Senegal

{
  "analysis_text": "The regulatory status of cryptocurrency in Senegal is best classified as \u0027Gray-Zone\u0027 due to the disconnect between recent AML/tax obligations and the absence of a permissive licensing regime. Unlike a \u0027Banned\u0027 jurisdiction, Senegal allows individuals to hold and trade digital assets without fear of criminal prosecution. In fact, the state has moved to monetize the sector through taxation, with the 2022 tax circular explicitly levying a 15% tax on capital gains from digital assets, treating them as \u0027movable property.\u0027\n\nHowever, the environment is restrictive for businesses. The primary financial authority, the Central Bank of West African States (BCEAO), has historically maintained that crypto assets are \u0027not permitted\u0027 within the WAEMU banking system. This creates a significant operational barrier, as local banks are deterred from offering fiat on/off ramps to crypto exchanges. Consequently, retail trading is heavily reliant on Peer-to-Peer (P2P) markets and mobile money integrations rather than direct bank transfers to local exchanges.\n\nA major regulatory shift occurred on February 2, 2024, with the adoption of Law No. 02/2024. This legislation transposed a WAEMU directive into national law, explicitly adding Virtual Asset Service Providers (VASPs) to the list of entities subject to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) obligations. This law effectively brings VASPs under the supervision of CENTIF (the Financial Intelligence Unit) for reporting purposes. While this legitimizes the *existence* of crypto service providers, it does not grant them a license to operate, as the BCEAO has not yet established a licensing framework for them.\n\nThis creates a complex \u0027Gray-Zone\u0027 where crypto activity is recognized for tax and crime prevention purposes but remains operationally marginalized by the banking regulator. There are no licensed local exchanges, and international platforms operate without local oversight. The trajectory suggests Senegal is moving toward a \u0027Regulated\u0027 status, likely in concert with a future pan-WAEMU regulatory framework, but for now, it remains in a transitional phase with conflicting signals between the Ministry of Finance (tax/AML) and the Central Bank (monetary stability).",
  "confidence_level": "High",
  "executive_summary": "Retail cryptocurrency trading in Senegal operates in a regulatory \u0027Gray-Zone\u0027. While buying, holding, and selling crypto assets is not explicitly criminalized for individuals, there is no licensing regime for exchanges, and the regional central bank (BCEAO) maintains a restrictive stance on banking integration. Recent legislative moves, specifically the 2024 AML law designating Virtual Asset Service Providers (VASPs) as reporting entities and a 2022 tax circular imposing a 15% capital gains tax, indicate a transition toward regulation, but a formal operating framework remains absent.",
  "grounding_urls": [
    {
      "resolved_url": "https://blog.voveid.com/aml-compliance-in-senegal-2025-guide-for-fintechs-regulated-startups/",
      "title": "voveid.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQHgP8H6-M22UjVgNWxubMWKBMd2CEaK7rQq1CQQGrqEpl2eplA5ftRM3o1pzG74Gt3lgP_pw4FKfVK2v4fVndGtY4qd7F71IcR2cC5JgNPbgDSiHWXnK8i-hfpLdkVGxAI9ctD4108rVpeijxqinpFtRpUHNLES7wkJ8O6R3OvnTnFOC-r3KHfCf_KCodZNlv_Vxx2__W4stA=="
    },
    {
      "resolved_url": "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/",
      "title": "allende.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQErVndGkM4fizKVaGhIyW_Xf8-S0Hj0LOxzTuTAZe56YAiE2-c-FjeLgMr4LMnOM_CpQ7hyxpb1_R6Rq9284IVf9BYT-oKHwQUmEvG2HaNdTa8xcb2rbD308FZaUu9IqGKJToT0v_SJFNy_ixVlYxfP428Kl1bzPhM_hoyfdW_UKQVnSprnF9pf-FJMT1tgPreLFSGCsRgojB2BCTRKcgFATf9GrDBD1rt_pQbJXOQ6g-BqoPHxJSGXujLYjK6Fx-4h2hgJxhRTyG6-5-cYYRP9DkWtk6uScbIaYOObn9kq"
    },
    {
      "resolved_url": "https://blog.upay.best/crypto-adoption/senegal/",
      "title": "upay.best",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEaqVb7l18BW8uftx70lotGZlWe0Ap8cc4ebHCdc-LvanGidzzIb-ta5XcWXJE_B7jIm3zOroOtf0F42F2FcMe4Y3OvGhOnLWRww4U8gXLHJg7OFzUXqkwkHjwHYSQ5yp_apS5PL7mODBW7"
    },
    {
