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Tunisia

Retail_Trading_Status

Banned Unknown
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Status Changed

Previous status: Gray-Zone

The primary difference between the two analyses is the identified status of retail cryptocurrency trading in Tunisia: the previous analysis (April 13, 2025) concluded "Gray-Zone," while the new analysis (June 26, 2025) concludes "Banned." Justification for the differences: 1. **Recency and Interpretation of Prevailing Regulations:** The new analysis, dated approximately two and a half months later, appears to give greater weight to the continued enforcement and practical impact of the 2018 Central Bank of Tunisia (BCT) directive. While the previous analysis highlighted a March 2024 draft amendment to the Foreign Exchange Law as a significant move towards potential legalization and regulation (creating a "Gray-Zone" in anticipation), the new analysis emphasizes that, as of June 2025, this draft law has not yet translated into a tangible change for retail traders. Instead, sources cited in the new analysis (e.g., AInvest, Coinfomania from June 2025) reiterate that the 2018 BCT directive, which prohibits transactions involving "virtual money" without state authorization, remains the dominant and enforced framework, effectively constituting a ban on general retail trading. 2. **Emphasis on Enforcement and Practical Reality:** The new analysis places a stronger emphasis on the direct consequences and enforcement actions stemming from the existing BCT directives. It explicitly states that banks are mandated to deny crypto-related transfers, profits from illegal trading can be seized, and violations can lead to significant fines and imprisonment. While the previous report acknowledged historical enforcement (like the teenager's arrest) and risks under foreign exchange laws, the new report frames these as current, direct outcomes of an active ban on retail activity, rather than risks within an ambiguous "Gray-Zone." 3. **Interpretation of the Draft Foreign Exchange Law's Impact:** The previous analysis viewed the March 2024 draft law as a pivotal development creating ambiguity and a transitional phase. It suggested that while not yet fully enacted, the *intent* to regulate and permit crypto trading (subject to BCT authorization and thresholds) shifted the status from a de facto prohibition to a "Gray-Zone." The new analysis, however, interprets the conditions within this draft law (BCT authorization, financial thresholds) as indicative that, even if passed, it does not immediately create an open, regulated environment for all retail traders. It suggests that until such authorizations are clearly defined and accessible, the overarching ban from the 2018 directive remains the de facto reality for the general public. The new analysis acknowledges the draft law but concludes that "the broader consensus and enforcement reality still point to a ban for the general public." 4. **Source Material and Timing:** The new analysis incorporates sources from mid-June 2025 (AInvest, Coinfomania) which appear to provide a more current assessment of the on-the-ground situation, potentially reflecting a lack of parliamentary passage of the draft law or a clarification that its provisions do not supersede the existing BCT ban for unauthorized retail activity. The previous analysis relied on information up to early 2025, with a strong focus on the *announcement* and *content* of the draft law. The new analysis seems to reflect a period where the initial optimism or anticipation surrounding the draft law has met the continued reality of the existing restrictive framework. 5. **Definition of "Ban" vs. "Gray-Zone":** The previous analysis defined "Gray-Zone" by the absence of an explicit law banning crypto, coupled with restrictive foreign exchange controls and BCT warnings, alongside a pending law that could formalize and regulate it. The new analysis leans towards defining the situation as "Banned" based on the BCT's 2018 directive being actively enforced to prohibit retail transactions, regardless of whether a specific, standalone "anti-crypto" law exists. It focuses on the effective prohibition rather than the nuances of legislative wording or pending changes. The sandbox activities mentioned in the new report are highlighted as exceptions, further underscoring that general retail activity is not permitted. In essence, the new analysis suggests that despite the legislative proposals from 2024, the practical and enforceable regulatory environment for retail cryptocurrency trading in Tunisia, as of late June 2025, remains one of prohibition based on the BCT's directives, leading to the updated status of "Banned." The "Gray-Zone" status of the earlier report reflected the uncertainty and transitional nature introduced by the draft law, but the later report indicates this transition has not yet altered the fundamental restrictions on retail participation.

Analysis ID
#536
Version
Latest
Created
2025-06-26 13:28
Workflow Stage
Live

Executive Summary

As of June 2025, retail cryptocurrency trading in Tunisia remains effectively banned. This prohibition stems primarily from a longstanding directive issued by the Central Bank of Tunisia (BCT) in May 2018, which actively enforces a ban on unauthorized virtual money transactions. Despite ongoing discussions and a draft foreign exchange law that includes provisions for crypto assets, no new legal developments have emerged to reverse this ban or move Tunisia towards full legalization. The existing foreign-exchange laws have not altered this restrictive stance, and enforcement actions continue to occur.

Key Pillars

  • Central Bank of Tunisia (BCT) Directive: The primary regulatory pillar is the 2018 directive from the Central Bank of Tunisia, which explicitly prohibits any transactions involving virtual money without state authorization. This directive covers public trading, exchange services, and the acceptance of crypto payments.

  • Foreign Exchange Control Laws: Tunisia's stringent foreign exchange control regime, primarily governed by the Foreign Trade and Foreign Exchange Code of 1976 (with updates), contributes significantly to the ban. The Tunisian Dinar is not fully convertible, and strict regulations govern the movement of currency into and out of the country, making unauthorized crypto transactions a violation of these laws.

  • Anti-Money Laundering (AML) Framework: The National Anti-Money-Laundering Commission (CTAF) monitors AML requirements in financial establishments, and the ban is partly driven by concerns over capital flight and money laundering.

Landmark Laws

Central Bank of Tunisia (BCT) Directive
- Authority: Central Bank of Tunisia (BCT)
- Date: May 2018
- Summary: This pivotal directive from the Central Bank of Tunisia formally banned cryptocurrency transactions due to concerns over capital flight and money laundering. Its impact has been significant, leading banks to block card purchases at foreign exchanges and making public trading, exchange services, and crypto payment acceptance illegal. Violations can result in criminal prosecution, fines, and imprisonment.

Foreign Trade and Foreign Exchange Code
- Authority: Tunisian Government
- Date: 1976 (and subsequent amendments)
- Summary: While not specifically targeting crypto, this overarching law dictates foreign exchange controls in Tunisia. It makes the Tunisian Dinar non-fully convertible and imposes strict regulations on cross-border financial transactions. The BCT applies these laws to foreign exchange, further solidifying the ban on crypto given its unauthorized nature for currency exchange purposes. The code of currency control in Tunisia allows for fines and up to five years in jail in case of violations related to foreign exchange.

Considerations

  • Asset Classification: As trading is illegal, cryptocurrency is not classified as property or currency under Tunisian law for taxation purposes.

  • Taxation: Tunisia currently lacks a specific crypto tax code due to the illegal nature of trading. Any discovered profits from crypto are considered illegal and are subject to seizure. Companies are also not permitted to record crypto assets on their local books.

  • Enforcement: The BCT actively cooperates with commercial banks, mobile-money operators, and customs to monitor crypto-related flows. Exchanges are required to geo-block Tunisian IP addresses, and local authorities monitor blockchain explorers and social media for large peer-to-peer trades. Penalties for violations are increasing and can include device seizure, personal key delivery requirements, and blocking of associated bank accounts. Importing ASIC rigs for mining and exchanging mined coins into dinars also violate the 2018 directive and can lead to equipment seizure.

Notes

  • Regulatory Sandbox: Since 2020, the Central Bank of Tunisia has operated a regulatory sandbox, signaling a cautious but evolving attitude toward innovation in financial technology. Blockchain or payment pilots must apply to the BCT sandbox for temporary, limited-scope testing.

  • Draft Foreign Exchange Law: A significant development is the approval by the cabinet of a draft law in March 2024 to overhaul Tunisia's foreign exchange system. This draft law reportedly includes provisions that allow for dealing with crypto assets. However, it remains unpassed by Parliament as of June 2025. This draft aims to gradually liberalize foreign currency policy, improve the investment climate, and facilitate foreign transactions, including possibly for crypto assets, but its final form and parliamentary approval are still pending.

  • Decriminalization Discussions: A high-profile case in 2021 where a teenager was jailed for exchanging a small amount of cryptocurrency prompted cabinet-level discussions about decriminalization, though these have yet to materialize into law. Parliamentary committees are reportedly considering a draft bill that would decriminalize possession and implement a licensing regime, with a virtual-asset framework anticipated by 2026.

  • Future Outlook: Projections from some sources suggest partial legalization within 24 months, potentially including conditional exchange licenses, mandatory on-shore KYC, and restricted corporate mining permits. Tax regulations, defining crypto profits as taxable income, are expected to follow once trading is legalized.

