Back to Analyses

Mozambique

Retail_Trading_Status

Allowed-Unregulated Unknown
Edit

Status Changed

Previous status: Allowed-UnRegulated

Okay, as a specialized financial regulatory analyst, here's a detailed breakdown of the changes between the "Previous Analysis" and the "New Analysis" regarding the Retail_Trading_Status in Mozambique. **Overall Summary of Changes:** The **Identified Status** remains **"Allowed-UnRegulated"** in both analyses. However, the "New Analysis" presents a slightly less detailed view on recent regulatory advancements concerning Anti-Money Laundering/Counter-Financing of Terrorism (AML/CFT) for Virtual Asset Service Providers (VASPs), which was a key point of emerging regulation in the "Previous Analysis." The "New Analysis" also incorporates more recent (early to mid-2025) general commentary and blog sources, while omitting some of the specific legal and central bank documentation highlighted previously regarding VASP registration. It introduces a new section discussing the pros and cons of regulation from a market perspective. **Detailed Changes Observed:** 1. **Emphasis on VASP AML/CFT Regulation (Law No. 14/2023 & Notice No. 4/GBM/2023):** * **Previous Analysis:** Gave significant weight to Law No. 14/2023 and Notice No. 4/GBM/2023, explaining that VASPs are now considered financial institutions for AML/CFT purposes and require registration with the Banco de Moçambique. It explicitly stated this focuses on *service providers*, not individual trading. It included direct excerpts and links to VdA Law Firm's analysis and the Banco de Moçambique's AML/CFT legislation page. * **New Analysis:** **Significantly de-emphasizes or omits these specific legal instruments.** It makes a general statement: "The Financial Action Task Force (FATF) recommendations, which include the 'travel rule' for virtual asset service providers, are increasingly being adopted globally, and this is likely to influence any future regulatory developments in Mozambique concerning AML/CFT for crypto assets." There is no direct mention of Law No. 14/2023 or Notice No. 4/GBM/2023, nor the requirement for VASPs to register with the Central Bank for AML/CFT purposes. * **Impact:** This is the most substantial change. The "Previous Analysis" indicated a concrete step towards regulating service providers, whereas the "New Analysis" presents a more general outlook on potential AML/CFT influences without referencing the existing specific framework for VASPs. 2. **Narrative on Central Bank Warnings:** * **Previous Analysis:** Focused on the 2018 warnings, highlighting non-legal tender status, lack of supervision, volatility, security risks, and potential illicit use (money laundering, terrorist financing). * **New Analysis:** Reiterates the 2018 warnings, adding "drug trafficking" to the list of illicit activities. It also explicitly states, "any losses incurred from cryptocurrency dealings would not be covered by any protections from the central bank." * **Impact:** Largely consistent, but the "New Analysis" adds a specific illicit activity and clarifies the lack of protection for losses. 3. **Taxation Details:** * **Previous Analysis:** Stated general income tax rules *may* apply and quoted CMS Law (2024-06-12) confirming gains are subject to Corporate or Personal Income Tax. * **New Analysis:** Confirms general tax laws apply and quotes the same CMS Law source. It adds a clarification: "However, there are no national tax laws that impose specific monitoring, documentation, or declaration requirements for crypto-asset activities." * **Impact:** The "New Analysis" provides a more nuanced understanding of the tax situation by highlighting the absence of crypto-specific tax compliance obligations beyond general income reporting. 4. **Trading Platforms and KYC:** * **Previous Analysis:** Mentioned trading via international platforms due to a lack of local regulated exchanges and the associated risks highlighted by the Central Bank. * **New Analysis:** Adds more color, stating some platforms "reportedly offering services in the local currency, the Mozambican Metical (MZN), and even options without mandatory Know Your Customer (KYC) procedures for trading on certain platforms." It then advises choosing secure, compliant exchanges. * **Impact:** The "New Analysis" provides more specific (though unverified "reportedly") details about platform accessibility and practices within Mozambique, including the availability of no-KYC options. 5. **Other Legislation Mentioned:** * **Previous Analysis:** Mentioned the Law on Electronic Transactions (2017) and general cybercrime laws. * **New Analysis:** Specifically names "Law No. 3/2017 of 9 January" (Law on Electronic Transactions) and adds that "in 2019, the parliament ratified the African Union Convention on Cyber Security and Personal Data Protection." * **Impact:** The "New Analysis" is slightly more specific on the electronic transactions law and adds another relevant, albeit general, legal instrument. 6. **Introduction of "Discussion on Regulation":** * **Previous Analysis:** Did not have a dedicated section discussing the arguments for or against regulation. * **New Analysis:** Includes a new paragraph: "The discussion around the need for regulation is ongoing in Mozambique. Proponents argue that clear regulation could provide more security for investors... Conversely, concerns exist that poorly planned regulations could create high fees, bureaucracy, and undue restrictions..." * **Impact:** This adds a new dimension to the analysis, reflecting on the broader debate surrounding crypto regulation in the country. 7. **Supporting Excerpts and Source Links:** * **Previous Analysis:** Heavily relied on official sources like Banco de Moçambique pages (including the AML/CFT specific page), law firm analyses (VdA on Notice 4/GBM/2023), and established legal information providers (CMS Law, Freeman Law). * **New Analysis:** * **Omissions:** Drops the VdA Law Firm analysis of Notice 4/GBM/2023 and the direct link to the Banco de Moçambique's AML/CFT legislation page. The link to the BdM Foreign Exchange Licensing page is also absent. * **Additions:** Introduces newer sources, some of which are blog posts or articles from less formal platforms (e.g., UEEx Technology, Binance Square, Science Publishing Group, Shufti Pro, Scorechain). While some are dated 2025, their depth or authority might differ from the legal analyses previously cited. * **Common Sources:** Retains CMS Law, Freeman Law, Club of Mozambique, and LEX Africa. * **Impact:** The "New Analysis" shifts its source base. While incorporating more recent commentary, it omits some of the key primary and secondary legal sources that underpinned the previous analysis's findings on VASP AML/CFT registration. This contributes to the de-emphasis of that specific regulatory development. **Conclusion of Changes:** While the overarching status of "Allowed-UnRegulated" remains consistent, the "New Analysis" provides an updated perspective that, paradoxically, seems to have *less detail* on the specific AML/CFT VASP registration requirements (Law No. 14/2023 and Notice No. 4/GBM/2023) that were a significant feature of the "Previous Analysis." Instead, it offers more general commentary on the crypto environment, including discussions on the pros and cons of regulation and anecdotal details about trading platforms. The shift in cited sources reflects this change in focus. The "New Analysis" might reflect a view that despite the VASP AML/CFT framework being in place, its practical impact on *retail trading status* or its visibility in general discourse remains limited, or it could be an oversight in the information gathering for the new report.

