Cabo Verde

{
  "analysis_text": "Cabo Verde occupies a \u0027Gray-Zone\u0027 status regarding retail cryptocurrency trading, characterized by a significant gap between its advanced legislative framework and the practical reality of its implementation. In June 2023, the National Assembly enacted Law No. 30/X/2023, a comprehensive statute designed to regulate Virtual Asset Service Providers (VASPs) and digital banks. This law explicitly brings crypto-asset activities under the supervision of the Banco de Cabo Verde (BCV), mandating registration for exchanges, custodians, and transfer services. It also subjects these entities to strict Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) obligations, aligning the country with FATF recommendations.\n\nDespite the legal clarity provided by the 2023 law, the operational licensing regime appears to be stalled or in a very early stage of development. As of late 2025, more than two years after the law\u0027s passage, there is no publicly available record of licensed VASPs operating in the country. The BCV launched a public consultation on the specific regulations for VASP registration in January 2024, indicating a delay in finalizing the practical mechanisms for market entry. This delay has resulted in a market that is legally \u0027open\u0027 but practically \u0027closed\u0027 to regulated domestic operators.\n\nEvidence from the local fintech sector reinforces this assessment. In November 2025, founders of \u0027CaboPay\u0027, a local payment startup, stated in interviews that \u0027no one works directly with cryptocurrencies in the country\u0027 and called for a \u0027clearer legal framework\u0027. This suggests that while the statute exists on paper, it has not yet fostered a regulated domestic market, and entrepreneurs still perceive regulatory barriers or ambiguity. Consequently, while retail trading is not criminalized, residents lack access to locally regulated platforms and must rely on international services, which operate outside the direct oversight of the BCV.\n\nThe Banco de Cabo Verde has previously issued warnings (e.g., in 2018) regarding the risks of virtual assets, emphasizing they are not legal tender and are not guaranteed by the state. While the 2023 law supersedes the notion of an unregulated \u0027Wild West\u0027, the absence of licensed entities triggers the \u0027Gray-Zone\u0027 classification criteria: a licensing regime is technically in force, but no licenses have been issued after more than 12 months, leaving the status of safe, regulated retail trading in limbo.",
  "confidence_level": "High",
  "executive_summary": "Retail cryptocurrency trading in Cabo Verde exists in a regulatory gray zone despite the enactment of a specific legal framework in June 2023. While Law No. 30/X/2023 formally regulates virtual asset service providers (VASPs) and requires registration with the Banco de Cabo Verde (BCV), no licensed entities have been publicly confirmed as of late 2025. Local fintech entrepreneurs report that the sector remains practically inactive with no domestic entities directly working with crypto, citing a continued need for clearer legal implementation.",
  "grounding_urls": [
    {
      "resolved_url": "https://proeliumlaw.com/cryptocurrency-regulation-tracker/",
      "title": "proeliumlaw.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEBdJ3tjm5TY_irM2I-Pm9zaSYZeNY9Nk1otGJiXho64egiw0WSZzZVtOQBuoMpqIGaWK0RMMx614VefFCJsaMvKpV9iBlHu0vPn3s7dNHmv5Ep4mORabD0fkXmN09P6SwPA7b0hjGomVV4erZczYobDvydKKM="
    },
    {
      "resolved_url": "https://bfibank.com/wp-content/uploads/2024/12/BFI_Relatorio-e-Contas_23.pdf",
      "title": "bfibank.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQE3udIMe11GXoaKjf751OZZHLjTIUC6SzUxBFetONgeTx7nRPMxYfEh39EPDlmv-HHMupG_yqS5vetEDGs3gbYhPQUmG6nu1opfzhNC59ORhn2XQALehUAs0GhDp4DAafRj66Ngcz1jjqwGdvh_0qzYXUk6TOfnxwuAUVuQ63y5HEdv-ceKHRc="
    }
  ],
