Back to Analyses

Mali

Retail_Trading_Status

Gray-Zone High Confidence
Edit
Analysis ID
#721
Version
Latest
Created
2025-12-12 04:50
Workflow Stage
Step 1

Executive Summary

Retail cryptocurrency trading in Mali operates in a regulatory gray zone. While there is no specific national law criminalizing the possession or trading of cryptocurrencies for individuals, the regional central bank (BCEAO) has explicitly prohibited the banking sector from facilitating crypto transactions and has issued strong warnings against their use. Consequently, no licensed local exchanges exist, and users must rely on foreign platforms or peer-to-peer (P2P) markets without legal recourse or consumer protection.

Key Pillars

BCEAO (Central Bank of West African States)
Regional Banking Prohibitions
Ministry of Economy and Finance (Mali)
WAEMU/UEMOA Banking Regulations

Landmark Laws

BCEAO Public Statement on Cryptocurrencies (Communiqué de Presse) - Enacted: 2018-03-01
- Official statement declaring that cryptocurrencies are not legal tender in the WAEMU zone and are not backed by the central bank. It explicitly warns against their use due to risks of volatility and lack of regulation.
- Source

Regulation No. 06/2024/CM/UEMOA on Foreign Exchange (Règlement N° 06/2024/CM/UEMOA) - Enacted: 2024-12-20
- New regional regulation governing foreign exchange relations. While not explicitly naming crypto, it tightens controls on capital flows and foreign assets, reinforcing the restriction on unauthorized financial transfers outside the zone.

Considerations

Banking Sector Ban: Financial institutions are prohibited from holding crypto or facilitating transactions.
No Legal Recourse: Since the sector is unregulated, users have no protection against fraud or exchange collapse.
Mining Status: Crypto mining is technically legal due to the absence of prohibition, but it is not formally regulated under the new Mining Code (which focuses on mineral resources).
P2P Reliance: Trading is heavily dependent on P2P networks and mobile money agents acting as informal on-ramps.

Notes

Mali's political transition and security situation may influence enforcement priorities. The focus is currently on traditional resource sovereignty (Mining Code 2023) rather than digital asset regulation.

Remaining Uncertainties

  • Will the WAEMU region adopt a specific VASP regulation framework similar to MiCA in the near future?
  • How does the new 2024 Foreign Exchange Regulation practically impact P2P crypto merchants using mobile money?
  • Are there any unpublicized government decrees in Mali specifically targeting crypto mining energy usage?

Detailed Explanation

Retail cryptocurrency trading in Mali operates in a regulatory gray zone. While there is no specific national law that criminalizes the possession or trading of cryptocurrencies for individuals, the activity exists without formal legal recognition or protection. The primary regulatory influence comes from the regional central bank, the Central Bank of West African States (BCEAO), which has taken a prohibitive stance. This creates a challenging environment where individuals can technically trade but are cut off from the formal banking sector and have no consumer recourse. The regulatory framework is defined by regional banking prohibitions and warnings rather than a comprehensive national law tailored to digital assets. The key regulatory bodies shaping this landscape are the BCEAO and the West African Economic and Monetary Union (WAEMU/UEMOA), whose regulations are directly applicable in Mali. The Ministry of Economy and Finance in Mali is also a relevant pillar, though its current focus appears to be on traditional resource sovereignty as evidenced by the 2023 Mining Code, which does not address cryptocurrency mining. The most significant piece of landmark legislation is the BCEAO Public Statement on Cryptocurrencies, enacted on March 1, 2018. This official communiqué declares that cryptocurrencies are not legal tender in the WAEMU zone and are not backed by the central bank. It explicitly warns the public against their use due to risks of volatility and the complete absence of a regulatory framework. A more recent development is the regional Regulation No. 06/2024/CM/UEMOA on Foreign Exchange, enacted on December 20, 2024. While not explicitly naming cryptocurrencies, this regulation tightens controls on capital flows and foreign assets, thereby reinforcing existing restrictions on unauthorized financial transfers outside the monetary union. The primary compliance requirement for financial institutions is a strict adherence to the BCEAO's prohibition, meaning banks are forbidden from holding cryptocurrencies or facilitating any transactions involving them. For individuals, there are no specific compliance requirements because the activity is unregulated, which simultaneously means there is no legal recourse in cases of fraud or exchange collapse. The most notable restrictions include the complete banking sector ban, which forces users to rely on foreign platforms or peer-to-peer (P2P) markets and informal mobile money agents as on-ramps. Cryptocurrency mining exists in a similar gray area; it is technically legal only because it is not explicitly prohibited, but it is not formally regulated under the new Mining Code, which focuses exclusively on mineral resources. Mali's ongoing political transition and security situation are important contextual factors that likely influence enforcement priorities, further contributing to the uncertain and gray-zone status of cryptocurrency activities.

Summary Points

I. Regulatory Status
* Gray Zone: Retail trading operates in a regulatory gray zone. There is no specific national law criminalizing possession or trading for individuals, but the regional central bank has issued prohibitions for the financial sector.
* No Formal Recognition: Cryptocurrencies are not legal tender and are not backed by any central authority.
* Unregulated Activity: The sector is unregulated, meaning users have no legal recourse or consumer protection.

II. Key Regulatory Bodies
* BCEAO (Central Bank of West African States): The regional central bank that sets monetary policy for the WAEMU zone, including Mali. It has explicitly prohibited banking sector involvement with crypto.
* WAEMU/UEMOA (West African Economic and Monetary Union): The regional economic union whose banking and financial regulations are directly applicable in Mali.
* Ministry of Economy and Finance (Mali): A national-level body, though its current regulatory focus is on traditional resources (e.g., Mining Code 2023) rather than digital assets.

