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Chad

Retail_Trading_Status

Gray-Zone High Confidence
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Analysis ID
#629
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Created
2025-12-12 04:03
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Executive Summary

Retail cryptocurrency trading in Chad is in a regulatory 'Gray-Zone' characterized by a conflict between regional financial market regulations and central bank prohibitions. While the regional financial regulator (COSUMAF) introduced a licensing framework for crypto asset service providers in 2022, the Central Bank (BEAC) strictly prohibits banking institutions from facilitating crypto transactions. As of late 2025, COSUMAF is still conducting public consultations on the practical instructions for this framework, and no licensed entities have been confirmed in Chad.

Key Pillars

COSUMAF (Central African Financial Market Supervisory Commission): The primary regulator for financial markets, which has established a theoretical licensing regime for crypto assets.
BEAC (Bank of Central African States): The central bank, which enforces a strict ban on the banking sector's involvement with crypto assets to protect monetary stability.
UMAC (Central African Monetary Union): The governing body that oversees the monetary policy and supports BEAC's restrictive stance.

Landmark Laws

Regulation No. 01/22/CEMAC/UMAC/COSUMAF (Regulation No. 01/22/CEMAC/UMAC/COSUMAF) - Enacted: 2022-07-21
- A regional regulation organizing the financial market in CEMAC states (including Chad). It formally recognizes 'Digital Asset Service Providers' (PSANs) and establishes a requirement for them to be approved by COSUMAF.
- Source

BEAC Decision on Crypto Assets (Decision No. D-2022/071) - Enacted: 2022-05-06
- A directive from the Central Bank prohibiting credit institutions and payment processors in the CEMAC zone from exchanging, holding, or facilitating transactions in cryptocurrencies.

COSUMAF Public Consultation on Instructions (Consultation Publique) - Enacted: 2025-07-09
- Ongoing regulatory work in 2025 to define the specific application modalities (Instructions) for the 2022 regulation, indicating the framework is not yet fully operational.
- Source

Considerations

Banking Blockade: Due to BEAC's prohibition, Chadian residents cannot legally use local bank accounts to fund crypto exchange accounts; banks may freeze accounts suspected of such activity.
Regional vs. National: Chad does not have its own independent crypto laws but follows the CEMAC regional framework. The conflict between CAR (pro-crypto) and the rest of CEMAC has complicated the landscape, but Chad aligns with the conservative BEAC stance.
Lack of Licensed Entities: Despite the 2022 regulation, COSUMAF frequently issues alerts warning that no entities are currently authorized to offer crypto investment services to the public.
Consumer Risk: COSUMAF has explicitly warned the public that crypto investments are unregulated and risky, and 'investment' schemes (often scams) are common.

Notes

The analysis date is December 12, 2025. The regulatory environment is dynamic, with COSUMAF actively consulting on implementation instructions throughout 2025. The 'Gray-Zone' status reflects the gap between the existence of a regulation (the 2022 text) and its lack of operational reality (no licenses, banking ban).

Remaining Uncertainties

  • Whether any specific 'Digital Asset Service Provider' (PSAN) licenses have been secretly issued or are in the final stages of approval as of late 2025.
  • How the conflict between the 2022 COSUMAF regulation and the BEAC banking ban will be legally resolved in practice.
  • If Chad will introduce any national-level decrees to enforce the regional COSUMAF regulation.

