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Tunisia

Retail_Trading_Status

Banned High Confidence
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Analysis ID
#808
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Created
2025-12-12 05:20
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Executive Summary

Retail cryptocurrency trading and possession are effectively illegal in Tunisia under current foreign exchange regulations. The Central Bank of Tunisia (BCT) issued a directive in 2018 criminalizing the use of virtual currencies as unauthorized foreign exchange activity, subjecting violators to fines and potential imprisonment. While a new Foreign Exchange Code proposing to legalize and regulate crypto assets has been drafted and submitted to Parliament as of late 2024/2025, it has not yet been enacted. Consequently, the strict prohibition remains in force, and the country maintains a closed currency regime.

Key Pillars

Central Bank of Tunisia (BCT) - Primary regulator enforcing the ban via foreign exchange controls.
Tunisian Financial Analysis Committee (CTAF) - Monitors AML/CFT compliance and flags suspicious financial flows related to crypto.
Ministry of Finance - Oversees the drafting of the new Foreign Exchange Code intended to eventually regularize the sector.

Landmark Laws

BCT Communiqué on Virtual Currencies (Communiqué BCT 2018) - Enacted: 2018-05-01
- Official statement by the Central Bank declaring that virtual currencies are not legal tender and that dealing in them constitutes a violation of foreign exchange regulations, subjecting users to criminal penalties.
- Source

Code des Changes (Foreign Exchange Code) (Law No. 76-18) - Enacted: 1976-01-21
- The foundational law governing foreign exchange. Its strict interpretation by the BCT classifies unauthorized crypto assets as illegal foreign holdings, forming the legal basis for the current ban.
- Source

Draft Foreign Exchange Code (Projet de Code des Changes) (Draft Bill (Pending))
- Proposed legislation approved by the Council of Ministers in March 2024 (and resubmitted/discussed in late 2025) that aims to liberalize exchange rules and explicitly allow/regulate 'crypto-actifs' under BCT authorization. Not yet law.

Considerations

Strict Capital Controls: The Tunisian Dinar is not fully convertible; using local funds to buy crypto is a direct violation of FX laws.
Criminal Penalties: Unlike 'risk warnings' in other jurisdictions, the BCT's stance links crypto usage to criminal FX offenses (fines and imprisonment).
Arrest Risk: There is a precedent of arrests for crypto trading, most notably the 2021 case of a teenager, which sparked the decriminalization debate.
Pending Legalization: The regulatory environment is in transition; the status could shift to 'Allowed-Regulated' if the new Foreign Exchange Code is passed and implemented.

Notes

While the status is 'Banned', the enforcement is sporadic and primarily targets those who interact with the banking system (e.g., large withdrawals/deposits linked to crypto). Peer-to-peer trading remains common but illegal. The '2025' dates in some source snippets reflect the ongoing legislative delays and recent parliamentary filings.

Remaining Uncertainties

  • The exact timeline for the parliamentary approval of the new Foreign Exchange Code.
  • Whether the final version of the law will retain the liberal provisions regarding crypto assets or if they will be watered down.
  • The specific criteria for the 'authorization' mentioned in the draft law (e.g., will it be accessible to retail users or only institutional players?).

