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Central African Republic

Retail_Trading_Status

Allowed-Unregulated High Confidence
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Status Changed

Previous status: Gray-Zone

Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. Original new analysis incorrectly classified as Gray-Zone. The correct status is Allowed-UnRegulated because the national law (Law No. 23.005 of March 2023) explicitly permits the voluntary use and acceptance of cryptocurrencies, placing the activity in an allowed category. However, no comprehensive national regulatory framework for licensing, consumer protection, or oversight of crypto assets exists, and the activity is further constrained by a regional banking ban (COBAC Decision D-2022/071). The 'Gray-Zone' classification was an AI error, likely overemphasizing the restrictive regional banking environment while underweighting the clear permissive national legal text. The Live analysis correctly identifies the status based on the national law's explicit allowance and the absence of specific regulation.

Analysis ID
#842
Version
Latest
Created
2025-12-13 06:57
Workflow Stage
Reconciled

Executive Summary

As of December 2025, the retail crypto trading landscape in the Central African Republic (CAR) is best described as allowed but unregulated. The nation has retreated from its groundbreaking and controversial 2022 law that made Bitcoin legal tender. Following significant domestic and regional pressure, the government repealed the law in March 2023. The current legal position affirms the freedom of individuals and businesses to accept cryptocurrencies as payment, but it removes any obligation to do so. This positions crypto in a legal gray area, where its use is not prohibited, but it operates without a formal, comprehensive regulatory framework for licensing, oversight, or consumer protection. The government is actively working to develop a new legal structure for digital assets, though this process is complicated by the staunch opposition of the regional Bank of Central African States (BEAC), which oversees the common currency of the Central African CFA franc. A key operational constraint is the regional Banking Commission of Central Africa (COBAC) ban, which prohibits financial institutions from processing crypto transactions, effectively severing banking rails for the industry.

Key Pillars

  • National Assembly of the Central African Republic: The legislative body responsible for passing and repealing laws related to cryptocurrency.
  • Presidency of the Central African Republic: The key driver behind the nation's push for cryptocurrency adoption, led by President Faustin-Archange Touadéra.
  • Constitutional Court of the Central African Republic: The highest court, which has played a crucial role in shaping the legal boundaries of crypto-initiatives, notably by striking down parts of the "Sango" project.
  • Bank of Central African States (BEAC): The regional central bank for the CEMAC monetary union. It is a primary antagonist to the CAR's crypto ambitions, viewing them as a threat to the stability of the CFA franc and the monetary union.
  • Financial Market Supervisory Commission of Central Africa (COSUMAF): The regional body responsible for regulating financial markets. It has created a preliminary framework for Virtual Asset Service Providers (VASPs), though its implementation is complicated by the BEAC's opposition.
  • Banking Commission of Central Africa (COBAC): Regional banking regulator enforcing a strict ban on crypto servicing by financial institutions, creating a major operational barrier.
  • National Agency for Regulation of Electronic Transactions (ANTE): Designated national body for crypto oversight under the 2022 law, but its operational status remains unclear.

Landmark Laws

Law No. 22.004 Governing Cryptocurrency in the Central African Republic
- Authority: National Assembly, promulgated by President Faustin-Archange Touadéra.
- Date: April 22, 2022.
- Summary: Made Bitcoin legal tender alongside the CFA franc, obligating its acceptance as payment. It generated significant international attention and immediate backlash from regional and international financial institutions, ultimately leading to its repeal.

COBAC Decision on Cryptocurrency Prohibitions (Decision D-2022/071)
- Authority: Banking Commission of Central Africa (COBAC).
- Date: May 6, 2022.
- Summary: A regional directive prohibiting all CEMAC banking and microfinance institutions from holding, exchanging, or settling transactions in cryptocurrencies to preserve financial stability.

Law Amending the Cryptocurrency Act of 2022 (Law No. 23.005)
- Authority: National Assembly.
- Date: March 23, 2023.
- Summary: Repealed Law No. 22.004. It removed Bitcoin's status as legal tender and the obligation to accept it, while explicitly permitting the voluntary use and acceptance of cryptocurrencies. This law moved the country from a state of "Allowed-Regulated" back to "Allowed-Unregulated."

Law on the Tokenization of Natural Resources
- Authority: National Assembly.
- Date: May 29, 2023.
- Summary: Authorizes the tokenization of state-owned land and natural resources, such as gold and uranium. This law underpins the government's continued "Sango" project and signals a persistent effort to integrate blockchain technology into its economic strategy, despite earlier setbacks.

