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North Macedonia

Retail_Trading_Status

Gray-Zone Unknown
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Status Changed

Previous status: Allowed-Regulated

The primary difference between the two analyses is the shift in the assessed status of retail cryptocurrency trading in North Macedonia from "Allowed-Regulated" in the previous analysis (April 12, 2025) to "Gray-Zone" in the new analysis (June 26, 2025). This change reflects a more nuanced interpretation of the existing regulatory framework and potentially new information or a refined understanding of the practical implications of the current legal situation. Justification for the differences: 1. Interpretation of "Regulated": The previous analysis classified the status as "Allowed-Regulated" primarily based on the 2022 amendments to the Law on Prevention of Money Laundering and Financing Terrorism (AML/CFT Law). It argued that the introduction of definitions for 'virtual assets' and 'virtual asset service providers' (VASPs), along with specific AML/CFT obligations for these entities, brought the sector under a regulatory regime, thus justifying the "Regulated" tag, even in the absence of a comprehensive, bespoke crypto law. The new analysis, while acknowledging the same AML/CFT amendments, interprets their impact differently. It views these measures as partial and not constituting a comprehensive regulatory framework. The "Gray-Zone" status emphasizes that despite these AML rules, significant gaps remain in areas like consumer protection, specific taxation rules, and the licensing of domestic exchanges. The new analysis suggests that while AML/CFT rules exist, their enforcement might still be developing ("full regulatory enforcement and further bylaws are still developing," "AML/CFT compliance is partially enforced"), and they do not cover the full spectrum of crypto activities to warrant a "Regulated" status. 2. Emphasis on Missing Elements: The previous report acknowledged the lack of a dedicated crypto-asset law but gave more weight to the existing AML/CFT regulations. The new report places greater emphasis on what is absent: a "comprehensive, specific legal framework directly regulating the buying, selling, and holding of cryptocurrencies," "limited specific consumer protection," "unclear taxation rules," and the lack of "licensed domestic exchanges." This focus on the missing pieces leads to the "Gray-Zone" conclusion, implying that the current regulations are insufficient to provide clarity and comprehensive oversight. 3. Evolution of Understanding and Source Material: The new analysis is dated slightly later and incorporates sources from June 2025 (e.g., AInvest, Coinfomania, TRT World). These newer sources explicitly use terms like "legal gray zone" (AInvest) or highlight the ongoing lack of a specific crypto law despite AML amendments (Coinfomania). This suggests that the intervening period between the two reports, or the availability of more recent commentary, has led to a refined understanding that the AML/CFT law, while a step, hasn't fully moved the needle out of a state of regulatory ambiguity for the entire retail trading ecosystem. For instance, the new analysis quotes AInvest stating, "Currently, cryptocurrencies in North Macedonia operate in a legal gray zone." 4. Practical Implications for Retail Traders: The new analysis more strongly highlights the practical consequences of the current regulatory state for individual traders, such as trading "at their own risk," primarily using "foreign-based exchanges," and facing potential scrutiny from local banks. This practical reality, where key aspects directly affecting retail users remain unaddressed by specific regulations, supports the "Gray-Zone" assessment over a more definitive "Regulated" status. 5. Nuance in "Allowed": Both reports agree that retail trading is not explicitly banned and is therefore "allowed." However, the previous report paired "Allowed" with "Regulated," implying a more structured environment. The new report's "Gray-Zone" status better captures the nuance that while allowed, the activity occurs in an environment lacking clear, comprehensive rules and protections, making it a less certain and more ambiguous domain for participants. The Bankarstvo.mk source in the new analysis encapsulates this: "trading and possession... is legal, while legally it is partially regulated... citizens can buy, sell and trade cryptocurrencies at their own risk..." This "partial regulation" is what the new analysis defines as a gray zone. In summary, the change from "Allowed-Regulated" to "Gray-Zone" is justified by a more critical assessment of the comprehensiveness and practical impact of existing regulations. While the 2022 AML/CFT law is a significant development acknowledged by both analyses, the new analysis concludes that these measures alone are insufficient to consider the entire retail trading sector as "Regulated" in a holistic sense. Instead, it highlights the persisting regulatory gaps and uncertainties that characterize a "Gray-Zone."

