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Senegal

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 supported by the absence of any law prohibiting individual trading, the 2022 tax circular which legally recognizes and taxes the activity, and the 2024 AML law which includes VASPs in reporting obligations. The BCEAO's restrictive stance on banks and lack of a licensing framework create an unregulated environment but do not make the activity illegal for individuals, hence Allowed-UnRegulated.

Analysis ID
#867
Version
Latest
Created
2025-12-13 07:25
Workflow Stage
Reconciled

Executive Summary

Retail cryptocurrency trading in Senegal is Allowed-UnRegulated. There is no explicit legal prohibition against individuals buying, selling, or holding cryptocurrencies, and the activity is implicitly acknowledged through a 2022 tax circular and a 2024 AML law. However, cryptocurrencies are not legal tender. The regional central bank, BCEAO, maintains a cautious stance and restricts financial institutions from engaging in crypto activities. There is no specific licensing regime for crypto exchanges, resulting in a lack of formal oversight and consumer protection for retail traders.

Key Pillars

The primary regulator influencing cryptocurrency activities is the Central Bank of West African States (BCEAO), which restricts banking sector interaction with crypto assets. The National Financial Intelligence Processing Unit (CENTIF) enforces AML/CFT rules; Virtual Asset Service Providers (VASPs) are designated as reporting entities under the 2024 law. The Ministry of Finance and Budget oversees taxation, classifying crypto assets as movable property. The Regional Council for Public Savings and Financial Markets (CREPMF) oversees public offerings involving crypto-assets.

Landmark Laws

Law No. 02/2024 on the Fight Against Money Laundering, Terrorist Financing and Proliferation (Enacted: 2024-02-02) - A uniform law that explicitly expands AML/CFT obligations to include Virtual Asset Service Providers (VASPs), requiring them to conduct due diligence and report suspicious activities to CENTIF.
General Tax Code Circular on Cryptocurrency Taxation (Enacted: 2022) - Classifies cryptocurrencies as 'movable property,' imposing a 15% capital gains tax on sales and a 30% income tax on mining activities.
BCEAO Public Warnings on Cryptocurrency (Various, notably 2018) - The regional central bank has stated it is 'against' Bitcoin, warned that cryptocurrencies are 'not admitted' in the BCEAO zone, and cautioned the public about associated risks.

Considerations

Cryptocurrencies are classified as 'movable property' under Senegalese tax law. Gains from sales are subject to a 15% capital gains tax, and mining is subject to a 30% income tax. The BCEAO has warned about volatility and risks, and financial institutions under its supervision are generally prohibited from cryptocurrency issuance or custody. Local banks are restricted from processing crypto-related transfers, pushing traders toward P2P methods. VASPs are required to report to CENTIF under the 2024 AML law but operate without a formal licensing framework from the BCEAO.

Notes

The BCEAO's cautious stance and warnings reflect concerns about risks, but there is no ban on individual participation. Discussions have occurred regarding a potential regional digital currency (eCFA). The 2024 AML law indicates a move toward recognizing and monitoring crypto activity, but a comprehensive regulatory and licensing framework is absent. International exchanges operating in Senegal implement their own KYC/AML procedures. The tax framework implies the underlying activity is not illegal for individuals.

Remaining Uncertainties

  • The specific mechanism for VASPs to register with CENTIF without a BCEAO operating license is unclear.
  • Whether the 2022 Tax Circular is being actively enforced on individual retail traders or primarily on businesses.
  • The timeline for a regional BCEAO directive that would formally license exchanges.

