Western Sahara
Retail_Trading_Status
- Analysis ID
- #827
- Version
- Archived
- Created
- 2025-12-12 05:24
- Run
- a1d42c95...
- History
- View all versions
- Workflow Stage
- Step 1
Executive Summary
Retail cryptocurrency trading in Western Sahara is currently in a transitional 'Gray-Zone'. The territory is largely controlled by Morocco, which maintains a 2017 ban on crypto assets but is actively in the process of adopting a new regulatory framework (Draft Bill 42.25) as of late 2025. While the Sahrawi Arab Democratic Republic (SADR) government claims to offer a licensing regime under a 'Crypto Company Act 2020', the de facto legal framework for the majority of the population and economic activity is Moroccan law, which currently prohibits use but is moving toward regulation.
Key Pillars
Bank Al-Maghrib (Morocco Central Bank) - Primary regulator leading the new draft legislation
Moroccan Capital Market Authority (AMMC) - Designated supervisor for token issuance and public offerings under the draft bill
Foreign Exchange Office (Office des Changes) - Enforces the existing 2017 ban on using foreign currency for crypto
Central Reserve Authority of Western Sahara (SADR) - Purported regulator for the SADR-controlled zones, offering offshore-style licenses
Landmark Laws
Draft Bill 42.25 (Morocco) (Bill 42.25)
- A comprehensive bill unveiled in November 2025 to regulate digital assets, licensing Crypto Asset Service Providers (CASPs) and defining crypto as financial instruments. It aims to replace the 2017 ban.
Office des Changes Circular (Morocco) (Press Release November 2017) - Enacted: 2017-11-20
- Explicitly banned the use of virtual currencies for payment, stating they constitute a violation of foreign exchange regulations.
- Source
Crypto Company Act 2020 (SADR) (Crypto Company Act 2020) - Enacted: 2020-01-01
- Legislation by the SADR government establishing a licensing regime for crypto exchanges and wallet providers, primarily targeted at offshore registrants.
Considerations
Sovereignty Dispute: The application of law depends on the territory (Moroccan-controlled vs. SADR-controlled), but Moroccan law applies to key economic hubs like Laayoune.
Transition Phase: Morocco is moving from a 'Banned' status to 'Allowed-Regulated', creating temporary uncertainty until Bill 42.25 is fully enacted and licenses are issued.
Currency Controls: The Moroccan Dirham is a closed currency; the 2017 ban was primarily driven by capital flight concerns, which the new law aims to address via strict oversight.
Offshore Licensing: SADR licenses are likely marketed to international entities for tax/offshore purposes and may not offer local operational banking rails.
Notes
The analysis assumes the user is inquiring about the de facto situation for residents. The 'Gray-Zone' determination is heavily influenced by the Moroccan 'Draft Law' status, which fits the schema's specific criteria for Gray-Zone ('Draft law / sandbox only'). If the law were fully passed with licenses issued, it would be 'Allowed-Regulated'. If the draft were abandoned, it would revert to 'Banned'.
Remaining Uncertainties
- The exact date of enactment for Moroccan Bill 42.25 is unknown.
- It is unclear if the SADR 'Crypto Company Act' is recognized by any international bodies or if it functions purely as a shell company registry.
- The strictness of enforcement of the 2017 ban during the transition period (late 2025) is not documented.
Full Analysis Report
Full Analysis Report
The regulatory status of cryptocurrency in Western Sahara is complex, defined primarily by the sovereignty dispute between Morocco and the Sahrawi Arab Democratic Republic (SADR). For the vast majority of the territory's population and economic activity (controlled by Morocco), the de facto status is currently transitioning from 'Banned' to 'Regulated'. Historically, the Moroccan Foreign Exchange Office instituted a strict ban in November 2017, warning that crypto transactions violated exchange regulations. This ban has been enforced intermittently, with warnings from Bank Al-Maghrib (BAM) regarding the risks of unregulated assets.
However, the landscape shifted significantly in late 2025. Recognizing the widespread underground adoption of crypto assets, Moroccan authorities, led by Bank Al-Maghrib governor Abdellatif Jouahri, unveiled Draft Bill 42.25. This legislation, developed with input from the World Bank and IMF, proposes a legal definition for digital assets and establishes a licensing regime for Crypto Asset Service Providers (CASPs). The bill divides oversight between BAM (for stablecoins) and the Moroccan Capital Market Authority (AMMC) (for utility tokens and other assets). Despite this progress, as of December 2025, the law is in the adoption phase and no licenses have been issued, placing the territory in a 'Gray-Zone' where the old ban is technically active but a new framework is imminent.
In contrast, the SADR government, which controls the eastern portion of the territory and operates from refugee camps, has established a divergent framework. Reports indicate the existence of a 'Crypto Company Act 2020' and a 'Central Reserve Authority' that issues licenses to crypto companies. This regime appears to be modeled on offshore jurisdictions, aiming to attract international registrations rather than regulating a local retail market. For a retail trader in Western Sahara, the relevance of this framework is limited unless they are specifically operating within SADR jurisdiction or using these offshore entities.