Detailed Explanation

As of December 12, 2025, the regulatory status for retail cryptocurrency trading in Chad is definitively a 'Gray-Zone,' characterized by a fundamental conflict between a permissive regional framework and a restrictive central bank policy. Chad, as a member of the Central African Economic and Monetary Community (CEMAC), does not have its own independent cryptocurrency laws and instead adheres to the regional regulatory structure. The primary framework is established by Regulation No. 01/22/CEMAC/UMAC/COSUMAF, enacted on July 21, 2022, by the Central African Financial Market Supervisory Commission (COSUMAF). This regulation formally organizes the regional financial market and recognizes 'Digital Asset Service Providers' (PSANs), establishing a requirement for them to obtain approval from COSUMAF. However, this framework remains largely theoretical. As of late 2025, COSUMAF is still conducting public consultations, specifically from July 9 to July 17, 2025, to define the specific application modalities (Instructions) for the 2022 regulation, indicating the licensing regime is not yet fully operational. Consequently, no entities have been confirmed as licensed to offer crypto services in Chad. In direct opposition to this developing framework, the Bank of Central African States (BEAC), the central bank for the CEMAC zone, enforces a strict prohibition. BEAC's Decision No. D-2022/071, enacted on May 6, 2022, explicitly forbids all credit institutions and payment processors from exchanging, holding, or facilitating transactions in cryptocurrencies. This creates a critical 'Banking Blockade,' meaning Chadian residents cannot legally use local bank accounts to fund crypto exchange accounts, and financial institutions may freeze accounts suspected of such activity. The Central African Monetary Union (UMAC) supports BEAC's restrictive stance to protect monetary stability. This regulatory conflict places consumers at significant risk, a point underscored by COSUMAF itself, which frequently issues public alerts warning that crypto investments are unregulated and risky, and that investment schemes are often scams. The 'Gray-Zone' status therefore reflects the tangible gap between the existence of a permissive regulation and its lack of operational reality due to the central bank's ban and the ongoing development of implementation rules.

Summary Points

I. Regulatory Status
* Chad's status is a 'Gray-Zone' as of December 12, 2025.
* This status results from a conflict between a regional licensing framework and a central bank prohibition.
* The country follows the CEMAC regional framework and lacks independent national crypto laws.

II. Key Regulatory Bodies
* COSUMAF (Central African Financial Market Supervisory Commission): The primary financial market regulator, which introduced a theoretical licensing regime for crypto asset service providers.
* BEAC (Bank of Central African States): The central bank, which prohibits the banking sector's involvement with crypto assets to protect monetary stability.
* UMAC (Central African Monetary Union): The monetary union governing body that supports BEAC's restrictive stance.

III. Important Legislation
* Regulation No. 01/22/CEMAC/UMAC/COSUMAF (Enacted: 2022-07-21)
* A regional regulation that formally organizes the financial market in CEMAC states.
* Recognizes 'Digital Asset Service Providers' (PSANs) and establishes a requirement for them to be approved by COSUMAF.
* BEAC Decision on Crypto Assets (Decision No. D-2022/071) (Enacted: 2022-05-06)
* A directive from the Central Bank prohibiting credit institutions and payment processors from exchanging, holding, or facilitating cryptocurrency transactions.
* COSUMAF Public Consultation on Instructions (Enacted: 2025-07-09)
* An ongoing regulatory process in 2025 to define the specific application modalities for the 2022 regulation, indicating the framework is not yet fully operational.

IV. Compliance Requirements
* In theory, any entity wishing to operate as a crypto service provider must be licensed by COSUMAF under the 2022 regulation.
* However, the specific application instructions are still under public consultation as of July 2025, meaning the licensing process is not yet active.
* No entities have been confirmed as licensed by COSUMAF to offer crypto investment services to the public.

V. Notable Restrictions or Limitations
* Banking Blockade: Due to BEAC's prohibition, Chadian residents cannot legally use local bank accounts to fund crypto exchange accounts. Banks may freeze accounts suspected of such activity.
* Consumer Risk: COSUMAF has explicitly warned the public that crypto investments are unregulated and risky, and that 'investment' schemes are often scams.

VI. Recent Developments or Notes
* The regulatory environment is dynamic, with COSUMAF actively consulting on implementation instructions throughout 2025.
* The 'Gray-Zone' status reflects the gap between the existence of a regulation (the 2022 text) and its lack of operational reality (no licenses, active banking ban).

