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Retail_Trading_Status

Current: In-Progress

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As of June 26, 2025, Rwanda's retail cryptocurrency trading status is 'In-Progress' as the country is actively developing a formal regulatory framework. Historically, the National Bank of Rwanda (NBR) discouraged participation in cryptocurrency trading due to its unregulated nature and associated risks. However, recent developments indicate a shift towards regulation rather than an outright ban. In March 2025, the Capital Markets Authority (CMA) and the NBR announced the enforcement of a draft law to regulate virtual assets, released on March 6, 2025. This draft law appoints the CMA as the primary regulator for the virtual asset sector and outlines licensing requirements for Virtual Asset Service Providers (VASPs), inviting public comment. NBR Governor John Rwangombwa stated in November 2024 that the central bank, in partnership with the CMA, planned to establish crypto regulations, potentially by the first quarter of 2025, acknowledging the impossibility of eliminating cryptocurrencies and aiming to govern their use. Despite these moves, the draft law explicitly states that virtual assets will not be recognized as legal tender and cannot be used for payments within Rwanda. Furthermore, it proposes a ban on crypto mining, virtual asset cash machines (ATMs), and mixer or tumbler services.

Prior to these recent developments, the NBR had a more prohibitive stance. In 2018, the NBR declared cryptocurrencies illegal, stating that anyone involved in buying or selling digital money did so at their own risk. Warnings about the risks of cryptocurrency investments and the unregulated nature of platforms have been reiterated by the NBR Governor as recently as March 2024. Financial institutions were also previously warned against engaging in crypto-related transactions. The impetus for the new regulatory framework includes addressing concerns raised by the Financial Action Task Force (FATF) regarding the potential use of virtual assets for money laundering and terrorist financing. The proposed regulations aim to mitigate these risks while fostering innovation. The framework is expected to include Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements, with the CMA overseeing compliance and fraud investigations. The draft law mandates the enforcement of the 'travel rule,' requiring exchanges to collect and share information on individuals transacting with cryptocurrencies. Operators of unlicensed VASPs could face significant fines and imprisonment.

Authorities, including Carine Twiringiyamana, CMA's manager of licensing and approvals, emphasize that the framework is designed to mitigate risks while fostering innovation. The NBR is also exploring the possibility of issuing its own Central Bank Digital Currency (CBDC). The final version of the law and its full implementation will determine the precise conditions under which retail cryptocurrency trading will be permitted and regulated. The environment is moving towards a regulated system with specific prohibitions and licensing requirements, but individuals are not explicitly banned from holding or trading cryptocurrencies at their own risk currently.

Bullet Points

## Rwanda: Retail Cryptocurrency Trading Status - June 2025

**Overall Status: In-Progress** - Rwanda is developing a regulatory framework for virtual assets, but it is not yet fully enacted and operational.

**1. Key Regulatory Bodies & Roles:**

*   **National Bank of Rwanda (NBR):**
    *   Historically issued warnings against cryptocurrency trading due to risks and lack of regulation.
    *   Partnering with CMA to establish crypto regulations.
    *   Exploring the possibility of issuing a Central Bank Digital Currency (CBDC).
*   **Capital Markets Authority (CMA):**
    *   Appointed as the primary regulator for the virtual asset sector under the draft law.
    *   Responsible for establishing licensing requirements for Virtual Asset Service Providers (VASPs).
    *   Overseeing compliance and fraud investigations.

**2. Key Legislation & Regulations:**

*   **Draft Law on Virtual Assets (Released March 6, 2025):**
    *   Aims to regulate virtual assets and VASPs.
    *   Currently under public consultation.
    *   Mandates licensing for VASPs from the CMA.
    *   Enforces the "travel rule" for AML/KYC.
    *   Proposes significant fines and imprisonment for unlicensed VASP operators.

**3. Requirements for Compliance (Proposed):**

*   **Licensing for Virtual Asset Service Providers (VASPs):** VASPs must apply for licenses from the CMA.
*   **Anti-Money Laundering (AML) and Know Your Customer (KYC) Requirements:** Expected to be implemented, overseen by the CMA.
*   **"Travel Rule" Enforcement:** Exchanges must collect and share information on individuals transacting with cryptocurrencies.

**4. Notable Restrictions & Limitations:**

*   **No Legal Tender Status:** Virtual assets will not be recognized as legal tender and cannot be used for payments within Rwanda.
*   **Proposed Bans:**
    *   Crypto mining.
    *   Virtual asset cash machines (ATMs).
    *   Mixer or tumbler services.