Practically, retail traders in the main cities (Laayoune, Dakhla) face the Moroccan regulatory environment. While the 2017 ban criminalized the use of foreign currency for crypto, the introduction of Bill 42.25 signals a move towards legalization. Until the bill is enacted and CASPs are licensed, trading remains legally precarious, though enforcement may be relaxing in anticipation of the new rules. The primary constraint remains the strict capital controls on the Moroccan Dirham, which the new law is expected to uphold by requiring strict KYC and transaction monitoring.
The regulatory status of cryptocurrency in Western Sahara is complex, defined primarily by the sovereignty dispute between Morocco and the Sahrawi Arab Democratic Republic (SADR). For the vast majority of the territory's population and economic activity (controlled by Morocco), the de facto status is currently transitioning from 'Banned' to 'Regulated'. Historically, the Moroccan Foreign Exchange Office instituted a strict ban in November 2017, warning that crypto transactions violated exchange regulations. This ban has been enforced intermittently, with warnings from Bank Al-Maghrib (BAM) regarding the risks of unregulated assets. However, the landscape shifted significantly in late 2025. Recognizing the widespread underground adoption of crypto assets, Moroccan authorities, led by Bank Al-Maghrib governor Abdellatif Jouahri, unveiled Draft Bill 42.25. This legislation, developed with input from the World Bank and IMF, proposes a legal definition for digital assets and establishes a licensing regime for Crypto Asset Service Providers (CASPs). The bill divides oversight between BAM (for stablecoins) and the Moroccan Capital Market Authority (AMMC) (for utility tokens and other assets). Despite this progress, as of December 2025, the law is in the adoption phase and no licenses have been issued, placing the territory in a 'Gray-Zone' where the old ban is technically active but a new framework is imminent. In contrast, the SADR government, which controls the eastern portion of the territory and operates from refugee camps, has established a divergent framework. Reports indicate the existence of a 'Crypto Company Act 2020' and a 'Central Reserve Authority' that issues licenses to crypto companies. This regime appears to be modeled on offshore jurisdictions, aiming to attract international registrations rather than regulating a local retail market. For a retail trader in Western Sahara, the relevance of this framework is limited unless they are specifically operating within SADR jurisdiction or using these offshore entities. Practically, retail traders in the main cities (Laayoune, Dakhla) face the Moroccan regulatory environment. While the 2017 ban criminalized the use of foreign currency for crypto, the introduction of Bill 42.25 signals a move towards legalization. Until the bill is enacted and CASPs are licensed, trading remains legally precarious, though enforcement may be relaxing in anticipation of the new rules. The primary constraint remains the strict capital controls on the Moroccan Dirham, which the new law is expected to uphold by requiring strict KYC and transaction monitoring.
Source Evidence
Primary and secondary sources cited in this analysis
"Morocco is in the process of adopting a draft law that will regulate cryptocurrencies. Abdellatif Jouahri, the governor of the country's central bank, Bank Al-Maghrib (BAM), announced the news today."
"The General Secretariat of the Government released a draft bill today that lays the foundation for a comprehensive legal framework governing digital assets."
"A new type of service provided by the Central Reserve Authority of Western Sahara, SADR is a license for virtual currency activities... Important Documents: The Crypto Company Act 2020."
"The legislation, drafted over nearly three years, would establish a licensing system for digital asset platforms... moving to regulate a market that has expanded despite being formally prohibited."
Web Sources (15)
Sources discovered via web search grounding
Search queries used (5)
- Western Sahara cryptocurrency laws
- Morocco cryptocurrency regulation status December 2025
- Bank Al-Maghrib crypto bill status 2024 2025
- crypto trading legality Western Sahara
- SADR cryptocurrency regulation
https://sahrawiarabdemocraticrepublicfinanciallicenses.com/crypto-companies/
https://www.youtube.com/watch?v=iIiy4wxKvTM
https://www.moroccoworldnews.com/2025/11/266685/morocco-moves-to-regulate-digital-assets-with-new-draft-law/
https://en.7news.ma/morocco-unveils-draft-law-to-regulate-crypto-industry/
https://en.hespress.com/121651-why-moroccos-central-bank-says-the-country-needs-a-crypto-law-now.html
https://igamingafrika.com/morocco-introduces-draft-law-to-regulate-digital-assets/
https://northafricapost.com/92187-morocco-unveils-draft-law-on-cryptocurrencies.html
https://www.leconomiste.com/crypto-asset-bill-the-legislator-chooses-caution/
https://sumsub.com/blog/crypto-regulations-in-the-us-a-complete-guide/
https://www.moroccoworldnews.com/2024/11/167943/morocco-moves-to-regulate-cryptocurrencies-with-draft-law/
https://thearabweekly.com/moroccan-central-bank-preparing-law-allow-cryptocurrencies
https://www.lightspark.com/knowledge/is-crypto-legal-in-morocco
https://www.jurist.org/news/2024/11/morocco-central-bank-governor-confirms-cryptocurrency-law-in-progress/
https://www.clubgestionriesgos.org/wp-content/uploads/Cryptocurrency-Regulation-Summary-2022-edition.pdf
https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory