Mozambique
Retail_Trading_Status
- Analysis ID
- #737
- Version
- Archived
- Created
- 2025-12-12 04:54
- Run
- 4268213e...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
Cryptocurrency in Mozambique falls into a Gray-Zone due to a disconnect between the legal framework and operational reality. While the Bank of Mozambique established a mandatory registration regime for Virtual Asset Service Providers (VASPs) in late 2023 via Notice No. 4/GBM/2023, no entities have been publicly confirmed as registered more than two years later. Furthermore, strict foreign exchange controls and recent banking sector fines for AML violations have led to a de facto restriction where commercial banks often block crypto-related transactions.
Key Pillars
Bank of Mozambique (Banco de Moçambique) as the primary regulator for VASPs
Mandatory registration for all entities providing virtual asset services (exchange, transfer, custody)
Strict AML/CFT compliance under Law No. 14/2023, designating VASPs as financial institutions
Foreign exchange controls limiting cross-border payments, impacting access to foreign exchanges
Landmark Laws
Notice No. 4/GBM/2023 (Registration of Virtual Asset Service Providers) (Aviso n.º 4/GBM/2023) - Enacted: 2023-09-14
- Establishes the mandatory registration framework for VASPs with the Bank of Mozambique. Defines activities requiring registration (exchange, transfer, custody) and sets fines for non-compliance. Came into force on November 14, 2023.
- Source
Law on Preventing and Combating Money Laundering and Terrorist Financing (Law No. 14/2023) - Enacted: 2023-08-28
- Designates VASPs as financial institutions subject to AML/CFT obligations. Grants the Bank of Mozambique authority to regulate and supervise the sector.
- Source
Notice No. 9/GBM/2025 (Limits on Payments Abroad) (Aviso n.º 9/GBM/2025) - Enacted: 2025-12-09
- Establishes strict limits on payments made abroad using bank cards, which effectively restricts residents from purchasing cryptocurrency on foreign exchanges.
- Source
Considerations
No public record of any VASP successfully registering despite the regime being active since late 2023.
Commercial banks are extremely risk-averse due to heavy fines for AML breaches, often resulting in blocked crypto transactions.
Strict foreign exchange controls (Notice 9/GBM/2025) severely limit the ability to buy crypto assets from international platforms.
Trading on unregistered platforms is considered 'at the user's own risk' but is not explicitly criminalized for the individual user.
Notes
The 'Gray-Zone' determination is driven by the 'Red Flag' that no licenses have been issued more than 12 months after the regulation was enacted. If a list of registered VASPs is published, the status would immediately upgrade to 'Allowed-Regulated'. The 'April 2025' bank ban mentioned in some user forums appears to be a misinterpretation of general FX control notices (Notice 9/GBM/2025) rather than a specific crypto prohibition.
Remaining Uncertainties
- Whether any VASP applications are currently under review or if the regulator is implicitly rejecting them.
- The specific threshold at which FX controls (Notice 9/GBM/2025) trigger blocks on crypto merchant codes (MCC 6051).
- If the central bank plans to issue a 'sandbox' framework to bridge the gap between the strict law and the lack of registrants.
Full Analysis Report
Full Analysis Report
Mozambique's regulatory status for cryptocurrency is currently classified as 'Gray-Zone' because, although a formal licensing regime exists on paper, it has not yet resulted in a functioning, regulated market. The Bank of Mozambique (Banco de Moçambique) took a significant step towards regulation with the enactment of Law No. 14/2023 and the subsequent Notice No. 4/GBM/2023 in September 2023. These regulations explicitly brought Virtual Asset Service Providers (VASPs) under the AML/CFT umbrella and mandated registration with the central bank. The framework requires VASPs to demonstrate robust compliance controls, physical presence, and fit-and-proper management.
However, despite the regulation coming into force in November 2023, there is no evidence that any VASP has been successfully registered as of late 2025. This 'paper tiger' situation—where a law exists but no licenses are issued—is a classic indicator of a Gray-Zone environment. It suggests either that the requirements are too onerous for local operators or that the central bank is delaying approvals to maintain a de facto ban while appearing compliant with FATF standards.
Operationally, the environment is restrictive. The Bank of Mozambique has aggressively enforced AML/CFT rules, fining major commercial banks (such as BCI and Millennium BIM) for compliance failures. This has created a chilling effect where banks refuse to process transactions related to crypto assets to avoid regulatory scrutiny. Additionally, strict foreign exchange controls, reinforced by Notice No. 9/GBM/2025, limit the amount of capital residents can transfer abroad via card payments, effectively blocking access to international crypto exchanges.
