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Namibia

Retail_Trading_Status

Gray-Zone High Confidence
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Analysis ID
#741
Version
Archived
Created
2025-12-12 04:55
Workflow Stage
Step 1

Executive Summary

Retail cryptocurrency trading in Namibia is currently in a transitional 'Gray-Zone' despite the enactment of the Virtual Assets and Virtual Asset Service Providers Act in 2023. While the legal framework for regulation exists, the Bank of Namibia (BoN) has only issued 'provisional' licenses as of late 2025, which explicitly prohibit licensees from conducting business with the public until full requirements are met. Consequently, there are no fully operational, licensed local exchanges for retail users, and the law reportedly restricts the operation of foreign unlicensed exchanges.

Key Pillars

Bank of Namibia (BoN) - Primary prudential regulator and licensing authority for Virtual Asset Service Providers (VASPs).
Financial Intelligence Centre (FIC) - Supervisory authority for Anti-Money Laundering (AML) and Combatting the Financing of Terrorism (CFT) compliance.
Namibia Financial Institutions Supervisory Authority (NAMFISA) - Supporting role for non-banking financial elements, though BoN is the lead designation.
Provisional Licensing Regime - A two-step authorization process where entities must first clear a 'build-and-comply' phase before serving the public.

Landmark Laws

Virtual Assets and Virtual Asset Service Providers Act, 2023 (Act No. 10 of 2023) - Enacted: 2023-07-25
- The primary framework legalizing and regulating VASPs. It mandates licensing for all crypto service providers, establishes the BoN as the regulator, and sets penalties (up to N$10 million or 10 years prison) for non-compliance. It effectively bans unlicensed foreign exchanges.
- Source

Payment System Management Act, 2023 (Act No. 14 of 2023) - Enacted: 2023-07-21
- Complementary legislation governing payment service providers, under which some fintech entities exploring virtual assets may also fall.

Directive No. 06 of 2023 (FIC Directive 06/2023) - Enacted: 2023-09-26
- Issued by the Financial Intelligence Centre, requiring all VASPs to register with the FIC and comply with the Financial Intelligence Act, 2012, regardless of their licensing status with BoN.
- Source

Considerations

Provisional License Restrictions: Current licenses (as of late 2025) are provisional and strictly prohibit the entities from transacting with the public.
Foreign Exchange Ban: The 2023 Act effectively criminalizes the operation of foreign, unlicensed exchanges targeting Namibian residents.
Not Legal Tender: The Bank of Namibia maintains that cryptocurrencies are not legal tender; merchants may accept them at their own discretion and risk.
Banking Access: While the outright bank ban was softened, banks remain cautious and await fully licensed entities before opening standard banking rails.

Notes

The classification 'Gray-Zone' is used here specifically because the licensing regime, while legally 'in force', is operationally dormant for the public. The 'provisional' status acts as a de facto sandbox, preventing legal retail trading. Once the first full license is issued and public trading commences, the status will immediately shift to 'Allowed-Regulated'.

Remaining Uncertainties

  • Whether Mindex Virtual Asset Exchange successfully obtained a full operational license after the November 21, 2025 extension deadline.
  • The extent of active enforcement against foreign exchanges (e.g., website blocking, payment blocking) under the new Act.
  • The specific timeline for when the Bank of Namibia will allow provisional licensees to commence public operations.

Full Analysis Report

Namibia's regulatory status for retail cryptocurrency trading is best classified as 'Gray-Zone' due to the significant gap between the enactment of legislation and its operational implementation. Although the 'Virtual Assets and Virtual Asset Service Providers Act, 2023' officially legalized the provision of crypto services and established a licensing regime, the market remains in a state of suspended animation. The Act, operational since July 25, 2023, designated the Bank of Namibia (BoN) as the primary regulator, marking a pivot from the Bank's previous 2018 position which declared crypto exchanges illegal.

Despite the legal clarity on paper, the practical reality for retail traders is restrictive. As of late 2025, the BoN has not issued any full operational licenses. Instead, on January 13, 2025, the Bank granted 'provisional authorizations' to two entities: Mindex Virtual Asset Exchange (Pty) Ltd and Landifa Bitcoin Trade CC. These provisional licenses were valid for six months (later extended for Mindex to November 2025) but came with a critical condition: the entities are prohibited from conducting any business with the public during this period. They are effectively in a regulatory sandbox, required to build infrastructure and prove compliance before they can go live.