III. Important Legislation
* BCEAO Public Statement on Cryptocurrencies (Communiqué de Presse)
* Enacted: 2018-03-01
* Summary: An official statement declaring that cryptocurrencies are not legal tender in the WAEMU zone and are not backed by the central bank. It issues strong public warnings about the risks of volatility and the lack of regulation.
* Regulation No. 06/2024/CM/UEMOA on Foreign Exchange
* Enacted: 2024-12-20
* Summary: A new regional regulation governing foreign exchange. While not explicitly naming cryptocurrencies, it reinforces restrictions on unauthorized financial transfers and capital flows outside the monetary union.

IV. Compliance Requirements
* For Financial Institutions: Strict prohibition from holding cryptocurrencies or facilitating any crypto-related transactions, as mandated by the BCEAO.
* For Individuals/Exchanges: There are no specific compliance requirements because the sector is unregulated. This also means there is no formal process for licensing exchanges; consequently, no licensed local exchanges exist.

V. Notable Restrictions or Limitations
* Banking Sector Ban: Financial institutions are prohibited from any involvement with cryptocurrency, cutting off formal on- and off-ramps.
* Reliance on P2P/Informal Markets: Trading is heavily dependent on foreign platforms, peer-to-peer (P2P) networks, and informal mobile money agents.
* No Consumer Protection: Users have no protection against fraud, theft, or exchange collapse.
* Mining Status: Cryptocurrency mining is technically legal due to the absence of prohibition but is not formally regulated (the Mining Code 2023 focuses on mineral resources).

VI. Recent Developments or Notes
* The enactment of Regulation No. 06/2024/CM/UEMOA in December 2024 represents a recent tightening of regional financial controls.
* Mali's political transition and security situation may influence the enforcement of existing financial regulations.
* The government's current focus appears to be on traditional resource sovereignty rather than creating a framework for digital assets.

Full Analysis Report

The regulatory status of cryptocurrency in Mali is defined by its membership in the West African Economic and Monetary Union (WAEMU/UEMOA). The regional central bank, the BCEAO, maintains a strict stance that cryptocurrencies are 'not permitted' within the zone's formal financial system. This position was solidified in 2018 and reiterated in subsequent communications, effectively creating a 'bank ban' where licensed financial institutions cannot hold digital assets or process payments related to them. As a result, there is no licensing regime for Virtual Asset Service Providers (VASPs), and no local exchanges are authorized to operate.

Despite the restrictions on the banking sector, there is no specific national legislation in Mali that criminalizes the individual possession, buying, or selling of cryptocurrencies. This creates a 'gray zone' where retail trading is tolerated de facto but not legally recognized. Citizens can and do access foreign exchanges (like Binance or Kraken) and use peer-to-peer (P2P) platforms, often utilizing mobile money services to settle transactions informally. However, these activities are conducted at the user's own risk, with no consumer protection mechanisms in place.

Recent regulatory updates in the region, such as the new Foreign Exchange Regulation (No. 06/2024/CM/UEMOA) adopted in December 2024, have focused on tightening control over financial flows and foreign assets. While this regulation does not explicitly address crypto assets, its strict provisions on capital exportation present practical challenges for large-scale crypto trading or arbitrage by formal entities. The lack of a specific 'crypto law' means that tax treatment remains ambiguous, likely falling under general capital gains rules if enforced at all.

Furthermore, while Mali adopted a new Mining Code in 2023 and an implementing decree in 2024, these regulations are strictly targeted at the extractive industries (gold, lithium, etc.) and do not cover cryptocurrency mining. Consequently, crypto mining operations exist in a legal vacuum—neither expressly forbidden nor licensed. The primary constraint for such operations is practical (electricity costs and internet stability) rather than regulatory. Overall, Mali remains a jurisdiction where crypto is technically accessible to individuals but institutionally ostracized.

Source Evidence

Primary and secondary sources cited in this analysis

2018-03-01

"La BCEAO informe que les cryptomonnaies ne présentent pas les caractéristiques associées à une monnaie classique... les transactions qu'elles génèrent ne sont ni encadrées, ni contrôlées par l'institut d'émission."

BCEAO Website - Payment Systems primary (official_government)
2024-01-01

"Official overview of authorized payment systems, excluding crypto assets."

2025-01-15

"As of the latest updates in 2025, cryptocurrency mining is legal in Mali. The Malian government has not enacted any laws specifically prohibiting the mining of cryptocurrencies."

"Le bitcoin et les cryptomonaies ne sont pas les bienvenus au sein de l'espace UEMOA."

Web Sources (4)

Sources discovered via web search grounding

Search queries used (9)
  • legal status of bitcoin in Mali
  • BCEAO cryptocurrency regulation stance 2024
  • Mali crypto trading ban or legal
  • UEMOA crypto regulation 2024
  • Mali cryptocurrency regulation 2024 2025
  • Mali crypto mining legal status 2024
  • Is it illegal to buy bitcoin in Mali
  • BCEAO communiqué cryptomonnaie interdiction banques
  • UEMOA regulation cryptocurrencies 2025
investopedia.com

https://www.investopedia.com/articles/forex/041515/countries-where-bitcoin-legal-illegal.asp

financialafrik.com

https://www.financialafrik.com/2018/03/01/tiemoko-meyliet-kone-gouverneur-de-la-bceao-le-bitcoin-non-merci/

mexc.com

https://blog.mexc.com/wiki/is-crypto-mining-legal-in-mali/

orishas-finance.com

https://orishas-finance.com/index.php/actualite/monnaie-la-bceao-alerte-les-populations-sur-les-risques-lies-cryptomonnaies-b69bb7a8

Reviews

No reviews yet

Submit Review

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