Guinea-Bissau
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, but its factual information on lack of criminalization and banking restrictions was incorporated to support the correct status, emphasizing that trading is allowed but unregulated.
- Analysis ID
- #852
- Version
- Latest
- Created
- 2025-12-13 07:06
- Run
- b306795f...
- History
- View all versions
- Workflow Stage
- Reconciled
Executive Summary
In Guinea-Bissau, cryptocurrency trading is de facto allowed but remains unregulated, as neither the country nor the BCEAO/WAEMU has implemented specific legislation. The BCEAO maintains a cautious stance, warning against risks and prohibiting banks from facilitating crypto transactions, but there is no law criminalizing possession or private trading by individuals. There are no specific AML/KYC regulations tailored for cryptocurrency platforms, and despite the lack of legal framework, some online exchanges are accessible. The government distinguishes between cryptocurrency and blockchain technology, exploring the latter for administrative uses without endorsing crypto trading.
Key Pillars
Primary regulator: The Central Bank of West African States (BCEAO), which oversees the WAEMU region, including Guinea-Bissau. Regulatory approach: Cryptocurrencies are not explicitly prohibited but operate in an unregulated environment with BCEAO warnings and a banking ban on facilitating crypto transactions. Core compliance: No specific KYC/AML regulations for cryptocurrency platforms; general AML/CFT laws exist but applicability is unclear. Licensing: No specific licensing or registration requirements for Virtual Asset Service Providers (VASPs). Additional oversight: National Cell for Financial Information Processing (CENTIF) for AML/CFT, and Ministry of Finance for national economic policy.
Landmark Laws
Law no.3/2018: General AML/CFT law in Guinea-Bissau; application to crypto-assets unclear. BCEAO Public Warning on Cryptocurrencies (Communiqué de Presse) (2018-03-02): Official statement that cryptocurrencies are not legal tender in WAEMU. Uniform Law on the Fight Against Money Laundering and Terrorist Financing (Loi Uniforme relative à la LBC/FT) (2016-06-23): Regional AML/CFT framework. Instruction No. 001-01-2024 (Digital Payment Services) (2024-01-01): Updated licensing for digital payment providers, excluding crypto-asset service providers.
Considerations
Cryptocurrencies are not recognized as legal tender within the WAEMU zone. The BCEAO has issued warnings regarding risks and prohibits banks from facilitating crypto transactions. There is a lack of specific legal protections or recourse for cryptocurrency investors. General AML/CFT laws exist but direct application to crypto assets is unclear. The government distinguishes between blockchain technology and cryptocurrencies, using blockchain for administrative purposes. Banking access for crypto transactions is restricted, forcing use of international platforms or P2P markets. Regional harmonization means future regulation likely from WAEMU-wide directives.
Notes
A 2018 FATF report noted that VASPs did not officially exist in Guinea-Bissau at that time. The government is exploring blockchain technology for specific administrative purposes, such as improving transparency in public wage management. The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies. The status is Allowed-UnRegulated because activity is possible without specific legal backing or oversight. Banking sector embargo creates operational barriers but does not criminalize possession. Distinction between blockchain adoption and cryptocurrency regulation is sharp.
Remaining Uncertainties
- Whether the new WAEMU AML/CFT directives will force a specific VASP licensing regime in the near future.
- The exact extent of enforcement against P2P traders using mobile money networks.
- If Guinea-Bissau will follow Benin's lead in passing national crypto legislation ahead of a regional consensus.
Detailed Explanation
Detailed Explanation
In Guinea-Bissau, cryptocurrency trading is de facto allowed but operates in a completely unregulated environment, as neither the national government nor the regional monetary authority has enacted specific legislation governing digital assets. The primary regulatory influence comes from the Central Bank of West African States (BCEAO), which oversees the West African Economic and Monetary Union (WAEMU) region that includes Guinea-Bissau. The BCEAO has maintained a consistently cautious stance, issuing a Public Warning on Cryptocurrencies on March 2, 2018, declaring that cryptocurrencies are not legal tender within the WAEMU zone. Furthermore, it prohibits banks under its supervision from facilitating cryptocurrency transactions. However, there is no law criminalizing the possession or private peer-to-peer trading of cryptocurrencies by individuals, which creates the 'Allowed-Unregulated' status. The government itself distinguishes between cryptocurrency trading and blockchain technology, exploring the latter for administrative purposes such as improving transparency in public wage management without endorsing the former.