The delay in issuing full licenses triggers the 'Gray-Zone' classification criteria (no permanent licenses issued >12 months after law passed). Furthermore, the 2023 Act introduced strict penalties for operating without a license, including fines of up to N$10 million and prison terms of up to 10 years. This creates a precarious environment where local entities cannot yet legally serve customers, and foreign exchanges (like Binance) are technically operating in violation of the new ring-fenced laws, with some reports indicating they are 'not operational' or restricted for Namibian users.

Retail investors, therefore, occupy a difficult position. While the possession of cryptocurrency is not criminalized and merchants can voluntarily accept it, there is no legal, regulated avenue to buy or sell assets domestically. The Bank of Namibia continues to emphasize that crypto is not legal tender and that the provisional licensees must not engage the public, leaving the market in a regulatory holding pattern until the first full license is finally granted.

Source Evidence

Primary and secondary sources cited in this analysis

"It is important to note that during the six-month provisional authorisation period, the entities are not allowed to conduct any business or engage with individuals or entities in Namibia."

"To provide for the licensing and regulation of virtual asset service providers... and to provide for incidental matters."

"The Virtual Assets Act, 2023, as per sections 7 to 10, require VASPs to be licensed and registered with the regulatory authority. Such authority is the Bank of Namibia (BoN)."

"The bank is currently conducting due diligence... Additionally, the bank has extended the provisional authorisation of Mindex Virtual Asset Exchange... until 21 November."

"Any crypto provider in the country not complying with the local laws will face a monetary penalty of up to 10 million Namibian dollars."

Web Sources (14)

Sources discovered via web search grounding

Search queries used (9)
  • Namibia Virtual Assets Act commencement date
  • Namibia crypto regulation retail trading status
  • Namibia Virtual Assets and Virtual Asset Service Providers Act 2023 status
  • Bank of Namibia cryptocurrency position 2024 2025
  • NAMFISA virtual asset service provider license list
  • Is Binance legal in Namibia 2025
  • Namibia ban on foreign crypto exchanges enforcement
  • Bank of Namibia VASP full license issuance 2025
  • Mindex Namibia full virtual asset license granted November 2025
mariblock.com

https://www.mariblock.com/namibia-shores-up-crypto-regulations-grants-provisional-licenses-to-two-crypto-firms/

thebrief.com.na

https://thebrief.com.na/2025/01/bon-grants-4-entities-payment-and-virtual-asset-licences/

intellinews.com

https://www.intellinews.com/namibia-s-government-grants-nation-s-first-cryptocurrency-exchange-licences-361865/

bitget.com

https://www.bitget.com/news/detail/12560604503894

binance.com

https://www.binance.com/en/square/post/2023-07-26-namibia-signs-crypto-exchange-regulation-bill-into-law-858092

bitcoin.com

https://news.bitcoin.com/namibia-flips-the-script-central-bank-grants-provisional-approval-to-crypto-firms/

bon.com.na

https://www.bon.com.na/Informations/Media/Media-Releases/2024-Media-Releases/Articles/13-01-2025-Provisional-Authorisation-Granted-to-Ne.aspx

thebanks.eu

https://thebanks.eu/list-of-vasps

cryptoassetbuyer.com

https://cryptoassetbuyer.com/bank-of-namibia-provisional-licenses-vasps/

binance.com

https://www.binance.com/en-AE/square/post/2023-07-26-namibia-signs-crypto-exchange-regulation-bill-into-law-858092

financemagnates.com

https://www.financemagnates.com/cryptocurrency/namibia-repeals-crypto-ban-with-new-regulations-for-exchanges/

allafrica.com

https://allafrica.com/stories/202508200592.html

bon.com.na

https://www.bon.com.na/Informations/Media/Media-Releases/2024-Media-Releases/Articles/13-01-2025-Provisional-Authorisation-Granted-to-Ne.aspx

namibian.com.na

https://www.namibian.com.na/cryptocurrencies-not-legal-tender-bank-of-namibia-insists/

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