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Mozambique

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. The latest analysis incorrectly classified the status as Gray-Zone, misinterpreting the existence of a non-operational VASP registration framework and practical banking barriers as creating legal ambiguity for retail traders. The correct status is Allowed-Unregulated because no law prohibits individual trading, and the regulatory framework, while drafted, is not active or enforced for retail crypto services.

Analysis ID
#861
Version
Latest
Created
2025-12-13 07:20
Workflow Stage
Reconciled

Executive Summary

As of December 2025, retail cryptocurrency trading in Mozambique is 'Allowed-Unregulated.' The Bank of Mozambique has issued warnings regarding the risks associated with cryptocurrencies, and while a registration framework for Virtual Asset Service Providers (VASPs) was established in 2023, no entities have been publicly registered. There are no specific laws prohibiting or regulating the buying, selling, or holding of cryptocurrencies by individuals. Strict foreign exchange controls and banking sector risk aversion create practical difficulties, but retail participation is not legally banned.

Key Pillars

The primary regulator is the Bank of Mozambique (Banco de Moçambique), which has issued warnings and established a registration regime for VASPs via Notice No. 4/GBM/2023. However, no VASPs have been publicly registered, and the framework is not yet operational for retail oversight. There is an absence of crypto-specific KYC/AML requirements for platforms, though general AML/CFT laws apply. No effective licensing or registration requirements exist for crypto exchanges serving retail users. Strict foreign exchange controls limit cross-border transactions.

Landmark Laws

Comunicado (November 2021) by the Bank of Mozambique: A public alert highlighting the risks of virtual assets, stating they are not legal tender, not backed by the central bank, and are highly volatile and susceptible to fraud and illicit use.

Law on Preventing and Combating Money Laundering and Terrorist Financing (Law No. 14/2023) - Enacted: 2023-08-28: Designates Virtual Asset Service Providers (VASPs) as financial institutions subject to AML/CFT obligations.

Notice No. 4/GBM/2023 (Registration of Virtual Asset Service Providers) - Enacted: 2023-09-14: Establishes a mandatory registration framework for VASPs with the Bank of Mozambique. Came into force on November 14, 2023.

Notice No. 9/GBM/2025 (Limits on Payments Abroad) - Enacted: 2025-12-09: Establishes strict limits on payments made abroad using bank cards, which can restrict residents from purchasing cryptocurrency on foreign exchanges.

Considerations

Cryptocurrencies are not considered legal tender in Mozambique. The Bank of Mozambique has warned about the speculative nature and risks, including high volatility and potential for use in illicit activities. There is a lack of clarity on issues such as taxation of crypto-assets. No VASPs are registered, and commercial banks, wary of AML fines, often block crypto-related transactions. Foreign exchange controls (Notice 9/GBM/2025) restrict cross-border payments, limiting access to international crypto exchanges. Individuals engaging in cryptocurrency trading do so at their own risk, without specific consumer protections or regulatory oversight.

Notes

Historically, Mozambique's financial regulatory landscape has focused on traditional instruments. The absence of a clear, operational regulatory framework may push cryptocurrency activity to informal channels. The situation is dynamic, and the Bank of Mozambique may introduce specific regulations in the future. The lack of VASP registrations despite the 2023 framework indicates a de facto unregulated environment for retail trading. Continuous monitoring of pronouncements from the Bank of Mozambique is advised.

Remaining Uncertainties

  • Whether any VASP applications are currently under review or if the regulator is implicitly rejecting them.
  • The specific threshold at which FX controls (Notice 9/GBM/2025) trigger blocks on crypto merchant codes (MCC 6051).
  • If the central bank plans to issue a 'sandbox' framework to bridge the gap between the strict law and the lack of registrants.

Detailed Explanation

As of December 2025, retail cryptocurrency trading in Mozambique is 'Allowed-Unregulated.' This status means that while there are no specific laws prohibiting individuals from buying, selling, or holding cryptocurrencies, the activity operates in a de facto unregulated environment without formal oversight or consumer protections. The primary regulatory body, the Bank of Mozambique (Banco de Moçambique), has established a foundational framework but has not yet operationalized it for retail market supervision. The bank's initial stance was articulated in a November 2021 Comunicado, a public alert that highlighted the risks of virtual assets, clarified they are not legal tender or backed by the central bank, and warned of their volatility and susceptibility to fraud and illicit use. This warning set the tone for a cautious regulatory approach.