Considerations

  • Asset Classification: Cryptocurrencies are not classified as legal tender. Following the March 2023 law, they are considered a form of payment that can be freely offered and accepted by private parties on a voluntary basis.
  • Taxation: The provision within the 2022 law that would have allowed taxes to be paid via cryptocurrency was eliminated by the 2023 amendment. A clear tax framework for crypto-asset transactions or gains has not yet been established.
  • Sango Project: The government remains committed to its national crypto initiative, "Sango." While the citizenship-by-investment component was nullified, the project continues with a focus on tokenizing natural resources and creating a digital economic zone.
  • Regional Conflict: The CAR's national crypto policies are in direct conflict with the regulations and stance of the Bank of Central African States (BEAC) and COBAC, which has prohibited financial institutions within the CEMAC zone from engaging in crypto transactions. This creates significant operational and legal uncertainty for any crypto-related business or service.
  • Banking Blockade: Local banks cannot process transfers to/from crypto exchanges due to the COBAC ban, forcing retail activity onto peer-to-peer or offshore platforms.
  • Infrastructure: Extremely low internet penetration and electricity access limit practical retail trading for the majority of the population.

Notes

The government's stated intention is to create a formal legal framework for cryptocurrencies. The establishment of a commission in late 2022 to draft a new bill indicates that the current "Unregulated" status is viewed as temporary. However, the path forward is complex. Any new national regulation will have to contend with the opposing position of the BEAC. Recent capacity-building workshops with the African Development Bank in December 2025 on combating illicit financial flows suggest that the government is trying to build institutional credibility, potentially to appease regional and international bodies concerned about its crypto ventures. For now, retail crypto trading and use exist in a space defined by national government approval and a lack of specific rules, overshadowed by prohibitive regional banking directives. The situation is unique: the national government is more pro-crypto than the regional banking sector, which is bound by restrictive rules. While trading is not criminally banned for individuals, the operational environment is severely restricted by the banking blockade.

Remaining Uncertainties

  • The operational status of the National Agency for Regulation of Electronic Transactions (ANTE) is unknown.
  • Whether COBAC has privately communicated any relaxation of rules for specific pilot projects (unlikely given public stance).
  • The current status of the Sango Coin platform's technical infrastructure and user base.

Detailed Explanation

As of December 2025, the retail cryptocurrency trading landscape in the Central African Republic (CAR) is best described as allowed but unregulated. This status was established by Law No. 23.005 on March 23, 2023, which repealed the nation's groundbreaking 2022 law that had made Bitcoin legal tender. The current legal position explicitly permits the voluntary use and acceptance of cryptocurrencies by individuals and businesses, but it removes any obligation to do so and does not provide a formal regulatory framework for licensing, oversight, or consumer protection. The government, led by President Faustin-Archange Touadéra, remains actively engaged in developing a new legal structure for digital assets, viewing the current unregulated state as temporary. However, this national ambition is complicated by a severe regional conflict. The Bank of Central African States (BEAC) and the Banking Commission of Central Africa (COBAC) are staunch opponents, viewing crypto as a threat to the stability of the CFA franc and the monetary union. COBAC's Decision D-2022/071, issued on May 6, 2022, prohibits all financial institutions within the CEMAC zone from holding, exchanging, or settling cryptocurrency transactions, creating a critical operational barrier known as a banking blockade. This means that while national law allows crypto activity, regional regulation effectively severs the banking rails necessary for easy on-ramping and off-ramping, forcing retail activity onto peer-to-peer or offshore platforms. The government continues to signal its commitment to blockchain technology through initiatives like the Sango project and the Law on the Tokenization of Natural Resources passed on May 29, 2023, which authorizes the tokenization of state-owned resources. Nevertheless, the path forward is fraught with uncertainty, as any new national framework must contend with the opposing position of powerful regional financial bodies, and practical adoption is limited by the country's extremely low internet penetration and electricity access.

Summary Points

I. Regulatory Status
* Allowed-Unregulated as of December 2025.
* Cryptocurrency use is permitted on a voluntary basis for individuals and businesses following the repeal of Bitcoin's legal tender status.
* No formal, comprehensive regulatory framework exists for licensing, oversight, or consumer protection.
* The government is actively working to develop a new legal structure, but the process is complicated by regional opposition.

II. Key Regulatory Bodies
* National Government:
* National Assembly of the Central African Republic: Legislative body responsible for passing and repealing crypto laws.
* Presidency of the Central African Republic: Key driver of crypto adoption initiatives under President Faustin-Archange Touadéra.
* Constitutional Court of the Central African Republic: Highest court, crucial in shaping legal boundaries, notably striking down parts of the Sango project.
* National Agency for Regulation of Electronic Transactions (ANTE): Designated national oversight body under the 2022 law, but its operational status is unclear.
* Regional Bodies (Opposition):
* Bank of Central African States (BEAC): Regional central bank; primary antagonist to CAR's crypto ambitions, viewing them as a threat to the CFA franc.
* Banking Commission of Central Africa (COBAC): Regional banking regulator enforcing a strict ban on crypto servicing by financial institutions.
* Financial Market Supervisory Commission of Central Africa (COSUMAF): Regional financial markets regulator; created a preliminary framework for Virtual Asset Service Providers (VASPs), but implementation is complicated by BEAC opposition.