Detailed Explanation

Tunisia maintains a highly restrictive environment for retail cryptocurrency trading as of June 2025. The definitive "Banned" status is rooted in a clear and actively enforced directive issued by the Central Bank of Tunisia (BCT) in May 2018. This directive explicitly prohibits any transactions involving virtual money that lack state authorization, encompassing all forms of public trading, exchange services, and the acceptance of crypto payments. The BCT's stance is heavily influenced by national concerns over capital flight and potential money laundering, aligning with Tunisia's broader, stringent foreign exchange control laws. The Tunisian Dinar is not freely convertible, and the existing Foreign Trade and Foreign Exchange Code of 1976, along with its subsequent revisions, imposes tight controls on currency movement, making unauthorized crypto transactions a direct violation of these laws, with potential penalties including fines and imprisonment.Despite this firm prohibition, there have been indications of a gradual shift in official attitude, albeit without concrete legislative changes to lift the ban on retail trading. Since 2020, the BCT has established and operated a regulatory sandbox, allowing for temporary and limited-scope testing of blockchain and payment-related pilot projects. While this demonstrates an openness to technological innovation, it does not extend to general retail crypto trading. Furthermore, a significant draft law aimed at overhauling Tunisia's longstanding foreign exchange system was approved by the cabinet in March 2024. This proposed legislation reportedly includes provisions for dealing with crypto assets and aims to gradually liberalize the movement of funds and improve the investment climate. However, as of June 2025, this draft has yet to be passed by Parliament, leaving the legal landscape unchanged regarding the ban.The current regulatory void for legal crypto activity means that there are no specific classifications for cryptocurrency as an asset or currency, nor is there a dedicated tax code. Any profits derived from crypto activities are considered illegal and are subject to seizure. The enforcement of the ban is active, with the BCT collaborating with financial institutions and customs to monitor crypto-related flows, block card purchases at foreign exchanges, and even geo-block Tunisian IP addresses on exchanges. Cases like the 2021 arrest of a teenager for a small crypto exchange highlight the active enforcement and the legal risks involved for individuals. While parliamentary discussions have touched upon decriminalizing possession and introducing a licensing regime, and some projections anticipate partial legalization by 2026, these remain proposals. For now, the 2018 Central Bank directive, underpinned by the national foreign exchange laws, continues to render retail crypto trading in Tunisia effectively banned.

Summary Points

Here's a clear, well-structured bullet point summary of the detailed regulatory analysis report on Retail Crypto Trading in Tunisia:

## Retail Crypto Trading Regulations in Tunisia (as of June 2025)

### 1. Current Regulatory Status

  • Effectively Banned: Retail cryptocurrency trading in Tunisia remains prohibited.
  • Primary Basis: Stemming from a Central Bank of Tunisia (BCT) Directive issued in May 2018.
  • Enforcement: The ban is actively enforced, with no new legal developments to reverse it.

### 2. Key Regulatory Bodies & Frameworks

  • Central Bank of Tunisia (BCT):
  • The primary authority enforcing the ban through its 2018 directive.
  • Actively monitors crypto-related flows in cooperation with commercial banks, mobile-money operators, and customs.
  • Operates a regulatory sandbox for FinTech innovation.
  • Foreign Exchange Control Regime:
  • Governed by the Foreign Trade and Foreign Exchange Code of 1976 (with updates).
  • The Tunisian Dinar is not fully convertible, and strict regulations govern currency movement.
  • Unauthorized crypto transactions are considered violations of these laws.
  • National Anti-Money-Laundering Commission (CTAF):
  • Monitors AML requirements in financial establishments.
  • The ban is partly driven by concerns over capital flight and money laundering.

### 3. Important Legislation & Regulations

  • Central Bank of Tunisia (BCT) Directive (May 2018):
  • Core Prohibition: Explicitly bans any transactions involving "virtual money" without state authorization.
  • Scope: Covers public trading, exchange services, and the acceptance of crypto payments.
  • Rationale: Concerns over capital flight and money laundering.
  • Impact: Banks block card purchases at foreign exchanges; makes public trading, exchange services, and crypto payment acceptance illegal.
  • Penalties: Violations can lead to criminal prosecution, fines, and imprisonment.
  • Foreign Trade and Foreign Exchange Code of 1976 (and subsequent amendments):
  • Overarching Law: Dictates foreign exchange controls in Tunisia.
  • Key Provision: Makes the Tunisian Dinar non-fully convertible and imposes strict regulations on cross-border financial transactions.
  • Application to Crypto: The BCT applies these laws to crypto, solidifying the ban due to its unauthorized nature for currency exchange.
  • Penalties: Violations can result in fines and up to five years in jail.