Detailed Explanation

Retail cryptocurrency trading in Senegal is Allowed-Unregulated. This means there is no explicit legal prohibition against individuals buying, selling, or holding cryptocurrencies, and the activity is implicitly acknowledged by the state through its tax and anti-money laundering frameworks. However, cryptocurrencies are not recognized as legal tender. The primary regulatory influence comes from the Central Bank of West African States (BCEAO), which maintains a cautious stance and has issued public warnings, notably in 2018, stating it is 'against' Bitcoin and that cryptocurrencies are 'not admitted' in the BCEAO zone. Consequently, financial institutions under BCEAO supervision are generally restricted from engaging in crypto activities, such as issuance or custody, and local banks are often prevented from processing crypto-related transfers, pushing traders toward peer-to-peer methods. The regulatory framework is defined by two key pieces of legislation. The General Tax Code Circular on Cryptocurrency Taxation from 2022 classifies crypto assets as 'movable property' and imposes a 15% capital gains tax on sales and a 30% income tax on mining activities, overseen by the Ministry of Finance and Budget. More recently, Law No. 02/2024 on the Fight Against Money Laundering, Terrorist Financing and Proliferation, enacted on 2024-02-02, explicitly brings Virtual Asset Service Providers (VASPs) under AML/CFT obligations, requiring them to conduct due diligence and report suspicious activities to the National Financial Intelligence Processing Unit (CENTIF). Despite these requirements, there is no specific licensing regime for crypto exchanges from the BCEAO, resulting in a lack of formal oversight and consumer protection for retail traders. The Regional Council for Public Savings and Financial Markets (CREPMF) would oversee any public offerings involving crypto-assets. The overall landscape is one of tacit permission for individuals within a framework that seeks to monitor activity for tax and AML purposes while the central bank restricts formal financial sector involvement, leaving the market largely unregulated for participants.

Summary Points

I. Regulatory Status
* Retail cryptocurrency trading is Allowed-Unregulated.
* There is no explicit legal prohibition for individuals to buy, sell, or hold cryptocurrencies.
* Cryptocurrencies are not legal tender.
* The activity is implicitly acknowledged through tax and AML laws.
* No comprehensive licensing or consumer protection framework exists for exchanges.

II. Key Regulatory Bodies
* Central Bank of West African States (BCEAO): The regional central bank sets a cautious tone, restricts supervised financial institutions from crypto activities, and has issued public warnings.
* National Financial Intelligence Processing Unit (CENTIF): Enforces AML/CFT rules; Virtual Asset Service Providers (VASPs) must report suspicious activities to CENTIF under the 2024 law.
* Ministry of Finance and Budget: Oversees taxation of crypto assets, classifying them as movable property.
* Regional Council for Public Savings and Financial Markets (CREPMF): Has oversight over public offerings involving crypto-assets.

III. Important Legislation
* Law No. 02/2024 on the Fight Against Money Laundering, Terrorist Financing and Proliferation (Enacted: 2024-02-02): A uniform law that explicitly expands AML/CFT obligations to include Virtual Asset Service Providers (VASPs), requiring due diligence and reporting to CENTIF.
* General Tax Code Circular on Cryptocurrency Taxation (Enacted: 2022): Classifies cryptocurrencies as 'movable property,' imposing a 15% capital gains tax on sales and a 30% income tax on mining activities.
* BCEAO Public Warnings on Cryptocurrency (Various, notably 2018): The BCEAO has stated it is 'against' Bitcoin, warned that cryptocurrencies are 'not admitted' in the BCEAO zone, and cautioned the public about associated risks.

IV. Compliance Requirements
* For individuals/traders: Capital gains from cryptocurrency sales are subject to a 15% tax; income from mining is subject to a 30% tax.
* For Virtual Asset Service Providers (VASPs): Must comply with AML/CFT obligations under the 2024 law, including customer due diligence and reporting suspicious activities to CENTIF.
* International exchanges operating in Senegal typically implement their own KYC/AML procedures.

V. Notable Restrictions or Limitations
* The BCEAO restricts financial institutions under its supervision from engaging in cryptocurrency issuance, custody, or related services.
* Local banks are generally restricted from processing cryptocurrency-related transfers, forcing traders to rely on peer-to-peer (P2P) methods.
* There is no formal licensing regime for cryptocurrency exchanges, resulting in a lack of formal oversight.

VI. Recent Developments or Notes
* The enactment of the 2024 AML law indicates a move toward recognizing and monitoring crypto activity for financial integrity purposes.
* Discussions have occurred regarding a potential regional digital currency (eCFA).
* The tax framework implies the underlying activity is not illegal for individuals.
* A comprehensive regulatory and licensing framework for the crypto sector remains absent.

