Ecuador
Retail_Trading_Status
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 live analysis is the source of truth, clearly stating the activity is allowed but unregulated. Information from the latest analysis (e.g., no licenses issued by late 2025, ongoing banking restrictions) was incorporated as it supports the 'unregulated' aspect of the correct status and does not contradict the fact that retail trading is permitted.
- Analysis ID
- #849
- Version
- Latest
- Created
- 2025-12-13 07:04
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- ee9e2190...
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- Reconciled
Executive Summary
In Ecuador, retail cryptocurrency trading is Allowed-UnRegulated; individuals can buy, sell, and hold crypto, but its use as legal tender is prohibited. The Central Bank of Ecuador (BCE) allows ownership due to constitutional property rights but emphasizes the US Dollar as the sole legal tender. Recent AML legislation (August 2024) introduces Virtual Asset Providers (PAV) which will require licensing and AML/CFT compliance, though specific rules are pending and no domestic licenses have been issued as of late 2025. Financial institutions are barred from crypto activities, and the BCE actively warns about associated risks. The banking sector remains restricted from direct crypto transactions, forcing reliance on international platforms and P2P markets.
Key Pillars
The primary regulator is the Central Bank of Ecuador (BCE), which permits the ownership and trading of cryptocurrencies as digital assets, but prohibits their use as legal tender. The Superintendency of Banks (SB) is mandated by the 2024 reform to license and supervise Virtual Asset Providers (PAVs), but as of late 2025, no domestic licensing regime is fully operational. The Financial Analysis Unit (UAFE) enforces AML/CFT regulations, and PAVs are designated as obligated subjects required to report suspicious transactions. The Junta de Política y Regulación Monetaria (JPRM) issues resolutions defining authorized means of payment. The Organic Monetary and Financial Code (COMF) and recent AML legislation define the regulatory landscape. Core compliance requirements, primarily through the August 2024 AML law, focus on AML/CFT regulations for PAVs, including registration, licensing, and reporting to the UAFE. There are currently no specific licensing or registration requirements for individuals engaging in retail cryptocurrency trading.
Landmark Laws
- Organic Monetary and Financial Code (COMF): Article 94 establishes the US Dollar as the sole legal tender. Article 98 prohibits the use of cryptocurrencies as a means of payment. (Enacted: 2014-09-12) Source
- Fintech Law of 2022 (Ley Orgánica para el Desarrollo de Servicios Financieros Tecnológicos): Aims to regulate financial technology services but does not specifically create a comprehensive framework for cryptocurrencies. (Enacted: 2022-12-22) Source
- "Ley Orgánica para la Mejora Recaudatoria a través del Combate de Lavado de Activos" (Organic Law for Improving Tax Collection through Combating Money Laundering): Enacted in August 2024, introduces the concept of "Virtual Asset Providers" (PAV) and imposes AML/CFT compliance requirements. This Decreto-Ley amended Article 99 of the COMF to include PAVs as recognized means of payment, subject to Superintendency of Banks licensing. (Enacted: 2024-08-10) Source
Considerations
Cryptocurrencies are classified as digital assets but are not legal tender in Ecuador and cannot be used to discharge debts or pay taxes. The BCE and other regulatory bodies have issued warnings about the volatility, speculative nature, lack of backing, and potential for financial loss associated with cryptocurrencies. Financial institutions are barred from participating in cryptocurrency transactions, restricting direct access to the crypto market through Ecuadorian bank accounts. Despite the 2024 law, traditional banks remain effectively barred from processing direct crypto transactions under prior JPRM resolutions. The UAFE requires crypto exchanges (even if offshore/unlicensed) to be treated as high-risk for AML monitoring by local banks. The Superintendency of Banks actively publishes 'blacklists' of unauthorized financial entities, creating risk for unregulated local platforms. The August 2024 AML law potentially enables taxation of crypto assets through the regulation of Virtual Asset Providers.
Notes
The Central Bank of Ecuador (BCE) has consistently maintained its stance on cryptocurrencies since at least January 2018. The General Manager of the BCE acknowledged the need for a specific law to regulate crypto asset investment in August 2024. There are concerns from the Superintendency of Companies, Securities, and Insurance regarding unregulated activities. The rules governing PAV licensing and operation as of December 2024 are still pending development, and as of late 2025, no domestic licensing regime is fully operational. The regulatory landscape remains ambiguous due to the absence of clear guidelines, as noted in April 2024 by Lexology (Heka Law Firm Analysis). The 2025 context shows a transition period where the law is on the books but the market reality is unlicensed operation, leading to a reliance on international platforms.
