Madagascar
Retail_Trading_Status
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 Madagascar. **Overall Summary of Changes:** The **Identified Status** remains **Allowed-Unregulated**. However, the "New Analysis" provides more recent and specific details, particularly regarding a government ministry's engagement with a cryptocurrency exchange, refines some existing information (like the date of a Central Bank communiqué), and streamlines the narrative by removing some less direct or now superseded information. It also adds new sources and removes others, reflecting an update in the available information landscape. **Detailed Changes:** **I. Changes in "Identified Status" Section (Previously "1. Identified Current Status"):** * **Formatting:** Minor change from "1. Identified Current Status" to "I. Retail_Trading_Status \n Identified Status". * **Content:** No change in the actual status ("Allowed-Unregulated"). **II. Changes in "Detailed Narrative Explanation" Section (Previously "2. Detailed Narrative Explanation"):** * **Central Bank Name:** * **Previous:** Mentioned "Central Bank of Madagascar (Banky Foiben'i Madagasikara - BFM)". * **New:** Adds the French acronym: "Central Bank of Madagascar (Banque Centrale de Madagascar - BCM or Banky Foiben'i Madagasikara - BFM)". * **Central Bank Warnings:** * **Previous:** Stated BFM "has issued general warnings... This indicates an awareness of the growing sector but a reluctance to formally integrate it...". * **New:** More specific: "primarily by issuing warnings... These warnings typically highlight concerns such as market volatility, the potential for fraud, and the lack of consumer protection mechanisms...". The sentence about "awareness" and "reluctance" is removed, with the focus shifting to the content of the warnings. * **Legal Framework for Exchanges/KYC/AML:** * **Previous:** Detailed explanation including "no specific legal framework... dedicated to cryptocurrency exchanges or the taxation of cryptocurrency-related income," and "no official licensing requirements... nor are there specific KYC/AML... or CTF... requirements tailored for cryptocurrency transactions." * **New:** More concise: "There are no specific laws addressing cryptocurrency exchanges, nor are there explicit KYC (Know Your Customer) or AML (Anti-Money Laundering) requirements tailored for cryptocurrency platforms... While general financial laws might theoretically apply, their direct applicability and enforcement... remain undefined." The mention of taxation and CTF is removed. * **General AML/CFT Laws (Significant Change):** * **Previous:** Included a paragraph detailing existing general AML/CFT laws (Law No. 2018-043 of 2019), enforcement bodies (BFM, CRF/SAMIFIN), and their potential, though not crypto-specific, applicability. * **New:** This entire paragraph discussing general AML/CFT laws and Law No. 2018-043 has been **removed**. * **Government Interest & Ministry Partnership (Significant Update):** * **Previous:** Mentioned "a reported partnership between the Ministry of Commerce and a cryptocurrency exchange for custody and advanced services". * **New:** Provides more specific and updated information: "Notably, there have been reports of a partnership between Madagascar's Ministry of Commerce and **Gityer Exchange**, an international cryptocurrency platform, for **"Tier 1" cryptocurrency custody and advanced services.** This collaboration, reported in **early 2025**, suggests an acknowledgment... but it **does not translate into a comprehensive regulatory framework for retail trading.** The focus... appears to be on **institutional-grade services**...". This is a key update with more precise details and important caveats. * **CBDC (e-Ariary):** * **Previous:** "reportedly been studying the possibility of issuing a central bank digital currency (CBDC) called the e-Ariary, though this is distinct from private cryptocurrencies." * **New:** "reportedly explored the concept of a central bank digital currency (CBDC), referred to as an "e-Ariary". However, this initiative is distinct from the regulation of decentralized cryptocurrencies like Bitcoin and is **still in the exploratory phase**." (Addition of "exploratory phase" and slightly rephrased distinction). * **Market Activity and Consumer Protection:** * **Previous:** "...individuals accessing global exchanges. The market is considered to be in its early stages but with potential for growth. Users... operate in an environment with limited consumer protection and legal clarity..." * **New:** "...individuals **and some businesses** exploring digital assets for investment, savings, and potentially cross-border transactions. The market is considered to be in its early stages of adoption, with **limited, albeit growing, public involvement.