### 4. Requirements for Compliance (or lack thereof)

  • No Legal Framework: As trading is illegal, there are no specific compliance requirements for legal crypto activities.
  • Prohibition: All forms of retail crypto trading, exchange, and payment acceptance are prohibited.
  • Geo-blocking: Foreign exchanges are required to geo-block Tunisian IP addresses.
  • Mining: Importing ASIC rigs for mining and exchanging mined coins into Tunisian Dinars are considered violations of the 2018 directive.

### 5. Notable Restrictions & Limitations

  • Asset Classification: Cryptocurrency is not classified as property or currency under Tunisian law.
  • Taxation:
  • No specific crypto tax code exists due to the illegal nature of trading.
  • Any discovered profits from crypto are considered illegal and subject to seizure.
  • Companies are not permitted to record crypto assets on their local books.
  • Enforcement:
  • Active monitoring by the BCT, commercial banks, mobile-money operators, and customs.
  • Monitoring of blockchain explorers and social media for large peer-to-peer trades.
  • Increasing penalties, including device seizure, requirements for personal key delivery, and blocking of associated bank accounts.
  • Equipment seizure for mining violations.

### 6. Recent Developments & Future Outlook

  • Regulatory Sandbox (since 2020):
  • The Central Bank of Tunisia operates a sandbox for FinTech innovation.
  • Allows for temporary, limited-scope testing of blockchain or payment pilot projects.
  • Signals a cautious but evolving attitude towards innovation, distinct from retail trading legalization.
  • Draft Foreign Exchange Law (March 2024):
  • Approved by the cabinet to overhaul Tunisia's foreign exchange system.
  • Reportedly includes provisions that allow for dealing with crypto assets.
  • Aims to gradually liberalize foreign currency policy and improve the investment climate.
  • Status: Remains unpassed by Parliament as of June 2025.
  • Decriminalization Discussions:
  • Prompted by a high-profile case in 2021 (teenager jailed for crypto exchange).
  • Cabinet-level discussions about decriminalization have occurred.
  • Parliamentary committees are reportedly considering a draft bill to decriminalize possession and implement a licensing regime.
  • A virtual-asset framework is anticipated by 2026.
  • Future Outlook (Projections):
  • Some sources project partial legalization within 24 months.
  • Potential future measures could include conditional exchange licenses, mandatory on-shore KYC, and restricted corporate mining permits.
  • Tax regulations defining crypto profits as taxable income are expected to follow any legalization.

Full Analysis Report

Report on Retail Trading Status of Cryptocurrencies in Tunisia

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: Banned

Narrative Explanation:

Tunisia maintains a restrictive stance on cryptocurrencies, with retail trading (buying, selling, and holding) effectively banned for individual citizens and residents. The Central Bank of Tunisia (BCT) issued a directive in 2018 prohibiting transactions involving "virtual money" without state authorization. This ban covers public trading, exchange services, and the acceptance of crypto payments. The regulatory framework is primarily overseen by the BCT, the Ministry of ICT & Digital Economy, and the Financial Market Council (CMF), which would regulate tokenized securities if the ban were lifted.

Historically, there was a period of regulatory ambiguity between 2013 and 2017, with some peer-to-peer Bitcoin trading occurring. However, the 2018 BCT directive formalized the ban, citing concerns over capital flight and money laundering. This led to banks blocking card purchases at foreign exchanges. Despite this strict stance, there are indications of a potential future shift. The BCT has been operating a regulatory sandbox since 2020 for fintech, including some blockchain-based payment and remittance pilots. These sandbox activities are conducted in a controlled environment with strict requirements, including thorough customer identification, detailed ledgers, and suspicious transaction reporting to the National Anti-Money-Laundering Commission (CTAF). It's important to note that these sandbox operations are exceptions and do not signify a general legalization of crypto trading for the public.

Currently, Tunisia does not issue licenses for cryptocurrency exchanges, custodians, or token-issuance platforms. Banks are mandated to deny crypto-related transfers. Any profits discovered from illegal crypto trading are considered illicit and can be seized, and there is no specific tax code for cryptocurrencies due to their illegal status. Violations of currency-control regulations related to cryptocurrencies can lead to significant fines and imprisonment for up to five years. Mining activities, including importing equipment and exchanging mined coins into Tunisian Dinar, also violate the 2018 directive.