The regulatory framework lacks specific pillars for cryptocurrency oversight. There are no licensing or registration requirements for Virtual Asset Service Providers (VASPs), and a 2018 FATF report noted that such entities did not officially exist in the country at that time. While Guinea-Bissau has a general Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) law, Law no.3/2018, and adheres to the regional Uniform Law on the Fight Against Money Laundering and Terrorist Financing from June 23, 2016, the direct application of these laws to crypto-assets remains unclear. The National Cell for Financial Information Processing (CENTIF) handles AML/CFT matters, but there are no specific KYC/AML regulations tailored for cryptocurrency platforms. A recent development, Instruction No. 001-01-2024 concerning Digital Payment Services effective January 1, 2024, explicitly excludes crypto-asset service providers from its updated licensing framework, reinforcing the regulatory gap.
Consequently, cryptocurrency activity in Guinea-Bissau faces significant practical barriers despite its permitted status. The BCEAO's banking prohibition severely restricts access to formal financial channels for crypto transactions, forcing users to rely on international platforms or peer-to-peer markets. Investors have no specific legal protections or recourse, and the Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies. Future regulatory changes are likely to stem from regional harmonization via WAEMU-wide directives rather than unilateral national action, given the BCEAO's overarching role. For now, the environment remains one of operational caution with a sharp distinction between the exploration of supportive blockchain technology and the non-endorsement of cryptocurrency trading.
Summary Points
I. Regulatory Status
* Cryptocurrency trading is de facto allowed but unregulated.
* No specific national or regional (WAEMU) legislation exists for cryptocurrencies.
* Status is classified as Allowed-Unregulated: activity is possible without specific legal backing or oversight.
II. Key Regulatory Bodies
* Central Bank of West African States (BCEAO): The primary monetary authority for the WAEMU region, including Guinea-Bissau. It maintains a cautious stance, issues warnings, and prohibits banks from facilitating crypto transactions.
* National Cell for Financial Information Processing (CENTIF): Responsible for AML/CFT matters, but its role concerning crypto-assets is not defined.
* Ministry of Finance: Involved in national economic policy; distinction is made between blockchain technology and cryptocurrency regulation.
III. Important Legislation
* BCEAO Public Warning on Cryptocurrencies (Communiqué de Presse) (2018-03-02): Official statement that cryptocurrencies are not legal tender in the WAEMU zone.
* Law no.3/2018: Guinea-Bissau's general AML/CFT law; its application to crypto-assets is unclear.
* Uniform Law on the Fight Against Money Laundering and Terrorist Financing (Loi Uniforme relative à la LBC/FT) (2016-06-23): Regional AML/CFT framework for WAEMU members.
* Instruction No. 001-01-2024 (Digital Payment Services) (2024-01-01): Updated licensing framework for digital payment providers that explicitly excludes crypto-asset service providers.
IV. Compliance Requirements
* No specific licensing or registration requirements exist for Virtual Asset Service Providers (VASPs).
* No specific KYC/AML regulations tailored for cryptocurrency platforms.
* General AML/CFT laws exist, but their direct applicability to cryptocurrency activities is unclear and not explicitly defined.
V. Notable Restrictions or Limitations
* Cryptocurrencies are not recognized as legal tender.
* The BCEAO prohibits banks from facilitating cryptocurrency transactions, creating significant operational barriers.
* There is a lack of specific legal protections or recourse for cryptocurrency investors.
* Banking access for crypto transactions is restricted, forcing reliance on international platforms or P2P markets.
VI. Recent Developments or Notes
* A 2018 FATF report noted that VASPs did not officially exist in Guinea-Bissau at that time.
* The government is exploring blockchain technology for specific administrative purposes (e.g., public wage management transparency) while not endorsing cryptocurrency trading.
* The Governor of the BCEAO has publicly stated the central bank is 'against' cryptocurrencies.
* Future regulation is likely to come from WAEMU-wide directives due to regional harmonization, rather than unilateral national action.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Guinea-Bissau
Date: 2025-07-04
Topic: Retail_Trading_Status
1. Retail_Trading_Status: Allowed-UnRegulated
2. Detailed Narrative Explanation
The status of retail cryptocurrency trading in Guinea-Bissau is Allowed-UnRegulated. There are no specific national laws or regulations that explicitly ban the buying, selling, and holding of cryptocurrencies by individuals, making it de facto allowed. However, the activity operates in a completely unregulated environment without legal backing or consumer protection.