**5. Recent Developments & Changes:**

*   **March 2025:** CMA and NBR announced the enforcement of a draft law to regulate virtual assets.
*   **November 2024:** NBR Governor stated plans to establish crypto regulations, potentially by Q1 2025.
*   **Prior to 2025:** NBR had a more prohibitive stance, declaring cryptocurrencies illegal in 2018 and issuing repeated warnings about risks.

**6. Rationale for Regulatory Shift:**

*   **Financial Action Task Force (FATF) Concerns:** Addressing concerns regarding the potential use of virtual assets for money laundering and terrorist financing.
*   **Mitigating Risks & Fostering Innovation:** Balancing the need to control risks with the potential benefits of virtual assets.

**7. Important Considerations:**

*   **Evolving Landscape:** The regulatory landscape is still evolving. The final version of the law and its full implementation will determine the precise conditions under which retail cryptocurrency trading will be permitted and regulated.
*   **No Explicit Ban (Yet):** Individuals are not explicitly banned from holding or trading cryptocurrencies at their own risk, but the environment is moving towards a regulated system.

Full Analysis Report

Complete markdown report for this analysis

## Report on Retail Cryptocurrency Trading Status in Rwanda

**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).

---

### Retail_Trading_Status: In-Progress

**1. Most Accurate Current Status:** In-Progress

**2. Detailed Narrative Explanation:**

Rwanda is currently in the process of establishing a regulatory framework for virtual assets, including cryptocurrencies. While historically the National Bank of Rwanda (NBR) has issued warnings and discouraged participation in cryptocurrency trading due to its unregulated nature and associated risks, recent developments indicate a shift towards regulation rather than an outright ban.

In March 2025, Rwanda's Capital Markets Authority (CMA) and the National Bank of Rwanda (NBR) announced the enforcement of a draft law to regulate virtual assets. This draft law, released on March 6, 2025, appoints the CMA as the primary regulator for the virtual asset sector and outlines licensing requirements for Virtual Asset Service Providers (VASPs). The public was invited to provide comments on this draft law, indicating an ongoing process of finalization and implementation.

The NBR Governor, John Rwangombwa, had previously stated in November 2024 that the central bank, in partnership with the CMA, was planning to establish crypto regulations, potentially by the first quarter of 2025. He acknowledged that cryptocurrencies cannot be eliminated and that the aim is to establish rules to govern their use within the country.

Despite these moves towards regulation, it's crucial to note that the draft law explicitly states that virtual assets will not be recognized as legal tender and cannot be used for payments within Rwanda. Furthermore, the draft law proposes a ban on crypto mining, virtual asset cash machines (ATMs), and mixer or tumbler services.

The impetus for the new regulatory framework includes addressing concerns raised by the Financial Action Task Force (FATF) regarding the potential use of virtual assets for money laundering and terrorist financing. The proposed regulations aim to mitigate these risks while fostering innovation. The framework is expected to include Anti-Money Laundering (AML) and Know Your Customer (KYC) requirements, with the CMA overseeing compliance and fraud investigations. The draft law mandates the enforcement of the "travel rule," requiring exchanges to collect and share information on individuals transacting with cryptocurrencies. Operators of unlicensed VASPs could face significant fines and imprisonment.

While the draft law marks a significant step, the regulatory landscape is still evolving. The final version of the law and its full implementation will determine the precise conditions under which retail cryptocurrency trading will be permitted and regulated. The National Bank of Rwanda is also exploring the possibility of issuing its own Central Bank Digital Currency (CBDC).

Therefore, the status is "In-Progress" because a formal regulatory framework is actively being developed and is not yet fully enacted and operational. While individuals are not explicitly banned from holding or trading cryptocurrencies at their own risk, the environment is moving towards a regulated system with specific prohibitions and licensing requirements.