Remaining Uncertainties
- Has the Superintendency of Banks issued any VASP licenses as of late 2025, or is the application process still stalled?
- Will the secondary norms (normativa secundaria) explicitly force international exchanges to register locally or face blocking?
- How does the tax authority (SRI) treat crypto gains in the absence of a specific tax form for VASPs?
Detailed Explanation
Detailed Explanation
In Ecuador, retail cryptocurrency trading is allowed but unregulated for individuals, meaning they can buy, sell, and hold crypto assets without specific licensing or registration requirements. However, the use of cryptocurrencies as legal tender is explicitly prohibited. The foundational regulatory framework is established by the Organic Monetary and Financial Code (COMF), enacted on September 12, 2014. Article 94 of the COMF designates the US Dollar as the sole legal tender, and Article 98 explicitly prohibits the use of cryptocurrencies as a means of payment. The Central Bank of Ecuador (BCE) is the primary regulator, permitting cryptocurrency ownership based on constitutional property rights while consistently warning about the associated risks, such as volatility and potential for financial loss. Financial institutions are barred from engaging in cryptocurrency transactions, which restricts direct market access and forces reliance on international platforms and peer-to-peer markets. The Superintendency of Banks (SB) is mandated to license and supervise Virtual Asset Providers (PAVs), but as of late 2025, no domestic licensing regime is fully operational, and no licenses have been issued. A significant recent development is the 'Ley Orgánica para la Mejora Recaudatoria a través del Combate de Lavado de Activos,' enacted on August 10, 2024. This law introduces PAVs as a regulated entity class, amending Article 99 of the COMF to include them as recognized means of payment subject to SB licensing and imposes Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) compliance obligations. The Financial Analysis Unit (UAFE) enforces these AML/CFT regulations, designating PAVs as obligated subjects required to report suspicious transactions. Despite this legislative progress, the specific rules for PAV licensing and operation are still pending, creating an ambiguous regulatory landscape where the market operates without a fully implemented framework. The Junta de Política y Regulación Monetaria (JPRM) issues resolutions defining authorized means of payment, and the banking sector remains restricted, with the Superintendency of Banks actively publishing 'blacklists' of unauthorized financial entities. The 2022 Fintech Law, enacted on December 22, 2022, aims to regulate financial technology services but does not create a comprehensive framework for cryptocurrencies. The regulatory environment is characterized by a transition period where new laws exist but are not yet fully enforced, maintaining the status of cryptocurrency as an allowed but unregulated and risky digital asset for retail users.
Summary Points
I. Regulatory Status
* Retail cryptocurrency trading is Allowed-Unregulated for individuals.
* Cryptocurrencies are classified as digital assets but are not legal tender; their use for payment is prohibited.
* Financial institutions are barred from cryptocurrency activities.
II. Key Regulatory Bodies
* Central Bank of Ecuador (BCE): Primary regulator; permits ownership, warns of risks, and upholds the US Dollar as sole legal tender.
* Superintendency of Banks (SB): Mandated to license and supervise Virtual Asset Providers (PAVs); no licenses issued as of late 2025.
* Financial Analysis Unit (UAFE): Enforces AML/CFT regulations; PAVs are obligated subjects.
* Junta de Política y Regulación Monetaria (JPRM): Issues resolutions on authorized means of payment.
III. Important Legislation
* Organic Monetary and Financial Code (COMF) (2014-09-12): Article 94 establishes the US Dollar as sole legal tender; Article 98 prohibits cryptocurrency as payment.
* Fintech Law of 2022 (2022-12-22): Regulates financial technology but does not provide a specific crypto framework.
* 'Ley Orgánica para la Mejora Recaudatoria a través del Combate de Lavado de Activos' (2024-08-10): Introduces Virtual Asset Providers (PAVs), amends COMF Article 99, and imposes AML/CFT requirements.
IV. Compliance Requirements
* For individuals: No specific licensing or registration requirements for trading.
* For Virtual Asset Providers (PAVs): Future requirements will include licensing by the SB and AML/CFT compliance and reporting to the UAFE, but specific rules are pending.
V. Notable Restrictions or Limitations
* Prohibition on using cryptocurrency as legal tender or to discharge debts.
