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North Macedonia

Retail_Trading_Status

Allowed-Regulated Unknown
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Status Changed

Previous status: Gray-Zone

Okay, as a specialized financial regulatory analyst, I've reviewed both the "Previous Analysis" and the "New Analysis" for Retail_Trading_Status in North Macedonia. Here's a detailed breakdown of the changes observed in the "New Analysis" compared to the "Previous Analysis": **I. Overall Status:** * **No Change in Identified Status:** Both analyses correctly identify the status as **"Gray-Zone."** **II. Changes in Detailed Narrative Explanation:** 1. **Emphasis on New Government (2024) and Priorities:** * **Previous:** Mentioned government intent to develop a framework and draft laws influenced by MiCA, with a timeline of 2025-2026 for licensing. * **New:** More specific, stating "A new government formed in 2024 is prioritizing crypto regulation to attract foreign capital and align with EU standards, particularly the Markets in Crypto-Assets (MiCA) framework." It also adds alignment with "Financial Action Task Force (FATF) standards" to the goals for 2025-2026. 2. **Refinement of NBRM's Historical Stance:** * **Previous:** NBRM indicated investing abroad could be illegal under Law on Foreign Exchange Operations; restrictions eased with EU SAA progression. * **New:** More precise, stating NBRM in 2016/2017 said investing was "not allowed, similar to restrictions on investing in foreign securities at the time." It clarifies the "transition to the second phase of the Stabilisation and Association Agreement with the EU, which allowed for investments in foreign markets" as the reason for the evolving stance. 3. **Specific Detail on AML/CTF Law Implementation:** * **Previous:** Mentioned AML/CTF amendments (July 2022) defining virtual assets/VASPs, registration with FIU, ban on privacy coins, €500 cash cap, ban on anonymizing tools. Stated "full regulatory enforcement and further bylaws are still developing." * **New:** Includes all the above but adds a crucial detail: "Specifically, for transactions involving virtual assets valued at EUR 1,000 or more, VASPs are required to provide data on the ordering party and the recipient." It also notes "some necessary bylaws are yet to be adopted" for full implementation. 4. **Future Taxation Clarity:** * **Previous:** Taxation unclear, general expectation to declare under income tax/capital gains, specific guidance lacking. * **New:** Similar, but adds a forward-looking statement: "The forthcoming specific crypto legislation is expected to introduce clear tax treatment for capital gains." 5. **Explicit Mention of Ongoing Work and Digital Denar:** * **Previous:** Implied government work but not detailed. * **New:** Explicitly states: "The Ministry of Finance and the NBRNM are actively working on a legal solution for cryptocurrencies, in consultation with commercial banks and experts. The NBRNM itself is also investigating the possibility of a digital denar." 6. **Inclusion of Ministry of Interior Warnings:** * **Previous:** General mention of risks like fraud. * **New:** Specifically adds: "The Ministry of Interior has issued warnings about fraudulent schemes involving individuals posing as 'financial advisors' offering cryptocurrency trading services, highlighting the risks present in the current environment." 7. **Slightly Different Phrasing and Structure:** The new narrative is restructured in places for clarity and flow, incorporating new information seamlessly. For example, the legal tender status is mentioned earlier. **III. Changes in Specific, Relevant Text Excerpts:** 1. **Updated Source Dates/Versions:** * AInvest: Previous used "June 2025," New uses "June 23, 2025." * CMS Law: Previous used "updated October 2023," New uses "updated October 5, 2023." The excerpt from CMS Law in the new analysis regarding AML/CTF is also more detailed on the cash cap and privacy coin ban. * Financial Intelligence Office: Previous used a Feb 2022 announcement (on the draft law), New uses a July 6, 2022 announcement (on the adopted law). 2. **Addition of New Sources and Excerpts:** * **Telegrafi (undated):** "At the moment, cryptocurrencies are not prohibited in Macedonia... The new government plans to submit a law for the regulation of this issue, with which there will be a tax on cryptocurrencies..." * **CoinStats (undated, referencing 2024 government formation):** Reinforces the gray zone status. * **National Bank of the Republic of North Macedonia (via Crypto.mk, September 28, 2022):** Explicitly states crypto-assets are not legal tender. * **Radio Free Europe (February 17, 2025):** Reinforces that cryptocurrencies are not legal tender. * **European Scientific Journal (April 2023):** "The National Bank... has no authority to regulate... nor a supervisory role regarding crypto assets." * **Advokatsko drustvo Debarliev Dameski & Kelesoska (April 6, 2023):** Confirms the new AML/CTF law defines "virtual assets" and "virtual assets service provider." 3. **Omission/Replacement of Some Previous Excerpts:** * The Radio MOF (quoting National Bank, February 2021) excerpt from the previous analysis is not explicitly included in the new one, though its content regarding legal tender is covered by newer and more direct NBRM statements/sources. * The Bankarstvo.mk excerpt is present in both, but the new analysis has a wider array of sources overall. **IV. Changes in Direct, Accessible URL Links to Sources:** * **Significant Expansion and Update:** The "New Analysis" provides a much more extensive and updated list of URLs. * **New Specific Links:** Includes direct links to: * More recent news articles (e.g., AInvest, Telegrafi, Radio Free Europe). * Specific NBRM pages (FAQ page). * Ministry of Finance announcements. * Financial Intelligence Office announcements regarding the *new* AML law. * Ministry of Interior warnings. * Academic journals (European Scientific Journal). * Legal firm analyses (Advokatsko drustvo Debarliev Dameski & Kelesoska). * **Replacement/Superseding:** Some older or more general links from the "Previous Analysis" may have been replaced by more specific or recent ones in the "New Analysis." For instance, the Wikipedia link is not present in the new list, which prioritizes primary and secondary sources. **Summary of Key Differences:** The "New Analysis" builds upon the "Previous Analysis" by: * Incorporating more recent developments (e.g., new government's focus, FATF alignment). * Providing more granular details on existing regulations (e.g., EUR 1,000 AML threshold). * Adding new dimensions to the regulatory landscape (e.g., NBRM's digital denar investigation, Ministry of Interior warnings). * Referencing a broader and more updated set of specific sources and official documents. Essentially, the "New Analysis" presents a more current, detailed, and nuanced picture of the "Gray-Zone" status, reflecting ongoing regulatory evolution and providing more specific evidence for its claims.