**3. Specific, Relevant Text Excerpts:**

*   **March 2025 (Draft Law Announcement):** "Rwanda's Capital Markets Authority (CMA) and the National Bank of Rwanda (NBR), have announced the enforcement of a draft law to regulate virtual assets in the country. Authorities are now asking virtual assets service providers (VASPs) in the country to apply for licenses from the CMA or risk prosecution."
*   **March 2025 (Details of Draft Law):** "The draft law confirms that virtual assets will not be recognised as legal tender, nor can they be used for payments within Rwanda. The proposal also bans crypto mining, virtual asset cash machines, and mixer or tumbler services."
*   **March 2025 (Regulatory Oversight):** "The draft law places virtual assets and virtual asset service providers (VASPs) under the regulatory oversight of the Capital Markets Authority of Rwanda (CMA Rwanda), which will establish the licensing requirements for VASPs."
*   **November 2024 (NBR Governor's Statement on Upcoming Regulations):** "The governor of the National Bank of Rwanda (NBR), John Rwangombwa, has said that the bank is making plans to regulate the use of cryptocurrencies in the country. The regulations may come into place as early as the first quarter of 2025."
*   **November 2024 (NBR Governor on Inevitability of Crypto):** "When quizzed on the apex bank's position on the increased use of bitcoin and other cryptocurrencies in the country, Rwangombwa said the NBR cannot get rid of the asset class. Instead, the bank can make rules to govern its use within Rwandan borders and advise its citizens to avoid dealing with any crypto in the absence of clear regulations, he added."
*   **March 2024 (NBR Governor's Warning):** "We have said this again and again that these cryptocurrency businesses are not regulated in Rwanda. There are a lot of scams around these cryptocurrency and other online businesses. We have given warning to people to avoid investing or buying these assets... They are not regulated and we advise people not to invest in these assets because people have lost money and they keep losing money."
*   **2018 (NBR's Previous Stance):** "In 2018, the National Bank of Rwanda (NBR) regarded cryptocurrency as forbidden. 'Anyone who gets involved in the business of buying and selling digital money will do so at their own risk,' the Governor of the National Bank of Rwanda said while presenting his Monetary Policy and Financial Stability statement."
*   **FATF Concerns and Regulatory Aims:** "Authorities say the move addresses concerns from the Financial Action Task Force (FATF) over the potential use of virtual assets for money laundering." "Carine Twiringiyamana, CMA's manager of licensing and approvals, emphasised that the framework is designed to mitigate risks while fostering innovation."

**4. Direct, Accessible URL Links to Specific Sources:**

*   [https://www.lexafrica.com/news-publications/digital-currencies-and-services-gaining-momentum-across-the-continent/](https://www.lexafrica.com/news-publications/digital-currencies-and-services-gaining-momentum-across-the-continent/)
*   [https://freemanlaw.com/rwanda-cryptocurrency-laws/](https://freemanlaw.com/rwanda-cryptocurrency-laws/)
*   [https://www.proeliumlaw.com/cryptocurrency-regulation-tracker/](https://www.proeliumlaw.com/cryptocurrency-regulation-tracker/)
*   [https://dig.watch/updates/rwanda-moves-to-regulate-virtual-assets-with-new-draft-law](https://dig.watch/updates/rwanda-moves-to-regulate-virtual-assets-with-new-draft-law)
*   [https://mariblock.com/rwanda-to-establish-crypto-regulations-in-2025-nbr/](https://mariblock.com/rwanda-to-establish-crypto-regulations-in-2025-nbr/)
*   [https://mariblock.com/rwanda-introduces-draft-regulations-for-cryptocurrencies/](https://mariblock.com/rwanda-introduces-draft-regulations-for-cryptocurrencies/)
*   [https://upay.africa/blog/cryptocurrency-adoption-around-the-world-rwanda](https://upay.africa/blog/cryptocurrency-adoption-around-the-world-rwanda)
*   [https://en.igihe.com/news/article/you-risk-losing-your-money-nbr-governor-warns-rwandans-against-stt-and-other](https://en.igihe.com/news/article/you-risk-losing-your-money-nbr-governor-warns-rwandans-against-stt-and-other)
*   [https://furtherafrica.com/2024/11/21/rwanda-moves-towards-cryptocurrency-regulation/](https://furtherafrica.com/2024/11/21/rwanda-moves-towards-cryptocurrency-regulation/)
*   [https://bitcoinke.io/2025/03/rwanda-draft-law-virtual-assets/](https://bitcoinke.io/2025/03/rwanda-draft-law-virtual-assets/)
*   [https://www.binance.com/en/square/post/5349989670054](https://www.binance.com/en/square/post/5349989670054) (Note: Binance Square is a user-generated content platform, but this specific post references and summarizes information that aligns with other cited sources regarding the draft law.)
*   [https://news.bitcoin.com/rwandan-regulators-unveil-draft-law-to-govern-virtual-assets/](https://news.bitcoin.com/rwandan-regulators-unveil-draft-law-to-govern-virtual-assets/)
*   [https://allafrica.com/stories/202503090043.html](https://allafrica.com/stories/202503090043.html)
*   [https://www.tralac.org/blog/article/15208-should-rwanda-adopt-a-national-digital-currency.html](https://www.tralac.org/blog/article/15208-should-rwanda-adopt-a-national-digital-currency.html)
*   [https://www.bnr.rw/storage/pdffiles/RESEARCH_PAPER_ON_RWANDA_CENTRAL_BANK_DIGITAL_CURRENCY_CBDC_Final_Version.pdf](https://www.bnr.rw/storage/pdffiles/RESEARCH_PAPER_ON_RWANDA_CENTRAL_BANK_DIGITAL_CURRENCY_CBDC_Final_Version.pdf) (Note: This is a direct link to a PDF download from the National Bank of Rwanda)
*   [https://ecommons.aku.edu/theses_dissertations/1003/](https://ecommons.aku.edu/theses_dissertations/1003/) (Academic research providing context)
*   [https://sanctionscanner.com/aml-compliance-guide/rwanda-aml-sanctions-compliance-guide-134](https://sanctionscanner.com/aml-compliance-guide/rwanda-aml-sanctions-compliance-guide-134) (General AML/CFT information for Rwanda)
*   [https://smileidentity.com/countries/rwanda-kyc-aml-compliance/](https://smileidentity.com/countries/rwanda-kyc-aml-compliance/) (General AML/KYC information for Rwanda)
*   [https://uqudo.com/blog/kyc-solution-in-rwanda/](https://uqudo.com/blog/kyc-solution-in-rwanda/) (General AML/KYC information for Rwanda)
*   [https://smileidentity.com/kyc-aml-compliance-guides/rwanda-kyc-guide/](https://smileidentity.com/kyc-aml-compliance-guides/rwanda-kyc-guide/) (General KYC information for Rwanda)
*   [https://uqudo.com/countries/rwanda/](https://uqudo.com/countries/rwanda/) (General KYC information for Rwanda)