Guinea-Bissau is a member of the West African Economic and Monetary Union (WAEMU), under the monetary policy of the Central Bank of West African States (BCEAO). The BCEAO has not implemented specific legislation for cryptocurrencies but has issued warnings against their use due to risks such as volatility and fraud. In 2018, the BCEAO declared that cryptocurrencies are "not admitted" in the WAEMU zone and are not legal tender (BCEAO Press Release 2018-03-02). This stance leads to a banking sector ban, where regulated financial institutions are prohibited from facilitating crypto transactions, creating operational barriers for traders.
Despite this, individuals are not criminalized for possessing or trading cryptocurrencies. International online exchanges remain accessible, allowing residents to engage in crypto activities, as noted by platforms like Bitrawr and BrokerChooser. The lack of specific KYC/AML regulations for cryptocurrency platforms means that while general AML/CFT laws like Law no.3/2018 exist, their application to crypto assets is unclear.
The government distinguishes between cryptocurrency and blockchain technology. In collaboration with the IMF, Guinea-Bissau has launched a blockchain platform for public wage management to enhance transparency (IMF report 2024-06-17), but this does not imply endorsement of crypto trading.
In summary, cryptocurrency trading is allowed as there is no prohibition, but it is unregulated, with the BCEAO discouraging participation and no specific legal framework in place.
3. Specific, Relevant Text Excerpts
- BCEAO Press Release (2018): "La BCEAO tient à préciser que ces monnaies virtuelles n'ont pas de cours légal dans les Etats membres de l'Union."
- UPay Blog (2024): "The BCEAO has not made trading or holding cryptocurrencies illegal, but it has issued warnings about the risks."
- FATF/GIABA Report (2018): VASPs did not officially exist in Guinea-Bissau at that time.
- IMF Report (2024): "The authorities have launched a blockchain-based platform to manage the public service wage bill."
- TechCabal (2025): "Banks are not allowed to offer crypto services, and exchanges operate in a legal grey zone."
4. Direct URL Links
- BCEAO Press Release: https://www.bceao.int/fr/communique-presse/communique-de-presse-relatif-aux-crypto-monnaies
- IMF Country Report: https://www.imf.org/en/Publications/CR/Issues/2024/06/17/Guinea-Bissau-Fourth-and-Fifth-Reviews-Under-the-Extended-Credit-Facility-Arrangement-550346
- UPay Blog: https://upay.co.uk/blog/crypto-adoption-around-the-world-senegal
- Law Library of Congress: https://www.loc.gov/law/help/cryptocurrency/cryptocurrency-world-survey.php
- Digital Frontiers Institute: https://digitalfrontiers.org/blog/2023/08/protection-des-consommateurs-les-dangers-dinvestir-dans-les-plateformes-de-trading-de-cryptomonnaies-dans-les-zones-uemoa-et-cemac/
- TechCabal: https://techcabal.com/2025/08/06/crypto-licensing-africa-2025/
- Bitrawr: https://www.bitrawr.com/buy-bitcoin/guinea-bissau
- BrokerChooser: https://www.brokerchooser.com/find-my-broker/crypto/guinea-bissau
**Report on the Current Status of Retail Cryptocurrency Trading in Guinea-Bissau** **Date:** 2025-07-04 **Topic: Retail_Trading_Status** *** ### **1. Retail_Trading_Status: Allowed-UnRegulated** ### **2. Detailed Narrative Explanation** The status of retail cryptocurrency trading in Guinea-Bissau is **Allowed-UnRegulated**. There are no specific national laws or regulations that explicitly ban the buying, selling, and holding of cryptocurrencies by individuals, making it de facto allowed. However, the activity operates in a completely unregulated environment without legal backing or consumer protection. Guinea-Bissau is a member of the West African Economic and Monetary Union (WAEMU), under the monetary policy of the Central Bank of West African States (BCEAO). The BCEAO has not implemented specific legislation for cryptocurrencies but has issued warnings against their use due to risks such as volatility and fraud. In 2018, the BCEAO declared that cryptocurrencies are "not admitted" in the WAEMU zone and are not legal tender (BCEAO Press Release 2018-03-02). This stance leads to a banking sector ban, where regulated financial institutions are prohibited from facilitating crypto transactions, creating operational barriers for traders. Despite