Gabon
Retail_Trading_Status
- Analysis ID
- #666
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- Created
- 2025-12-12 04:19
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- bb665756...
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Executive Summary
Retail cryptocurrency trading in Gabon operates in a regulatory gray zone characterized by conflicting regional directives. While the regional market regulator (COSUMAF) has established a legal framework for digital asset service providers (Regulation No. 01/22), the regional central bank (BEAC) and banking commission (COBAC) maintain a strict prohibition on banking institutions facilitating crypto transactions. Consequently, while holding and trading assets is not explicitly criminalized for individuals, no licensed local exchanges exist, and access to the banking system for crypto-related payments is blocked.
Key Pillars
COSUMAF (Commission de Surveillance du Marché Financier de l'Afrique Centrale)
BEAC (Bank of Central African States)
COBAC (Central African Banking Commission)
Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF (Market Framework)
COBAC Decision D-2022/071 (Banking Ban)
Landmark Laws
Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF (Regulation No. 01/22) - Enacted: 2022-07-21
- Establishes the organization and functioning of the Central African financial market, explicitly defining 'Digital Assets' and creating a regime for 'Digital Asset Service Providers' (PSANs) to be licensed by COSUMAF.
- Source
COBAC Decision on Crypto-Assets (Decision D-2022/071) - Enacted: 2022-05-06
- Prohibits all banking and microfinance institutions in the CEMAC zone from holding, exchanging, or facilitating transactions related to cryptocurrencies to preserve financial stability.
- Source
Considerations
Banking Blockade: Local banks are forbidden from processing crypto-related transfers, forcing traders to use P2P methods or foreign cards.
Regional Conflict: The market regulator (COSUMAF) invites licensing, while the central bank (BEAC) views crypto as a threat to the CFA franc and foreign reserves.
No Active Licenses: Despite the 2022 regulation, as of late 2025, COSUMAF is still in the process of examining applications, with no public list of fully authorized PSANs.
Scam Risks: Regulators frequently issue warnings against unlicensed platforms (e.g., BMI Investissement Gabon) soliciting public funds.
Notes
Gabon is a member of the CFA franc monetary union. While the Central African Republic (a fellow member) attempted to adopt Bitcoin as legal tender in 2022, Gabon has remained aligned with the conservative regional consensus of the BEAC. The 'Gray-Zone' status is primarily due to the deadlock between the market regulator (which wants to license crypto) and the central bank (which blocks the banking rails).
Remaining Uncertainties
- Will BEAC/COBAC lift the banking ban to align with COSUMAF's licensing regime?
- Have any specific PSAN licenses been fully granted in Gabon as of late 2025, or are they still in the 'examination' phase?
- How does the Gabonese government's 'Project for Society' digitization plan interact with the regional crypto restrictions?
Detailed Explanation
Detailed Explanation
Retail cryptocurrency trading in Gabon operates in a regulatory gray zone, characterized by a fundamental conflict between regional regulatory bodies that creates a deadlock for the formal market. The status is defined by the existence of a legal framework for licensing digital asset service providers that is simultaneously undermined by a banking prohibition, leaving no operational, licensed exchanges. The primary framework is established by Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF, enacted on July 21, 2022, by the regional market regulator COSUMAF. This regulation explicitly defines 'Digital Assets' and creates a formal regime for 'Digital Asset Service Providers' (PSANs) to obtain a license, signaling an intent to regulate the sector. However, this framework is effectively nullified for practical access by a separate directive from the banking authorities. The Central African Banking Commission (COBAC), with the Bank of Central African States (BEAC), issued Decision D-2022/071 on May 6, 2022, which strictly prohibits all banking and microfinance institutions in the CEMAC zone from holding, exchanging, or facilitating transactions related to cryptocurrencies. This banking blockade severs the critical link between the traditional financial system and crypto activities, making it impossible for any licensed entity to operate with local banking rails. Consequently, while holding and trading crypto assets is not explicitly illegal for individuals, the environment is restrictive. No PSANs have been fully authorized by COSUMAF as of late 2025, with the regulator still examining applications. Retail traders are forced to rely on peer-to-peer (P2P) methods or foreign payment cards, and the market is rife with risks from unlicensed platforms, against which regulators frequently issue warnings. The gray-zone status is thus a direct result of the regional conflict between COSUMAF's licensing ambitions and the BEAC's conservative stance aimed at preserving the stability of the CFA franc and foreign reserves.
