Sao Tome and Principe
Retail_Trading_Status
- Analysis ID
- #779
- Version
- Latest
- Created
- 2025-12-12 05:12
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- 4883555b...
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- Workflow Stage
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Executive Summary
Cryptocurrency trading and holding are currently legal but unregulated in São Tomé and Príncipe. The country lacks a specific legal framework for virtual assets, and the Central Bank of São Tomé and Príncipe (BCSTP) has not issued explicit prohibitions or licensing regimes for crypto-asset service providers. A 2024 Mutual Evaluation Report by GIABA confirmed that the jurisdiction has not yet conducted a risk assessment for virtual assets or implemented FATF Recommendation 15, leaving the sector in a regulatory void.
Key Pillars
Banco Central de São Tomé e Príncipe (BCSTP) - Primary financial regulator, currently inactive regarding specific crypto regulation.
Unregulated Status - No specific licensing or registration regime exists for Virtual Asset Service Providers (VASPs).
General AML/CFT Framework - Existing anti-money laundering laws apply generally to financial activities but lack specific provisions for virtual assets.
Exchange Controls - General foreign exchange restrictions likely apply to cross-border transfers for crypto purchases due to the Dobra's peg to the Euro.
Landmark Laws
Lei do Sistema de Pagamentos (Payment System Law) (Lei n.º 13/2018 (Approximate date of recent updates)) - Enacted: 2018-01-01
- Governs the national payment system and electronic money issuance. While it regulates digital fiat (e-money), it does not explicitly cover or prohibit decentralized cryptocurrencies.
- Source
Lei de Prevenção e Combate ao Branqueamento de Capitais (AML Law) (Lei n.º 12/2013 (Updated by subsequent decrees)) - Enacted: 2013-01-01
- Establishes the AML framework. The 2024 GIABA report notes this framework has not yet been effectively extended to cover virtual asset activities.
Considerations
No Consumer Protection: Investors have no recourse to the Financial Ombudsman or Central Bank in cases of fraud or exchange collapse.
Banking Access: While not explicitly banned, local banks may block crypto-related transactions due to de-risking and lack of regulatory clarity.
Currency Peg: The Dobra (STN) is pegged to the Euro; strict capital controls may practically limit the ability to send large amounts of fiat to foreign exchanges.
Distinction from E-Money: The Central Bank licenses 'Dobra Digital' (e-money), which explicitly states it does not support cryptocurrency, highlighting a clear regulatory distinction.
Notes
The 'Allowed-UnRegulated' status is common among small island developing states (SIDS) where resources for specific crypto regulation are limited. The status is stable but could change if the government moves to address the deficiencies identified by GIABA to avoid grey-listing.
Remaining Uncertainties
- Whether the Central Bank plans to issue a warning or regulation in response to the 2024 GIABA findings.
- The exact application of capital gains tax to crypto assets, which is likely governed by general tax codes but untested.
Detailed Explanation
Detailed Explanation
Cryptocurrency trading and holding are currently legal but unregulated in São Tomé and Príncipe, a status confirmed as of 2024. The country lacks a specific legal framework for virtual assets, creating a regulatory void where no explicit prohibitions exist, but also no formal licensing or registration regimes are in place for Virtual Asset Service Providers (VASPs). The primary financial regulator, the Banco Central de São Tomé e Príncipe (BCSTP), has not issued specific rules for the crypto-asset sector and remains inactive regarding its direct oversight. This 'Allowed-Unregulated' status means that while individuals and businesses can engage with cryptocurrencies, they operate without the protections or clear guidelines of a dedicated regulatory regime. The existing general anti-money laundering and counter-terrorist financing (AML/CFT) framework, established under the Lei de Prevenção e Combate ao Branqueamento de Capitais (Lei n.º 12/2013), applies broadly to financial activities but, as noted in a 2024 Mutual Evaluation Report by GIABA, has not been effectively extended to cover virtual asset activities. Furthermore, the country has not yet conducted a national risk assessment for virtual assets and has not implemented the Financial Action Task Force's Recommendation 15, which addresses virtual assets and VASPs. The regulatory landscape is further defined by the Lei do Sistema de Pagamentos (Lei n.º 13/2018), which governs the national payment system and electronic money issuance. This law regulates digital fiat, or e-money, but does not explicitly cover or prohibit decentralized cryptocurrencies, a distinction made clear by the BCSTP's licensed 'Dobra Digital' e-money platform, which explicitly states it does not support cryptocurrency. Consequently, investors have no formal consumer protection, such as recourse to the Financial Ombudsman or the Central Bank, in cases of fraud or exchange collapse. Practical restrictions also exist; while not explicitly banned, banking access for crypto-related transactions may be blocked by local institutions due to de-risking and the lack of regulatory clarity. Additionally, the Dobra's (STN) peg to the Euro means general foreign exchange controls and strict capital controls likely apply to cross-border transfers for crypto purchases, practically limiting the ability to send large amounts of fiat to foreign exchanges. The current status is considered stable but could evolve if the government acts on the deficiencies identified by GIABA to avoid potential grey-listing.
