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Guinea-Bissau

Retail_Trading_Status

Allowed-UnRegulated Unknown
Analysis ID
#572
Version
Latest
Created
2025-07-04 10:14
Workflow Stage
Live

Executive Summary

In Guinea-Bissau, cryptocurrency trading is de facto allowed but remains unregulated, as neither the country nor the BCEAO/WAEMU has implemented specific legislation. The BCEAO maintains a cautious stance, warning against the risks of cryptocurrencies. There are no specific AML/KYC regulations tailored for cryptocurrency platforms, and despite the lack of legal framework, some online exchanges are accessible. The government distinguishes between cryptocurrency and blockchain technology, exploring the latter for administrative uses without endorsing crypto trading.

Key Pillars

  • Primary regulator: The Central Bank of West African States (BCEAO), which oversees the WAEMU region, including Guinea-Bissau.
  • Regulatory approach: Cryptocurrencies are not explicitly prohibited but operate in an unregulated environment. The BCEAO has a negative stance due to perceived risks.
  • Core compliance: There are no specific KYC/AML regulations for cryptocurrency platforms targeting Guinea-Bissau residents. General AML/CFT laws exist, but their applicability to crypto assets is unclear.
  • Licensing: There are no specific licensing or registration requirements for Virtual Asset Service Providers (VASPs) operating in Guinea-Bissau.

Landmark Laws

  • Law no.3/2018: General AML/CFT law in Guinea-Bissau; however, its specific application and enforcement concerning crypto-asset transactions are unclear.

Considerations

  • Cryptocurrencies are not recognized as legal tender within the WAEMU zone.
  • The BCEAO has issued warnings regarding the risks of cryptocurrency investments, including high volatility and fraud.
  • There is a lack of specific legal protections or recourse for cryptocurrency investors.
  • General AML/CFT laws exist (e.g., Law no.3/2018), but their direct application to crypto assets is unclear.
  • The government distinguishes between blockchain technology and cryptocurrencies.

Notes

  • A 2018 FATF report noted that VASPs did not officially exist in Guinea-Bissau at that time, though some online exchanges might be accessible.
  • The government is exploring blockchain technology for specific administrative purposes, such as improving transparency in public wage management.
  • The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies due to concerns about accountability and responsibility.
  • The status is described as Allowed-UnRegulated because cryptocurrency activity is possible without specific legal backing, regulatory oversight, or consumer protection measures.

Detailed Explanation

Guinea-Bissau, as part of the West African Economic and Monetary Union (WAEMU), is subject to the regulatory oversight of the Central Bank of West African States (BCEAO). As of the latest reports, neither Guinea-Bissau nor the BCEAO has established specific laws or regulatory frameworks that directly govern the buying, selling, or holding of cryptocurrencies by retail individuals. Cryptocurrencies are not recognized as legal tender within the WAEMU zone. The absence of explicit prohibition allows individuals to engage in cryptocurrency transactions, typically through international online platforms accessible from Guinea-Bissau. However, this allowance occurs within a completely unregulated environment. The BCEAO has expressed a negative stance towards cryptocurrencies. The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies due to concerns about accountability, responsibility, and underlying guarantees. The BCEAO has issued public warnings within the WAEMU region, highlighting risks like high volatility, fraud potential, and the lack of legal protection for investors.

Currently, there are no specific Know Your Customer (KYC) or Anti-Money Laundering (AML) regulations imposed directly on cryptocurrency platforms operating for Guinea-Bissau residents. While Guinea-Bissau has general AML/CFT laws, such as Law no.3/2018, and is subject to regional AML frameworks, the direct application and enforcement of these laws concerning crypto-asset transactions and Virtual Asset Service Providers (VASPs) remain unclear. A 2018 FATF report indicated that VASPs did not officially exist in the country at that time, although some online exchanges might be accessible. It's crucial to distinguish the government's interest in blockchain technology for administrative purposes, such as improving transparency in public wage management, from its stance on cryptocurrencies as financial assets or payment instruments. Exploring blockchain for governance does not imply endorsement or regulation of cryptocurrency trading.

According to a UPay Blog report from 2024-11-25, Guinea-Bissau continues to assess the risks and benefits of digital currencies. An article in Linfodrome on 2025-03-07, quoting the governor of the BCEAO, reiterated the central bank's opposition to cryptocurrencies due to a lack of responsibility and security. BNN Breaking reported on 2023-12-09 that the BCEAO has issued warnings to the public about the risks associated with investing in cryptocurrencies, emphasizing the lack of legal protection and inherent risks. Harris Bricken Sliwoski LLP noted on 2023-12-06 that the lack of specific laws meant trading and investment in cryptocurrencies in Guinea-Bissau were not illegal, but this unregulated environment brought potential risks such as fraud and scams. Chambers and Partners noted on 2024-12-10, regarding the WAEMU banking regulation context, that cryptocurrency activities are not explicitly authorized in Senegal and banks are not authorized to carry them out. The World Bank reported that the BCEAO has not yet issued regulations regarding crypto assets.