Summary Points
I. Regulatory Status
* Gabon is classified as a Gray-Zone jurisdiction for cryptocurrency.
* The regulatory environment is defined by a conflict between regional directives: a market framework for licensing exists but is rendered non-functional by a banking prohibition.
* Retail trading is not explicitly criminalized for individuals, but no licensed local exchanges operate, and access to banking for crypto is blocked.
II. Key Regulatory Bodies
* COSUMAF (Commission de Surveillance du Marché Financier de l'Afrique Centrale): The regional financial market regulator for the CEMAC zone. It is responsible for licensing and supervising Digital Asset Service Providers (PSANs) under its 2022 regulation.
* BEAC (Bank of Central African States): The central bank for the CFA franc monetary union. It views cryptocurrency as a threat to monetary sovereignty and financial stability, supporting the banking ban.
* COBAC (Central African Banking Commission): The regional banking supervisor. It enacted the decisive prohibition (Decision D-2022/071) that forbids banks from engaging with crypto assets.
III. Important Legislation
* Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF (Enacted: 2022-07-21)
* Establishes the legal framework for the Central African financial market, explicitly defining 'Digital Assets'.
* Creates a licensing regime for 'Digital Asset Service Providers' (PSANs) under COSUMAF's authority.
* Source
* COBAC Decision D-2022/071 on Crypto-Assets (Enacted: 2022-05-06)
* Prohibits all banking and microfinance institutions in the CEMAC zone from holding, exchanging, or facilitating transactions related to cryptocurrencies.
* This decision is the primary enforcement mechanism creating the operational deadlock.
* Source
IV. Compliance Requirements
* For a business to operate legally as a crypto exchange or service provider, it must obtain a PSAN license from COSUMAF under Regulation No. 01/22.
* However, as of late 2025, COSUMAF is still in the process of examining applications, and no public list of fully authorized PSANs exists.
* Any licensed entity would still be unable to partner with local banks or payment processors due to the COBAC ban.
V. Notable Restrictions or Limitations
* Banking Blockade: The COBAC decision creates an absolute prohibition, forcing all crypto-related fund flows to use P2P methods or foreign cards.
* Regional Regulatory Conflict: The market regulator (COSUMAF) invites licensing, while the central bank (BEAC/COBAC) blocks the necessary banking infrastructure.
* High Scam Risks: The absence of licensed operators has led to a proliferation of unlicensed platforms. Regulators frequently issue public warnings against entities like BMI Investissement Gabon that solicit public funds.
* Monetary Policy Alignment: Gabon remains aligned with the BEAC's conservative consensus, unlike fellow CFA member the Central African Republic's 2022 attempt to adopt Bitcoin as legal tender.
VI. Recent Developments or Notes
* The 'Gray-Zone' status is a direct result of the deadlock between COSUMAF's licensing framework and the BEAC/COBAC banking ban.
* The situation highlights the challenges of regulating emerging asset classes within a multi-country monetary union like the CEMAC zone.
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in Gabon is defined by its membership in the Central African Economic and Monetary Community (CEMAC). The environment is currently split between a progressive market framework and a restrictive monetary policy. In July 2022, the regional financial market regulator, COSUMAF, adopted Regulation No. 01/22, which formally recognized 'digital assets' and established a licensing regime for Digital Asset Service Providers (PSANs). This move was intended to bring the sector under supervision and allow for legal issuance and trading of tokens as financial assets.
