Côte d'Ivoire
Retail_Trading_Status
- Analysis ID
- #642
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- 2025-12-12 04:06
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Executive Summary
Retail cryptocurrency trading in Côte d'Ivoire exists in a regulatory gray zone. While individual possession and trading are not explicitly criminalized, the Central Bank of West African States (BCEAO) has issued strict warnings and prohibited financial institutions from facilitating crypto transactions. A new AML/CFT ordinance enacted in late 2023 explicitly defines 'virtual assets' and 'virtual asset service providers' (VASPs) for monitoring purposes, but no licensing regime currently exists to allow these businesses to operate formally.
Key Pillars
BCEAO (Central Bank): Issues monetary policy and enforces the banking ban on crypto interactions.
CENTIF-CI (Financial Intelligence Unit): Enforces AML/CFT compliance, now covering virtual assets under Ordinance No. 2023-875.
AMF-UMOA (Regional Financial Market Authority): Oversees financial markets and has indicated that crypto assets are not yet recognized financial instruments.
Landmark Laws
Ordinance No. 2023-875 on AML/CFT (Ordonnance N° 2023-875) - Enacted: 2023-11-23
- Explicitly defines 'Virtual Assets' (Actif virtuel) and 'Virtual Asset Service Providers' (PSAV) for the first time in Ivorian law, subjecting them to AML/CFT monitoring obligations despite the lack of a business license.
- Source
BCEAO Press Release on Cryptocurrencies (Communiqué de Presse) - Enacted: 2018-03-01
- Official statement by the BCEAO Governor declaring that Bitcoin is not a currency, is not welcome in the UEMOA zone, and that banks are prohibited from dealing in it.
- Source
Law No. 2016-992 (Repealed) (Loi N° 2016-992) - Enacted: 2016-11-14
- Previous AML law that did not explicitly cover virtual assets; replaced by Ordinance No. 2023-875 to align with FATF standards.
Considerations
Banking Ban: Local banks cannot open accounts for crypto exchanges or process direct crypto-related transfers.
FATF Grey List: Côte d'Ivoire is on the FATF Grey List (as of late 2024), increasing pressure to enforce the new AML rules on virtual assets.
No Licensing Regime: Despite the AML definition, there is no mechanism for a VASP to obtain an operating license from the AMF-UMOA or BCEAO.
Tax Uncertainty: No specific crypto tax regime exists; general capital gains rules likely apply but enforcement is difficult due to the informal nature of the market.
Notes
The 'mining is legal' claim appearing in some 2025-dated online articles (e.g., MEXC Wiki) references 'Law No. 2024-352'. Research confirms this law exists but relates to 'Electronic Communications' generally, without explicit text legalizing crypto mining. This analysis treats that claim as unverified marketing content.
Remaining Uncertainties
- Will the AMF-UMOA introduce a specific licensing regime for VASPs in 2025?
- Clarification on the 'mining is legal' rumors—no official law confirms this despite online speculation.
- How strictly will the new AML ordinance be enforced against P2P traders?
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading in Côte d'Ivoire operates in a regulatory gray zone, where the activity is not explicitly criminalized but faces significant institutional restrictions. The primary regulatory framework is defined by a 2018 prohibition from the Central Bank of West African States (BCEAO), which declared that Bitcoin is not a currency and is not welcome in the UEMOA zone, explicitly forbidding financial institutions from facilitating any crypto transactions. This banking ban creates a major barrier to formal market operations. However, a significant development occurred with the enactment of Ordinance No. 2023-875 on November 23, 2023, which modernized the country's anti-money laundering and counter-terrorist financing (AML/CFT) regime. This ordinance explicitly defines 'virtual assets' and 'virtual asset service providers' (VASPs) for the first time in Ivorian law, bringing them under the monitoring purview of the national Financial Intelligence Unit, CENTIF-CI. This move aligns with Côte d'Ivoire's position on the FATF Grey List, increasing pressure to enforce these new rules. Despite this AML recognition, there is no corresponding licensing regime established by the regional financial market authority, AMF-UMOA, or the BCEAO to allow VASPs to operate formally, leaving businesses in a paradoxical situation of being subject to compliance obligations without a legal pathway to obtain a business license. Tax treatment remains uncertain with no specific crypto tax regime, likely falling under general capital gains rules, though enforcement is challenging. Claims regarding the legalization of cryptocurrency mining via 'Law No. 2024-352' are unverified, as the law pertains to electronic communications and does not contain explicit text on mining, indicating that the regulatory environment remains restrictive and defined by prohibition at the institutional level.