Analysis ID
#248
Version
Archived
Created
2025-06-26 09:12
Workflow Stage
Initial Research

Executive Summary

Retail cryptocurrency trading in North Macedonia exists in a legal gray zone; it is not explicitly banned, but lacks comprehensive regulation. The National Bank of the Republic of North Macedonia (NBRM) has historically issued warnings about cryptocurrency risks, but now acknowledges that the absence of regulation doesn't inherently make cryptocurrencies illegal. Amendments to the Law on Prevention of Money Laundering and Terrorism Financing in July 2022 introduced some regulations for virtual assets and VASPs, including AML/CFT obligations, registration with the Financial Intelligence Unit, and a ban on anonymous coins, though full regulatory enforcement and further bylaws are still developing. The government intends to develop a clearer regulatory framework influenced by the EU's MiCA regulation, potentially licensing crypto exchanges by 2025-2026.

Key Pillars

The primary regulator is the National Bank of the Republic of North Macedonia (NBRM), which has historically issued warnings but now states that the absence of specific regulation does not inherently mean cryptocurrencies are illegal. Core compliance requirements are evolving, with the Law on Prevention of Money Laundering and Terrorism Financing mandating AML/CFT obligations for VASPs, including registration with the Financial Intelligence Unit, a prohibition on trading anonymous coins, a cap on cash transactions, and a ban on anonymizing tools. There is no specific licensing or registration requirement for cryptocurrency exchanges currently, but the government aims to introduce licensing for crypto exchanges by 2025-2026.

Landmark Laws

  • Law on Foreign Exchange Operations: Historically, the NBRM indicated that investing in cryptocurrencies abroad by residents could be considered illegal under this law due to restrictions on residents holding accounts or securities abroad. Restrictions have since been eased.
  • Law on Prevention of Money Laundering and Terrorism Financing (amended July 4, 2022): Introduced definitions for 'virtual assets' and 'virtual asset service providers' (VASPs). It mandates AML/CFT obligations for VASPs, including registration with the Financial Intelligence Unit, a prohibition on trading anonymous coins, a cap on cash transactions (up to €500 equivalent), and a ban on using anonymizing tools.

Considerations

Cryptocurrencies are not recognized as legal tender in North Macedonia; payments must be made in the local currency, the denar. Taxation of cryptocurrency gains is unclear, with no specific crypto tax code, though individuals are expected to declare income from digital assets under general income tax laws. The NBRM has raised concerns regarding price volatility and fraud associated with cryptocurrencies. Some local banks may block or scrutinize transactions related to cryptocurrencies due to compliance risks and regulatory ambiguity.

Notes

In 2016 and 2017, the NBRM issued warnings regarding cryptocurrency risks and potential illegality of foreign cryptocurrency investments under the Law on Foreign Exchange Operations. The government intends to develop a clearer regulatory framework influenced by the EU's Markets in Crypto-Assets (MiCA) regulation. The Financial Intelligence Unit is designated as the supervisory authority for VASPs concerning AML/CTF aspects. A dedicated law for cryptocurrencies covering aspects like consumer protection, specific taxation rules, and licensing of domestic exchanges is not yet in place. Most cryptocurrency trading by residents occurs on international platforms due to the lack of licensed domestic exchanges.

Detailed Explanation

Retail cryptocurrency trading in North Macedonia is currently in a legal "Gray-Zone." While not explicitly banned, there is no comprehensive legal framework directly regulating the buying, selling, and holding of cryptocurrencies for individual citizens and residents. Cryptocurrency trading is allowed but there are no clear rules on taxation, and consumers lack safeguards. The current regulatory framework lacks a dedicated crypto law, but general financial and anti-money laundering (AML) rules apply. Cryptocurrencies do not have legal tender status, and trading is conducted freely but mostly through offshore exchanges due to the absence of local regulations. AML/CFT compliance is partially enforced, applying only to registered financial service providers.

Historically, the National Bank of the Republic of North Macedonia (NBRM) has issued warnings regarding the risks associated with cryptocurrencies, including price volatility and fraud. In 2016 and 2017, the NBRM indicated that investing in cryptocurrencies abroad by residents could be considered illegal under the existing Law on Foreign Exchange Operations, which had restrictions on residents holding accounts or securities abroad; these restrictions on investing in foreign markets were later eased. More recently, the NBRM has stated that the absence of specific regulation does not inherently mean cryptocurrencies are illegal. According to Radio MOF (quoting the National Bank, February 2021), "Crypto-assets are not a legal means of payment in our country. According to the existing regulation, payments in the country can be made in the domestic currency - the denar. As in many other countries, in our country too, there is no regulation that regulates the issuance, investment and trading of crypto-assets."