Summary Points
I. Regulatory Status
* Cryptocurrency trading and holding are legal but unregulated.
* Status is Allowed-Unregulated as of 2024.
* No specific legal framework or licensing regime exists for Virtual Asset Service Providers (VASPs).
* A 2024 GIABA Mutual Evaluation Report confirmed the jurisdiction has not conducted a virtual asset risk assessment or implemented FATF Recommendation 15.
II. Key Regulatory Bodies
* Banco Central de São Tomé e Príncipe (BCSTP): The primary financial regulator, currently inactive regarding specific crypto regulation.
III. Important Legislation
* Lei do Sistema de Pagamentos (Payment System Law) (Lei n.º 13/2018):
* Enacted on 2018-01-01.
* Governs the national payment system and electronic money (e-money) issuance.
* Does not explicitly cover or prohibit decentralized cryptocurrencies.
* Lei de Prevenção e Combate ao Branqueamento de Capitais (AML Law) (Lei n.º 12/2013):
* Enacted on 2013-01-01 (updated by subsequent decrees).
* Establishes the general AML/CFT framework.
* According to the 2024 GIABA report, this framework has not been effectively extended to cover virtual asset activities.
IV. Compliance Requirements
* No specific compliance requirements exist for VASPs due to the lack of a licensing regime.
* General AML/CFT laws apply to financial activities but lack specific provisions for virtual assets.
V. Notable Restrictions or Limitations
* Consumer Protection: No formal recourse exists for investors in cases of fraud or exchange collapse; the Financial Ombudsman and Central Bank do not provide protection for crypto activities.
* Banking Access: While not explicitly banned, local banks may block crypto-related transactions due to de-risking and lack of regulatory clarity.
* Exchange Controls: General foreign exchange restrictions likely apply to cross-border transfers for crypto purchases, practically limiting fiat outflows due to the Dobra's (STN) peg to the Euro.
* Distinction from E-Money: The BCSTP-licensed 'Dobra Digital' e-money platform explicitly states it does not support cryptocurrency, highlighting the regulatory separation.
VI. Recent Developments or Notes
* The 'Allowed-Unregulated' status is common among small island developing states (SIDS) with limited regulatory resources.
* The status is stable but could change if the government acts to address the deficiencies identified by GIABA to avoid grey-listing.
Full Analysis Report
Full Analysis Report
In São Tomé and Príncipe, the retail trading of cryptocurrencies falls into the category of 'Allowed-UnRegulated'. There is no legislative act or central bank circular that criminalizes the buying, selling, or holding of digital assets by private individuals. Consequently, citizens are free to access international exchanges and peer-to-peer platforms, provided they can facilitate the necessary payments. The Central Bank of São Tomé and Príncipe (BCSTP) has maintained a passive stance, neither endorsing the technology nor issuing the hostile banking bans seen in other Central African jurisdictions.