Summary Points
I. Regulatory Status
* The regulatory status for retail cryptocurrency trading is a Gray-Zone.
* Individual possession and trading are not explicitly criminalized.
* There is no licensing regime for virtual asset service providers (VASPs) to operate formally.
II. Key Regulatory Bodies
* Central Bank of West African States (BCEAO): Issues monetary policy and enforces the banking ban on cryptocurrency interactions.
* CENTIF-CI (Financial Intelligence Unit): Enforces AML/CFT compliance, now covering virtual assets under Ordinance No. 2023-875.
* AMF-UMOA (Regional Financial Market Authority): Oversees financial markets and has indicated that crypto assets are not yet recognized as financial instruments.
III. Important Legislation
* Ordinance No. 2023-875 on AML/CFT (Enacted: 2023-11-23):
* Explicitly defines 'Virtual Assets' (Actif virtuel) and 'Virtual Asset Service Providers' (PSAV) for the first time in Ivorian law.
* Subjects VASPs to AML/CFT monitoring obligations.
* BCEAO Press Release on Cryptocurrencies (Enacted: 2018-03-01):
* Official statement declaring Bitcoin is not a currency and is not welcome in the UEMOA zone.
* Prohibits banks from dealing in cryptocurrencies.
* Law No. 2016-992 (Repealed):
* Previous AML law that did not explicitly cover virtual assets; replaced by Ordinance No. 2023-875.
IV. Compliance Requirements
* Virtual Asset Service Providers (VASPs), as defined by law, are subject to AML/CFT monitoring obligations under the new ordinance.
* Compliance is enforced by CENTIF-CI.
V. Notable Restrictions or Limitations
* Banking Ban: Local financial institutions are prohibited from opening accounts for crypto exchanges or processing direct crypto-related transfers.
* No Formal Market: The lack of a licensing regime prevents VASPs from operating with formal business authorization.
* Tax Uncertainty: No specific cryptocurrency tax regime exists; general capital gains rules likely apply but enforcement is difficult.
VI. Recent Developments or Notes
* Côte d'Ivoire is on the FATF Grey List (as of late 2024), increasing pressure to enforce the new AML rules on virtual assets.
* The claim that 'mining is legal' under 'Law No. 2024-352' is treated as unverified marketing content; research confirms the law relates to 'Electronic Communications' generally without explicit text on crypto mining.
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in Côte d'Ivoire is characterized by a 'Gray-Zone' environment where enforcement focuses on financial institutions rather than individual users. The Central Bank of West African States (BCEAO), which governs monetary policy for the West African Economic and Monetary Union (UEMOA), has maintained a prohibitive stance since 2018. The BCEAO explicitly stated that cryptocurrencies are not legal tender and has instructed banking institutions to refrain from holding, trading, or facilitating transactions involving digital assets. Consequently, retail traders cannot use local bank accounts to directly fund crypto exchange accounts, forcing them to rely on peer-to-peer (P2P) markets and mobile money workarounds.
Despite the banking restrictions, the legal framework took a significant step forward with the enactment of Ordinance No. 2023-875 in November 2023. This legislation, designed to align Côte d'Ivoire with FATF recommendations, introduced the first legal definitions for 'Virtual Assets' and 'Virtual Asset Service Providers' (PSAV). By defining these terms, the government has brought crypto assets under the scope of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations. This creates a paradoxical situation where VASPs are recognized as entities subject to AML scrutiny but have no regulatory pathway to obtain a license to operate legally.
The regional financial market regulator, AMF-UMOA, has not yet established a framework for public offers or trading of crypto assets. While they have issued warnings about the risks of unregulated investment products, they have not moved to ban individual possession. Therefore, it is not a criminal offense for Ivorian citizens to buy, sell, or hold Bitcoin or other cryptocurrencies in a personal capacity, provided they do not violate AML laws.
Practically, the market operates in the shadows. International exchanges are accessible but often require P2P methods for fiat on-ramping. The recent inclusion of 'Virtual Assets' in the AML ordinance suggests a potential shift towards future regulation, but for now, it primarily serves to police illicit financial flows rather than to legitimize the industry. The 'mining is legal' narrative found in some online sources appears to be unsubstantiated by official gazettes and likely confuses general digital economy laws with specific crypto permissions.