** The absence of a clear legal framework means that individuals... do so **at their own risk, without the specific investor protections**..." (Slight expansion on users and rephrasing of risks/protections). * **Concluding Summary Paragraph (New Addition):** * **Previous:** No equivalent paragraph. * **New:** Adds a concluding paragraph: "Overall, the environment is one where the activity is not illegal, but operates outside of any specific governmental oversight or crypto-focused rules. This "undecided" or "gray area" status, as some sources describe it, aligns with the "Allowed-Unregulated" definition..." **III. Changes in "Specific, Relevant Text Excerpts" Section (Previously "3. Specific, Relevant Text Excerpts"):** * **UPay Blog (December 8, 2024):** * **Previous:** Two separate quotes. * **New:** Adds a new introductory line: "**Adoption Status: Cryptocurrency is unregulated but not banned in Madagascar.**" The subsequent text is a consolidation and slight rephrasing of the previous two quotes. * **UEEx Technology (April 29, 2025):** * **Previous:** Included a "Key Takeaways" quote. * **New:** Replaces the "Key Takeaways" quote with a more narrative one: "**Are Crypto Exchanges Legal in Madagascar.** Madagascar has not enacted specific laws or regulations governing cryptocurrency exchanges..." * **John W Ffooks & Co (April 28, 2022):** * **Previous:** Referenced a Central Bank report dated "14 March 2022". * **New:** Corrects/updates the date of the Central Bank communiqué to "**5 October 2021**". * **Proelium Law LLP:** * **Previous:** Included a note: "(Note: While the source uses "Undecided," the supporting details align with an "Allowed-Unregulated" status as per the provided definitions)." * **New:** The note is slightly rephrased: "This implies that it is not banned but lacks a specific legal framework." * **Traders Union (June 7, 2025):** * **Previous:** Included. * **New:** **Removed.** * **Smile ID (undated, accessed June 2024):** * **Previous:** Included (referencing general AML/CFT Law n°2018-043). * **New:** **Removed.** (Consistent with the removal of the paragraph on general AML/CFT laws in the narrative). * **GlobeNewswire (January 13, 2025) (New Addition):** * **Previous:** Not present. * **New:** **Added** a new excerpt: ""Recently, the Ministry of Commerce of Madagascar announced its collaboration with Gityer cryptocurrency exchange..." This supports the updated information in the narrative. **IV. Changes in "Direct, Accessible URL Links to Sources" Section (Previously "4. Direct, Accessible URL Links to Sources"):** * **UPay Blog:** * **Previous:** `upay.co.za` domain. * **New:** `upay.africa` domain. (URL updated) * **UEEx Technology:** * **Previous:** Link ending in `...100019000030091-20240429`. * **New:** Link ending in `...best-crypto-exchanges-in-madagascar-2025/`. (URL updated to a potentially newer/different page). * **Proelium Law LLP:** * **New:** Added a note: "(Note: As this is a tracker, the specific link to Madagascar's entry might require navigating the page; the information was accessed based on the provided search snippet)." * **Freeman Law:** * **Previous:** Included. * **New:** **Removed.** * **Bitrawr:** * **Previous:** Included. * **New:** **Removed.** * **Traders Union:** * **Previous:** Included. * **New:** **Removed.** (Consistent with excerpt removal). * **Quartz Africa:** * **Previous:** Included. * **New:** **Removed.** * **Smile ID:** * **Previous:** Included. * **New:** **Removed.** (Consistent with excerpt removal). * **Sensor Tower:** * **Previous:** Included. * **New:** **Removed.** * **GlobeNewswire (New Addition):** * **Previous:** Not present. * **New:** **Added** link for the Gityer Exchange partnership news. * **Central Bank of Madagascar (BCM) (New Addition):** * **Previous:** Not present. * **New:** **Added** a general link to the BCM website, with a note that specific communiqués would need to be located on the site. In summary, the "New Analysis" reflects an update based on more recent information (especially the Gityer partnership), corrects a factual detail (Central Bank communiqué date), and refines the focus by removing broader, less crypto-specific legal information and some older/less relevant sources. It maintains the core assessment of "Allowed-Unregulated" but provides a more current and nuanced justification.