Change Tracking

Change Justification

Explain why this analysis was changed or reconciled

The primary difference between the two analyses lies in the assigned "Current Status" for retail cryptocurrency trading in Rwanda and the nuance in interpreting the impact of the March 2025 draft regulatory framework. The Previous Analysis assigns "Allowed-Regulated," while the New Analysis assigns "In-Progress."

Justification for the differences:

1.  Interpretation of "Draft" vs. "Enacted" Regulation:
    The Previous Analysis, dated March 2025 (the same month the draft law was introduced), interprets the release of the draft regulatory framework as a definitive shift from an "Allowed-Unregulated" state to an "Allowed-Regulated" one. It focuses on the content and intent of the draft law, such as the requirement for VASP licensing by the CMA and AML/CFT measures, as immediately defining the new regulatory environment, even while acknowledging its draft status and potential for evolution. It implies that the rules laid out in the draft are the new operational reality for anyone wishing to trade or offer services.

The New Analysis, dated June 2025, takes a more cautious and process-oriented view. It emphasizes that because the framework is still a "draft law" and was open for public consultation, the regulatory system is not yet fully enacted, finalized, or operational. The status "In-Progress" reflects that while significant steps have been taken towards regulation (the introduction of the draft), the journey to a fully implemented and enforceable regulatory regime is ongoing. It highlights that the final version of the law and its full implementation are still pending, which will ultimately determine the precise conditions for regulated trading.

2.  Timing and Perspective:
    The Previous Analysis was written contemporaneously with the release of the draft law. At that moment, the introduction of such a comprehensive framework might have been perceived as an immediate and substantial change in the regulatory landscape, warranting the "Allowed-Regulated" status based on the new proposed rules.

The New Analysis, with the benefit of a few additional months (June 2025 vs. March 2025), can assess whether the draft has moved significantly towards full enactment. The "In-Progress" status suggests that, as of June 2025, the draft remains a proposal under development rather than a fully operational legal framework. This later perspective allows for a more nuanced understanding that the transition to a regulated environment is a process that takes time beyond the initial announcement of a draft.

3.  Definition of "Regulated":
    The Previous Analysis seems to consider the existence of a detailed draft framework with clear regulatory intentions (licensing, AML/KYC, oversight by CMA) as sufficient to categorize the activity as "Regulated." It focuses on the fact that rules *have been proposed* and authorities are *asking* VASPs to prepare for licensing.

The New Analysis appears to apply a stricter definition of "Regulated," likely requiring the law to be formally passed, gazetted, and the regulatory bodies (CMA) to be actively implementing it, such as by issuing licenses and enforcing compliance under the new law. Since the law is still a draft, these conditions for a fully "Regulated" environment are not yet met, hence "In-Progress."

In essence, both analyses identify the same key event – the introduction of the draft regulatory framework in March 2025. The Previous Analysis views this event as the point of transition to a regulated environment based on the draft's provisions. The New Analysis views it as a critical step *towards* a regulated environment, but one that is not yet complete, thus justifying the "In-Progress" status. The New Analysis more explicitly highlights the ongoing nature of legislative and regulatory implementation.

Previous Status: Allowed-Regulated

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