurrency-regulation-in-Africa-Ecobank-August-2018.pdf](https://www.crowdfundinsider.com/wp-content/uploads/2018/08/Cryptocurrency-regulation-in-Africa-Ecobank-August-2018.pdf) (See page 6)

*Disclaimer: The regulatory landscape for cryptocurrencies is rapidly evolving. While this report reflects the most current information available from the sources, the status could change.*