The regulatory void was highlighted in the 2024 Mutual Evaluation Report by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). The report explicitly noted that São Tomé and Príncipe has not conducted a risk assessment for virtual assets and has not implemented regulations for Virtual Asset Service Providers (VASPs) as required by FATF Recommendation 15. This confirms that the sector operates outside the formal financial supervision framework, with no licensing regime in place for local exchanges.
Functionally, the Central Bank distinguishes between regulated electronic money and unregulated cryptocurrency. For instance, the BCSTP-licensed mobile wallet 'Dobra Digital' explicitly clarifies in its terms that it does not facilitate cryptocurrency transactions. This indicates that while the regulator is active in modernizing the payment system for fiat currency, it has deliberately excluded decentralized assets from the current authorized perimeter.
Practical challenges for retail traders primarily stem from the country's monetary policy. The local currency, the Dobra (STN), is pegged to the Euro, and the country maintains foreign exchange controls to protect this peg. These controls can make it difficult for residents to transfer fiat currency to foreign crypto exchanges via the banking system. Traders likely rely on peer-to-peer (P2P) markets or foreign currency accounts to bypass these friction points.
In São Tomé and Príncipe, the retail trading of cryptocurrencies falls into the category of 'Allowed-UnRegulated'. There is no legislative act or central bank circular that criminalizes the buying, selling, or holding of digital assets by private individuals. Consequently, citizens are free to access international exchanges and peer-to-peer platforms, provided they can facilitate the necessary payments. The Central Bank of São Tomé and Príncipe (BCSTP) has maintained a passive stance, neither endorsing the technology nor issuing the hostile banking bans seen in other Central African jurisdictions. The regulatory void was highlighted in the 2024 Mutual Evaluation Report by the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA). The report explicitly noted that São Tomé and Príncipe has not conducted a risk assessment for virtual assets and has not implemented regulations for Virtual Asset Service Providers (VASPs) as required by FATF Recommendation 15. This confirms that the sector operates outside the formal financial supervision framework, with no licensing regime in place for local exchanges. Functionally, the Central Bank distinguishes between regulated electronic money and unregulated cryptocurrency. For instance, the BCSTP-licensed mobile wallet 'Dobra Digital' explicitly clarifies in its terms that it does not facilitate cryptocurrency transactions. This indicates that while the regulator is active in modernizing the payment system for fiat currency, it has deliberately excluded decentralized assets from the current authorized perimeter. Practical challenges for retail traders primarily stem from the country's monetary policy. The local currency, the Dobra (STN), is pegged to the Euro, and the country maintains foreign exchange controls to protect this peg. These controls can make it difficult for residents to transfer fiat currency to foreign crypto exchanges via the banking system. Traders likely rely on peer-to-peer (P2P) markets or foreign currency accounts to bypass these friction points.
Source Evidence
Primary and secondary sources cited in this analysis
"No risk assessment of activities linked to virtual assets has been conducted by STP."
"Site search reveals no specific circulars (Avisos) prohibiting cryptocurrency."
"Somos um operador licenciado pelo Banco Central de São Tomé e Príncipe. Esta aplicação não utiliza cripto-moedas nem permite a sua compra ou venda."
Web Sources (1)
Sources discovered via web search grounding
Search queries used (9)
- Sao Tome and Principe cryptocurrency regulation
- Sao Tome and Principe virtual assets legal status
- GIABA Mutual Evaluation Report Sao Tome and Principe virtual assets
- Banco Central de São Tomé e Príncipe comunicado bitcoins
- Banco Central de São Tomé e Príncipe criptomoedas aviso
- GIABA Mutual Evaluation Report Sao Tome and Principe 2024 Recommendation 15 virtual assets
- "Banco Central de São Tomé e Príncipe" aviso criptoativos
- Sao Tome and Principe exchange control regulations cryptocurrency
- "Lei do Sistema de Pagamentos" São Tomé e Príncipe criptomoedas
https://veja.abril.com.br/economia/bc-cria-regras-para-que-criptomoedas-cumpram-mesmas-obrigacoes-que-bancos-e-corretoras/