* Ban on financial institutions participating in crypto transactions.
* Reliance on international platforms and P2P markets due to domestic banking restrictions.
* Active publication of 'blacklists' of unauthorized entities by the Superintendency of Banks.
VI. Recent Developments or Notes
* The August 2024 law represents a significant shift but is not yet fully implemented; the regulatory landscape remains ambiguous.
* As of late 2025, no domestic licensing regime for PAVs is operational.
* The BCE has maintained its consistent stance on cryptocurrencies since at least January 2018.
* The 2024 law potentially enables future taxation of crypto assets.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Ecuador
Date: 2025-12-11
Topic: Retail_Trading_Status
Description: An assessment of whether individual citizens and residents in Ecuador are legally permitted to buy, sell, and hold cryptocurrencies, detailing the regulatory environment surrounding this activity.
Retail_Trading_Status: Allowed-UnRegulated
1. Current Status: Allowed-UnRegulated
2. Detailed Narrative Explanation:
Retail cryptocurrency trading in Ecuador is Allowed-UnRegulated. Individuals are legally permitted to buy, sell, and hold cryptocurrencies as a form of private property, a stance supported by the Central Bank of Ecuador (BCE) based on constitutional property rights. However, the activity exists in a regulatory environment characterized by significant restrictions and warnings, rather than a comprehensive licensing or consumer protection framework.
The foundational legal principle is established by the Organic Monetary and Financial Code (COMF), which designates the US Dollar as the sole legal tender (Article 94) and explicitly prohibits the use of cryptocurrencies as a means of payment (Article 98). The BCE has consistently reinforced this position, warning citizens that engaging with cryptocurrencies is done at their own risk due to volatility, lack of backing, and potential for illicit use.
A pivotal development occurred in August 2024 with the enactment of the "Ley Orgánica para la Mejora Recaudatoria a través del Combate de Lavado de Activos." This law amended the COMF to introduce "Virtual Asset Providers" (PAVs) as a regulated category, subject to future licensing by the Superintendency of Banks and AML/CFT obligations. This represents a legislative intent to bring service providers under supervision. However, as of late 2025, the secondary regulations necessary to operationalize this licensing regime have not been finalized, and no domestic PAV licenses have been issued.
Consequently, while the law theoretically creates a path for regulated exchanges, the current market reality is one of unregulated operation. Ecuadorian traders primarily rely on international platforms (e.g., Binance, Kraken) and peer-to-peer (P2P) markets. The banking sector remains walled off from direct crypto transactions due to enduring resolutions from the Junta de Política y Regulación Monetaria (JPRM), forcing all fiat on-ramps and off-ramps to occur through P2P mechanisms.
In summary, retail trading is allowed and occurs freely, but it is not "regulated" in the sense of having active, licensed domestic intermediaries or specific rules for individual traders. The regulatory focus is on prohibiting crypto as legal tender, restricting financial institutions, and planning a future licensing regime for service providers, leaving individual activity in an allowed but unregulated space.
3. Specific, Relevant Text Excerpts:
-
Central Bank of Ecuador (BCE) Official Communication (August 2024):
> "El Banco Central del Ecuador recuerda que los criptoactivos no son una moneda de curso legal, ni un medio de pago autorizado en Ecuador." (The Central Bank of Ecuador reminds that crypto assets are not legal tender, nor an authorized means of payment in Ecuador.)- Source: BCE Official Website.
-
Legal Analysis of the 2024 AML Law Reform (December 2024):
> "La reforma sustituye el artículo 99... Ahora, los Proveedores de Activos Virtuales (PAV) podrán operar bajo la supervisión de la Superintendencia de Bancos." (The reform replaces Article 99... Now, Virtual Asset Providers (PAVs) may operate under the supervision of the Superintendency of Banks.)- Source: Derecho.ec analysis.
-
Superintendency of Banks Enforcement Alert (November 2025):
> "La Superintendencia de Bancos alerta sobre nuevas entidades No autorizadas detectadas... 56 entidades en 2025." (The Superintendency of Banks alerts about new unauthorized entities detected... 56 entities in 2025.)- Source: Superintendency of Banks website.