The regulatory framework consists of two key pieces of legislation. First, the Law on Preventing and Combating Money Laundering and Terrorist Financing (Law No. 14/2023), enacted on August 28, 2023, designates Virtual Asset Service Providers (VASPs) as financial institutions subject to Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) obligations. Second, and more directly, Notice No. 4/GBM/2023, enacted on September 14, 2023, established a mandatory registration framework for VASPs with the Bank of Mozambique, which came into force on November 14, 2023. However, a critical fact is that no VASPs have been publicly registered under this framework, meaning there are no effectively licensed or registered crypto exchanges serving retail users. Consequently, while general AML/CFT laws apply, there are no crypto-specific KYC/AML requirements actively enforced for platforms. Practical participation is heavily constrained by broader financial controls. Notice No. 9/GBM/2025, enacted on December 9, 2025, imposes strict limits on payments made abroad using bank cards, which severely restricts residents' ability to purchase cryptocurrency on foreign exchanges. Furthermore, commercial banks, wary of AML fines, often preemptively block crypto-related transactions. Therefore, individuals engage in cryptocurrency trading entirely at their own risk, facing significant practical hurdles due to foreign exchange controls and banking sector risk aversion, all within a landscape where the promised regulatory framework for service providers exists on paper but is not yet active.

Summary Points

I. Regulatory Status
* Retail cryptocurrency trading is Allowed-Unregulated as of December 2025.
* No specific laws prohibit individuals from buying, selling, or holding cryptocurrencies.
* The environment is de facto unregulated for retail trading, with no operational oversight or specific consumer protections.

II. Key Regulatory Bodies
* Bank of Mozambique (Banco de Moçambique): The primary financial regulator.
* Has issued public warnings on crypto risks.
* Established the registration framework for Virtual Asset Service Providers (VASPs).

III. Important Legislation
* Comunicado (November 2021) by the Bank of Mozambique: A public alert stating cryptocurrencies are not legal tender, are highly volatile, and are susceptible to fraud and illicit use.
* Law on Preventing and Combating Money Laundering and Terrorist Financing (Law No. 14/2023): Enacted on 2023-08-28. Designates Virtual Asset Service Providers (VASPs) as financial institutions subject to AML/CFT obligations.
* Notice No. 4/GBM/2023 (Registration of Virtual Asset Service Providers): Enacted on 2023-09-14. Established a mandatory registration framework for VASPs with the Bank of Mozambique. Came into force on November 14, 2023.
* Notice No. 9/GBM/2025 (Limits on Payments Abroad): Enacted on 2025-12-09. Imposes strict limits on payments made abroad using bank cards, restricting access to international crypto exchanges.

IV. Compliance Requirements
* For Virtual Asset Service Providers (VASPs): Mandatory registration with the Bank of Mozambique is required under Notice No. 4/GBM/2023.
* No VASPs have been publicly registered as of the reporting date, so the framework is not operational.
* General AML/CFT laws apply to VASPs as designated financial institutions, but there are no crypto-specific KYC/AML requirements actively enforced for platforms serving retail users.

V. Notable Restrictions or Limitations
* Cryptocurrencies are not legal tender in Mozambique.
* Strict Foreign Exchange Controls: Notice No. 9/GBM/2025 limits cross-border payments, creating a major practical barrier to using international exchanges.
* Banking Sector Aversion: Commercial banks, wary of AML risks, often block crypto-related transactions.
* Lack of Clarity: Issues such as the taxation of crypto-assets are not clearly defined.
* Individuals trade at their own risk with no specific consumer protections.

VI. Recent Developments or Notes
* The situation is dynamic, and the Bank of Mozambique may introduce specific regulations in the future.
* The absence of a clear, operational framework may push cryptocurrency activity to informal channels.
* Continuous monitoring of pronouncements from the Bank of Mozambique is advised.

Full Analysis Report

Report on Retail Cryptocurrency Trading Status in Mozambique

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.


Retail_Trading_Status

Identified Status: Allowed-Unregulated

Detailed Narrative Explanation:

As of December 2025, retail cryptocurrency trading in Mozambique operates in an environment best described as "Allowed-Unregulated." No specific laws explicitly prohibit or regulate the buying, selling, or holding of cryptocurrencies by individual citizens and residents.

The Bank of Mozambique (Banco de Moçambique) has demonstrated awareness and concern through multiple communications. In November 2021, it issued a public alert (Comunicado) highlighting the risks of virtual assets, stating they are not legal tender, are not backed by the central bank, and are highly volatile and susceptible to fraud. This was a warning, not a regulatory prohibition.

Subsequent regulatory developments have not altered this fundamental status for retail traders. In 2023, the Bank of Mozambique enacted Law No. 14/2023 and Notice No. 4/GBM/2023, establishing a mandatory registration framework for Virtual Asset Service Providers (VASPs) and bringing them under AML/CFT obligations. However, as of mid-2025, no VASPs have been publicly registered. This means the framework is not operational, and there is no licensed, regulated channel for crypto exchange services in Mozambique.

Furthermore, the Bank of Mozambique has enforced strict foreign exchange controls (Notice No. 9/GBM/2025) and penalized commercial banks for AML breaches. This has led banks to block crypto-related transactions, creating significant practical barriers to accessing international exchanges. Nevertheless, these measures target financial intermediaries and cross-border flows, not the act of retail trading itself.

Therefore, individuals in Mozambique can legally trade cryptocurrencies but do so entirely at their own risk. They have no access to locally regulated platforms, no specific consumer protections, and face banking and FX restrictions. The absence of a functioning regulatory regime, despite one being drafted, confirms the unregulated nature of the activity. The central bank's stance remains cautious, monitoring the sector while allowing individual participation.

