Equatorial Guinea
Retail_Trading_Status
- Analysis ID
- #654
- Version
- Archived
- Created
- 2025-12-12 04:16
- Run
- daef23d2...
- History
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- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading in Equatorial Guinea is in a regulatory gray zone characterized by conflicting directives from regional bodies. While the Central African Banking Commission (COBAC) explicitly prohibits banks from facilitating crypto transactions, the regional market regulator (COSUMAF) has introduced a framework to license Virtual Asset Service Providers (VASPs). As of late 2025, this conflict remains unresolved; no local exchanges are fully licensed and operational, and the banking sector remains closed to crypto-related flows, although individual possession is not explicitly criminalized.
Key Pillars
COBAC (Banking Regulator): Enforces a strict ban on banks and microfinance institutions holding, exchanging, or processing crypto assets.
COSUMAF (Market Regulator): Established a theoretical licensing regime for VASPs (Regulation No. 01/22) and launched a census of actors in July 2025.
BEAC (Central Bank): Maintains a restrictive stance to protect the CFA franc and foreign reserves, opposing the integration of crypto into the banking system.
National Agency for Financial Investigation (ANIF): Responsible for AML/CFT oversight, though specific crypto guidance is limited.
Landmark Laws
COBAC Decision on Cryptocurrencies (Decision D-2022/071) - Enacted: 2022-05-06
- Prohibits all banking and microfinance institutions in the CEMAC zone from holding, exchanging, converting, or settling transactions related to cryptocurrencies for their own account or third parties.
- Source
Regulation on the Organization and Functioning of the Financial Market (Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF) - Enacted: 2022-07-21
- Extends the definition of market intermediaries to include 'Digital Asset Service Providers' (PSAN), creating a legal basis for licensing crypto exchanges and custodians, though implementation is stalled by the banking ban.
- Source
Tax Code of Equatorial Guinea (Law No. 1/2024) - Enacted: 2024-01-01
- Updated the general tax framework (reducing corporate tax to 25%) but notably excluded specific provisions for cryptocurrency taxation, leaving crypto gains largely untaxed due to lack of recognition.
Considerations
Banking Blockade: Local bank accounts cannot be used to fund crypto exchange accounts; transfers identified as crypto-related are blocked.
Regulatory Conflict: A tug-of-war exists between the banking regulator (COBAC) which bans crypto interaction, and the market regulator (COSUMAF) which seeks to regulate it.
Tax Status: There is currently no specific capital gains tax regime for crypto assets, as they are not legally recognized as taxable property.
Regional Volatility: The nearby Central African Republic's attempt to legalize Bitcoin created regional friction, leading to stricter enforcement of the CFA franc's exclusivity in Equatorial Guinea.
Notes
The 'Gray-Zone' classification is driven by the 'Bank Ban' trigger in the decision flowchart. While market regulations (COSUMAF) suggest a path to 'Allowed-Regulated', the operational reality is defined by the banking prohibition (COBAC). The July 2025 census by COSUMAF indicates a move towards regulation, but until banks can legally process these funds, the sector remains effectively blocked from the formal financial system.
Remaining Uncertainties
- Will the COBAC banking ban be lifted or amended to allow COSUMAF-licensed entities to open bank accounts?
- Has any specific entity successfully completed the COSUMAF licensing process initiated by the July 2025 census?
- Will Equatorial Guinea issue national guidelines that diverge from the regional BEAC stance, similar to the Central African Republic (unlikely but possible)?
Full Analysis Report
Full Analysis Report
Equatorial Guinea's regulatory status for retail cryptocurrency trading falls squarely into the 'Gray-Zone' due to a sharp dichotomy between banking prohibitions and emerging market regulations. As a member of the Central African Economic and Monetary Community (CEMAC), the country is subject to regional regulations that supersede national rules. The primary obstacle to legal retail trading is Decision D-2022/071, issued by the Central African Banking Commission (COBAC) in May 2022. This directive explicitly forbids all credit institutions, microfinance entities, and payment providers from holding, exchanging, or facilitating transactions in cryptocurrencies. Consequently, while it is not a crime for an individual to own Bitcoin, they cannot legally use the national banking system to buy or sell it.