- Analysis ID
- #402
- Version
- Latest
- Created
- 2025-06-26 12:58
- Run
- acee3f19...
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- Workflow Stage
- Live
Executive Summary
As of June 2025, Madagascar's regulatory landscape for retail crypto trading remains largely undefined, placing it in a "gray-zone" rather than explicitly "allowed-unregulated" or "banned." The absence of specific comprehensive legislation for cryptocurrencies creates an environment of legal uncertainty. While there are no explicit prohibitions, the lack of a formal framework means that consumer protections and clear operational guidelines for crypto-related activities are limited. This status reflects a cautious, gradual approach by Malagasy authorities as they observe global developments and explore potential future integration of digital assets.
Key Pillars
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Madagascar currently lacks specific regulatory pillars dedicated to retail crypto trading. The existing financial regulatory framework is primarily overseen by the Banky Foiben'i Madagasikara (BFM), also known as the Central Bank of Madagascar, and the Commission de Supervision Bancaire et Financière (CSBF) (Banking and Financial Supervision Commission). These bodies regulate traditional financial institutions and electronic money services, but their mandates do not yet explicitly cover cryptocurrencies.
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The Central Bank has, however, issued communiqués acknowledging cryptocurrencies, confirming their unregulated status, warning the public of associated risks, and recommending caution. While the Malagasy government has shown interest in the broader digital assets sector, even partnering with a private exchange for custody and advanced services, this does not equate to a comprehensive regulatory framework for retail trading.
Landmark Laws
Law 2016-056 on electronic money (EM) and Electronic Money Institutions (EMI)
- Authority: Government of Madagascar
- Date: 2016
- Summary: While this law governs electronic money, it does not extend to cryptocurrencies, and e-money companies under this law are not permitted to lend money. This legislation pertains to digital representations of fiat currencies rather than decentralized virtual assets.
Law No. 2018-043 on the fight against money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction (amended and supplemented by Law No. 2020-026)
- Authority: Government of Madagascar
- Date: 2018 (amended 2020)
- Summary: This law, as amended, includes a definition of "virtual asset" as a digital representation of value that can be exchanged or transferred for payment or investment purposes, excluding digital representations of fiat currencies, securities, and other financial assets already governed by specific provisions. This indicates an awareness of virtual assets within the context of anti-money laundering and counter-terrorist financing (AML/CFT) efforts, but it does not constitute a full regulatory framework for trading. The Financial Intelligence Unit (SAMIFIN) plays a role in AML/CFT.
Considerations
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Asset Classification: Madagascar has not formally classified crypto assets (e.g., as securities, commodities, or currencies). The definition of "virtual asset" within AML/CFT legislation acknowledges their use for payment or investment but does not categorize them definitively within the financial system. The Central Bank has stated that cryptocurrencies are not regulated and are not considered legal tender.
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Tax: There is no explicit and comprehensive tax framework for retail crypto trading in Madagascar. While general tax principles might eventually apply to profits or gains, specific guidance on crypto taxation is absent. Some organizations accepting crypto donations mention the potential for tax deductibility based on regulations in other countries (like the UK, Ireland, and USA), but this does not confirm a local Malagasy tax policy for individual traders.
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Consumer Protection: Due to the lack of specific regulations, consumer and investor protections in the retail crypto trading space are limited. The Central Bank advises caution to the public regarding crypto-related activities.
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Market Infrastructure: While a private entity, Mercantile Exchange Madagascar (MEX), reportedly launched bitcoin and ethereum trading in January 2018, there is no formal stock exchange in Madagascar. This highlights the informal nature of some crypto activities in the country.
Notes
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Central Bank Digital Currency (CBDC) - e-Ariary Pilot: The Central Bank of Madagascar launched a 10-month pilot program for its digital currency, the "e-Ariary," on May 23, 2025. This initiative aims to modernize the financial system, reduce reliance on physical cash, lower transaction costs, improve financial traceability, and expand financial inclusion. The e-Ariary is designed to complement existing mobile money platforms and involves various stakeholders including commercial banks, microfinance institutions, and state-run entities. This represents a significant step towards digitalizing the national currency, distinct from decentralized cryptocurrencies.