The government of North Macedonia has signaled its intent to develop a clearer regulatory framework for digital assets, influenced by the EU's Markets in Crypto-Assets (MiCA) regulation, with an aim to legitimize the sector, attract investment, and mitigate risks such as money laundering and fraud. Draft laws on digital assets are anticipated, with a potential timeline for licensing crypto exchanges by 2025-2026. The Minister of MoF has announced that a separate law for crypto currencies will be adopted in order to regulate this field.

Amendments to the Law on Prevention of Money Laundering and Terrorism Financing in July 2022 introduced definitions for "virtual assets" and "virtual asset service providers" (VASPs). The AML and CTF Law with amendments regarding crypto currencies was published in the official gazette of the Republic of North Macedonia on July 4, 2022. 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. This law mandates AML/CFT obligations for VASPs, including registration with the Financial Intelligence Unit, a prohibition on trading anonymous (privacy) coins, a cap on cash transactions involving crypto (up to €500 equivalent), and a ban on using anonymizing tools. The Financial Intelligence Unit is designated as the supervisory authority for VASPs concerning AML/CTF aspects; full regulatory enforcement and further bylaws are still developing. According to the Financial Intelligence Office of North Macedonia (February 2022), "The Republic of North Macedonia will for the first time regulate activities related to virtual or crypto-assets, publicly known as 'cryptocurrencies', which is foreseen by the Draft Law on Prevention of Money Laundering and Terrorist Financing... With the adoption of the law, the process of regulating the crypto-sphere begins, including the aspect of risks from money laundering and terrorist financing..."

Despite these AML-related amendments, a dedicated law for cryptocurrencies covering aspects like consumer protection, specific taxation rules, and licensing of domestic exchanges is not yet in place. Most cryptocurrency trading by residents occurs on international platforms due to the lack of licensed domestic exchanges. Some local banks may block or scrutinize transactions related to cryptocurrencies due to compliance risks and the current regulatory ambiguity.

Taxation of cryptocurrency gains is also unclear, with no specific crypto tax code. Individuals are generally expected to declare income from digital assets under general income tax laws, potentially as capital gains or "internet income," but specific guidance is lacking. In our country, trading and possession of cryptocurrencies or virtual assets is legal, while legally it is partially regulated by the Law on Prevention of Money Laundering. Currently, the country does not have specific regulations prohibiting cryptocurrencies, but there is also no detailed law that directly regulates their use. This means that citizens can buy, sell and trade cryptocurrencies at their own risk...

Summary Points

Retail Cryptocurrency Trading in North Macedonia: Regulatory Analysis (June 2025)

1. Overall Regulatory Status:

  • Gray Zone: Retail cryptocurrency trading is neither explicitly legal nor illegal, operating in a legal gray zone.
  • No Comprehensive Framework: A specific legal framework directly regulating the buying, selling, and holding of cryptocurrencies is lacking.
  • Limited Consumer Protection: Limited specific consumer protection measures are in place.
  • Unclear Taxation: Taxation rules are unclear.

2. Key Regulatory Bodies and Their Roles:

  • National Bank of the Republic of North Macedonia (NBRM):
    • Issued warnings about cryptocurrency risks (price volatility, fraud).
    • Initially indicated foreign cryptocurrency investments by residents might be illegal under the Law on Foreign Exchange Operations (restrictions on foreign accounts).
    • Currently states the absence of specific regulation does not inherently mean cryptocurrencies are illegal.
  • Financial Intelligence Unit:
    • Supervisory authority for Virtual Asset Service Providers (VASPs) concerning AML/CFT aspects.
    • Responsible for VASP registration.
  • Government of North Macedonia:
    • Signals intent to develop a clearer regulatory framework for digital assets.
    • Plans to draft laws influenced by EU's MiCA regulation.

3. Important Legislation and Regulations:

  • Law on Prevention of Money Laundering and Terrorism Financing (amended July 2022):
    • Introduced definitions for "virtual assets" and "Virtual Asset Service Providers" (VASPs).
    • Mandates AML/CFT obligations for VASPs.
  • Law on Foreign Exchange Operations (Historically):
    • Previously restricted residents from holding accounts or securities abroad, potentially impacting cryptocurrency investments. Restrictions have been eased.
  • Draft Laws on Digital Assets (Anticipated):
    • Expected to legitimize the sector, attract investment, and mitigate risks.
    • Potential timeline for licensing crypto exchanges by 2025-2026.

