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Cameroon

Retail_Trading_Status

Gray-Zone High Confidence
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Analysis ID
#624
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Created
2025-12-12 03:58
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Executive Summary

Retail cryptocurrency trading in Cameroon exists in a regulatory gray zone characterized by a strict banking ban but no explicit prohibition on individual possession or private trading. The regional regulator, COBAC, formally prohibited all financial institutions from facilitating crypto transactions in May 2022 to protect the CFA franc. However, in October 2024, President Paul Biya issued a circular instructing the government to enhance supervision of the sector, signaling a potential shift from exclusion to regulation.

Key Pillars

Central African Banking Commission (COBAC) - Regional banking supervisor enforcing the ban on financial institutions.
Bank of Central African States (BEAC) - Regional central bank managing monetary policy and opposing crypto as a threat to the CFA franc.
National Agency for Financial Investigation (ANIF) - Responsible for AML/CFT oversight, though specific crypto guidelines are nascent.
Ministry of Finance (MINFI) - Oversees national fiscal policy and recently tasked with developing supervision mechanisms.

Landmark Laws

Decision on the Holding and Use of Cryptocurrencies by Institutions Subject to COBAC (Decision COBAC D-2022/071) - Enacted: 2022-05-06
- Explicitly prohibits banks, microfinance institutions, and payment providers in the CEMAC zone from holding, exchanging, converting, or settling transactions related to cryptocurrencies.
- Source

Circular on the Preparation of the State Budget for the 2025 Financial Year (Circular No. 001) - Enacted: 2024-10-24
- Presidential instruction to the Prime Minister to 'enhance the supervision of cryptocurrency-related activities,' indicating a move towards monitoring and potential taxation rather than a total ban.

Regulation on Systems, Means and Incidents of Payment (Regulation No. 02/18/CEMAC/UMAC/CM) - Enacted: 2018-12-21
- Establishes the legal framework for payment services in CEMAC; does not recognize crypto as valid legal tender or electronic money.
- Source

Considerations

Banking Blockade: Local banks cannot process transfers to crypto exchanges; users rely on P2P markets and mobile money agents operating informally.
Regional Tension: The regulatory stance is heavily influenced by the conflict between the regional central bank (BEAC) and the Central African Republic (CAR) over the latter's adoption of Bitcoin.
Legal Vacuum: While banks are restricted, no law criminalizes individual holding of crypto, adhering to the principle of 'nulla poena sine lege'.
Fraud Risk: The lack of regulated local exchanges has led to a proliferation of scams (e.g., Ponzi schemes) which authorities struggle to police.

Notes

Cameroon's situation is unique because it is caught between a conservative regional central bank (BEAC) protecting the CFA franc and a national government seeking new revenue streams. The 2022 ban was a direct reaction to the Central African Republic's adoption of Bitcoin, which was seen as a threat to the monetary union.

Remaining Uncertainties

  • How the Cameroonian government intends to 'supervise' crypto activities while the COBAC banking ban remains in force.
  • Whether specific tax guidelines for crypto assets will be introduced in the 2025 Finance Law.
  • If COBAC will update its 2022 decision to accommodate national desires for regulation and taxation.

Detailed Explanation

Cameroon's cryptocurrency regulatory status is a Gray-Zone, characterized by a restrictive regional banking prohibition but no explicit national ban on individual possession or peer-to-peer trading. The primary regulatory framework is defined by a regional banking directive and a recent national presidential instruction. The landmark regulation is the Central African Banking Commission (COBAC) Decision D-2022/071, enacted on May 6, 2022, which explicitly prohibits all financial institutions under its supervision—including banks, microfinance institutions, and payment service providers—from holding, exchanging, converting, or settling transactions involving cryptocurrencies. This banking blockade, enforced to protect the monetary sovereignty of the CFA franc managed by the Bank of Central African States (BEAC), effectively severs formal financial channels for crypto activity. The legal framework is further anchored by the BEAC's Regulation No. 02/18/CEMAC/UMAC/CM from December 21, 2018, which governs payment systems and does not recognize cryptocurrencies as legal tender or electronic money, thereby excluding them from the formal payment ecosystem. The regulatory stance is heavily influenced by regional tensions, particularly the Central African Republic's adoption of Bitcoin, which prompted the COBAC ban. Consequently, while institutional facilitation is banned, a legal vacuum persists for individuals, adhering to the principle of 'nulla poena sine lege' (no penalty without law), though this has led to increased fraud risk from unregulated schemes. A significant potential shift was signaled on October 24, 2024, when President Paul Biya issued Circular No. 001, instructing the government to enhance supervision of cryptocurrency-related activities as part of the 2025 budget preparation. This directive, assigned to the Ministry of Finance (MINFI), suggests a move from outright exclusion towards monitoring and potential future regulation, possibly including taxation. Oversight for anti-money laundering and counter-terrorist financing (AML/CFT) falls under the National Agency for Financial Investigation (ANIF), though specific crypto guidelines remain nascent. In practice, the regulatory environment forces retail traders to rely on informal peer-to-peer markets and mobile money agents, operating outside the protected financial system but not explicitly outlawed for individuals.