Analysis ID
#272
Version
Archived
Created
2025-06-26 09:09
Workflow Stage
Initial Research

Executive Summary

Retail cryptocurrency trading in Mozambique is currently in an "Allowed-Unregulated" state, meaning it is not explicitly prohibited but lacks specific regulatory oversight. The Bank of Mozambique has issued warnings regarding the risks of cryptocurrencies, particularly their potential for illicit activities, and has stated it does not regulate or supervise Bitcoin transactions. While general financial laws, like those concerning income tax, may apply to crypto-related gains, there are no dedicated crypto regulations or mandated KYC/AML requirements under Mozambican law.

Key Pillars

The primary regulator is the Bank of Mozambique, which has adopted a cautionary stance towards cryptocurrencies, emphasizing the associated risks without imposing outright prohibitions. Core compliance requirements such as AML and KYC are not specifically mandated by Mozambican law for crypto platforms, though international platforms accessible in Mozambique may adhere to their own standards. Currently, there are no specific licensing or registration requirements for cryptocurrency exchanges or virtual asset service providers within Mozambique.

Landmark Laws

Law on Electronic Transactions (Law No. 3/2017 of 9 January): Establishes the legal framework for electronic transactions, electronic commerce, and consumer protection in the digital space. It does not, however, specifically regulate cryptocurrencies.
African Union Convention on Cyber Security and Personal Data Protection (ratified in 2019): Addresses broader digital activities and cybercrime but does not include specific regulations for cryptocurrencies.