Specific, Relevant Text Excerpts and Sources:

  • Source: Bank of Mozambique - Comunicado (November 2021)
    • Excerpt Summary: The Bank warned the public that cryptocurrencies are not legal tender, are not backed by the central bank, and are highly risky.
  • Source: Law No. 14/2023 (2023-08-28)
    • Excerpt Summary: Designates virtual asset service providers as financial institutions for AML/CFT purposes.
  • Source: Notice No. 4/GBM/2023 (2023-09-14)
    • Excerpt Summary: Establishes mandatory prior registration for entities wishing to carry out virtual asset activities.
  • Source: Notice No. 9/GBM/2025 (2025-12-09)
    • Excerpt Summary: Establishes strict limits on payments made abroad using bank cards.
  • Source: Bank of Mozambique Annual Report 2023 (2024-05-17)
    • Excerpt Summary: Confirms the legal framework for VASP registration was established.

Direct, Accessible URL Links to Sources:
* Bank of Mozambique: https://www.bancomoc.mz/
* Law No. 14/2023: https://www.bancomoc.mz/fm/rules/2023/08/28/Lei-14-2023.pdf
* Notice No. 4/GBM/2023: https://www.bancomoc.mz/fm/rules/2023/09/14/Aviso-4-GBM-2023.pdf
* Secondary Analysis: https://www.mdradvogados.com/en/media/legal-alert/registration-of-virtual-asset-service-providers-before-the-mozambique-central-bank/
* News on Bank Fines: https://clubofmozambique.com/news/mozambique-central-bank-fines-nine-financial-institutions-for-breaches-of-regulations-276185/

Note: The regulatory situation is dynamic, and the Bank of Mozambique may activate its VASP framework in the future, which would change the status. Continuous monitoring is advised.

Source Evidence

Primary and secondary sources cited in this analysis

"The Bank of Mozambique alerted the public to the risks associated with virtual assets/cryptocurrencies, stating they are not legal tender, not backed by the central bank, highly volatile, and susceptible to use in illicit activities."

"Considers virtual asset service providers to be financial institutions for the purposes of complying with their duties in terms of preventing and combating ML/TF."

"The prior registration of entities wishing to carry out activities related to virtual assets is now mandatory, under penalty of a misdemeanor."

"The legal framework for the registration of virtual asset service providers at the Banco de Moçambique was established, as provided by Notice No. 4/GBM/2023."

"Establishes strict limits on payments made abroad using bank cards, which effectively restricts residents from purchasing cryptocurrency on foreign exchanges."

"Notice no. 4/GBM/2023 will come into force on 14 November 2023."

"The Bank of Mozambique announced today that it has fined nine credit institutions... for violating prudential rules to prevent and combat money laundering."

Web Sources (10)

Sources discovered via web search grounding

Search queries used (12)
  • Mozambique AML law virtual asset service providers
  • Bank of Mozambique warning virtual assets
  • Mozambique crypto legal framework 2024
  • Banco de Moçambique cryptocurrency regulation status
  • Lei n.º 11/2022 Moçambique criptomoedas
  • Bank of Mozambique crypto ban commercial banks
  • Mozambique registered virtual asset service providers list
  • Banco de Moçambique prohibited banks crypto transactions 2024 2025
  • "Notice no. 4/GBM/2023" registered entities
  • Mozambique crypto exchange license issued
  • "Notice No. 9/GBM/2025" crypto
  • Banco de Moçambique "registered" virtual asset service providers
ueex.com

https://blog.ueex.com/best-crypto-exchanges-in-mozambique/

binance.com

https://www.binance.com/en-IN/square/profile/square-creator-37b0b52b1d4a0

esaamlg.org

https://www.esaamlg.org/reports/Mozambique%20FUR-April%202025.pdf

www.bancomoc.mz

https://www.bancomoc.mz/en/areas-of-expertise/supervision/anti-money-laundering-and-countering-the-financing-of-terrorism-and-proliferation/

mexc.com

https://blog.mexc.com/wiki/is-crypto-legal-in-mozambique/

www.bancomoc.mz

https://www.bancomoc.mz/media/sz0gnzrh/bm-annual-report-2023-24-12-2023_v02.pdf

www.bancomoc.mz

https://www.bancomoc.mz/media/dbmbrzgh/the-challenge-of-new-technologies-in-anti-money-laundering-countering-the-financing-of-terrorism-and-proliferation-of-weapons-of-mass-destruction.pdf

jlaadvogados.com

https://www.jlaadvogados.com/approvalofthelegalframework?lang=en

aimnews.org

https://aimnews.org/2025/02/07/bank-of-mozambique-sanctions-nine-institutions-for-violation-of-financial-rules/

voveid.com

https://blog.voveid.com/kyc-compliance-in-mozambique-a-2025-guide-for-fintechs-and-digital-platforms/

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