Consequently, while retail trading is not explicitly criminalized for individuals, the lack of local registered options and the banking sector's blockade make it difficult to operate legally. Users are forced to rely on peer-to-peer (P2P) markets or foreign platforms, often circumventing FX controls, which places them in a precarious legal position. The central bank continues to warn that such activities are at the user's sole risk.
Mozambique's regulatory status for cryptocurrency is currently classified as 'Gray-Zone' because, although a formal licensing regime exists on paper, it has not yet resulted in a functioning, regulated market. The Bank of Mozambique (Banco de Moçambique) took a significant step towards regulation with the enactment of Law No. 14/2023 and the subsequent Notice No. 4/GBM/2023 in September 2023. These regulations explicitly brought Virtual Asset Service Providers (VASPs) under the AML/CFT umbrella and mandated registration with the central bank. The framework requires VASPs to demonstrate robust compliance controls, physical presence, and fit-and-proper management. However, despite the regulation coming into force in November 2023, there is no evidence that any VASP has been successfully registered as of late 2025. This 'paper tiger' situation—where a law exists but no licenses are issued—is a classic indicator of a Gray-Zone environment. It suggests either that the requirements are too onerous for local operators or that the central bank is delaying approvals to maintain a de facto ban while appearing compliant with FATF standards. Operationally, the environment is restrictive. The Bank of Mozambique has aggressively enforced AML/CFT rules, fining major commercial banks (such as BCI and Millennium BIM) for compliance failures. This has created a chilling effect where banks refuse to process transactions related to crypto assets to avoid regulatory scrutiny. Additionally, strict foreign exchange controls, reinforced by Notice No. 9/GBM/2025, limit the amount of capital residents can transfer abroad via card payments, effectively blocking access to international crypto exchanges. Consequently, while retail trading is not explicitly criminalized for individuals, the lack of local registered options and the banking sector's blockade make it difficult to operate legally. Users are forced to rely on peer-to-peer (P2P) markets or foreign platforms, often circumventing FX controls, which places them in a precarious legal position. The central bank continues to warn that such activities are at the user's sole risk.
Source Evidence
Primary and secondary sources cited in this analysis
"The prior registration of entities wishing to carry out activities related to virtual assets is now mandatory, under penalty of a misdemeanor."
"Considers virtual asset service providers to be financial institutions for the purposes of complying with their duties in terms of preventing and combating ML/TF."
"The legal framework for the registration of virtual asset service providers at the Banco de Moçambique was established, as provided by Notice No. 4/GBM/2023."
"Notice no. 4/GBM/2023 will come into force on 14 November 2023."
"The Bank of Mozambique announced today that it has fined nine credit institutions... for violating prudential rules to prevent and combat money laundering."
Web Sources (10)
Sources discovered via web search grounding
Search queries used (12)
- Mozambique AML law virtual asset service providers
- Bank of Mozambique warning virtual assets
- Mozambique crypto legal framework 2024
- Banco de Moçambique cryptocurrency regulation status
- Lei n.º 11/2022 Moçambique criptomoedas
- Bank of Mozambique crypto ban commercial banks
- Mozambique registered virtual asset service providers list
- Banco de Moçambique prohibited banks crypto transactions 2024 2025
- "Notice no. 4/GBM/2023" registered entities
- Mozambique crypto exchange license issued
- "Notice No. 9/GBM/2025" crypto
- Banco de Moçambique "registered" virtual asset service providers
https://blog.ueex.com/best-crypto-exchanges-in-mozambique/
https://www.binance.com/en-IN/square/profile/square-creator-37b0b52b1d4a0
https://www.esaamlg.org/reports/Mozambique%20FUR-April%202025.pdf
https://www.bancomoc.mz/en/areas-of-expertise/supervision/anti-money-laundering-and-countering-the-financing-of-terrorism-and-proliferation/
https://blog.mexc.com/wiki/is-crypto-legal-in-mozambique/
https://www.bancomoc.mz/media/sz0gnzrh/bm-annual-report-2023-24-12-2023_v02.pdf
https://www.bancomoc.mz/media/dbmbrzgh/the-challenge-of-new-technologies-in-anti-money-laundering-countering-the-financing-of-terrorism-and-proliferation-of-weapons-of-mass-destruction.pdf
https://www.jlaadvogados.com/approvalofthelegalframework?lang=en
https://aimnews.org/2025/02/07/bank-of-mozambique-sanctions-nine-institutions-for-violation-of-financial-rules/
https://blog.voveid.com/kyc-compliance-in-mozambique-a-2025-guide-for-fintechs-and-digital-platforms/