Equatorial Guinea
Retail_Trading_Status
Status Changed
Previous status: Gray-Zone
Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. The live analysis correctly identifies the absence of explicit prohibition for individuals and lack of regulation, while the latest analysis incorrectly classified it as Gray-Zone by overemphasizing banking restrictions. The correct status is Allowed-UnRegulated because individuals can engage in crypto trading without penalties, despite regulatory barriers for institutions.
- Analysis ID
- #847
- Version
- Latest
- Created
- 2025-12-13 07:02
- Run
- daef23d2...
- History
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- Workflow Stage
- Reconciled
Executive Summary
As of December 2025, retail cryptocurrency trading in Equatorial Guinea operates in an unregulated environment with no explicit legal prohibition for individuals. The Central African Banking Commission (COBAC) prohibits financial institutions from engaging in crypto transactions through Decision D-2022-071, but individuals face no penalties or enforcement actions. A regional market regulator, COSUMAF, introduced a licensing framework for Virtual Asset Service Providers (VASPs) via Regulation No. 01/22 in July 2022, yet no entities are fully licensed, and the banking ban persists. Cryptocurrencies are not recognized as legal tender, and there is no specific taxation due to lack of formal recognition.
Key Pillars
- Absence of Specific Crypto Legislation: No dedicated national laws governing cryptocurrencies.
- Lack of Formal Definitions: Cryptocurrencies and Virtual Asset Service Providers (VASPs) are not formally defined under national law.
- Central Bank and Financial Authority Stance: COBAC bans regulated financial institutions from crypto transactions, but no direct guidance or prohibition exists for individual retail trading.
- No Enforcement or Penalties for Individuals: Engaging in cryptocurrency activities is not considered illegal and is not subject to penalties.
- Regulatory Conflict: COBAC's banking prohibition conflicts with COSUMAF's emerging VASP licensing regime, creating an unregulated operational environment for individuals.
Landmark Laws
COBAC Decision D-2022-071
- Authority: Banking Commission of Central Africa (COBAC)
- Date: May 6, 2022
- Summary: Prohibits institutions under COBAC's mandate (banks, microfinance institutions, payment service providers) from holding, using, exchanging, or converting cryptocurrencies for themselves or third parties.
Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF
- Authority: Financial Market Supervisory Commission of CEMAC (COSUMAF)
- Date: July 21, 2022
- Summary: Extends the definition of market intermediaries to include Digital Asset Service Providers (PSANs), creating a legal basis for licensing crypto exchanges and custodians, though implementation is stalled by the COBAC banking ban.
Law No. 1/2024 (New Tax Law)
- Authority: Equatorial Guinea Government
- Date: November 19, 2024
- Summary: Modernizes the general tax system but does not introduce specific taxation or classification for cryptocurrencies.
Considerations
- Asset Classification: Cryptocurrencies are not recognized as legal tender; the Central African Franc is the official currency.
- Taxation: No specific taxes on cryptocurrencies due to lack of formal recognition; the Tax Code (Law No. 1/2024) does not include crypto provisions.
- Virtual Asset Service Providers (VASPs): No national legislation exists; COSUMAF's Regulation No. 01/22 provides a regional framework, but specific implementation in Equatorial Guinea is absent.
- Banking Sector Restrictions: Regulated financial institutions are prohibited from crypto transactions per COBAC Decision D-2022-071, forcing individuals to use international exchanges or peer-to-peer methods.
- Regulatory Deadlock: The conflict between COBAC's banking ban and COSUMAF's licensing regime hinders formal market development, maintaining an unregulated environment for retail trading.
Notes
- There are no known government proposals or official pilot programs for cryptocurrency regulation in Equatorial Guinea as of December 2025.
- The regional focus is on financial stability and AML/CFT measures, with a conservative approach to crypto integration.
- The 'Gray-Zone' classification in the latest analysis was due to the banking ban, but individual activity remains unregulated and not prohibited.
- COSUMAF launched a census of crypto actors in December 2025 to transition them into a regulated status, but without banking access, practical operation is blocked.
Remaining Uncertainties
- Will the COBAC banking ban be lifted or amended to allow COSUMAF-licensed entities to open bank accounts?
- Has any specific entity successfully completed the COSUMAF licensing process initiated by the July 2025 census?
- Will Equatorial Guinea issue national guidelines that diverge from the regional BEAC stance?