Analysis ID
#386
Version
Latest
Created
2025-06-26 12:49
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 on Retail_Trading_Status 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).

Retail_Trading_Status

Identified Status: Gray-Zone

Detailed Narrative Explanation:

The status of retail cryptocurrency trading in North Macedonia is best described as a "Gray-Zone." While not explicitly banned, the regulatory framework is still under development, creating an environment of legal ambiguity. Individual citizens and residents are engaging in the buying, selling, and holding of cryptocurrencies, primarily through foreign-based exchanges, as there are no licensed domestic crypto exchanges.

Historically, the National Bank of the Republic of North Macedonia (NBRNM) issued warnings regarding the risks associated with cryptocurrencies, including price volatility and fraud. In 2016 and 2017, the NBRNM stated that investing in cryptocurrencies by residents was not allowed, similar to restrictions on investing in foreign securities at the time. However, this stance has evolved. With the country's transition to the second phase of the Stabilisation and Association Agreement with the EU, which allowed for investments in foreign markets, the NBRM has more recently clarified that the lack of specific regulation does not mean cryptocurrencies are illegal. The authorities acknowledge the citizens' interest in investing in cryptocurrencies.

Currently, cryptocurrencies are not considered legal tender in North Macedonia, meaning they cannot be used for official payment transactions within the country; payments must be made in the domestic currency, the denar.

The government has signaled a clear intention to regulate the cryptocurrency sector. A new government formed in 2024 is prioritizing crypto regulation to attract foreign capital and align with EU standards, particularly the Markets in Crypto-Assets (MiCA) framework. Draft laws on digital assets are anticipated by 2025, with the aim to license exchanges and implement stricter Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) rules in line with Financial Action Task Force (FATF) standards by 2025-2026.

The Law on Prevention of Money Laundering and Terrorist Financing (AML/CTF Law), with amendments published in July 2022, has begun to address virtual assets. This law defines "virtual assets" and "virtual asset service providers" (VASPs). It imposes obligations on VASPs regarding customer due diligence, transaction monitoring, and reporting to the Financial Intelligence Unit (FIU). Specifically, for transactions involving virtual assets valued at EUR 1,000 or more, VASPs are required to provide data on the ordering party and the recipient. The AML/CTF Law also prohibits service providers from trading in fully anonymous virtual assets (privacy coins) and from using tools to anonymize transactions. Cash transactions involving crypto are capped at the MKD equivalent of EUR 500. However, the full implementation of these AML/CTF measures for VASPs is still in progress, as some necessary bylaws are yet to be adopted.