The regulatory status of cryptocurrency in Côte d'Ivoire is characterized by a 'Gray-Zone' environment where enforcement focuses on financial institutions rather than individual users. The Central Bank of West African States (BCEAO), which governs monetary policy for the West African Economic and Monetary Union (UEMOA), has maintained a prohibitive stance since 2018. The BCEAO explicitly stated that cryptocurrencies are not legal tender and has instructed banking institutions to refrain from holding, trading, or facilitating transactions involving digital assets. Consequently, retail traders cannot use local bank accounts to directly fund crypto exchange accounts, forcing them to rely on peer-to-peer (P2P) markets and mobile money workarounds. Despite the banking restrictions, the legal framework took a significant step forward with the enactment of Ordinance No. 2023-875 in November 2023. This legislation, designed to align Côte d'Ivoire with FATF recommendations, introduced the first legal definitions for 'Virtual Assets' and 'Virtual Asset Service Providers' (PSAV). By defining these terms, the government has brought crypto assets under the scope of Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) regulations. This creates a paradoxical situation where VASPs are recognized as entities subject to AML scrutiny but have no regulatory pathway to obtain a license to operate legally. The regional financial market regulator, AMF-UMOA, has not yet established a framework for public offers or trading of crypto assets. While they have issued warnings about the risks of unregulated investment products, they have not moved to ban individual possession. Therefore, it is not a criminal offense for Ivorian citizens to buy, sell, or hold Bitcoin or other cryptocurrencies in a personal capacity, provided they do not violate AML laws. Practically, the market operates in the shadows. International exchanges are accessible but often require P2P methods for fiat on-ramping. The recent inclusion of 'Virtual Assets' in the AML ordinance suggests a potential shift towards future regulation, but for now, it primarily serves to police illicit financial flows rather than to legitimize the industry. The 'mining is legal' narrative found in some online sources appears to be unsubstantiated by official gazettes and likely confuses general digital economy laws with specific crypto permissions.
Source Evidence
Primary and secondary sources cited in this analysis
"Actif virtuel : la représentation numérique d'une valeur qui peut être échangée ou transférée par un procédé numérique."
"Le Bitcoin et les cryptomonnaies ne sont pas les bienvenus au sein de l'espace UEMOA."
"En Côte d'Ivoire, l'activité de cryptomonnaie échappe à tout contrôle. Toutefois, elle a été identifiée pour être prise en compte dans l'analyse des vulnérabilités."
"There are active VASPs in Côte d'Ivoire. However, they are neither licensed, nor regulated, nor supervised, in the absence of a relevant legal framework."
Web Sources (10)
Sources discovered via web search grounding
Search queries used (14)
- Côte d'Ivoire crypto tax laws
- legality of bitcoin in Ivory Coast
- BCEAO communiqué crypto-monnaies
- BCEAO cryptocurrency regulation Côte d'Ivoire
- AMF-UMOA crypto regulation
- Is crypto mining legal in Ivory Coast official sources
- BCEAO communiqué presse crypto monnaie 2018
- Côte d'Ivoire loi cryptomonnaie 2024
- BCEAO circular prohibition banks cryptocurrency
- Côte d'Ivoire digital asset regulation 2025
- CENTIF Côte d'Ivoire cryptomonnaie
- Ordonnance N° 2023-875 Côte d'Ivoire actifs virtuels
- Ordinance No. 2023-875 AML CFT Ivory Coast virtual assets
- Loi lutte contre le blanchiment Côte d'Ivoire crypto monnaie
https://apisec.giaba.org/api/storage/f/b6b87cbab0e239526c19b086d5605df4653acf3526a7a02c16242f6a2bff1cc4/Second%20Enhanced%20Follow-up%20Report%20of%20the%20Republic%20of%20Cote%20dIvoire%20-May%202025.pdf
https://www.elibrary.imf.org/view/journals/002/2023/307/article-A001-en.xml
https://compliance-ci.com/wp-content/uploads/2023/12/Publication-JORCI_Ordonnance-2023-875-relative-a-la-LBC-FT.pdf
https://www.centif.ci/wp-content/uploads/2024/09/RESUME-ANALYTIQUE-ENR-BCFT.pdf
https://centif.ci/documents/arrete0482du28juin2024finances.pdf
https://www.scribd.com/document/740521933/Ordonnance-n-2023-875-du-23-novembre-2023-LBC-FTP
https://www.centif.ci/wp-content/uploads/2024/09/RESUME-ANALYTIQUE-ENR-BCFT.pdf
https://www.droit-afrique.com/upload/doc/cote-divoire/RCI-Loi-2005-554-lutte-blanchiment-capitaux.pdf
https://proeliumlaw.com/cryptocurrency-regulation-tracker/
https://www.anqacompliance.com/cote-divoire-aml-giaba