Considerations

Cryptocurrencies are not recognized as legal tender in Mozambique. Gains from crypto asset exchanges are subject to Corporate Income Tax or Personal Income Tax under general legislation. The Bank of Mozambique has raised concerns about the use of cryptocurrencies in illicit activities such as money laundering, terrorist financing, and drug trafficking. Operationally, users may face challenges related to the lack of specific regulatory guidance and the varying levels of KYC/AML compliance among available exchanges, with some platforms offering services without mandatory KYC procedures.

Notes

Historically, the Bank of Mozambique issued warnings in January 2018 about the risks associated with cryptocurrencies, advising citizens to avoid them due to their potential for illicit use and lack of legal standing. Despite the absence of specific regulations, many Mozambicans are exploring Bitcoin as an investment and means of exchange. The discussion regarding the need for crypto regulation is ongoing, with proponents arguing that clear rules could enhance security and attract investment, while opponents fear that poorly designed regulations could stifle market growth. Several exchanges are accessible to Mozambican residents, some offering services in the local currency (MZN) and without mandatory KYC, highlighting the informal nature of the market.

Detailed Explanation

The current status of retail cryptocurrency trading in Mozambique is "Allowed-Unregulated". This means that while no explicit laws prohibit individual citizens and residents from buying, selling, and holding cryptocurrencies, there is no dedicated regulatory framework governing this activity. The Bank of Mozambique, the country's central bank, has historically issued warnings regarding cryptocurrencies. In January 2018, the Bank of Mozambique cautioned the public about the risks associated with cryptocurrencies like Bitcoin, highlighting their potential use in illicit activities such as money laundering, terrorist financing, and drug trafficking. The central bank clarified that it does not regulate, supervise, or monitor transactions involving Bitcoin because it is not issued by a national monetary authority and lacks legal standing in the country. Any losses incurred from cryptocurrency dealings would not be covered by the central bank.

Despite these warnings and the absence of specific regulations, the trading and use of cryptocurrencies are not prohibited. The cryptocurrency market in Mozambique is still in its early stages, and regulations are evolving. The lack of specific legislation creates uncertainty. General financial laws may still apply; for instance, gains from the exchange of crypto-assets for conventional FIAT currency or other crypto-assets are subject to Corporate Income Tax or Personal Income Tax under general legislation. However, there are no national tax laws that impose specific monitoring, documentation, or declaration requirements for crypto-asset activities.

The discussion around the need for regulation is ongoing in Mozambique. Proponents argue that clear regulation could provide more security for investors, encourage greater adoption by companies, attract international investment, and help prevent financial crimes. Concerns exist that poorly planned regulations could create high fees, bureaucracy, and undue restrictions, potentially hindering the growth of the crypto market. Several cryptocurrency exchanges are accessible to Mozambican residents, with some platforms reportedly offering services in the local currency, the Mozambican Metical (MZN), and even options without mandatory Know Your Customer (KYC) procedures for trading on certain platforms.

Mozambique does have a Law on Electronic Transactions (Law No. 3/2017 of 9 January), establishing the legal framework for electronic transactions, electronic commerce, and the protection of consumers in this domain. Additionally, in 2019, the parliament ratified the African Union Convention on Cyber Security and Personal Data Protection. While these laws address broader digital activities and cybercrime, they do not specifically regulate cryptocurrencies. The Financial Action Task Force (FATF) recommendations, including the

Summary Points

Retail Cryptocurrency Trading Status in Mozambique: Regulatory Analysis

I. Overall Regulatory Status:

  • Allowed-Unregulated: Retail cryptocurrency trading (buying, selling, and holding) is permitted but lacks specific regulatory oversight.
  • No explicit laws prohibit cryptocurrency trading for individuals.
  • No dedicated regulatory framework governs cryptocurrencies.

II. Key Regulatory Bodies and Their Roles:

  • Bank of Mozambique (Banco de Moçambique):
    • The central bank has issued warnings about the risks associated with cryptocurrencies (e.g., money laundering, terrorist financing).
    • Does not regulate, supervise, or monitor Bitcoin transactions.
    • Not liable for losses resulting from cryptocurrency transactions.
    • Companies transacting with Bitcoin are not regulated under Mozambican law.
  • Parliament: Ratified the African Union Convention on Cyber Security and Personal Data Protection in 2019.