  "status": "Gray-Zone",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "Cabo Verde occupies a \u0027Gray-Zone\u0027 status regarding retail cryptocurrency trading, characterized by a significant gap between its advanced legislative framework and the practical reality of its implementation. In June 2023, the National Assembly enacted Law No. 30/X/2023, a comprehensive statute designed to regulate Virtual Asset Service Providers (VASPs) and digital banks. This law explicitly brings crypto-asset activities under the supervision of the Banco de Cabo Verde (BCV), mandating registration for exchanges, custodians, and transfer services. It also subjects these entities to strict Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) obligations, aligning the country with FATF recommendations.\n\nDespite the legal clarity provided by the 2023 law, the operational licensing regime appears to be stalled or in a very early stage of development. As of late 2025, more than two years after the law\u0027s passage, there is no publicly available record of licensed VASPs operating in the country. The BCV launched a public consultation on the specific regulations for VASP registration in January 2024, indicating a delay in finalizing the practical mechanisms for market entry. This delay has resulted in a market that is legally \u0027open\u0027 but practically \u0027closed\u0027 to regulated domestic operators.\n\nEvidence from the local fintech sector reinforces this assessment. In November 2025, founders of \u0027CaboPay\u0027, a local payment startup, stated in interviews that \u0027no one works directly with cryptocurrencies in the country\u0027 and called for a \u0027clearer legal framework\u0027. This suggests that while the statute exists on paper, it has not yet fostered a regulated domestic market, and entrepreneurs still perceive regulatory barriers or ambiguity. Consequently, while retail trading is not criminalized, residents lack access to locally regulated platforms and must rely on international services, which operate outside the direct oversight of the BCV.\n\nThe Banco de Cabo Verde has previously issued warnings (e.g., in 2018) regarding the risks of virtual assets, emphasizing they are not legal tender and are not guaranteed by the state. While the 2023 law supersedes the notion of an unregulated \u0027Wild West\u0027, the absence of licensed entities triggers the \u0027Gray-Zone\u0027 classification criteria: a licensing regime is technically in force, but no licenses have been issued after more than 12 months, leaving the status of safe, regulated retail trading in limbo.",
    "executive_summary": "Retail cryptocurrency trading in Cabo Verde exists in a regulatory gray zone despite the enactment of a specific legal framework in June 2023. While Law No. 30/X/2023 formally regulates virtual asset service providers (VASPs) and requires registration with the Banco de Cabo Verde (BCV), no licensed entities have been publicly confirmed as of late 2025. Local fintech entrepreneurs report that the sector remains practically inactive with no domestic entities directly working with crypto, citing a continued need for clearer legal implementation.",
    "important_considerations": [
      "Implementation Lag: Although the law passed in mid-2023, the operational framework (licensing) was still in consultation in 2024, with no active licensees confirmed by late 2025.",
      "No Legal Tender: Virtual assets are not legal tender in Cabo Verde; the Escudo (CVE) remains the sole legal tender.",
      "Taxation: Capital gains from crypto assets are generally subject to a flat tax rate (often cited as 20% for capital gains), though specific enforcement on retail traders is unclear.",
      "Market Reality: Local startups in late 2025 described the domestic crypto sector as virtually non-existent, with no entities directly working with crypto assets locally."
    ],
    "key_regulatory_pillars": [
      "Banco de Cabo Verde (BCV) - Primary regulator and supervisor for VASPs",
      "Mandatory Registration - All entities providing virtual asset services must register with the BCV",
      "AML/CFT Compliance - VASPs are subject to the Anti-Money Laundering and Countering Financing of Terrorism laws (Law No. 38/VII/2009 as amended)",
      "Fit and Proper Requirements - Management and beneficial owners must undergo suitability assessments"
    ],
    "landmark_legislation": [
      {
        "date_enacted": "2023-06-21",
        "identifier": "Lei n.\u00ba 30/X/2023",
        "name": "Law No. 30/X/2023",
        "summary": "Establishes the legal regime for the provision of services with virtual assets and the constitution of digital banks. It mandates prior registration with the Central Bank for any VASP activity and imposes AML/CFT obligations.",
        "url": "https://www.bcv.cv/pt/O%20Banco/Sala%20de%20Imprensa/Arquivo/Documents/Lei%20n.%C2%BA%2030-X-2023%20-%20Regula%20a%20presta%C3%A7%C3%A3o%20de%20servi%C3%A7os%20com%20ativos%20virtuais%20e%20a%20constitui%C3%A7%C3%A3o%20de%20bancos%20digitais.pdf"
      },
      {
        "date_enacted": "2023-06-21",