4. Requirements for Compliance (Primarily for VASPs):

  • Registration with the Financial Intelligence Unit.
  • AML/CFT Obligations: Compliance with anti-money laundering and counter-terrorist financing regulations.

5. Notable Restrictions and Limitations:

  • No Legal Tender Status: Cryptocurrencies are not recognized as legal tender.
  • Payments in Denar: Payments within the country must be made in the local currency (denar).
  • Restrictions on VASPs:
    • Prohibition on trading anonymous (privacy) coins.
    • Cap on cash transactions involving crypto (up to €500 equivalent).
    • Ban on using anonymizing tools.
  • Bank Scrutiny: Some local banks may block or scrutinize cryptocurrency-related transactions.

6. Recent Developments and Changes:

  • Amendments to AML/CFT Law (July 2022): Defined virtual assets and VASPs, imposing AML/CFT obligations.
  • Government Intent to Regulate: Plans to develop a comprehensive regulatory framework influenced by EU's MiCA.
  • Potential Licensing of Exchanges: Possible licensing of domestic crypto exchanges by 2025-2026.
  • Eased Restrictions on Foreign Investment: Restrictions on residents investing in foreign markets have been eased, impacting cryptocurrency investments.

Full Analysis Report

Report on the Current Status of Retail Trading of Cryptocurrencies in North Macedonia

Date: 2025-06-26

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

Gray-Zone

2. Detailed Narrative Explanation

Retail cryptocurrency trading in North Macedonia currently operates in a legal gray zone. While not explicitly banned for individual citizens and residents, there is no comprehensive, specific legal framework directly regulating the buying, selling, and holding of cryptocurrencies. This means that while individuals can and do participate in cryptocurrency trading, often through foreign-based exchanges, they do so in an environment with limited specific consumer protection, unclear taxation rules, and evolving anti-money laundering (AML) and counter-terrorist financing (CTF) measures.

Historically, the National Bank of the Republic of North Macedonia (NBRM) has issued warnings regarding the risks associated with cryptocurrencies, including price volatility and fraud. In 2016 and 2017, the NBRM indicated that investing in cryptocurrencies abroad by residents could be considered illegal under the existing Law on Foreign Exchange Operations, which had restrictions on residents holding accounts or securities abroad. However, with the country's progression in the EU Stabilization and Association Agreement, restrictions on investing in foreign markets were eased for residents. More recently, the NBRM has stated that the absence of specific regulation does not inherently mean cryptocurrencies are illegal.

The government of North Macedonia has signaled its intent to develop a clearer regulatory framework for digital assets. This includes plans to draft laws influenced by the EU's Markets in Crypto-Assets (MiCA) regulation, with an aim to legitimize the sector, attract investment, and mitigate risks such as money laundering and fraud. Draft laws on digital assets are anticipated, with a potential timeline for licensing crypto exchanges by 2025-2026.

Amendments to the Law on Prevention of Money Laundering and Terrorism Financing in July 2022 introduced definitions for "virtual assets" and "virtual asset service providers" (VASPs). This law mandates AML/CFT obligations for VASPs, including registration with the Financial Intelligence Unit, a prohibition on trading anonymous (privacy) coins, a cap on cash transactions involving crypto (up to €500 equivalent), and a ban on using anonymizing tools. The Financial Intelligence Unit is designated as the supervisory authority for VASPs concerning AML/CTF aspects. However, full regulatory enforcement and further bylaws are still developing.

Despite these AML-related amendments, a dedicated law for cryptocurrencies covering aspects like consumer protection, specific taxation rules, and licensing of domestic exchanges is not yet in place. Cryptocurrencies are not recognized as legal tender, and payments within the country are to be made in the local currency, the denar. Most cryptocurrency trading by residents occurs on international platforms due to the lack of licensed domestic exchanges. Some local banks may block or scrutinize transactions related to cryptocurrencies due to compliance risks and the current regulatory ambiguity.

Taxation of cryptocurrency gains is also unclear, with no specific crypto tax code. Individuals are generally expected to declare income from digital assets under general income tax laws, potentially as capital gains or "internet income," but specific guidance is lacking.

The evolving regulatory landscape, the active use of cryptocurrencies by residents, the government's stated intention to regulate, and the partial application of AML laws without a comprehensive crypto-specific framework contribute to the "Gray-Zone" status.