III. Important Legislation and Regulations:

  • Lack of Crypto-Specific Legislation: No specific laws or regulations dedicated to cryptocurrencies.
  • General Financial Laws:
    • Gains from crypto-asset exchanges are subject to Corporate Income Tax or Personal Income Tax.
    • No national tax laws impose specific monitoring, documentation, or declaration requirements for crypto-asset activities.
  • Law on Electronic Transactions (Law No. 3/2017 of 9 January):
    • Establishes the legal framework for electronic transactions, electronic commerce, and consumer protection in this domain.
    • Does not specifically regulate cryptocurrencies.
  • African Union Convention on Cyber Security and Personal Data Protection (2019):
    • Addresses broader digital activities and cybercrime.
    • Does not specifically regulate cryptocurrencies.

IV. Requirements for Compliance:

  • No Specific KYC/AML Requirements: No specific KYC/AML requirements for crypto platforms mandated by Mozambican law.
  • International Standards: Users are recommended to choose exchanges that prioritize security, transparency, and compliance with international standards, including KYC/AML measures.
  • FATF Recommendations: The Financial Action Task Force (FATF) recommendations, including the "travel rule" for virtual asset service providers, are increasingly being adopted globally, and this is likely to influence any future regulatory developments in Mozambique concerning AML/CFT for crypto assets.

V. Notable Restrictions or Limitations:

  • Lack of Legal Protection: Losses incurred from cryptocurrency dealings are not covered by any protections from the central bank.
  • Central Bank Warnings: The Bank of Mozambique has cautioned the public about the risks associated with cryptocurrencies.
  • Uncertainty: The lack of specific legislation creates uncertainty for investors and businesses.

VI. Recent Developments or Changes:

  • Ongoing Discussion: Discussions are ongoing regarding the need for cryptocurrency regulation in Mozambique.
  • Early Stage Market: The cryptocurrency market is still considered to be in its early stages, with regulations evolving.
  • Accessibility of Exchanges: Several cryptocurrency exchanges are accessible to Mozambican residents, with some platforms reportedly offering services in the local currency, the Mozambican Metical (MZN), and even options without mandatory Know Your Customer (KYC) procedures for trading on certain platforms.
  • Global Trends: Increasing adoption of FATF recommendations globally is likely to influence future regulatory developments in Mozambique.

Full Analysis Report

Report on the Current Status of Retail Trading of Cryptocurrencies in Mozambique

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 Current Status: Allowed-Unregulated

2. Detailed Narrative Explanation:

Retail cryptocurrency trading, including buying, selling, and holding, is currently Allowed-Unregulated in Mozambique. This means that while there are no specific laws explicitly prohibiting the activity for individual citizens and residents, there is also no dedicated regulatory framework governing cryptocurrencies.

Historically, the Bank of Mozambique (Banco de Moçambique), the country's central bank, has issued warnings regarding cryptocurrencies. In January 2018, the Bank of Mozambique cautioned the public about the risks associated with cryptocurrencies like Bitcoin, highlighting their potential use in illicit activities such as money laundering, terrorist financing, and drug trafficking. The central bank clarified that it does not regulate, supervise, or monitor transactions involving Bitcoin because it is not issued by a national monetary authority and lacks legal standing in the country. This stance essentially means that any losses incurred from cryptocurrency dealings would not be covered by any protections from the central bank.

Despite these warnings and the absence of specific regulations, the trading and use of cryptocurrencies are not prohibited. The cryptocurrency market in Mozambique is still considered to be in its early stages, with regulations evolving. There is an acknowledgment that the lack of specific legislation creates uncertainty.

While there is no crypto-specific legislation, general financial laws may still apply. For instance, any gains from the exchange of crypto-assets for conventional FIAT currency or other crypto-assets are subject to Corporate Income Tax or Personal Income Tax under general legislation. However, there are no national tax laws that impose specific monitoring, documentation, or declaration requirements for crypto-asset activities.