However, this regulatory progress is effectively stalled by the stance of the Bank of Central African States (BEAC) and the Central African Banking Commission (COBAC). In May 2022, shortly before the COSUMAF regulation was passed, COBAC issued Decision D-2022/071, which explicitly bans all supervised financial institutions (banks, microfinance) from dealing with crypto assets. This includes a prohibition on holding crypto for their own account or for third parties, and banning the conversion of CFA francs into crypto. This creates a significant operational bottleneck: while a crypto exchange could theoretically obtain a license from COSUMAF, it would struggle to find a local bank partner to process fiat deposits and withdrawals.
As of late 2025, the situation remains in a 'Gray-Zone'. COSUMAF has held consultation meetings in Libreville (July 2025) to discuss the practical application of the law and has begun examining license applications, but no entities have been publicly authorized to operate. Meanwhile, BEAC officials have reiterated their opposition, citing risks to the region's foreign exchange reserves and the stability of the CFA franc. Consequently, retail trading is not illegal for individuals, but it is unsupported by the local financial infrastructure, pushing activity into informal peer-to-peer markets or offshore platforms.
The regulatory status of cryptocurrency in Gabon is defined by its membership in the Central African Economic and Monetary Community (CEMAC). The environment is currently split between a progressive market framework and a restrictive monetary policy. In July 2022, the regional financial market regulator, COSUMAF, adopted Regulation No. 01/22, which formally recognized 'digital assets' and established a licensing regime for Digital Asset Service Providers (PSANs). This move was intended to bring the sector under supervision and allow for legal issuance and trading of tokens as financial assets. However, this regulatory progress is effectively stalled by the stance of the Bank of Central African States (BEAC) and the Central African Banking Commission (COBAC). In May 2022, shortly before the COSUMAF regulation was passed, COBAC issued Decision D-2022/071, which explicitly bans all supervised financial institutions (banks, microfinance) from dealing with crypto assets. This includes a prohibition on holding crypto for their own account or for third parties, and banning the conversion of CFA francs into crypto. This creates a significant operational bottleneck: while a crypto exchange could theoretically obtain a license from COSUMAF, it would struggle to find a local bank partner to process fiat deposits and withdrawals. As of late 2025, the situation remains in a 'Gray-Zone'. COSUMAF has held consultation meetings in Libreville (July 2025) to discuss the practical application of the law and has begun examining license applications, but no entities have been publicly authorized to operate. Meanwhile, BEAC officials have reiterated their opposition, citing risks to the region's foreign exchange reserves and the stability of the CFA franc. Consequently, retail trading is not illegal for individuals, but it is unsupported by the local financial infrastructure, pushing activity into informal peer-to-peer markets or offshore platforms.
Source Evidence
Primary and secondary sources cited in this analysis
"COBAC recalled certain prohibitions related to the use of crypto-assets in CEMAC... notably the exchange or conversion, settlement or hedging in currency or CFA francs of transactions relating to cryptocurrencies."
"The exercise of crypto-asset activities in the CEMAC space is not subject to regulatory framework... no digital asset provider can offer such services."
"Title V: Digital Assets... Article 145: The status of Digital Asset Service Provider (PSAN) is subject to mandatory approval by COSUMAF."
"The regional banking regulator COBAC issued a regulation prohibiting its supervised institutions from engaging in transactions with crypto assets."
"BEAC has firmly indicated its opposition... citing concerns that cryptocurrencies could deplete the community's foreign exchange reserves."
Web Sources (5)
Sources discovered via web search grounding
Search queries used (5)
- Gabon cryptocurrency regulation 2024 2025
- Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF digital assets
- COSUMAF crypto regulation CEMAC status 2024
- BEAC COBAC cryptocurrency ban Gabon current status
- list of licensed crypto exchanges Gabon COSUMAF
https://freemanlaw.com/cryptocurrency/central-african-states/
https://4mlegaltax.com/virtual-assets-regulation-within-the-cemac-zone/
https://cosumaf.org/tag/crypto-actifs/
https://cemac-eco.finance/consumaf-sounds-alarm-over-cryptocurrency-in-cemac-zone/
https://www.businessincameroon.com/finance/0502-13620-cemac-beac-rejects-cryptocurrency-regulation-amid-fintech-demands