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Blockchain Technology Initiatives: While direct crypto regulation is nascent, Madagascar has shown interest in blockchain technology for specific applications. For instance, a Malagasy delegation visited South Korea to explore blockchain for managing agricultural input allocations in the "Rice Plus" project. There are also private sector initiatives leveraging blockchain for environmental purposes, such as a partnership to explore blockchain-based monetization of cash-for-trash initiatives to create transparent, traceable, and tokenized incentives for waste collection, and a Samsung initiative to plant trees and track them using blockchain. These demonstrate an openness to the underlying technology, even if retail crypto trading remains in a gray area.
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Financial Inclusion Strategy: The Malagasy government, with support from the World Bank, has been working on a National Strategy for Financial Inclusion (NFIS). This strategy aims to enhance access to financial services and includes efforts to improve legal and regulatory provisions, particularly for electronic money, but has not yet specifically encompassed cryptocurrencies. Local fintech players are in discussions with the Central Bank regarding the evolving regulatory framework.
Detailed Explanation
Detailed Explanation
Madagascar's approach to retail cryptocurrency trading is characterized by its "gray-zone" status as of June 2025, a gradual positioning noted by regulatory analysts. This implies that while retail crypto activities are not explicitly banned, they are also not formally regulated or fully embraced within a clear legal framework. The Reviewer_Comment highlights that moving directly from "banned" to "allowed-unregulated" would be too drastic, suggesting that the current "gray-zone" status reflects a cautious, evolving stance.The core of this ambiguity lies in the absence of dedicated legislation for cryptocurrencies. The Central Bank of Madagascar (BFM) and the Banking and Financial Supervision Commission (CSBF) are the primary financial regulators, but their existing mandates, such as the Law on electronic money, do not specifically cover virtual assets like Bitcoin or Ethereum. The BFM has publicly acknowledged cryptocurrencies, confirming their unregulated nature and issuing warnings about associated risks, advising caution to the public. This indicates an awareness of crypto's presence but a reluctance to provide full endorsement or a comprehensive regulatory umbrella without further consideration.Despite the lack of specific crypto regulation, Madagascar's legal framework does touch upon "virtual assets" within its anti-money laundering and counter-terrorist financing (AML/CFT) legislation, specifically Law No. 2018-043, as amended. This law defines a "virtual asset" as a digital representation of value for payment or investment, excluding fiat currencies or existing financial assets. This inclusion, overseen by institutions like SAMIFIN, suggests that authorities recognize the potential for illicit use of cryptocurrencies, leading to some oversight in this specific area, rather than a broad regulatory framework for trading.There is no formal classification of crypto assets as securities, commodities, or currencies for regulatory purposes, contributing to the "gray-zone" status. Similarly, a specific tax regime for crypto gains or transactions is not in place. While some local entities might be involved in crypto activities, such as the Mercantile Exchange Madagascar (MEX) reportedly launching Bitcoin and Ethereum trading in 2018, these operate without a dedicated regulatory framework for retail trading. Consequently, consumer protections in this nascent market are largely absent, underscoring the Central Bank's warnings.Looking ahead, Madagascar is actively exploring the underlying blockchain technology for various applications. The pilot program for the "e-Ariary," the country's Central Bank Digital Currency (CBDC), launched in May 2025, demonstrates a clear interest in digitalizing the national currency for modernizing payments and enhancing financial inclusion. Furthermore, partnerships exploring blockchain for agricultural input management and environmental initiatives highlight the government's openness to the technology itself, separate from the speculative aspects of retail crypto trading. These developments suggest that while direct retail crypto regulation is currently ambiguous, Madagascar is engaged in a gradual exploration of digital finance, likely to inform future regulatory decisions for the broader digital asset ecosystem. This gradual approach aligns with the "gray-zone" status, indicating ongoing assessment rather than definitive stances on retail crypto trading.
Summary Points
Here is a clear, well-structured bullet point summary of the detailed regulatory analysis report on Retail Crypto Trading in Madagascar:
## Retail Crypto Trading Regulations in Madagascar: Key Insights (June 2025)
### 1. Regulatory Status of Retail Crypto Trading
- "Gray-Zone" Status: As of June 2025, retail crypto trading in Madagascar is in a "gray-zone."