Taxation of cryptocurrency gains is currently unclear, though it is generally expected that capital gains tax may apply, and individuals are expected to declare income from digital assets voluntarily under general income tax laws. The forthcoming specific crypto legislation is expected to introduce clear tax treatment for capital gains.

The Ministry of Finance and the NBRNM are actively working on a legal solution for cryptocurrencies, in consultation with commercial banks and experts. The NBRNM itself is also investigating the possibility of a digital denar.

Despite the lack of specific crypto licenses, some entities offer services related to cryptocurrencies, and residents primarily use international platforms. The Ministry of Interior has issued warnings about fraudulent schemes involving individuals posing as "financial advisors" offering cryptocurrency trading services, highlighting the risks present in the current environment. Banks in North Macedonia remain cautious, and some may block crypto-related transactions due to compliance risks.

In summary, retail trading of cryptocurrencies in North Macedonia is not prohibited, but it operates in a developing regulatory landscape. While AML/CTF provisions have begun to cover virtual assets, a comprehensive framework for licensing, taxation, and consumer protection is still in progress, placing the current status firmly in a "Gray-Zone."

Specific, Relevant Text Excerpts:

  • AInvest (June 23, 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 23, 2025): "North Macedonia is working on new crypto regulations for 2025-2026, intending to license exchanges for fighting money laundering and adopting EU standards."
  • Telegrafi (undated, referencing recent government proposals): "At the moment, cryptocurrencies are not prohibited in Macedonia, as there is no special law regulating their use. The new government plans to submit a law for the regulation of this issue, with which there will be a tax on cryptocurrencies..."
  • 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."
  • CoinStats (undated, referencing 2024 government formation): "Currently, crypto operations are under a legal gray zone, where trading is, on one hand, allowed but leaves the consumer without safeguards and unclear rules on taxation."
  • CMS Law (updated October 5, 2023, referencing NBRM announcements): "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 5, 2023, referencing AML/CTF Law): "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, control mechanisms in case of potential misuse of virtual or crypto funds, and trading of virtual assets in cash in the amount of up to EUR 500 in MKD equivalent will be allowed. 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."
  • National Bank of the Republic of North Macedonia (via Crypto.mk, September 28, 2022): "Crypto-assets do not represent a legal means of payment in our country, i.e. it is not allowed to pay with crypto-assets. According to the existing regulation, payments can be made in the domestic currency - the denar." (Original in Macedonian, translated)
  • Radio Free Europe (February 17, 2025): "Cryptocurrencies are not legal tender in North Macedonia - meaning they are not allowed to be used for payment within the territory, the country's National Bank tells Radio Free Europe."
  • Ministry of Finance of the Republic of North Macedonia (October 6, 2020): "The usage of virtual assets as representations of value known as “cryptocurrencies” will be governed by law. At present, Ministry of Finance together with the Financial Intelligence Office, as well as the financial regulators and the supervisors work on determining all aspects arising from this phenomena. Solutions will be implemented in the new Law on Money Laundering and Financing of Terrorism."
  • Financial Intelligence Office of North Macedonia (July 6, 2022, regarding the new AML/CTF Law): "With the adoption of the law, the regulation of the crypto-sphere from the aspect of AML/CFT is established to a certain extent..." (Original in Macedonian, translated)
  • European Scientific Journal (April 2023): "The National Bank of the Republic of North Macedonia has no authority to regulate the creation, holding, or trading, nor a supervisory role regarding crypto assets."
  • Advokatsko drustvo Debarliev Dameski & Kelesoska (April 6, 2023, regarding the new AML/CTF Law): The new Law on anti-money laundering and countering financing of terrorism "...also includes solutions provided for overcoming any risks that previously have... (v.) defines new terms such as: "virtual assets", "virtual assets service provider"..."

Direct, Accessible URL Links to Sources:

Web Sources (18)

Sources discovered via web search grounding

Search queries used (9)
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