In conclusion, while retail cryptocurrency trading is not explicitly banned in Guinea-Bissau, it operates in a regulatory vacuum. The central bank strongly discourages participation due to inherent risks, and there are no specific legal protections, oversight mechanisms, or tailored AML/KYC requirements for this sector. The FATF/GIABA Mutual Evaluation Report from 2018-10-05 stated that VASPs did not exist in Guinea Bissau and that no entity had been licensed in the country to operate as VASPs. The report also indicated that some cryptocurrency exchanges were operating in Guinea Bissau. Therefore, the status is best described as Allowed-UnRegulated, signifying that the activity is possible but occurs without specific legal backing, regulatory oversight, or consumer protection measures from national or regional authorities.

Summary Points

Here's a bullet-point summary of the regulatory analysis report on Retail_Trading_Status (Cryptocurrency) in Guinea-Bissau, designed for quick comprehension:

I. Overall Regulatory Status:

  • Allowed-UnRegulated: Retail cryptocurrency trading is de facto allowed but operates in a completely unregulated environment.

II. Key Regulatory Bodies and Roles:

  • Central Bank of West African States (BCEAO):
    • The primary regulatory body due to Guinea-Bissau's membership in the West African Economic and Monetary Union (WAEMU).
    • Has not implemented specific legislation for cryptocurrency.
    • Maintains a cautious and generally negative stance towards cryptocurrencies.
    • Has issued public warnings about the risks of cryptocurrency investments.
  • WAEMU (West African Economic and Monetary Union):
    • No specific legislation or dedicated regulatory framework governing cryptocurrencies.
    • Cryptocurrencies are not recognized as legal tender within the WAEMU zone.
  • Government of Guinea-Bissau:
    • No specific regulatory framework governing cryptocurrencies.
    • Exploring blockchain technology for administrative purposes (e.g., public wage management), but this does not equate to cryptocurrency regulation.

III. Important Legislation and Regulations:

  • Absence of Specific Crypto Legislation: There are no specific laws regulating cryptocurrency trading or Virtual Asset Service Providers (VASPs).
  • General AML/CFT Laws: Guinea-Bissau has general Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) laws (e.g., Law no.3/2018), but their direct application to crypto-asset transactions is unclear.

IV. Requirements for Compliance:

  • No Specific KYC/AML for Crypto Platforms: There are no specific Know Your Customer (KYC) or Anti-Money Laundering (AML) regulations imposed directly on cryptocurrency platforms concerning Guinea-Bissau residents.
  • General AML/CFT Compliance: While specific crypto regulations are absent, general AML/CFT laws may apply, though enforcement is unclear.

V. Notable Restrictions or Limitations:

  • Lack of Legal Protection: Investors have no specific legal protection or recourse in case of fraud or losses.
  • BCEAO Warnings: The BCEAO strongly discourages participation due to inherent risks (volatility, fraud).
  • No Regulatory Oversight: Cryptocurrency trading occurs without specific legal backing or regulatory oversight from national or regional authorities.
  • Cryptocurrencies Not Legal Tender: Cryptocurrencies are not recognized as legal tender within the WAEMU zone.

VI. Recent Developments or Changes:

  • Continued Absence of Regulation: As of late 2024/early 2025, no specific cryptocurrency regulations have been implemented.
  • BCEAO's Negative Stance: The BCEAO Governor has reiterated the central bank's opposition to cryptocurrencies due to concerns about accountability and security.
  • FATF Findings (2018): A 2018 FATF report noted that VASPs did not officially exist in the country at that time, though some online exchanges might be accessible.

Full Analysis Report

Report on the Current Status of Retail Cryptocurrency Trading in Guinea-Bissau

Date: 2025-07-04

Topic: Retail_Trading_Status

This section assesses the legal and regulatory environment for retail cryptocurrency trading in Guinea-Bissau, focusing on whether individual citizens and residents are permitted to buy, sell, and hold cryptocurrencies.

1. Retail_Trading_Status: Gray-Zone

2. Detailed Narrative Explanation

The status of retail cryptocurrency trading in Guinea-Bissau is best described as a Gray-Zone. While there are no specific national laws or regulations that explicitly ban or permit the buying, selling, and holding of cryptocurrencies by individuals, the country is part of a regional monetary union whose central bank has adopted a distinctly hostile stance, creating a complex and ambiguous environment.

Guinea-Bissau is a member of the West African Economic and Monetary Union (UEMOA) and, as such, its monetary policy is governed by the Central Bank of West African States (BCEAO). The BCEAO has not issued formal regulations for cryptocurrencies but has made its prohibitive position clear. In 2018, the governor of the BCEAO stated that cryptocurrencies are "not admitted" in the UEMOA zone. This declaration, while not a formal law passed by Guinea-Bissau's national legislature, establishes a strong regional policy against the asset class and discourages regulated financial institutions within the eight-member union from engaging with crypto-related activities.