Detailed Explanation

As of late 2024/2025, the status of cryptocurrency in Tunisia is 'Banned'. Retail trading and possession of cryptocurrencies are effectively illegal under the country's stringent foreign exchange regulations. The Central Bank of Tunisia (BCT) is the primary regulator enforcing this prohibition. In 2018, the BCT issued a specific communiqué declaring virtual currencies are not legal tender and that dealing in them constitutes a violation of foreign exchange regulations, subjecting users to criminal penalties. This stance is underpinned by the foundational 1976 Foreign Exchange Code (Law No. 76-18), which establishes a closed currency regime for the Tunisian Dinar. The BCT's interpretation classifies the acquisition of crypto assets using local funds as an unauthorized foreign exchange activity, a criminal offense punishable by fines and potential imprisonment. The Tunisian Financial Analysis Committee (CTAF) also plays a role by monitoring anti-money laundering and counter-terrorist financing compliance, flagging suspicious financial flows related to crypto. There is a precedent of arrests for crypto trading, underscoring the real enforcement risk, particularly for transactions interacting with the formal banking system. The regulatory environment is currently in a state of transition. A new Draft Foreign Exchange Code (Projet de Code des Changes), which was approved by the Council of Ministers in March 2024 and has been under parliamentary discussion into late 2025, proposes to liberalize exchange rules and explicitly allow and regulate 'crypto-actifs' under BCT authorization. However, this draft legislation has not yet been enacted into law. Consequently, the strict prohibition based on the 2018 BCT communiqué and the 1976 Foreign Exchange Code remains fully in force, maintaining Tunisia's position as a jurisdiction where cryptocurrency activities are banned.

Summary Points

I. Regulatory Status
* The status is Banned.
* Retail cryptocurrency trading and possession are effectively illegal under foreign exchange regulations.
* The regulatory environment is in transition, with a draft law proposing legalization pending.

II. Key Regulatory Bodies
* Central Bank of Tunisia (BCT): The primary regulator enforcing the ban via foreign exchange controls and issuing the 2018 communiqué.
* Tunisian Financial Analysis Committee (CTAF): Monitors AML/CFT compliance and flags suspicious financial flows related to crypto.
* Ministry of Finance: Oversees the drafting of the new Foreign Exchange Code intended to eventually regularize the sector.

III. Important Legislation
* BCT Communiqué on Virtual Currencies (2018):
* Enacted: 2018-05-01
* Declares virtual currencies are not legal tender and that dealing in them violates foreign exchange regulations, subjecting users to criminal penalties.
* Code des Changes (Foreign Exchange Code) (Law No. 76-18):
* Enacted: 1976-01-21
* The foundational law governing foreign exchange. Its strict interpretation by the BCT classifies unauthorized crypto assets as illegal foreign holdings, forming the legal basis for the current ban.
* Draft Foreign Exchange Code (Projet de Code des Changes):
* Status: Draft Bill (Pending)
* Proposed legislation approved by the Council of Ministers in March 2024 (and resubmitted/discussed in late 2025). It aims to liberalize exchange rules and explicitly allow/regulate 'crypto-actifs' under BCT authorization. Not yet law.

IV. Compliance Requirements
* Not applicable under the current banned status. Any activity is non-compliant with existing law.

V. Notable Restrictions or Limitations
* Strict Capital Controls: The Tunisian Dinar is not fully convertible; using local funds to buy crypto is a direct violation of FX laws.
* Criminal Penalties: The BCT's stance links crypto usage to criminal FX offenses, punishable by fines and imprisonment, unlike mere 'risk warnings' in other jurisdictions.
* Arrest Risk: There is a precedent of arrests for crypto trading, most notably a 2021 case involving a teenager.

VI. Recent Developments or Notes
* While the status is 'Banned', enforcement is sporadic and primarily targets those who interact with the banking system (e.g., large withdrawals/deposits linked to crypto).
* Peer-to-peer trading remains common but is illegal.
* The regulatory landscape is poised for potential change, with the pending Draft Foreign Exchange Code representing a possible shift to a 'Allowed-Regulated' status if passed and implemented.

Full Analysis Report

As of December 2025, the regulatory status of retail cryptocurrency trading in Tunisia remains Banned. This classification stems from the strict application of the country's foreign exchange laws by the Central Bank of Tunisia (BCT). In 2018, the BCT issued a landmark communiqué explicitly stating that virtual currencies are not legal tender and that any activity involving them without specific authorization constitutes a violation of the Foreign Exchange Code (Law No. 76-18). Because the BCT does not issue licenses for crypto activity, all retail trading is effectively treated as an illegal operation, exposing participants to the risk of asset seizure, heavy fines, and imprisonment.