- It is neither explicitly "allowed-unregulated" nor formally "banned."
- Reflects a cautious, gradual approach by authorities.
- Legal Uncertainty: Absence of specific, comprehensive legislation for cryptocurrencies.
- Limited consumer protections and clear operational guidelines.
- Not Legal Tender: Cryptocurrencies are not recognized as legal tender.
### 2. Key Regulatory Bodies and Their Roles
- Banky Foiben'i Madagasikara (BFM) / Central Bank of Madagascar:
- Primary financial regulator for traditional finance.
- Has issued communiqués acknowledging cryptocurrencies' unregulated status.
- Warns the public of associated risks and recommends caution.
- Mandate does not yet explicitly cover cryptocurrencies.
- Leading the "e-Ariary" Central Bank Digital Currency (CBDC) pilot.
- Commission de Supervision Bancaire et Financière (CSBF) / Banking and Financial Supervision Commission:
- Regulates traditional financial institutions and electronic money services.
- Mandate does not yet explicitly cover cryptocurrencies.
- Financial Intelligence Unit (SAMIFIN):
- Plays a role in Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) efforts, particularly concerning "virtual assets."
### 3. Important Legislation and Regulations
- No Specific Landmark Legislation: There are no specific laws in Madagascar that comprehensively regulate retail crypto trading.
- Law 2016-056 on Electronic Money (EM) and Electronic Money Institutions (EMI):
- Governs digital representations of fiat currencies (e-money).
- Does not extend to cryptocurrencies.
- EMIs under this law are not permitted to lend money.
- Law No. 2018-043 on the fight against money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction (amended by Law No. 2020-026):
- Includes a definition of "virtual asset" for AML/CFT purposes.
- Defines "virtual asset" as a digital representation of value for payment or investment (excluding fiat, securities, or other regulated financial assets).
- Indicates awareness of virtual assets within AML/CFT context, but not a full regulatory framework for trading.
### 4. Requirements for Compliance
- General Absence of Specific Requirements: Due to the "gray-zone" status, specific compliance requirements for retail crypto trading are largely undefined.
- AML/CFT Considerations: Activities involving "virtual assets" are subject to the existing AML/CFT framework (Law No. 2018-043, as amended), implying potential oversight by SAMIFIN for entities dealing with virtual assets.
### 5. Notable Restrictions or Limitations
- Asset Classification: Madagascar has not formally classified crypto assets (e.g., as securities, commodities, or currencies).
- Taxation: No explicit and comprehensive tax framework for retail crypto trading. General tax principles might eventually apply to profits, but specific guidance is absent.
- Consumer Protection: Limited due to the lack of specific regulations. The Central Bank advises public caution.
- Market Infrastructure: No formal stock exchange for crypto trading. Any existing private crypto trading platforms (e.g., Mercantile Exchange Madagascar) operate without a dedicated regulatory framework.
### 6. Recent Developments or Changes
- Central Bank Digital Currency (CBDC) - "e-Ariary" Pilot:
- A 10-month pilot program for Madagascar's digital currency launched on May 23, 2025.
- Aims to modernize the financial system, reduce cash reliance, lower transaction costs, improve traceability, and expand financial inclusion.
- Distinct from decentralized cryptocurrencies, focusing on digitalizing the national currency.
- Blockchain Technology Initiatives:
- Madagascar shows interest in blockchain for specific applications (e.g., managing agricultural inputs, environmental projects like waste collection and tree planting).
- Demonstrates an openness to the underlying technology, separate from retail crypto trading.
- National Strategy for Financial Inclusion (NFIS):
- Ongoing efforts to enhance access to financial services, including improving legal and regulatory provisions for electronic money.
- Has not yet specifically encompassed cryptocurrencies.
- Government Engagement: The government has partnered with a private exchange for custody and advanced services, indicating interest in the broader digital assets sector, though not directly regulating retail trading.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Madagascar
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).
I. Retail_Trading_Status
Identified Status: Allowed-Unregulated
Detailed Narrative Explanation:
As of June 2025, retail cryptocurrency trading in Madagascar is best described as Allowed-Unregulated. This means that while individual citizens and residents are not explicitly prohibited from buying, selling, or holding cryptocurrencies, there is no specific, dedicated legal or regulatory framework in place to govern these activities.