3. Specific, Relevant Text Excerpts

  • AInvest (June 2025): "Currently, cryptocurrencies in North Macedonia operate in a legal gray zone. While trading is allowed, there are no clear rules on taxation, and consumers lack safeguards."
  • AInvest (June 2025): "The current regulatory framework in North Macedonia lacks a dedicated crypto law, but general financial and anti-money laundering (AML) rules apply. Cryptocurrencies do not have legal tender status, and trading is conducted freely but mostly through offshore exchanges due to the absence of local regulations. AML/CFT compliance is partially enforced, applying only to registered financial service providers."
  • Coinfomania (June 2025): "At this time (June 2025), there is no law specifically about cryptocurrencies in place... Even so, after reaching the EU Stabilization and Association Agreement, the government declared that using cryptocurrencies is legal, but they have not been regulated."
  • Coinfomania (June 2025) on AML/CTF Law Developments: "Last year, there were amendments made to the Law on Prevention of Money Laundering and Terrorism Financing. Thanks to this act, virtual assets were given legal identification and certain actors such as VASPs were mentioned in the law. Key provisions include: Trading of anonymous (privacy) coins is prohibited; Cash transactions involving crypto are capped at €500 equivalent; All VASPs must register with the Financial Intelligence Unit; Use of coin-mixing or anonymizing tools is banned. Further bylaws are pending. Full regulatory enforcement is expected by 2026."
  • CMS Law (updated October 2023, referencing earlier developments): "Now, NBRM is stating that it does not mean that crypto currencies are illegal if they are not regulated. The authorities recognise the interest by the citizens to invest in crypto currencies. The Minister of MoF has announced that a separate law for crypto currencies will be adopted in order to regulate this field."
  • CMS Law (updated October 2023, referencing earlier developments): "The AML and CTF Law with amendments regarding crypto currencies was published in the official gazette of the Republic of North Macedonia on the 4 July 2022. 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."
  • Financial Intelligence Office of North Macedonia (February 2022): "Република Северна Македонија за прв пат ќе ги регулира активностите поврзани со виртуелните односно крипто -средства, а во јавноста познати како „критповалути“ што се предвидува со Предлог-Законот за спречување перење пари и финансирање тероризам... Со донесување на законот започнува процесот на регулација на крипто-сферата, вклучувајќи го аспектот на ризиците од перење пари и финансирање на тероризам..." (Translation: "The Republic of North Macedonia will for the first time regulate activities related to virtual or crypto-assets, publicly known as 'cryptocurrencies', which is foreseen by the Draft Law on Prevention of Money Laundering and Terrorist Financing... With the adoption of the law, the process of regulating the crypto-sphere begins, including the aspect of risks from money laundering and terrorist financing...")
  • Radio MOF (quoting National Bank, February 2021): "„Крипто-средствата не претставуваат законско средство за плаќање во нашата земја. Согласно со постојната регулатива, плаќањата во земјата можат да се вршат во домашната валута ‒ денарот. Како и во многу други земји, така и кај нас, не постои регулатива со која се регулираат издавањето, вложувањето и тргувањето со крипто-средствата“" (Translation: "Crypto-assets are not a legal means of payment in our country. According to the existing regulation, payments in the country can be made in the domestic currency - the denar. As in many other countries, in our country too, there is no regulation that regulates the issuance, investment and trading of crypto-assets.")
  • Bankarstvo.mk (undated, accessed June 2025): "Во нашата држава тргувањето и поседувањето на криптовалути или виртуелни средства е легално, додека законски е парцијално регулирано со Законот за спречување на перење пари. Во моментов, земјата нема конкретна регулатива што ги забранува криптовалутите, но исто така нема и детален закон што директно го регулира нивното користење. Ова значи дека граѓаните можат да купуваат, продаваат и тргуваат со криптовалути на сопствен ризик..." (Translation: "In our country, trading and possession of cryptocurrencies or virtual assets is legal, while legally it is partially regulated by the Law on Prevention of Money Laundering. Currently, the country does not have specific regulations prohibiting cryptocurrencies, but there is also no detailed law that directly regulates their use. This means that citizens can buy, sell and trade cryptocurrencies at their own risk...")

4. Direct, Accessible URL Links to Sources

Web Sources (14)

Sources discovered via web search grounding

Search queries used (7)
  • Retail cryptocurrency trading status North Macedonia
  • North Macedonia cryptocurrency regulation
  • National Bank of North Macedonia cryptocurrency
  • North Macedonia financial regulator cryptocurrency
  • Закон за спречување перење пари и финансирање на тероризам Северна Македонија криптовалути
  • Народна Банка на Република Северна Македонија криптовалути
  • Регулација на криптовалути во Северна Македонија
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