        "identifier": "Lei n.\u00ba 29/X/2023",
        "name": "Law No. 29/X/2023",
        "summary": "Amends the General Tax Code. While primarily focused on financial transparency, it is part of the legislative package that accompanied the VASP law, establishing the framework for taxing digital financial activities.",
        "url": "https://www.bcv.cv/pt/Supervisao/Bancos%20e%20Outras%20Instituicoes%20Financeiras/Legisla%C3%A7%C3%A3o/Documents/Lei%20n.%C2%BA%2029-X-2023%20-%20Procede%20%C3%A0%20segunda%20altera%C3%A7%C3%A3o%20%C3%A0%20Lei%20n.%C2%BA%2047-VIII-2013,%20de%2020%20de%20dezembro,%20alterada%20pela%20Lei%20n.%C2%BA%2086-IX-2020,%20de%2028%20de%20abril,%20que%20aprova%20o%20C%C3%B3digo%20Geral%20Tribut%C3%A1rio.pdf"
      },
      {
        "date_enacted": "2024-01-23",
        "identifier": "Aviso do BCV sobre Registo de Ativos Virtuais",
        "name": "Notice No. 4/2024 (Draft/Consultation)",
        "summary": "A regulatory notice placed for public consultation in early 2024 to operationalize the registration process for VASPs, detailing the forms and specific requirements for market entry.",
        "url": null
      }
    ],
    "notes_and_comments": "The classification is \u0027Gray-Zone\u0027 rather than \u0027Allowed-Regulated\u0027 strictly due to the lack of evidence of operational licensing. The legal framework is robust and modern (post-2023), but the market reality lags significantly. If the BCV publishes a list of authorized VASPs, the status would immediately upgrade to \u0027Allowed-Regulated\u0027.",
    "primary_sources": [
      {
        "date": "2023-06-21",
        "key_quote": "The exercise of activities with virtual assets will, from now on, be subject to prior registration with Banco de Cabo Verde.",
        "source_type": "law_text",
        "title": "Law No. 30/X/2023 - Regulates the provision of services with virtual assets",
        "url": "https://www.bcv.cv/pt/O%20Banco/Sala%20de%20Imprensa/Arquivo/Documents/Lei%20n.%C2%BA%2030-X-2023%20-%20Regula%20a%20presta%C3%A7%C3%A3o%20de%20servi%C3%A7os%20com%20ativos%20virtuais%20e%20a%20constitui%C3%A7%C3%A3o%20de%20bancos%20digitais.pdf"
      },
      {
        "date": "2024-05-13",
        "key_quote": "Documents needed to file the Application for Registration of the entities indicated below",
        "source_type": "regulator",
        "title": "Banco de Cabo Verde - Registration Dossier",
        "url": "https://www.bcv.cv/en/Supervisao/Mercado%20de%20Capitais/Dossier%20de%20Registo/Paginas/default.aspx"
      },
      {
        "date": "2018-03-31",
        "key_quote": "Virtual currencies, or crypto-currencies, such as Bitcoin, do not have legal tender status... and are not guaranteed by a central bank.",
        "source_type": "regulator",
        "title": "Banco de Cabo Verde Warning on Virtual Currencies",
        "url": "https://www.bcv.cv/pt/O%20Banco/Sala%20de%20Imprensa/Comunicados/Documents/Alerta%20sobre%20Moedas%20Virtuais.pdf"
      }
    ],
    "remaining_uncertainties": [
      "Has any specific entity successfully completed the registration process with BCV as of late 2025?",
      "What are the specific capital requirements and fees detailed in the final regulations (Avisos) for VASPs?",
      "How does the tax authority practically enforce the 20% capital gains tax on individual crypto traders?"
    ],
    "secondary_sources": [
      {
        "date": "2025-11-13",
        "key_quote": "In relation to the use of cryptocurrencies, the young entrepreneur defended the need for a \u0027more clear\u0027 legal framework in Cabo Verde... \u0027At this moment, no one works directly with cryptocurrencies in the country\u0027",
        "source_type": "news",
        "title": "Startup Cabo-verdiana CaboPay at Web Summit 2025",
        "url": "https://inforpress.cv/en/technology/portugalweb-summit-2025-cape-verdean-startup-wants-to-make-international-transfer-faster-and-cheaper"
      },
      {
        "date": "2023-06-26",
        "key_quote": "Entities that engage in activities with virtual assets on national territory are now subject to compliance with the duties to prevent money laundering... subject to prior registration with Banco de Cabo Verde.",
        "source_type": "analysis",
        "title": "VPQ Advogados Legal Alert: Provision of Virtual Asset Services",
        "url": "https://www.vpqadvogados.com/xms/files/2023-06-26_Legal_Alert_-_Provision_of_virtual_asset_and_digital_banking_services.pdf"
      }
    ],
    "status": "Gray-Zone"
  }
}