4. Direct, Accessible URL Links:
- Central Bank of Ecuador (BCE): Official communications page for updates and warnings: https://www.bce.fin.ec/
- Superintendency of Banks: For information on authorized entities and enforcement actions: https://www.superbancos.gob.ec
- Text of the Fintech Law (2022): Hosted by the Superintendency of Companies, Securities, and Insurance (SCVS): https://www.supercias.gob.ec/wp-content/uploads/2023/05/Ley-Organica-para-el-Desarrollo-Regulacion-y-Control-de-los-Servicios-Financieros-Tecnologicos-Ley-Fintech.pdf
- Legal Analysis of 2024 P2P Regulations: https://derecho.ec/normativa-legal-comercio-p2p-criptomonedas-ecuador
Individuals in Ecuador engaging in cryptocurrency trading should be aware of the associated risks, the lack of domestic regulatory protection, and the ongoing restrictions within the traditional banking system.
## Report on the Current Status of Retail Cryptocurrency Trading in Ecuador
**Date:** 2025-12-11
**Topic:** Retail_Trading_Status
**Description:** An assessment of whether individual citizens and residents in Ecuador are legally permitted to buy, sell, and hold cryptocurrencies, detailing the regulatory environment surrounding this activity.
---
### Retail_Trading_Status: Allowed-UnRegulated
**1. Current Status:** Allowed-UnRegulated
**2. Detailed Narrative Explanation:**
Retail cryptocurrency trading in Ecuador is **Allowed-UnRegulated**. Individuals are legally permitted to buy, sell, and hold cryptocurrencies as a form of private property, a stance supported by the Central Bank of Ecuador (BCE) based on constitutional property rights. However, the activity exists in a regulatory environment characterized by significant restrictions and warnings, rather than a comprehensive licensing or consumer protection framework.
The foundational legal principle is established by the Organic Monetary and Financial Code (COMF), which designates the US Dollar as the sole legal tender (Article 94) and explicitly prohibits the use of cryptocurrencies as a means of payment (Article 98). The BCE has consistently reinforced this position, warning citizens that engaging with cryptocurrencies is done at their own risk due to volatility, lack of backing, and potential for illicit use.
A pivotal development occurred in August 2024 with the enactment of the "Ley Orgánica para la Mejora Recaudatoria a través del Combate de Lavado de Activos." This law amended the COMF to introduce "Virtual Asset Providers" (PAVs) as a regulated category, subject to future licensing by the Superintendency of Banks and AML/CFT obligations. This represents a legislative intent to bring service providers under supervision. However, as of late 2025, the secondary regulations necessary to operationalize this licensing regime have not been finalized, and no domestic PAV licenses have been issued.
Consequently, while the law theoretically creates a path for regulated exchanges, the current market reality is one of unregulated operation. Ecuadorian traders primarily rely on international platforms (e.g., Binance, Kraken) and peer-to-peer (P2P) markets. The banking sector remains walled off from direct crypto transactions due to enduring resolutions from the Junta de Política y Regulación Monetaria (JPRM), forcing all fiat on-ramps and off-ramps to occur through P2P mechanisms.
In summary, retail trading is allowed and occurs freely, but it is not "regulated" in the sense of having active, licensed domestic intermediaries or specific rules for individual traders. The regulatory focus is on prohibiting crypto as legal tender, restricting financial institutions, and planning a future licensing regime for service providers, leaving individual activity in an allowed but unregulated space.
**3. Specific, Relevant Text Excerpts:**
* **Central Bank of Ecuador (BCE) Official Communication (August 2024):**
> "El Banco Central del Ecuador recuerda que los criptoactivos no son una moneda de curso legal, ni un medio de pago autorizado en Ecuador." (The Central Bank of Ecuador reminds that crypto assets are not legal tender, nor an authorized means of payment in Ecuador.)
* *Source:* BCE Official Website.
* **Legal Analysis of the 2024 AML Law Reform (December 2024):**
> "La reforma sustituye el artículo 99... Ahora, los Proveedores de Activos Virtuales (PAV) podrán operar bajo la supervisión de la Superintendencia de Bancos." (The reform replaces Article 99... Now, Virtual Asset Providers (PAVs) may operate under the supervision of the Superintendency of Banks.)
* *Source:* Derecho.ec analysis.
* **Superintendency of Banks Enforcement Alert (November 2025):**
> "La Superintendencia de Bancos alerta sobre nuevas entidades No autorizadas detectadas... 56 entidades en 2025." (The Superintendency of Banks alerts about new unauthorized entities detected... 56 entities in 2025.)