Detailed Explanation
Detailed Explanation
As of December 2025, retail cryptocurrency trading in Equatorial Guinea is allowed but operates in a completely unregulated environment with no explicit legal prohibition for individuals. The country lacks any dedicated national legislation that defines cryptocurrencies or Virtual Asset Service Providers (VASPs), creating a legal vacuum for individual activity. The primary regulatory influence comes from regional bodies within the Central African Economic and Monetary Community (CEMAC). The Central African Banking Commission (COBAC), through its Decision D-2022-071 dated May 6, 2022, has instituted a strict prohibition, banning all regulated financial institutions—including banks and payment service providers—from holding, using, exchanging, or converting cryptocurrencies for themselves or on behalf of clients. This banking ban is a critical restriction, forcing individuals to rely on international exchanges or peer-to-peer methods, but it does not criminalize individual trading. Concurrently, the regional market regulator, COSUMAF, introduced Regulation No. 01/22 on July 21, 2022, which extends the definition of market intermediaries to include Digital Asset Service Providers (PSANs), establishing a potential licensing framework for crypto exchanges and custodians. However, this framework is inoperative in practice due to the COBAC banking ban, and no entities are fully licensed. The national government's recent modernization of the tax system via Law No. 1/2024, enacted on November 19, 2024, does not introduce any specific taxation or classification for cryptocurrencies, as they remain unrecognized as legal tender. This conflict between COBAC's prohibition and COSUMAF's nascent licensing regime results in a regulatory deadlock, where individual retail trading faces no penalties or enforcement but is structurally hindered from formal market development. The regional focus remains on financial stability and anti-money laundering measures, with a conservative stance that maintains an unregulated operational gray zone for individuals.
Summary Points
I. Regulatory Status
* Status: Allowed-Unregulated for retail trading by individuals.
* No explicit national prohibition or penalties exist for individuals engaging in cryptocurrency activities.
* The environment is characterized by a lack of specific national legislation and formal definitions for crypto assets or service providers.
* A regulatory deadlock exists between a regional banking ban and an unimplemented licensing framework, preventing formal market development.
II. Key Regulatory Bodies
* Central African Banking Commission (COBAC): The regional banking supervisor for the CEMAC zone, whose decisions are binding in Equatorial Guinea. It has issued a prohibition on crypto transactions for regulated financial institutions.
* Financial Market Supervisory Commission of CEMAC (COSUMAF): The regional financial markets authority that has introduced a licensing regime for Virtual Asset Service Providers (VASPs), though it is not yet operational.
* Equatorial Guinea Government: Has not enacted specific crypto legislation; its role is limited to general laws like the Tax Code which do not address cryptocurrencies.
III. Important Legislation
* COBAC Decision D-2022-071 (May 6, 2022): Prohibits all institutions under COBAC's supervision (banks, microfinance, payment providers) from any activity involving cryptocurrencies, including holding, using, exchanging, or converting them.
* Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF (July 21, 2022): Extends the definition of market intermediaries to include Digital Asset Service Providers (PSANs/VASPs), creating a legal basis for licensing crypto businesses at the regional level.
* Law No. 1/2024 (New Tax Law) (November 19, 2024): Modernizes the general tax system but contains no specific provisions for the classification or taxation of cryptocurrencies.
IV. Compliance Requirements
* For individuals: There are no formal compliance requirements, as activity is unregulated.
* For businesses/VASPs: No national framework exists. The regional COSUMAF licensing framework is theoretically applicable but is stalled and unimplemented, with no entities fully licensed as of December 2025.
V. Notable Restrictions or Limitations
* Banking Sector Ban: The COBAC Decision D-2022-071 creates a severe restriction by prohibiting all regulated financial institutions from crypto transactions, forcing reliance on international platforms and peer-to-peer methods.
* Asset Classification: Cryptocurrencies are not recognized as legal tender; the official currency remains the Central African Franc.
* Taxation: No specific taxes apply to cryptocurrency transactions due to their lack of formal recognition in law.
* Operational Conflict: The COBAC banking prohibition directly conflicts with the COSUMAF VASP licensing regime, creating an environment where licensed operation is practically impossible.
VI. Recent Developments or Notes
* As of December 2025, there are no known government proposals or official pilot programs for national cryptocurrency regulation in Equatorial Guinea.
* COSUMAF launched a census of crypto actors in December 2025 aimed at transitioning them into a regulated status, but the effectiveness is blocked by the persistent banking ban.
* The regional regulatory focus remains on financial stability and AML/CFT measures, favoring a conservative approach that inhibits formal crypto market integration.
* The 'Gray-Zone' classification in prior analyses stems from the banking ban, but individual retail activity itself remains explicitly unregulated and not prohibited.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Equatorial Guinea
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 Status:
Allowed-UnRegulated
2. Detailed Narrative Explanation:
Equatorial Guinea, a member of the Central African Economic and Monetary Community (CEMAC), has no specific national legislation explicitly permitting or prohibiting retail cryptocurrency trading. The regulatory landscape is shaped by regional directives. COBAC Decision D-2022-071, enacted on May 6, 2022, bans regulated financial institutions from holding, using, or facilitating cryptocurrency transactions. However, this prohibition does not extend to individuals, who are not subject to penalties or enforcement actions for engaging in crypto activities. Consequently, retail trading operates in an unregulated environment where individuals can access cryptocurrencies via international platforms or peer-to-peer methods, albeit without formal banking support.