The discussion around the need for regulation is ongoing in Mozambique. Proponents argue that clear regulation could provide more security for investors, encourage greater adoption by companies, attract international investment, and help prevent financial crimes. Conversely, concerns exist that poorly planned regulations could create high fees, bureaucracy, and undue restrictions, potentially hindering the growth of the crypto market.

Several cryptocurrency exchanges are accessible to Mozambican residents, with some platforms reportedly offering services in the local currency, the Mozambican Metical (MZN), and even options without mandatory Know Your Customer (KYC) procedures for trading on certain platforms. However, the general trend globally, and a recommendation for users in Mozambique, is to choose exchanges that prioritize security, transparency, and compliance with international standards, including KYC/AML measures. The Financial Action Task Force (FATF) recommendations, which include the "travel rule" for virtual asset service providers, are increasingly being adopted globally, and this is likely to influence any future regulatory developments in Mozambique concerning AML/CFT for crypto assets.

Mozambique does have a Law on Electronic Transactions (Law No. 3/2017 of 9 January) which establishes the legal framework for electronic transactions, electronic commerce, and the protection of consumers in this domain. Additionally, in 2019, the parliament ratified the African Union Convention on Cyber Security and Personal Data Protection. While these laws address broader digital activities and cybercrime, they do not specifically regulate cryptocurrencies.

In summary, individuals in Mozambique can engage in cryptocurrency trading, but they do so in an environment that lacks specific regulatory oversight for these assets. The central bank has warned about the risks, and while general tax laws apply to profits, there are no dedicated crypto regulations, including specific KYC/AML requirements for crypto platforms mandated by Mozambican law, though international platforms may apply their own standards.

3. Specific, Relevant Text Excerpts:

  • UEEx Technology (2025-04-25): "The legality of crypto exchanges in Mozambique remains unclear. Although, the cryptocurrency market is still in its early stages, and regulations are evolving. The Bank of Mozambique has not officially recognized cryptocurrencies as legal tender, but trading and using crypto are not prohibited."
  • CMS Law (2024-06-12): "As mentioned at Q1, 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."
  • CMS Law (2024-06-12): "There is no specific law that imposes specific obligations on the activity of crypto-assets."
  • Freeman Law (referencing a Club of Mozambique article from Jan 9, 2020, which cites a 2018 Bank of Mozambique statement): "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."
  • Club of Mozambique (2018-01-09, citing a Bank of Mozambique statement): "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."
  • Club of Mozambique (2018-01-09, citing a Bank of Mozambique statement): "The central bank however goes on to warn that, although there are benefits, there are also risks that need to be safeguarded against because, given its nature, the currency may be linked to criminal activities such as money laundering, terrorist financing and drug trafficking, for example."
  • Binance Square, VINTE FERNANDO SANDE (2025-03-26): "While countries like Nigeria and South Africa are advancing in the regulation of the crypto sector, Mozambique still lacks specific laws."
  • LEX Africa (quoting Célia Francisco, partner at CGA in Maputo): "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, according to Célia Francisco, partner at CGA in Maputo. She says that in one of the bank's statements it said 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."
  • Science Publishing Group (2025-03-06): "Despite the lack of specific cryptocurrency regulation by the Central Bank, many Mozambicans are exploring Bitcoin as an investment and means of exchange, drawn by the potential for high returns and the convenience of digital transactions."

4. Direct, Accessible URL Links to Specific Sources:

Web Sources (13)

Sources discovered via web search grounding

Search queries used (5)
  • current status of retail cryptocurrency trading in Mozambique 2025
  • Mozambique cryptocurrency laws and regulations for individuals 2025
  • Banco de Moçambique official statements on cryptocurrency 2025
  • AML/KYC requirements for cryptocurrency platforms in Mozambique 2025
  • Is cryptocurrency trading legal for citizens in Mozambique 2025
Source

Source

Source

Source

Source

Source

Source

Source

Source

Source

Source

Source

Source

Reviews

No reviews yet

Submit Review

Challenge: Disagree with the analysis | Approval: Confirm it's correct | Refinement: Suggest improvements