Back to Analyses

Central African Republic

Retail_Trading_Status

Gray-Zone High Confidence
Edit
Analysis ID
#627
Version
Archived
Created
2025-12-12 04:03
Workflow Stage
Step 1

Executive Summary

Retail cryptocurrency trading in the Central African Republic (CAR) occupies a complex regulatory gray zone due to conflicting national and regional directives. While the CAR government explicitly legalized crypto assets and initially declared Bitcoin legal tender via Law No. 22.004, it later repealed the legal tender status in March 2023 under pressure from the Central African Economic and Monetary Community (CEMAC). Currently, individuals may legally hold and trade cryptocurrencies as 'reference values,' but the regional banking regulator (COBAC) strictly prohibits all financial institutions from processing crypto-related transactions, effectively severing the banking rails for the industry.

Key Pillars

Banking Commission of Central Africa (COBAC) - Regional banking regulator enforcing a strict ban on crypto servicing by financial institutions
National Agency for Regulation of Electronic Transactions (ANTE) - Designated national body for crypto oversight (operational status unclear)
Ministry of Finance and Budget - Oversees national economic policy regarding digital assets
Anti-Money Laundering (AML) - Regional standards apply, but specific crypto implementation is hampered by the banking ban

Landmark Laws

Law No. 23.005 amending Law No. 22.004 governing cryptocurrency (Loi n°23.005) - Enacted: 2023-03-23
- Repealed the legal tender status of Bitcoin, downgrading cryptocurrencies to 'reference values' that can be voluntarily accepted. It aligned CAR's framework closer to CEMAC standards while keeping crypto activities legal.

Law No. 22.004 governing cryptocurrency in the Central African Republic (Loi n°22.004) - Enacted: 2022-04-22
- The original 'Bitcoin Law' that established a legal framework for crypto assets, initially granting them legal tender status and tax exemptions. Key provisions were later amended.
- Source

COBAC Decision on Cryptocurrency Prohibitions (Decision D-2022/071) - Enacted: 2022-05-06
- A regional directive prohibiting all CEMAC banking and microfinance institutions from holding, exchanging, or settling transactions in cryptocurrencies to preserve financial stability.

Considerations

Banking Blockade: Local banks cannot process transfers to/from crypto exchanges due to the COBAC ban.
Regional Conflict: The CAR government promotes crypto (e.g., Sango Coin project), while the regional central bank (BEAC) and regulator (COBAC) oppose it.
Sango Coin: The state-backed crypto project has faced legal hurdles, including a Constitutional Court ruling blocking citizenship-by-investment via the token.
Infrastructure: Extremely low internet penetration and electricity access limit practical retail trading for the majority of the population.

Notes

The situation in CAR is unique: it is one of the few jurisdictions where the government is more pro-crypto than the private banking sector (which is bound by regional rules). The 'Gray-Zone' status here is due to the 'Bank Ban' trigger, despite the government's permissive stance. Traders should be aware that while they won't be arrested for trading, they likely cannot use their local bank accounts to fund the activity.

Remaining Uncertainties

  • The operational status of the National Agency for Regulation of Electronic Transactions (ANTE) is unknown.
  • Whether COBAC has privately communicated any relaxation of rules for specific pilot projects (unlikely given public stance).
  • The current status of the Sango Coin platform's technical infrastructure and user base.

Full Analysis Report

The regulatory status of retail cryptocurrency trading in the Central African Republic is best classified as 'Gray-Zone' due to the stark contradiction between national aspirations and regional financial enforcement. In April 2022, the CAR government made headlines by becoming the second country in the world to adopt Bitcoin as legal tender through Law No. 22.004. This law established a broad framework allowing for tax payments in crypto and mandating acceptance by economic agents. However, this move was immediately met with fierce opposition from the Bank of Central African States (BEAC) and the Banking Commission of Central Africa (COBAC), which govern the monetary union (CEMAC) to which CAR belongs.

In response to the CAR's unilateral move, COBAC issued Decision D-2022/071 in May 2022, explicitly prohibiting all credit and microfinance institutions in the CEMAC zone from dealing in crypto assets. This effectively created a firewall between the traditional financial system and the crypto economy, preventing users from funding accounts or withdrawing fiat via local banks. Consequently, while trading is not criminally banned for individuals under national law, the operational environment is severely restricted.

Under significant diplomatic and economic pressure from CEMAC and the IMF, the CAR parliament passed Law No. 23.005 in March 2023. This legislation formally repealed the legal tender status of Bitcoin, reclassifying cryptocurrencies as 'reference values' that are legal to hold and trade but not mandatory for merchants to accept. This amendment was intended to harmonize CAR's legislation with regional treaties, though the government continues to pursue its 'Sango' blockchain initiatives.

Despite the legal permission for individuals to trade, the ecosystem remains dysfunctional. The state-backed 'Sango Coin' project has stalled following a Constitutional Court ruling that deemed the sale of citizenship for crypto unconstitutional. Furthermore, without access to local banking rails, retail traders are forced to rely on peer-to-peer (P2P) markets or offshore platforms, often with limited liquidity and high friction. The regulatory environment remains in a stalemate: legal on paper within CAR, but operationally blocked by the regional monetary authority.

Source Evidence

Primary and secondary sources cited in this analysis

"The authorities have agreed with BEAC to harmonize their crypto legislation with the monetary union framework on April 6, 2023—including by amending key articles of the crypto law pertaining to the legal tender status."

"La présente loi a pour objet de régir toutes les transactions liées aux cryptomonnaies en République Centrafricaine, sans restriction..."

"The Central African Republic's parliament has repealed legislation that gave bitcoin and other cryptocurrencies legal tender status."

"COBAC met in an extraordinary session and decided a general ban on cryptocurrencies and crypto assets by all the credit institutions of the Community."

"A new law has been enacted, designating Bitcoin and other cryptocurrencies as reference values that citizens can voluntarily use or accept as payment."

Web Sources (8)

Sources discovered via web search grounding

Search queries used (5)
  • COBAC ban cryptocurrency Central African Republic
  • Central African Republic bitcoin legal tender repealed 2023
  • Central African Republic crypto law 2024 status
  • Law No 22.004 Central African Republic cryptocurrency
  • Sango Coin current status 2025
imf.org

https://www.imf.org/-/media/files/publications/cr/2023/english/1cafea2023002.pdf

jbgsmining.com

https://www.jbgsmining.com/en/post/central-african-republic-drops-bitcoin-as-legal-tender

reddit.com

https://www.reddit.com/r/Bitcoin/comments/12r0m7u/the_central_african_republic_drops_bitcoin_as/

techcabal.com

https://techcabal.com/2025/08/06/crypto-licensing-in-africa/

mariblock.com

https://www.mariblock.com/central-african-republic-to-review-law-that-makes-bitcoin-a-legal-tender-president-touadera/

africlaw.com

https://africlaw.com/2022/07/21/regulating-cryptocurrencies-in-the-central-african-republic-has-the-cart-been-put-before-the-horse/

africlaw.com

https://africlaw.com/tag/law-n22-004/

imf.org

https://www.elibrary.imf.org/view/journals/002/2023/156/article-A001-en.xml

Reviews

No reviews yet

Submit Review

Challenge: Disagree with the analysis | Approval: Confirm it's correct | Refinement: Suggest improvements