Summary Points

I. Regulatory Status
* Cameroon's cryptocurrency regulatory status is a Gray-Zone.
* Characterized by a strict regional banking ban but no explicit national prohibition on individual possession or private peer-to-peer trading.
* The environment is caught between a conservative regional monetary authority and a national government showing signs of moving towards supervision.

II. Key Regulatory Bodies
* Central African Banking Commission (COBAC): The regional banking supervisor that enforces the prohibition on financial institutions facilitating crypto transactions.
* Bank of Central African States (BEAC): The regional central bank managing the CFA franc; it opposes cryptocurrency as a threat to monetary policy and sovereignty.
* National Agency for Financial Investigation (ANIF): The national body responsible for AML/CFT oversight, though its specific framework for crypto is nascent.
* Ministry of Finance (MINFI): Oversees national fiscal policy and was recently tasked with developing supervision mechanisms for the sector.

III. Important Legislation
* Decision COBAC D-2022/071 (Enacted: 2022-05-06): "Decision on the Holding and Use of Cryptocurrencies by Institutions Subject to COBAC."
* Explicitly prohibits all regulated financial institutions (banks, microfinance, payment providers) in the CEMAC zone from holding, exchanging, converting, or settling cryptocurrency transactions.
* Circular No. 001 (Enacted: 2024-10-24): "Circular on the Preparation of the State Budget for the 2025 Financial Year."
* A presidential instruction to "enhance the supervision of cryptocurrency-related activities," signaling a potential shift from exclusion to monitoring and regulation.
* Regulation No. 02/18/CEMAC/UMAC/CM (Enacted: 2018-12-21): "Regulation on Systems, Means and Incidents of Payment."
* Establishes the legal framework for payment services in the CEMAC region and does not recognize cryptocurrency as valid legal tender or electronic money.

IV. Compliance Requirements
* For financial institutions: Strict prohibition on any involvement with cryptocurrency, as per COBAC D-2022/071.
* For individuals and informal traders: No specific compliance framework exists due to the legal vacuum; however, general laws against fraud and financial crimes apply.
* AML/CFT oversight by ANIF is theoretically applicable but not specifically tailored to crypto activities.

V. Notable Restrictions or Limitations
* Banking Blockade: Local banks and payment providers are forbidden from processing transfers to or from cryptocurrency exchanges.
* No Legal Tender Status: Cryptocurrencies are not recognized as a valid means of payment under regional payment regulations.
* Lack of Regulated On-Ramps: There are no licensed local cryptocurrency exchanges, forcing users to rely on informal P2P markets and mobile money agents.
* High Fraud Risk: The unregulated environment has led to a proliferation of scams and Ponzi schemes, which authorities struggle to police effectively.

VI. Recent Developments or Notes
* The 2022 COBAC ban was a direct reaction to the Central African Republic's adoption of Bitcoin, viewed as a threat to the regional monetary union.
* The October 2024 presidential circular represents the first high-level national directive on cryptocurrency and indicates a potential future focus on supervision and taxation rather than a total ban.
* The regulatory tension is unique, pitting the regional imperative to protect the CFA franc (BEAC/COBAC) against national interests in potential revenue and oversight (Cameroonian government).