Full Analysis Report

Report on Retail Trading Status of Cryptocurrencies in Senegal

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: Allowed-UnRegulated


1. Identified Current Status: Allowed-UnRegulated

2. Detailed Narrative Explanation:
Retail cryptocurrency trading in Senegal is Allowed-UnRegulated. Individuals are legally permitted to buy, sell, and hold cryptocurrencies, as there is no explicit prohibition. This permissibility is substantiated by governmental actions that regulate and tax the activity, rather than ban it. In 2022, the Senegalese tax authority issued a circular classifying cryptocurrencies as 'movable property' and imposing a 15% capital gains tax on sales and a 30% income tax on mining. This tax framework legally recognizes cryptocurrency transactions and creates an obligation for participants, implying the underlying activity is lawful.

Further evidence of tolerated activity is the 2024 Anti-Money Laundering law (Law No. 02/2024), which designates Virtual Asset Service Providers (VASPs) as reporting entities to the national financial intelligence unit (CENTIF). This law brings crypto service providers under AML/CFT supervision, acknowledging their operation within the country's legal framework, even in the absence of a specific licensing regime for exchanges.

The primary monetary authority, the Central Bank of West African States (BCEAO), influences the environment through a cautious stance. The BCEAO has consistently warned that cryptocurrencies are not legal tender within the West African Economic and Monetary Union (WAEMU) and has advised financial institutions under its supervision to refrain from facilitating crypto transactions. This creates a 'banking blockade,' limiting fiat on-ramps and off-ramps, but does not constitute a ban on individual possession or peer-to-peer trading.

International and regional crypto exchanges offer services to Senegalese users, often implementing their own KYC and AML procedures. The activity occurs without a dedicated regulatory framework for consumer protection or exchange licensing, which defines the 'UnRegulated' aspect of the status. The regional financial market regulator, CREPMF, requires authorization for crypto-asset activities linked to public offerings, but this is targeted at businesses issuing tokens, not individual retail trading.

In summary, the combination of tax recognition, AML inclusion for VASPs, and the absence of any law criminalizing individual participation confirms that retail trading is allowed. The lack of a comprehensive regulatory and licensing system for service providers means it is unregulated, placing Senegal in the Allowed-UnRegulated category.

3. Specific, Relevant Text Excerpts:
* UPay Blog (2024-12-07): "In 2022, the Senegalese tax authority issued a circular providing guidance on the taxation of cryptocurrencies. Cryptocurrencies are classified as movable property... Sale of Cryptocurrencies: Subject to a 15% capital gains tax. Mining of Cryptocurrencies: Considered a business activity and subject to a 30% income tax."
* Avocats Houda (2024-02-02) re: Law No. 02/2024: "Extending the scope of the law to virtual asset service providers (Psav)... On 2 February 2024, the Senegalese National Assembly adopted Bill 02/2024."
* Legal 500 (referring to Houda Law Firm insights): "Cryptocurrency activities are not explicitly authorised in Senegal, and banks are not permitted to engage in cryptocurrency issuance or custody. There is currently no specific legal framework regulating cryptocurrency operations."
* Quartz (July 20, 2022, quoting BCEAO's stance): "The currency is issued and regulated by a Dakar-based central bank known as BCEAO, which has warned that the adoption and usage of crypto is illegal with commercial banks operating in the union are forbidden to process crypto transactions."
* UEEx Technology (2025-04-29): "Are crypto exchanges legal in Senegal? Cryptocurrency is not officially recognized as legal money in Senegal. However, there are no strict laws banning crypto trading, so many people still use crypto exchanges to buy and sell digital assets."