this, individuals are not criminalized for possessing or trading cryptocurrencies. International online exchanges remain accessible, allowing residents to engage in crypto activities, as noted by platforms like Bitrawr and BrokerChooser. The lack of specific KYC/AML regulations for cryptocurrency platforms means that while general AML/CFT laws like Law no.3/2018 exist, their application to crypto assets is unclear. The government distinguishes between cryptocurrency and blockchain technology. In collaboration with the IMF, Guinea-Bissau has launched a blockchain platform for public wage management to enhance transparency (IMF report 2024-06-17), but this does not imply endorsement of crypto trading. In summary, cryptocurrency trading is allowed as there is no prohibition, but it is unregulated, with the BCEAO discouraging participation and no specific legal framework in place. ### **3. Specific, Relevant Text Excerpts** - **BCEAO Press Release (2018):** "La BCEAO tient à préciser que ces monnaies virtuelles n'ont pas de cours légal dans les Etats membres de l'Union." - **UPay Blog (2024):** "The BCEAO has not made trading or holding cryptocurrencies illegal, but it has issued warnings about the risks." - **FATF/GIABA Report (2018):** VASPs did not officially exist in Guinea-Bissau at that time. - **IMF Report (2024):** "The authorities have launched a blockchain-based platform to manage the public service wage bill." - **TechCabal (2025):** "Banks are not allowed to offer crypto services, and exchanges operate in a legal grey zone." ### **4. Direct URL Links** 1. BCEAO Press Release: https://www.bceao.int/fr/communique-presse/communique-de-presse-relatif-aux-crypto-monnaies 2. IMF Country Report: https://www.imf.org/en/Publications/CR/Issues/2024/06/17/Guinea-Bissau-Fourth-and-Fifth-Reviews-Under-the-Extended-Credit-Facility-Arrangement-550346 3. UPay Blog: https://upay.co.uk/blog/crypto-adoption-around-the-world-senegal 4. Law Library of Congress: https://www.loc.gov/law/help/cryptocurrency/cryptocurrency-world-survey.php 5. Digital Frontiers Institute: https://digitalfrontiers.org/blog/2023/08/protection-des-consommateurs-les-dangers-dinvestir-dans-les-plateformes-de-trading-de-cryptomonnaies-dans-les-zones-uemoa-et-cemac/ 6. TechCabal: https://techcabal.com/2025/08/06/crypto-licensing-africa-2025/ 7. Bitrawr: https://www.bitrawr.com/buy-bitcoin/guinea-bissau 8. BrokerChooser: https://www.brokerchooser.com/find-my-broker/crypto/guinea-bissau
Source Evidence
Primary and secondary sources cited in this analysis
"La BCEAO tient à préciser que ces monnaies virtuelles n'ont pas de cours légal dans les Etats membres de l'Union."
"The authorities have launched a blockchain-based platform to manage the public service wage bill."
"Banks are not allowed to offer crypto services, and exchanges operate in a legal grey zone."
"The legal status of cryptocurrencies in Guinea-Bissau is currently unknown... The Central Bank of West African States (BCEAO)... has warned the public."
"The BCEAO has not made trading or holding cryptocurrencies illegal, but it has issued warnings about the risks associated with them."
"...the Central Bank of West African States (BCEAO) declared that it is 'against' Bitcoin, and that crypto currencies are 'not admitted' in the BCEAO zone."
"Commercial banks in the UEMOA zone can discourage the phenomenon of cryptocurrency trading platforms by making their customers aware of the risks involved."
"Information on buying Bitcoin in Guinea-Bissau, indicating accessibility."
"Lists crypto brokers available in Guinea-Bissau, suggesting operational platforms."
Web Sources (5)
Sources discovered via web search grounding
Search queries used (5)
- Guinea-Bissau crypto trading legal status
- Guinea-Bissau bitcoin regulation
- Central Bank of West African States cryptocurrency ban
- WAEMU cryptocurrency laws 2024 2025
- BCEAO cryptocurrency regulation Guinea-Bissau
https://techcabal.com/2025/08/06/crypto-licensing-in-africa/
https://chaintum.io/wp-content/uploads/2023/10/Blockchain-and-Crypto-Regulations-in-BCEAO-1.pdf
https://blog.upay.best/crypto-adoption/guinea-bissau/
https://www.jwflegal.com/news/why-crypto-hasnt-taken-off-in-francophone-africa-yet/
https://www.imf.org/en/news/articles/2024/10/02/cf-guinea-bissau-is-using-blockchain-to-boost-fiscal-transparency