Full Analysis Report

The regulatory status of cryptocurrency in Cameroon is defined by a dichotomy between regional banking restrictions and national tolerance. As a member of the Central African Economic and Monetary Community (CEMAC), Cameroon falls under the jurisdiction of the Bank of Central African States (BEAC) and the Central African Banking Commission (COBAC). In May 2022, following the Central African Republic's controversial decision to adopt Bitcoin as legal tender, COBAC issued Decision D-2022/071. This directive explicitly banned all regulated financial institutions—including commercial banks and microfinance entities—from dealing in, holding, or facilitating transactions involving cryptocurrencies. Consequently, the formal financial system is completely severed from the crypto market, forcing traders to operate in a 'gray zone' using peer-to-peer (P2P) methods and mobile money rails that bypass direct banking oversight.

Despite the banking ban, individual retail trading remains technically legal due to the absence of national penal laws criminalizing the asset class. The principle of 'nulla poena sine lege' (no penalty without law) protects individual holders from prosecution solely for possession. However, the operational environment is hostile; traders cannot use local bank cards to purchase assets on major global exchanges and often face account closures if crypto-related activity is detected by their banks. This has driven the market underground, where it thrives on informal P2P networks, often facilitating remittances and cross-border trade in a region with strict foreign exchange controls.

A significant shift in the national stance appeared in late 2024. In his circular regarding the 2025 state budget, President Paul Biya instructed the government to 'enhance the supervision of cryptocurrency-related activities.' This directive suggests that the Cameroonian government is moving away from the strict prohibitionist stance of the regional regulator (COBAC) towards a pragmatic approach focused on supervision, likely driven by the desire to broaden the tax base and mitigate risks associated with money laundering and scams. This creates a complex regulatory landscape where the national executive branch signals interest in regulation, while the regional banking authority maintains a strict blockade.

Currently, no local exchanges are licensed, as COBAC refuses to authorize such activities. International platforms operate without local registration, and users access them at their own risk. The primary risks for retail investors include the lack of consumer protection, high susceptibility to Ponzi schemes (which have been rampant in the region), and the potential for sudden account freezes if regional regulators tighten enforcement mechanisms. Until a harmonized framework is established between the CEMAC regional bodies and the Cameroonian national government, the status will remain in this gray zone of 'legal to hold, difficult to bank.'

Source Evidence

Primary and secondary sources cited in this analysis

"Les établissements assujettis à la COBAC ainsi que leurs partenaires techniques... ne sont pas autorisés à souscrire ou détenir... les cryptomonnaies."

"Enhance the supervision of cryptocurrency-related activities."

2022-04-29

"The prohibition of the use of cryptocurrencies as a means of payment in the CEMAC."

"President Paul Biya instructed the prime minister to 'enhance the supervision of cryptocurrency-related activities.'"

"The decision was made during an extraordinary session which took place May 6, 2022."

Web Sources (7)

Sources discovered via web search grounding

Search queries used (8)
  • Is crypto legal in Cameroon 2025
  • BEAC cryptocurrency stance Cameroon
  • Cameroon cryptocurrency regulation status 2024 2025
  • COBAC CEMAC cryptocurrency regulation 2024
  • UMAC circular cryptocurrency ban CEMAC
  • COBAC decision May 6 2022 cryptocurrency text
  • Paul Biya circular 001 October 24 2024 cryptocurrency
  • COBAC decision D-2022-071 cryptocurrency
investiraucameroun.com

https://www.investiraucameroun.com/finance/1605-17911-cemac-la-cobac-met-les-operations-en-cryptomonnaies-sous-surveillance-apres-la-legalisation-du-bitcoin-par-la-rca

cesttoutdroit.com

https://cesttoutdroit.com/wp-content/uploads/2023/06/06-mai-2022-Decision-COBAC-D-2022-071-relative-a-la-detention-lutilisation-lechange-et-la-conversion-des-cryptomonnaies-par-les-etablissements-assujettis.pdf

mimimefoinfos.com

https://mimimefoinfos.com/biya-signals-cameroons-friendly-approach-to-cryptocurrency/

4mlegaltax.com

https://4mlegaltax.com/regulation-of-cryptocurrency-in-the-cemac/

4mlegaltax.com

https://4mlegaltax.com/virtual-assets-regulation-within-the-cemac-zone/

businessincameroon.com

https://www.businessincameroon.com/finance/1705-12556-cobac-steps-up-vigilance-on-cryptocurrencies-after-drc-legalizes-btc

droitmediasfinance.com

https://droitmediasfinance.com/index.php/actualites/droit-bancaire/355-cemac-la-commission-bancaire-interdit-les-crypto-actifs-aux-banques-et-assimiles-la-cosumaf-reste-attendue

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