III. Important Legislation
* Law No. 22.004 Governing Cryptocurrency in the Central African Republic (April 22, 2022): Made Bitcoin legal tender alongside the CFA franc, obligating its acceptance. Repealed in 2023.
* COBAC Decision D-2022/071 (May 6, 2022): Regional directive prohibiting all CEMAC banking and microfinance institutions from holding, exchanging, or settling cryptocurrency transactions.
* Law No. 23.005 Amending the Cryptocurrency Act of 2022 (March 23, 2023): Repealed Law No. 22.004, removed Bitcoin's legal tender status, and established the current allowed-unregulated environment by permitting voluntary use.
* Law on the Tokenization of Natural Resources (May 29, 2023): Authorizes the tokenization of state-owned land and natural resources, underpinning the government's continued Sango project.

IV. Compliance Requirements
* No specific licensing or operational requirements exist for crypto businesses due to the lack of a formal national regulatory framework.

V. Notable Restrictions or Limitations
* Banking Blockade: The COBAC ban prohibits all financial institutions from processing crypto transactions, severing critical banking rails and forcing activity to peer-to-peer platforms.
* Regional Conflict: National policy is in direct conflict with the restrictive stance of BEAC and COBAC, creating significant legal and operational uncertainty.
* Infrastructure Constraints: Extremely low internet penetration and electricity access limit practical retail trading for the majority of the population.
* Taxation: The 2023 repeal eliminated the provision allowing tax payments in crypto; a clear tax framework for crypto transactions or gains has not been established.

VI. Recent Developments or Notes
* The government remains committed to its Sango project, focusing on tokenizing natural resources and creating a digital economic zone after the citizenship-by-investment component was nullified.
* A commission was established in late 2022 to draft a new crypto bill, indicating the current unregulated status is viewed as temporary.
* Recent capacity-building workshops with the African Development Bank in December 2025 on combating illicit financial flows suggest efforts to build institutional credibility, potentially to appease regional and international bodies.
* The situation is unique: the national government is more pro-crypto than the regional banking sector, which is bound by restrictive rules.

Full Analysis Report

Report on the Current Status of Retail Trading in Cryptocurrencies in the Central African Republic

Date: 2025-06-26
Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in the country are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity.

1. Identified Current Status: Allowed-UnRegulated

2. Detailed Narrative Explanation:

Retail cryptocurrency trading in the Central African Republic (CAR) is legally allowed but operates in an unregulated environment, characterized by a lack of specific national rules for licensing, consumer protection, and oversight, and is further complicated by restrictive regional banking policies.

Legal Foundation: The current legal position is defined by Law No. 23.005, enacted on March 23, 2023. This law amended the groundbreaking but controversial 2022 Bitcoin law. The 2023 amendment explicitly repealed Bitcoin's status as legal tender and removed the obligation for merchants to accept it. However, it crucially states: "All economic agents are free to accept cryptocurrencies as a form of payment." This provision legally permits individuals and businesses to engage in crypto transactions on a voluntary basis, placing the activity in an "Allowed" category. No subsequent national law has established a comprehensive regulatory framework for crypto assets, resulting in an "UnRegulated" status.

Historical Context and Regional Conflict: The CAR's initial adoption of Bitcoin as legal tender in April 2022 (Law No. 22.004) was met with immediate opposition from the Bank of Central African States (BEAC) and the Banking Commission of Central Africa (COBAC). COBAC's Decision D-2022/071, issued in May 2022, prohibits all financial institutions within the CEMAC monetary union from holding, exchanging, or settling crypto transactions. This ban remains in force and creates a significant operational barrier, effectively preventing the use of local bank accounts for crypto trading. While the national government has retreated from its legal tender stance to appease regional bodies, it maintains a permissive national policy.

Government Initiatives and Setbacks: The government continues to promote blockchain technology through its "Sango" project, which includes a national digital currency and plans to tokenize natural resources, as authorized by a law passed in May 2023. However, key components of Sango, such as citizenship-by-investment, were struck down by the Constitutional Court in 2022. The project has struggled to gain traction.