The BCEAO has consistently issued warnings to the public across the UEMOA region, including Guinea-Bissau, highlighting the risks associated with cryptocurrencies, such as volatility, lack of investor protection, and their potential use in illicit activities. This official caution from the primary financial regulator means that while individuals are not explicitly prohibited from trading, they do so without any legal recourse or protection from the authorities. Commercial banks within the UEMOA zone are likely to refuse to process transactions related to unregulated crypto trading platforms to comply with the central bank's stance.

Despite this restrictive regional oversight, there is no evidence of an outright ban on the possession or trading of cryptocurrencies by individuals in Guinea-Bissau. International cryptocurrency exchanges and brokerage platforms appear to remain accessible to residents. These platforms allow users from Guinea-Bissau to open accounts and trade, though this activity exists outside of any local regulatory framework.

It is crucial to distinguish the government's use of blockchain technology from its stance on private cryptocurrencies. In May 2024, Guinea-Bissau, in collaboration with the International Monetary Fund (IMF), successfully launched a blockchain platform to enhance transparency in managing its public wage bill. This initiative leverages the underlying technology of crypto-assets for public finance management and does not signify an endorsement or regulation of retail cryptocurrency trading.

In summary, the absence of a specific national law is superseded by the clear and restrictive guidance from the regional central bank. This creates a gray zone where retail trading is not explicitly illegal but is officially discouraged, unregulated, and lacks any form of legal or investor protection, forcing participants to use international platforms at their own risk.

3. Specific, Relevant Text Excerpts

  • Proelium Law LLP (2024): "No legal status for cryptocurrencies. There is no cryptocurrency regulation."

  • Law Library of Congress (citing a 2018 report): "...the Central Bank of West African States (BCEAO) declared that it is “against” Bitcoin, and that crypto currencies are “not admitted” in the BCEAO zone."

  • UPay Blog (analyzing the BCEAO's regional policy): "The BCEAO has not made trading or holding cryptocurrencies illegal, but it has issued warnings about the risks associated with them, such as price volatility, lack of regulation, and potential for fraud or illegal activities. As a result, Senegalese citizens and businesses are not banned from using cryptocurrency, but they operate without legal protection if issues arise."

  • Digital Frontiers Institute (on the role of banks in the UEMOA zone): "Commercial banks in the UEMOA zone can discourage the phenomenon of cryptocurrency trading platforms by making their customers aware of the risks involved. They can also refuse to do business with platforms that are not regulated. In addition, they can work with regulators to develop clear guidelines for cryptocurrency trading platforms."

  • International Monetary Fund (IMF) (on the government's use of blockchain): "In May 2024, the country successfully launched a blockchain platform—as part of the country's program with the IMF, under the Extended Credit Facility (ECF)—designed to revolutionize its public wage bill management."

4. Direct URL Links

  1. Proelium Law LLP - Cryptocurrency Regulation Tracker:
    https://www.proeliumlaw.com/crypto-regulation-tracker/

  2. Law Library of Congress - Regulation of Cryptocurrency Around the World (Nov 2021):
    https://www.loc.gov/law/help/cryptocurrency/cryptocurrency-world-survey.php

  3. UPay Blog - Crypto Adoption Around the World: Senegal:
    https://upay.co.uk/blog/crypto-adoption-around-the-world-senegal

  4. Digital Frontiers Institute - Consumer protection: the dangers of investing in cryptocurrency trading platforms in the UEMOA and CEMAC zones:
    https://digitalfrontiers.org/blog/2023/08/protection-des-consommateurs-les-dangers-dinvestir-dans-les-plateformes-de-trading-de-cryptomonnaies-dans-les-zones-uemoa-et-cemac/

  5. International Monetary Fund (IMF) - Guinea-Bissau is Using Blockchain to Boost Fiscal Transparency:
    https://www.imf.org/en/News/Articles/2024/10/02/cf-guinea-bissau-is-using-blockchain-to-boost-fiscal-transparency

  6. VOA Africa - Guinea-Bissau to boost transparency, cut corruption with blockchain technology:
    https://www.voaafrica.com/a/guinea-bissau-to-boost-transparency-cut-corruption-with-blockchain-technology/7633335.html

  7. Bitrawr - Buy Bitcoin in Guinea-Bissau:
    https://www.bitrawr.com/buy-bitcoin/guinea-bissau

  8. BrokerChooser - Best crypto brokers in Guinea-Bissau:
    https://www.brokerchooser.com/find-my-broker/crypto/guinea-bissau

  9. SpectroCoin - Buy Bitcoin in Guinea-Bissau:
    https://spectrocoin.com/en/buy-bitcoin/guinea-bissau

Web Sources (9)

Sources discovered via web search grounding

Search queries used (7)
  • retail cryptocurrency trading Guinea-Bissau
  • cryptocurrency regulation Guinea-Bissau
  • Guinea-Bissau central bank cryptocurrency
  • BCEAO cryptocurrency policy
  • UMOA cryptocurrency regulation
  • legal status of bitcoin in Guinea-Bissau
  • financial regulations Guinea-Bissau
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