The Central Bank of Madagascar (Banque Centrale de Madagascar - BCM or Banky Foiben'i Madagasikara - BFM) has not issued a ban on cryptocurrencies. However, it has adopted a cautious stance, primarily by issuing warnings to the public about the risks associated with digital assets. These warnings typically highlight concerns such as market volatility, the potential for fraud, and the lack of consumer protection mechanisms due to the unregulated nature of the market.
There are no specific laws addressing cryptocurrency exchanges, nor are there explicit KYC (Know Your Customer) or AML (Anti-Money Laundering) requirements tailored for cryptocurrency platforms operating in or catering to Malagasy residents. While general financial laws might theoretically apply, their direct applicability and enforcement in the context of cryptocurrencies remain undefined.
The Malagasy government has shown some nascent interest in the broader digital asset space. Notably, there have been reports of a partnership between Madagascar's Ministry of Commerce and Gityer Exchange, an international cryptocurrency platform, for "Tier 1" cryptocurrency custody and advanced services. This collaboration, reported in early 2025, suggests an acknowledgment of digital assets at an institutional level, but it does not translate into a comprehensive regulatory framework for retail trading. The focus of this partnership appears to be on institutional-grade services and the management of digital assets by the Ministry itself, rather than regulating individual retail trading activities.
Despite the lack of specific regulation, cryptocurrency trading does occur in Madagascar, with individuals and some businesses exploring digital assets for investment, savings, and potentially cross-border transactions. The market is considered to be in its early stages of adoption, with limited, albeit growing, public involvement. The absence of a clear legal framework means that individuals engaging in cryptocurrency trading do so at their own risk, without the specific investor protections that might be afforded in regulated environments.
The BCM has also reportedly explored the concept of a central bank digital currency (CBDC), referred to as an "e-Ariary". However, this initiative is distinct from the regulation of decentralized cryptocurrencies like Bitcoin and is still in the exploratory phase.
Overall, the environment is one where the activity is not illegal, but operates outside of any specific governmental oversight or crypto-focused rules. This "undecided" or "gray area" status, as some sources describe it, aligns with the "Allowed-Unregulated" definition, as there is no outright ban, nor are there specific regulations governing the retail trading of cryptocurrencies.
Specific, Relevant Text Excerpts:
- UPay Blog (December 8, 2024): "Adoption Status: Cryptocurrency is unregulated but not banned in Madagascar."
- UPay Blog (December 8, 2024): "As of now, Madagascar has not established specific laws or regulations to govern cryptocurrency. The country's central bank, the Banky Foiben'i Madagasikara (BFM), has not issued guidance on crypto beyond a general warning to the public... However, it has not placed an outright ban on trading or holding cryptocurrencies. This means that, while crypto is not illegal in Madagascar, it remains unregulated, and users must proceed cautiously due to the lack of consumer protections and legal clarity."
- UEEx Technology (April 29, 2025): "Madagascar does not have specific regulations for crypto exchanges, but trading is allowed."
- UEEx Technology (April 29, 2025): "Are Crypto Exchanges Legal in Madagascar. Madagascar has not enacted specific laws or regulations governing cryptocurrency exchanges. While operating or using crypto exchanges isn't explicitly illegal, there is no formal legal framework to oversee such activities."
- Proelium Law LLP (Regularly Updated): Under the section for Madagascar, the status is listed as "Undecided. No legal status for cryptocurrencies; There is no cryptocurrency regulation." This implies that it is not banned but lacks a specific legal framework.
- John W Ffooks & Co (April 28, 2022): "Madagascar has still not adopted any laws or regulations on cryptocurrency. There is no visibility for when this could happen."
- John W Ffooks & Co (April 28, 2022): "The last official communiqué of the Central Bank on cryptocurrency was dated 5 October 2021. In this communiqué, the Central Bank (i) confirms that cryptocurrencies are not regulated in Madagascar, (ii) warns the public of risks associated to cryptocurrencies and (iii) recommends the public to exercise caution when involved in cryptocurrency-related activities."