* *Source:* Superintendency of Banks website.
**4. Direct, Accessible URL Links:**
* **Central Bank of Ecuador (BCE):** Official communications page for updates and warnings: [https://www.bce.fin.ec/](https://www.bce.fin.ec/)
* **Superintendency of Banks:** For information on authorized entities and enforcement actions: [https://www.superbancos.gob.ec](https://www.superbancos.gob.ec)
* **Text of the Fintech Law (2022):** Hosted by the Superintendency of Companies, Securities, and Insurance (SCVS): [https://www.supercias.gob.ec/wp-content/uploads/2023/05/Ley-Organica-para-el-Desarrollo-Regulacion-y-Control-de-los-Servicios-Financieros-Tecnologicos-Ley-Fintech.pdf](https://www.supercias.gob.ec/wp-content/uploads/2023/05/Ley-Organica-para-el-Desarrollo-Regulacion-y-Control-de-los-Servicios-Financieros-Tecnologicos-Ley-Fintech.pdf)
* **Legal Analysis of 2024 P2P Regulations:** [https://derecho.ec/normativa-legal-comercio-p2p-criptomonedas-ecuador](https://derecho.ec/normativa-legal-comercio-p2p-criptomonedas-ecuador)
Individuals in Ecuador engaging in cryptocurrency trading should be aware of the associated risks, the lack of domestic regulatory protection, and the ongoing restrictions within the traditional banking system.
Source Evidence
Primary and secondary sources cited in this analysis
"El Banco Central del Ecuador recuerda que los criptoactivos no son una moneda de curso legal, ni un medio de pago autorizado en Ecuador."
"La reforma sustituye el artículo 99... Ahora, los Proveedores de Activos Virtuales (PAV) podrán operar bajo la supervisión de la Superintendencia de Bancos."
"La Superintendencia de Bancos alerta sobre nuevas entidades No autorizadas detectadas... 56 entidades en 2025."
"While the Central Bank (BCE) allows citizens to buy or sell digital assets online, they repeatedly stress that crypto is not legal tender."
"With no local crypto laws [fully operational], Ecuador favors trusted global exchanges."
"The law defines virtual assets and establishes that entities offering services related to them must register with the Superintendency of Companies, Securities, and Insurance and comply with AML/CFT regulations."
"The Central Bank of Ecuador (BCE) allows the purchase and sale of cryptocurrencies by individuals, citing constitutional property rights, but reiterates that cryptocurrencies are not authorized as a means of payment."
Web Sources (12)
Sources discovered via web search grounding
Search queries used (9)
- Junta de Política y Regulación Monetaria Ecuador criptoactivos
- legalidad bitcoin Ecuador 2024
- Ecuador cryptocurrency regulation status 2024 2025
- Ley Fintech Ecuador criptoactivos regulación
- Banco Central del Ecuador comunicado criptomonedas 2023 2024
- Are there licensed crypto exchanges in Ecuador 2025
- "Decreto-Ley" lavado de activos Ecuador criptomonedas artículo 99
- Junta de Política y Regulación Monetaria resolución activos virtuales 2025
- Superintendencia de Bancos Ecuador lista proveedores activos virtuales autorizados 2025
https://blog.ueex.com/best-crypto-exchanges-in-ecuador/
https://www.cryptowinrate.com/best-crypto-exchanges-ecuador
https://www.dentons.com/es/insights/alerts/2022/december/28/puntos-clave-de-la-ley-fintech-en-ecuador
https://revistas.uteq.edu.ec/index.php/csye/article/view/983/1014
https://www.superbancos.gob.ec/bancos/superintendencia-de-bancos-alerta-sobre-entidades-no-autorizadas/
https://publications.iadb.org/publications/spanish/document/Regulacion-de-blockchain-e-identidad-digital-en-America-Latina-El-futuro-de-la-identidad-digital.pdf
https://corralrosales.com/ley-fintech/
https://www.openbankproject.com/blog/la-ley-fintech-de-ecuador/
https://www.bitrawr.com/ecuador
https://www.onesafe.io/blog/crypto-exchange-in-ecuador
https://derecho.ec/normativa-legal-para-el-comercio-p2p-de-criptomonedas-en-ecuador/
https://ocedic.com/_lawcedic/files/v2/Gu%C3%ADa%20para%20la%20regulaci%C3%B3n%20ALACFT%20AV-PSAV.pdf