Full Analysis Report

The regulatory status of retail cryptocurrency trading in Chad is best classified as 'Gray-Zone' due to a significant divergence between the regional financial market regulator and the central bank. Chad is a member of the Central African Economic and Monetary Community (CEMAC), meaning its financial regulations are determined at the regional level. In July 2022, the Central African Financial Market Supervisory Commission (COSUMAF) enacted Regulation No. 01/22/CEMAC/UMAC/COSUMAF. This landmark text formally recognized 'Digital Asset Service Providers' (PSANs) and brought them under COSUMAF's supervision, theoretically creating a path for legal, regulated trading.

However, this 'Allowed-Regulated' path remains theoretical rather than practical for Chadian retail traders. The Bank of Central African States (BEAC), which controls the monetary policy for Chad and the region, issued Decision No. D-2022/071 in May 2022, explicitly prohibiting banks and microfinance institutions from holding, exchanging, or facilitating transactions related to cryptocurrencies. This creates a 'banking blockade' where, even if an exchange were to obtain a COSUMAF license, it would struggle to access the local banking system to process fiat deposits and withdrawals for clients.

Furthermore, the implementation of the COSUMAF regulation has been slow. As of late 2025, COSUMAF is still conducting public consultations (e.g., in July and November 2025) to finalize the 'Instructions' that detail how the 2022 regulation should be applied. This indicates that the licensing regime is not yet fully operational. There is no public record of any entity receiving a full license to operate in Chad, and COSUMAF continues to issue warnings against unauthorized platforms soliciting funds from the public.

Consequently, while buying and holding cryptocurrency is not explicitly criminalized for individuals in Chad (unlike in 'Banned' jurisdictions), the lack of licensed intermediaries and the active hostility from the banking sector place it firmly in the Gray-Zone. Retail investors operate in a precarious environment where they have no consumer protection, cannot use local banking rails, and face risks of account freezes if they attempt to interact with crypto platforms using traditional finance channels.

Source Evidence

Primary and secondary sources cited in this analysis

"La COSUMAF lance une consultation publique sur des projets d'Instructions précisant les modalités d'application des dispositions du Règlement n°01/22/CEMAC/UMAC/CM/ COSUMAF"

2020-10-23

"La COSUMAF alerte le public que l'exercice des activités de crypto-actifs dans l'espace CEMAC ne fait pas l'objet d'encadrement règlementaire."

"The regional banking regulator COBAC issued a regulation prohibiting its supervised institutions from engaging in transactions with crypto assets... (Decision D-2022/071 from May 6, 2022)."

"Regulation nº 01/22/CEMAC/UMAC/COSUMAF... contains provisions on... cryptoasset platforms have been identified... without the necessary authorizations from COSUMAF."

"BEAC has firmly indicated its opposition... citing concerns that cryptocurrencies could deplete the community's foreign exchange reserves."

Web Sources (7)

Sources discovered via web search grounding

Search queries used (9)
  • Is Bitcoin legal in Chad
  • BEAC crypto ban Chad status
  • Regulation No. 01/22/CEMAC/UMAC/COSUMAF details
  • COSUMAF regulation cryptocurrency Chad
  • Chad cryptocurrency regulation retail trading status 2024
  • Regulation No. 01/22/CEMAC/UMAC/COSUMAF text summary
  • Chad specific crypto enforcement actions 2024 2025
  • COSUMAF crypto licenses issued list 2024 2025
  • BEAC stance on crypto 2025
cosumaf.org

https://cosumaf.org/tag/crypto-monnaie/

cosumaf.org

https://cosumaf.org/tag/crypto-actifs/

imf.org

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

fatf-gafi.org

https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Equatorial-Guinea-MER.pdf.coredownload.inline.pdf

chambers.com

https://practiceguides.chambers.com/practice-guides/comparison/1026/16029/23622-23623-23624-23625-23626-23627-23628-23629-23630-23631-23632

scribd.com

https://www.scribd.com/document/955528519/Legiafrica-Article-by-Doctor-Ako-o

4mlegaltax.com

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

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