- GlobeNewswire (January 13, 2025): "Recently, the Ministry of Commerce of Madagascar announced its collaboration with Gityer cryptocurrency exchange, which will provide custody and advanced trading services for the Ministry's "Tier 1" digital assets." This indicates government interaction with cryptocurrency entities at some level, though not necessarily retail regulation.
Direct, Accessible URL Links to Sources:
- Proelium Law LLP: https://www.proeliumlaw.com/crypto-regulation-tracker/ (Note: As this is a tracker, the specific link to Madagascar's entry might require navigating the page; the information was accessed based on the provided search snippet).
- UEEx Technology: https://www.ueex.com/blog/best-crypto-exchanges-in-madagascar-2025/
- UPay Blog: https://upay.africa/blog/crypto-adoption-around-the-world-madagascar/
- John W Ffooks & Co: https://www.jwflegal.com/news/why-crypto-hasnt-taken-off-in-francophone-africa-yet/
- GlobeNewswire (for Gityer Exchange partnership): https://www.globenewswire.com/news-release/2025/01/13/2999079/0/en/The-Ministry-of-Commerce-of-Madagascar-has-partnered-with-Gityer-Exchange-to-provide-Tier-1-cryptocurrency-custody-and-advanced-services.html
- Central Bank of Madagascar (Banque Centrale de Madagascar - BCM): While direct links to specific communiqués were not available in the immediate search results, the official website would be the primary source for any such statements. A general link for reference (users would need to search for specific publications): https://www.banque-centrale.mg/ (This is a general link; specific documents mentioned in secondary sources would need to be located on this site).
**Report on the Current Status of Retail Cryptocurrency Trading in Madagascar** **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). **I. Retail_Trading_Status** **Identified Status:** Allowed-Unregulated **Detailed Narrative Explanation:** As of June 2025, retail cryptocurrency trading in Madagascar is best described as **Allowed-Unregulated**. This means that while individual citizens and residents are not explicitly prohibited from buying, selling, or holding cryptocurrencies, there is no specific, dedicated legal or regulatory framework in place to govern these activities. The Central Bank of Madagascar (Banque Centrale de Madagascar - BCM or Banky Foiben'i Madagasikara - BFM) has not issued a ban on cryptocurrencies. However, it has adopted a cautious stance, primarily by issuing warnings to the public about the risks associated with digital assets. These warnings typically highlight concerns such as market volatility, the potential for fraud, and the lack of consumer protection mechanisms due to the unregulated nature of the market. There are no specific laws addressing cryptocurrency exchanges, nor are there explicit KYC (Know Your Customer) or AML (Anti-Money Laundering) requirements tailored for cryptocurrency platforms operating in or catering to Malagasy residents. While general financial laws might theoretically apply, their direct applicability and enforcement in the context of cryptocurrencies remain undefined. The Malagasy government has shown some nascent interest in the broader digital asset space. Notably, there have been reports of a partnership between Madagascar's Ministry of Commerce and Gityer Exchange, an international cryptocurrency platform, for "Tier 1" cryptocurrency custody and advanced services. This collaboration, reported in early 2025, suggests an acknowledgment of digital assets at an institutional level, but it does not translate into a comprehensive regulatory framework for retail trading. The focus of this partnership appears to be on institutional-grade services and the management of digital assets by the Ministry itself, rather than regulating individual retail trading activities. Despite the lack of specific regulation, cryptocurrency trading does occur in Madagascar, with individuals and some businesses exploring digital assets for investment, savings, and potentially cross-border transactions. The market is considered to be in its early stages of adoption, with limited, albeit growing, public involvement. The absence of a clear legal framework means that individuals engaging in cryptocurrency trading do so at their own risk, without the specific investor protections that might be afforded in regulated environments. The BCM has also reportedly explored the concept of a central bank digital currency (CBDC), referred to as an "e-Ariary". However, this initiative is distinct from the regulation of decentralized cryptocurrencies like Bitcoin and is still in the exploratory phase. Overall, the environment is one where the activity is not