While some sources describe Tunisia's crypto environment as a "legal gray area" because no specific laws explicitly prohibit cryptocurrencies, the overarching directives from the Central Bank and the enforcement actions, such as the jailing of a teenager in 2021 for a small crypto transaction, point towards an effective ban on retail trading. Discussions at the cabinet level about decriminalization have occurred but have not yet led to concrete changes in the legal status. Some projections suggest a potential partial legalization within the next 24 months, with conditional licenses and KYC/AML requirements, but as of June 2025, the ban remains firmly in place.

The government's "Digital Tunisia 2025" project does list blockchain technology for enhancing transparency in supply chains and record-keeping, but this is focused on permissioned ledgers and does not extend to public cryptocurrency trading.

Relevant Text Excerpts and Sources:

  • AInvest (June 16, 2025): "Tunisia has maintained a restrictive stance on cryptocurrency since 2018, when the Central Bank of Tunisia (BCT) issued a directive prohibiting any transactions involving virtual money without state authorization. This ban encompasses public trading, exchange services, and the acceptance of crypto payments."
  • AInvest (June 16, 2025): "Crypto policies in Tunisia are clear: all crypto payments are illegal, and merchants are not allowed to accept digital assets as payment. Mining activities, including importing ASIC rigs and exchanging mined coins into dinar, violate the 2018 directive and can result in equipment seizure by customs authorities."
  • AInvest (June 16, 2025): "Violations of currency-control regulations can result in fines and up to five years in jail."
  • AInvest (June 16, 2025): "Since trading is illegal, Tunisia lacks a specific crypto tax code, and any profits discovered are considered illegal and can be seized."
  • Coinfomania (June 19, 2025): "A 2018 statement by the Central Bank of Tunisia (BCT) makes it a crime to undertake any result in virtual-money without the authorisation of the state, hence forbidding any public trading, exchange services, and even crypto payment acceptance."
  • Coinfomania (June 19, 2025): "Tunisia does not provide any extended permit to exchanges, custodians, or platforms of token-issuance."
  • Coinfomania (June 19, 2025): "Fines and jail time: Up to five years in jail and fines are possible under currency-control regulations, operating an exchange, marketing tokens, or crypto holdings."
  • UPay Blog (December 11, 2024): "Digital assets and cryptocurrency were declared illegal in 2018 by the Central Bank of Tunisia and Islamic Law."
  • UPay Blog (December 11, 2024): "Adoption Status: Transacting in cryptocurrency and other digital assets is illegal in Tunisia."
  • Proelium Law LLP (Accessed June 2024, content likely from Jan 2022 or shortly after): "As of Jan 2022, Tunisia has strictly banned the use of crypto-assets."
  • UEEx Technology (January 15, 2025): "Tunisia banned cryptocurrencies due to concerns about money laundering, fraud, and the potential use of digital assets for illegal purposes."
  • ResearchGate (May 19, 2025) citing Managers.tn (March 18, 2024) and Taxir.xyz (March 17, 2024): Some recent analysis in May 2025 pointed to a March 2024 amended foreign exchange law that "facilitates foreign currency trading and includes provisions for the use of cryptocurrencies," permitting citizens to hold and exchange them subject to BCT authorization and financial thresholds. However, this contrasts sharply with other recent reports that reiterate the 2018 ban is still the prevailing framework for retail activity, with sandbox exceptions being very limited. The broader consensus and enforcement reality still point to a ban for the general public. The referenced articles themselves note the need for BCT authorization and adherence to specific thresholds, which implies it's not an open, "Allowed-Regulated" environment for retail traders yet. The dominant information from multiple sources indicates the ban on general retail trading remains.

URL Links to Sources:

Web Sources (9)

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Search queries used (7)
  • current status of retail cryptocurrency trading in Tunisia 2025
  • Tunisia cryptocurrency laws and regulations for individuals 2025
  • Central Bank of Tunisia official position on cryptocurrency 2025
  • Tunisian financial markets authority (CMF) crypto guidelines 2025
  • AML/KYC requirements for cryptocurrency transactions in Tunisia 2025
  • penalties for cryptocurrency trading in Tunisia 2025
  • news reports on cryptocurrency legality Tunisia 2024 2025
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