The prohibition is primarily enforced through the banking sector and foreign exchange controls. Tunisian banks are instructed to block transactions related to crypto exchanges, and the Financial Analysis Committee (CTAF) monitors for suspicious flows. The legal theory relied upon by regulators is that cryptocurrencies represent unauthorized foreign assets; under the 1976 Exchange Code, residents are prohibited from holding assets abroad or dealing in foreign currencies without express permission. This interpretation was famously highlighted in 2021 when a 17-year-old was arrested for a small crypto transaction, triggering a national debate on the obsolescence of the country's financial laws.

Despite the strict ban, Tunisia is currently in a transitional phase. Recognizing the economic potential of digital assets and the futility of a total ban in the face of global adoption, the government has been working on a new Foreign Exchange Code ('Nouveau Code des Changes'). A draft of this law, which includes specific provisions to define and regulate 'crypto-assets' (crypto-actifs), was approved by the Council of Ministers in March 2024. The proposed framework aims to allow residents to hold and trade digital assets under a licensed regime supervised by the BCT, marking a shift from prohibition to regulation.

However, as of late 2025, this new code has not yet been enacted by the Assembly of the Representatives of the People (ARP). Reports from October and December 2025 indicate that the bill is still undergoing parliamentary review, with some amendments related to foreign currency accounts facing rejection or delay. Until this legislation is formally passed and the subsequent implementing circulars are published by the BCT, the 2018 ban remains the law of the land. Retail investors should assume that trading, mining, or holding cryptocurrencies continues to carry significant legal and criminal risks.

Source Evidence

Primary and secondary sources cited in this analysis

"The Central Bank of Tunisia warns the public against the risks associated with the use of virtual currencies... [which] are not subject to any specific regulation and... may constitute a violation of the regulations governing exchange and foreign trade."

2024-03-29

"The draft new legislation... authorizing crypto-currency transactions... is part of a drive to open up new economic prospects."

"The amended law aims to facilitate foreign currency trading... includes provisions that allow for dealing with crypto assets."

"MP Maher Ktari submitted a proposal for complete reform... The project takes into account financial and digital innovations, such as digital assets... to replace texts considered obsolete."

Web Sources (9)

Sources discovered via web search grounding

Search queries used (10)
  • Tunisia cryptocurrency regulation status 2024 2025
  • Tunisia crypto arrests legal status
  • Tunisia new foreign exchange code crypto assets
  • Is bitcoin legal in Tunisia 2024
  • Central Bank of Tunisia crypto circular warning
  • Tunisie Code des Changes crypto monnaie 2025
  • "Maher Katari" Tunisia Foreign Exchange Code status
  • Tunisia new Foreign Exchange Code passed parliament 2025
  • Tunisia crypto arrests 2024 2025
  • "Banque Centrale de Tunisie" crypto circular 2018 text
lightspark.com

https://www.lightspark.com/knowledge/is-crypto-legal-in-tunisia

launchbaseafrica.com

https://launchbaseafrica.com/2024/12/03/not-yet-tunisian-parliament-rejects-reforms-to-foreign-currency-account-rules/

sigma.world

https://sigma.world/news/tunisia-rethinks-imprisonment-of-crypto-traders/

state.gov

https://www.state.gov/reports/2025-investment-climate-statements/tunisia

webdo.tn

https://webdo.tn/en/actualite/national/tunisia-a-proposal-for-complete-reform-of-the-exchange-code-submitted-to-the-arp/397592/

africanmanager.com

https://en.africanmanager.com/2025-will-be-a-year-of-investment-and-a-new-foreign-exchange-code/

kapitalis.com

https://kapitalis.com/tunisie/2025/01/08/les-cryptomonnaies-bientot-reglementee-en-tunisie/

tunisienumerique.com

https://news-tunisia.tunisienumerique.com/tunisia-the-new-foreign-exchange-code-opens-the-door-to-paypal-and-crypto-assets-video/

lapresse.tn

https://www.lapresse.tn/2025/10/17/tunisie-depot-imminent-du-projet-de-code-des-changes-au-bureau-dordre-de-larp/

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