illegal, but operates outside of any specific governmental oversight or crypto-focused rules. This "undecided" or "gray area" status, as some sources describe it, aligns with the "Allowed-Unregulated" definition, as there is no outright ban, nor are there specific regulations governing the retail trading of cryptocurrencies. **Specific, Relevant Text Excerpts:** * **UPay Blog (December 8, 2024):** "Adoption Status: Cryptocurrency is unregulated but not banned in Madagascar." * **UPay Blog (December 8, 2024):** "As of now, Madagascar has not established specific laws or regulations to govern cryptocurrency. The country's central bank, the Banky Foiben'i Madagasikara (BFM), has not issued guidance on crypto beyond a general warning to the public... However, it has not placed an outright ban on trading or holding cryptocurrencies. This means that, while crypto is not illegal in Madagascar, it remains unregulated, and users must proceed cautiously due to the lack of consumer protections and legal clarity." * **UEEx Technology (April 29, 2025):** "Madagascar does not have specific regulations for crypto exchanges, but trading is allowed." * **UEEx Technology (April 29, 2025):** "Are Crypto Exchanges Legal in Madagascar. Madagascar has not enacted specific laws or regulations governing cryptocurrency exchanges. While operating or using crypto exchanges isn't explicitly illegal, there is no formal legal framework to oversee such activities." * **Proelium Law LLP (Regularly Updated):** Under the section for Madagascar, the status is listed as "Undecided. No legal status for cryptocurrencies; There is no cryptocurrency regulation." This implies that it is not banned but lacks a specific legal framework. * **John W Ffooks & Co (April 28, 2022):** "Madagascar has still not adopted any laws or regulations on cryptocurrency. There is no visibility for when this could happen." * **John W Ffooks & Co (April 28, 2022):** "The last official communiqué of the Central Bank on cryptocurrency was dated 5 October 2021. In this communiqué, the Central Bank (i) confirms that cryptocurrencies are not regulated in Madagascar, (ii) warns the public of risks associated to cryptocurrencies and (iii) recommends the public to exercise caution when involved in cryptocurrency-related activities." * **GlobeNewswire (January 13, 2025):** "Recently, the Ministry of Commerce of Madagascar announced its collaboration with Gityer cryptocurrency exchange, which will provide custody and advanced trading services for the Ministry's "Tier 1" digital assets." This indicates government interaction with cryptocurrency entities at some level, though not necessarily retail regulation. **Direct, Accessible URL Links to Sources:** * **Proelium Law LLP:** [https://www.proeliumlaw.com/crypto-regulation-tracker/](https://www.proeliumlaw.com/crypto-regulation-tracker/) (Note: As this is a tracker, the specific link to Madagascar's entry might require navigating the page; the information was accessed based on the provided search snippet). * **UEEx Technology:** [https://www.ueex.com/blog/best-crypto-exchanges-in-madagascar-2025/](https://www.ueex.com/blog/best-crypto-exchanges-in-madagascar-2025/) * **UPay Blog:** [https://upay.africa/blog/crypto-adoption-around-the-world-madagascar/](https://upay.africa/blog/crypto-adoption-around-the-world-madagascar/) * **John W Ffooks & Co:** [https://www.jwflegal.com/news/why-crypto-hasnt-taken-off-in-francophone-africa-yet/](https://www.jwflegal.com/news/why-crypto-hasnt-taken-off-in-francophone-africa-yet/) * **GlobeNewswire (for Gityer Exchange partnership):** [https://www.globenewswire.com/news-release/2025/01/13/2999079/0/en/The-Ministry-of-Commerce-of-Madagascar-has-partnered-with-Gityer-Exchange-to-provide-Tier-1-cryptocurrency-custody-and-advanced-services.html](https://www.globenewswire.com/news-release/2025/01/13/2999079/0/en/The-Ministry-of-Commerce-of-Madagascar-has-partnered-with-Gityer-Exchange-to-provide-Tier-1-cryptocurrency-custody-and-advanced-services.html) * **Central Bank of Madagascar (Banque Centrale de Madagascar - BCM):** While direct links to specific communiqués were not available in the immediate search results, the official website would be the primary source for any such statements. A general link for reference (users would need to search for specific publications): [https://www.banque-centrale.mg/](https://www.banque-centrale.mg/) (This is a general link; specific documents mentioned in secondary sources would need to be located on this site).
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- current status of retail cryptocurrency trading in Madagascar
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