COSUMAF Regulation No. 01/22, dated July 21, 2022, introduces a licensing framework for Digital Asset Service Providers (PSANs) in the CEMAC zone, but this has not been implemented in Equatorial Guinea, and no local exchanges are licensed. The Tax Code (Law No. 1/2024) modernizes general taxation but does not include crypto-specific provisions, leaving gains untaxed due to lack of recognition. The Bank of Central African States (BEAC) maintains a restrictive stance to protect the CFA franc, but individual possession remains unregulated. As of December 2025, COSUMAF launched a census of crypto actors to potentially regulate them, but the COBAC banking ban persists, creating a regulatory conflict that sustains the unregulated status for retail traders.
3. Specific, Relevant Text Excerpts:
- Proelium Law LLP: "Equatorial Guinea. Undecided. No legal status for cryptocurrencies. There is no cryptocurrency regulation."
- World Bank Document (2023): "COBAC prohibits institutions under its mandate from directly or indirectly engaging in transactions related to cryptocurrencies."
- LEX Africa: Summarizes COBAC Decision D-2022/071 as prohibiting banks and microfinance institutions from using crypto-assets.
- 4m legal and tax: Notes COBAC's prohibition on banks facilitating crypto transactions and COSUMAF's warning on unregulated crypto offerings.
- FATF Mutual Evaluation Report: Indicates COBAC's decision requires institutions to identify and report crypto-related transactions, but does not criminalize individual activity.
- UPay Blog (2024): "Digital currency is not legal tender, but it is not illegal to engage in cryptocurrency-related activities."
4. Direct, Accessible URL Links to Sources:
- Proelium Law LLP - Cryptocurrency Regulation Tracker: https://www.proeliumlaw.com/crypto-regulation-tracker
- World Bank Document - Equatorial Guinea Digital Economy Diagnostic (2023): https://documents.worldbank.org/en/publication/documents-reports/documentdetail/099300006272322047/p1773430c72c570a509099081e915dfa68e
- LEX Africa - Digital currencies and services gaining momentum across the continent: https://www.lexafrica.com/digital-currencies-and-services-gaining-momentum-across-the-continent/
- 4m legal and tax - Virtual Assets Regulation Within The CEMAC Zone: https://4mtaxlegal.com/virtual-assets-regulation-within-the-cemac-zone/
- FATF - Mutual Evaluation Report on Equatorial Guinea: https://www.fatf-gafi.org/en/countries/detail/Equatorial-Guinea.html
- UPay Blog - Crypto Adoption in Equatorial Guinea: https://upay.best/blog/crypto-adoption-equatorial-guinea
- COBAC Decision D-2022-071: https://www.beac.int
- COSUMAF Regulation No. 01/22: https://www.cosumaf.org
- IMF Country Report No. 23/382: https://www.imf.org/en/Publications/CR/Issues/2023/12/19/Central-African-Economic-and-Monetary-Community-CEMAC-Common-Policies-of-Member-Countries-542616
**Report on the Current Status of Retail Cryptocurrency Trading in Equatorial Guinea** **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 Status:** Allowed-UnRegulated **2. Detailed Narrative Explanation:** Equatorial Guinea, a member of the Central African Economic and Monetary Community (CEMAC), has no specific national legislation explicitly permitting or prohibiting retail cryptocurrency trading. The regulatory landscape is shaped by regional directives. COBAC Decision D-2022-071, enacted on May 6, 2022, bans regulated financial institutions from holding, using, or facilitating cryptocurrency transactions. However, this prohibition does not extend to individuals, who are not subject to penalties or enforcement actions for engaging in crypto activities. Consequently, retail trading operates in an unregulated environment where individuals can access cryptocurrencies via international platforms or peer-to-peer methods, albeit without formal banking support. COSUMAF Regulation No. 01/22, dated July 21, 2022, introduces a licensing framework for Digital Asset Service Providers (PSANs) in the CEMAC zone, but this has not been implemented in Equatorial Guinea, and no local exchanges are licensed. The Tax Code (Law No. 1/2024) modernizes general taxation but does not include crypto-specific provisions, leaving gains untaxed due to lack of recognition. The Bank of Central African States (BEAC) maintains a restrictive stance to protect the CFA franc, but individual possession remains unregulated. As of December 2025, COSUMAF launched a census of crypto actors to potentially regulate them, but the COBAC banking ban persists, creating a regulatory conflict that sustains the unregulated status for retail traders. **3. Specific, Relevant Text