Conversely, the regional financial market supervisor, COSUMAF, has attempted to bring the sector under a regulatory umbrella. In July 2022, COSUMAF adopted Regulation No. 01/22/CEMAC/UMAC/CM, which formally recognizes 'Digital Asset Service Providers' (PSANs) as market intermediaries eligible for licensing. This created a theoretical pathway for exchanges to operate legally. In July 2025, COSUMAF moved to operationalize this by launching a 'census' of crypto actors operating in the zone, intending to transition them into a regulated status. However, without access to banking services (due to the COBAC ban), these entities cannot practically operate, creating a regulatory deadlock.
For retail investors in Equatorial Guinea, this environment presents significant operational risks. There are no locally licensed exchanges. Traders typically resort to foreign platforms or peer-to-peer (P2P) markets, settling transactions via mobile money or cash to bypass banking filters. While the government of Equatorial Guinea has not issued a national decree criminalizing possession, the strict stance of the Bank of Central African States (BEAC) regarding the protection of the CFA franc means that any integration of crypto into the formal economy is actively suppressed. The IMF has also advised CEMAC nations to maintain restrictive measures until a harmonized framework—likely one that prioritizes financial stability over innovation—is fully agreed upon by all regional bodies.
Equatorial Guinea's regulatory status for retail cryptocurrency trading falls squarely into the 'Gray-Zone' due to a sharp dichotomy between banking prohibitions and emerging market regulations. As a member of the Central African Economic and Monetary Community (CEMAC), the country is subject to regional regulations that supersede national rules. The primary obstacle to legal retail trading is Decision D-2022/071, issued by the Central African Banking Commission (COBAC) in May 2022. This directive explicitly forbids all credit institutions, microfinance entities, and payment providers from holding, exchanging, or facilitating transactions in cryptocurrencies. Consequently, while it is not a crime for an individual to own Bitcoin, they cannot legally use the national banking system to buy or sell it. Conversely, the regional financial market supervisor, COSUMAF, has attempted to bring the sector under a regulatory umbrella. In July 2022, COSUMAF adopted Regulation No. 01/22/CEMAC/UMAC/CM, which formally recognizes 'Digital Asset Service Providers' (PSANs) as market intermediaries eligible for licensing. This created a theoretical pathway for exchanges to operate legally. In July 2025, COSUMAF moved to operationalize this by launching a 'census' of crypto actors operating in the zone, intending to transition them into a regulated status. However, without access to banking services (due to the COBAC ban), these entities cannot practically operate, creating a regulatory deadlock. For retail investors in Equatorial Guinea, this environment presents significant operational risks. There are no locally licensed exchanges. Traders typically resort to foreign platforms or peer-to-peer (P2P) markets, settling transactions via mobile money or cash to bypass banking filters. While the government of Equatorial Guinea has not issued a national decree criminalizing possession, the strict stance of the Bank of Central African States (BEAC) regarding the protection of the CFA franc means that any integration of crypto into the formal economy is actively suppressed. The IMF has also advised CEMAC nations to maintain restrictive measures until a harmonized framework—likely one that prioritizes financial stability over innovation—is fully agreed upon by all regional bodies.
Source Evidence
Primary and secondary sources cited in this analysis
"Les établissements assujettis... ne sont pas autorisés à souscrire ou détenir... les cryptomonnaies... Il est interdit... d'échanger ou de convertir... les transactions relatives aux cryptomonnaies."
"Extends the definition of market intermediaries to crypto assets service providers (Art 145) and is defining such services to include buying and selling crypto assets."
"COBAC's earlier Decision D-2022/071 prohibiting the use of cryptocurrencies by entities under its remit [remains in force]."
"The Financial Market Regulator... has prohibited Banks... from facilitating transactions in cryptocurrency."
"Currently, the cryptocurrency sector in Equatorial Guinea has no specific laws... Digital currency is not legal tender, but it is not illegal to engage in cryptocurrency-related activities."
Web Sources (2)
Sources discovered via web search grounding
Search queries used (9)
- Equatorial Guinea retail crypto trading legality
- Regulation No. 01/22/CEMAC/UMAC/CM crypto
- COSUMAF crypto regulation CEMAC Equatorial Guinea
- BEAC cryptocurrency ban Equatorial Guinea
- Equatorial Guinea cryptocurrency regulation 2024 2025
- Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF text
- Equatorial Guinea crypto tax laws 2025
- COBAC Decision D-2022/071 text
- BEAC crypto stance 2025
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
https://www.elibrary.imf.org/view/journals/002/2023/156/article-A001-en.xml