Regulatory Gaps and Uncertainties: There is no specific national licensing regime for crypto exchanges or clear KYC/AML rules tailored for Virtual Asset Service Providers (VASPs). The National Agency for Regulation of Electronic Transactions (ANTE), envisioned in the 2022 law, has an unclear operational status. General AML/CFT frameworks exist at the regional level, but their application to the crypto sector is hampered by the banking ban and lack of national implementation. The regional financial market supervisor, COSUMAF, has created a preliminary VASP framework, but its practical effect in CAR is limited by the BEAC's opposition.

Conclusion: Individuals in the CAR are legally free to buy, sell, and hold cryptocurrencies. However, they do so in an environment devoid of a formal national regulatory structure for consumer protection and market integrity. This activity is further constrained by a regional banking blockade. Therefore, the status is accurately classified as Allowed-UnRegulated.

3. Specific, Relevant Text Excerpts:
* March 2023 Amended Law: "The new law says: 'All economic agents are free to accept cryptocurrencies as a form of payment.'" (Source: Central Banking, March 27, 2023).
* COBAC Decision: "COBAC met in an extraordinary session and decided a general ban on cryptocurrencies and crypto assets by all the credit institutions of the Community." (Source: AfricLaw, July 21, 2022).
* IMF Report on Legal Tender Repeal: "The authorities have agreed with BEAC to harmonize their crypto legislation with the monetary union framework on April 6, 2023—including by amending key articles of the crypto law pertaining to the legal tender status." (Source: IMF Country Report No. 23/150, May 2, 2023).
* Original 2022 Law: "Article 1er : La présente Loi a pour objet de régir toutes les transactions liées aux cryptomonnaies en République Centrafricaine, sans restriction..." (Source: Droit-Afrique.com, Law No. 22.004).
* BEAC's Opposition: "The regional central bank, the Bank of Central African States (BEAC), had strongly opposed the law... In May 2022, the regional banking regulator reaffirmed prohibitions on cryptocurrency holdings and transactions by financial institutions." (Source: Central Banking, March 27, 2023).

4. Direct, Accessible URL Links to Specific Sources:
* https://www.centralbanking.com/fintech/crypto-assets/7957486/car-to-drop-crypto-as-legal-tender
* https://www.droit-afrique.com/uploads/RCA-Cryptomonnaies-loi-2022-004.pdf
* https://africlaw.com/2022/07/21/regulating-cryptocurrencies-in-the-central-african-republic-has-the-cart-been-put-before-the-horse/
* https://www.imf.org/en/Publications/CR/Issues/2023/05/02/Central-African-Republic-Selected-Issues-533031
* https://www.radiondekeluka.org/actualites/economie/la-loi-rectificative-sur-les-cryptomonnaies-adoptee-par-lassemblee-nationale/

Source Evidence

Primary and secondary sources cited in this analysis

"The new law says: “All economic agents are free to accept cryptocurrencies as a form of payment.”"

"Article 1er : La présente Loi a pour objet de régir toutes les transactions liées aux cryptomonnaies en République Centrafricaine, sans restriction..."

"The authorities have agreed with BEAC to harmonize their crypto legislation with the monetary union framework on April 6, 2023—including by amending key articles of the crypto law pertaining to the legal tender status."

"COBAC met in an extraordinary session and decided a general ban on cryptocurrencies and crypto assets by all the credit institutions of the Community."

"A new law has been enacted, designating Bitcoin and other cryptocurrencies as reference values that citizens can voluntarily use or accept as payment."

"Cette modification permet ainsi à la République centrafricaine de respecter la norme communautaire en matière de monnaie, recommandée par les organisations sous régionales."

Web Sources (8)

Sources discovered via web search grounding

Search queries used (5)
  • COBAC ban cryptocurrency Central African Republic
  • Central African Republic bitcoin legal tender repealed 2023
  • Central African Republic crypto law 2024 status
  • Law No 22.004 Central African Republic cryptocurrency
  • Sango Coin current status 2025
imf.org

https://www.imf.org/-/media/files/publications/cr/2023/english/1cafea2023002.pdf

jbgsmining.com

https://www.jbgsmining.com/en/post/central-african-republic-drops-bitcoin-as-legal-tender

reddit.com

https://www.reddit.com/r/Bitcoin/comments/12r0m7u/the_central_african_republic_drops_bitcoin_as/

techcabal.com

https://techcabal.com/2025/08/06/crypto-licensing-in-africa/

mariblock.com

https://www.mariblock.com/central-african-republic-to-review-law-that-makes-bitcoin-a-legal-tender-president-touadera/

africlaw.com

https://africlaw.com/2022/07/21/regulating-cryptocurrencies-in-the-central-african-republic-has-the-cart-been-put-before-the-horse/

africlaw.com

https://africlaw.com/tag/law-n22-004/

imf.org

https://www.elibrary.imf.org/view/journals/002/2023/156/article-A001-en.xml

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