4. Direct, Accessible URL Links to Specific Sources:
* UPay Blog (2024-12-07): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHySM37kgmzwWa6AKYU6FWOSfxMVJ_umhCARKVP0nKF9M3hHwwH2_osGQ0wqrjvYJsN9KMu4F9u3NJuY0UWQTMcfUeO566SuqDSB2bci3Bn8QyQ4VNajKtVe_Bl1Ezlq0w7nr1cJW99A3dy
* Avocats Houda on Law No. 02/2024 (2024-02-02): https://www.avocatshouda.com/en/news/senegal-adoption-of-the-new-uniform-law-on-the-fight-against-money-laundering-terrorist-financing-and-the-proliferation-of-weapons-of-mass-destruction-aml-cft-fp
* Legal 500 - Senegal: Banking & Finance: https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGxuWlibXMk7pv9DBTxktdzpW0zW69Asv95L4FOmTgGVbfwAGOljhFarYTiIsnpkNRcH4N3H_2D0jwrR3pvo6kOU3BqPU_WtA-HAiaiDMvY1hG7DTdv-4IomRkjhfC9otzeRGfdWTi-leFZ_77-_AIG9ZWv0CY3WgScjfc=
* Quartz (2022-07-20): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFH3B_h3dl08WRTu2YuLonl9SKh0ZT1VyFcZMg4FoFHLxEmBfcGW_KwG0DLLc0MbZ1GM9xj27qYFKrdam18oYi3HmeC6dpVY25Ui2PItc-bx3IqnhPCnW3o1qPQkt_J6T4MxvSVcKVicHjo2kC_qL81QddtJXvHfuchg5_OoV0Xw1DuJr5AoxWK_6BnJnwcEWzb
* UEEx Technology (2025-04-29): https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQF9SBRCNWI1EiR55JgxC0Rplaz1_mpPdmc3ZI-MnTaccCpiij2tf7-fiO6Dv0jxSX391UbdDMAbAq0_TOxaETDjB159HJH_c_56HbYprYDHl86MqzVE6qY73SkZhQssjjvibly6BBiRcIycGh20XwborZVyeuO56vA=

Source Evidence

Primary and secondary sources cited in this analysis

"In 2022, the Senegalese tax authority issued a circular providing guidance on the taxation of cryptocurrencies. Cryptocurrencies are classified as movable property... Sale of Cryptocurrencies: Subject to a 15% capital gains tax."

"Extending the scope of the law to virtual asset service providers (Psav)... On 2 February 2024, the Senegalese National Assembly adopted Bill 02/2024."

"Cryptocurrency activities are not explicitly authorised in Senegal, and banks are not permitted to engage in cryptocurrency issuance or custody. There is currently no specific legal framework regulating cryptocurrency operations."

"The currency is issued and regulated by a Dakar-based central bank known as BCEAO, which has warned that the adoption and usage of crypto is illegal with commercial banks operating in the union are forbidden to process crypto transactions."

"Are crypto exchanges legal in Senegal? Cryptocurrency is not officially recognized as legal money in Senegal. However, there are no strict laws banning crypto trading, so many people still use crypto exchanges to buy and sell digital assets."

"The enactment of AML/CFT/PWMD Law n°2024-08 has enabled Senegal to mostly meet the requirements... business practice and those that may arise from VASP-related activities have not been assessed."

"Law No. 02/2024... Expanded the list of reporting entities to include... virtual asset service providers (VASPs)."

Web Sources (6)

Sources discovered via web search grounding

Search queries used (8)
  • Is cryptocurrency legal in Senegal
  • BCEAO regulation on crypto assets WAEMU
  • Senegal cryptocurrency regulation 2024 2025
  • BCEAO cryptocurrency stance 2024
  • Senegal crypto tax laws
  • Senegal tax circular 2022 cryptocurrency 15%
  • Senegal Law No. 02/2024 crypto VASP
  • BCEAO instruction crypto banks
voveid.com

https://blog.voveid.com/aml-compliance-in-senegal-2025-guide-for-fintechs-regulated-startups/

allende.com

https://allende.com/en/banking/crypto-law-regulation-of-the-registration-of-virtual-asset-service-providers-with-the-national-securities-commission-cnv-03-25-2024/

upay.best

https://blog.upay.best/crypto-adoption/senegal/

chaintum.io

https://chaintum.io/wp-content/uploads/2023/10/Blockchain-and-Crypto-Regulations-in-BCEAO-1.pdf

tradingview.com

https://www.tradingview.com/news/cointelegraph:cc6efff66094b:0-countries-across-africa-approve-new-crypto-laws-as-adoption-grows/

avocatshouda.com

https://www.avocatshouda.com/en/senegal-new-law-aml-cft-fp/

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