Excerpts:** - **Proelium Law LLP:** "Equatorial Guinea. Undecided. No legal status for cryptocurrencies. There is no cryptocurrency regulation." - **World Bank Document (2023):** "COBAC prohibits institutions under its mandate from directly or indirectly engaging in transactions related to cryptocurrencies." - **LEX Africa:** Summarizes COBAC Decision D-2022/071 as prohibiting banks and microfinance institutions from using crypto-assets. - **4m legal and tax:** Notes COBAC's prohibition on banks facilitating crypto transactions and COSUMAF's warning on unregulated crypto offerings. - **FATF Mutual Evaluation Report:** Indicates COBAC's decision requires institutions to identify and report crypto-related transactions, but does not criminalize individual activity. - **UPay Blog (2024):** "Digital currency is not legal tender, but it is not illegal to engage in cryptocurrency-related activities." **4. Direct, Accessible URL Links to Sources:** - Proelium Law LLP - Cryptocurrency Regulation Tracker: https://www.proeliumlaw.com/crypto-regulation-tracker - World Bank Document - Equatorial Guinea Digital Economy Diagnostic (2023): https://documents.worldbank.org/en/publication/documents-reports/documentdetail/099300006272322047/p1773430c72c570a509099081e915dfa68e - LEX Africa - Digital currencies and services gaining momentum across the continent: https://www.lexafrica.com/digital-currencies-and-services-gaining-momentum-across-the-continent/ - 4m legal and tax - Virtual Assets Regulation Within The CEMAC Zone: https://4mtaxlegal.com/virtual-assets-regulation-within-the-cemac-zone/ - FATF - Mutual Evaluation Report on Equatorial Guinea: https://www.fatf-gafi.org/en/countries/detail/Equatorial-Guinea.html - UPay Blog - Crypto Adoption in Equatorial Guinea: https://upay.best/blog/crypto-adoption-equatorial-guinea - COBAC Decision D-2022-071: https://www.beac.int - COSUMAF Regulation No. 01/22: https://www.cosumaf.org - IMF Country Report No. 23/382: https://www.imf.org/en/Publications/CR/Issues/2023/12/19/Central-African-Economic-and-Monetary-Community-CEMAC-Common-Policies-of-Member-Countries-542616
Source Evidence
Primary and secondary sources cited in this analysis
"Equatorial Guinea. Undecided. No legal status for cryptocurrencies. There is no cryptocurrency regulation."
"In May 2022, COBAC adopted the Decision on the holding, use, exchange and conversion of cryptocurrencies or crypto assets by institutions subject to the COBAC. The COBAC prohibits institutions under its mandate from directly or indirectly engaging in transactions related to cryptocurrencies."
"In essence it ruled that banks, microfinance institutions, payment institutions, exchange offices, and their technical partners in the CEMAC are prohibited from using crypto-assets."
"The Financial Market Regulator of CEMAC Member States has prohibited Banks, Microfinance Institutions, and Payment Service Providers from facilitating transactions in cryptocurrency."
"COBAC's decision merely requires them to identify transactions carried out or rejected in connection with crypto-currencies and to provide the Secretariat General of COBAC and BEAC with a detailed statement of these transactions."
"Les établissements assujettis... ne sont pas autorisés à souscrire ou détenir... les cryptomonnaies... Il est interdit... d'échanger ou de convertir... les transactions relatives aux cryptomonnaies."
"Extends the definition of market intermediaries to crypto assets service providers (Art 145) and is defining such services to include buying and selling crypto assets."
"COBAC's earlier Decision D-2022/071 prohibiting the use of cryptocurrencies by entities under its remit [remains in force]."
"Currently, the cryptocurrency sector in Equatorial Guinea has no specific laws... Digital currency is not legal tender, but it is not illegal to engage in cryptocurrency-related activities."
Web Sources (2)
Sources discovered via web search grounding
Search queries used (9)
- Equatorial Guinea retail crypto trading legality
- Regulation No. 01/22/CEMAC/UMAC/CM crypto
- COSUMAF crypto regulation CEMAC Equatorial Guinea
- BEAC cryptocurrency ban Equatorial Guinea
- Equatorial Guinea cryptocurrency regulation 2024 2025
- Regulation No. 01/22/CEMAC/UMAC/CM/COSUMAF text
- Equatorial Guinea crypto tax laws 2025
- COBAC Decision D-2022/071 text
- BEAC crypto stance 2025
https://cesttoutdroit.com/wp-content/uploads/2023/06/06-mai-2022-Decision-COBAC-D-2022-071-relative-a-la-detention-lutilisation-lechange-et-la-conversion-des-cryptomonnaies-par-les-etablissements-assujettis.pdf
https://www.elibrary.imf.org/view/journals/002/2023/156/article-A001-en.xml