      "resolved_url": "https://chaintum.io/wp-content/uploads/2023/10/Blockchain-and-Crypto-Regulations-in-BCEAO-1.pdf",
      "title": "chaintum.io",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEnAwL6oFZH_H39g6gULdXBwBKTf9WH49eG7pBb4PNY7Ks2yYzv8LCz_JlSud6fu1-WFmaHmL_mqY1ssygck7OiSv7RAmuly6ekdEa1eXPBXgfvipBCxdy_YSksK3KH6AfvqnEVrOuiUMOCpKCU07ubH9vNT11rTw5yljDan3p_vtKBPwO9svJsNC8aoNDOb1ZUPsgNpwc_Qb32"
    },
    {
      "resolved_url": "https://www.tradingview.com/news/cointelegraph:cc6efff66094b:0-countries-across-africa-approve-new-crypto-laws-as-adoption-grows/",
      "title": "tradingview.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFzBe5vyjfZ8M9qWAJyHgERqIFsvcwpwU_wSuMAiBJ-2gWkP-M6yJBNzCOYSq_keVG1WF6CyOufGgzBWZsjeA4jEOIk9lqCjkTWxgKd_F3vL-1SKhiSZT2JwdltnbVUpH8fdeQybE1i90U_L2hebmj32czlhA8-iZtwjJhiCZswXY-fnv6VcTmkhE2c7kD4ouLBhP73PiYyVLbiJAdRiyO53f5B3TakNpLHAB9CZE99s2iLgP36e9DkDcdgh2o="
    },
    {
      "resolved_url": "https://www.avocatshouda.com/en/senegal-new-law-aml-cft-fp/",
      "title": "avocatshouda.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGt8MMoucJ4FHqd6PnZETOqYMjUKhyzI5adUT_ClgimE3uTHOPASp6djIXXE2TtO337_4LhyB82Ts1pZeA2NF-QtiPvlxSRegpQx_dK96ALP_5bKpxRiiSQMWwsltXrYUejvtsYtsXGEAt8Vwld8UsQ0pHtiN0p"
    }
  ],
  "status": "Gray-Zone",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "The regulatory status of cryptocurrency in Senegal is best classified as \u0027Gray-Zone\u0027 due to the disconnect between recent AML/tax obligations and the absence of a permissive licensing regime. Unlike a \u0027Banned\u0027 jurisdiction, Senegal allows individuals to hold and trade digital assets without fear of criminal prosecution. In fact, the state has moved to monetize the sector through taxation, with the 2022 tax circular explicitly levying a 15% tax on capital gains from digital assets, treating them as \u0027movable property.\u0027\n\nHowever, the environment is restrictive for businesses. The primary financial authority, the Central Bank of West African States (BCEAO), has historically maintained that crypto assets are \u0027not permitted\u0027 within the WAEMU banking system. This creates a significant operational barrier, as local banks are deterred from offering fiat on/off ramps to crypto exchanges. Consequently, retail trading is heavily reliant on Peer-to-Peer (P2P) markets and mobile money integrations rather than direct bank transfers to local exchanges.\n\nA major regulatory shift occurred on February 2, 2024, with the adoption of Law No. 02/2024. This legislation transposed a WAEMU directive into national law, explicitly adding Virtual Asset Service Providers (VASPs) to the list of entities subject to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) obligations. This law effectively brings VASPs under the supervision of CENTIF (the Financial Intelligence Unit) for reporting purposes. While this legitimizes the *existence* of crypto service providers, it does not grant them a license to operate, as the BCEAO has not yet established a licensing framework for them.\n\nThis creates a complex \u0027Gray-Zone\u0027 where crypto activity is recognized for tax and crime prevention purposes but remains operationally marginalized by the banking regulator. There are no licensed local exchanges, and international platforms operate without local oversight. The trajectory suggests Senegal is moving toward a \u0027Regulated\u0027 status, likely in concert with a future pan-WAEMU regulatory framework, but for now, it remains in a transitional phase with conflicting signals between the Ministry of Finance (tax/AML) and the Central Bank (monetary stability).",
    "executive_summary": "Retail cryptocurrency trading in Senegal operates in a regulatory \u0027Gray-Zone\u0027. While buying, holding, and selling crypto assets is not explicitly criminalized for individuals, there is no licensing regime for exchanges, and the regional central bank (BCEAO) maintains a restrictive stance on banking integration. Recent legislative moves, specifically the 2024 AML law designating Virtual Asset Service Providers (VASPs) as reporting entities and a 2022 tax circular imposing a 15% capital gains tax, indicate a transition toward regulation, but a formal operating framework remains absent.",
    "important_considerations": [
      "Banking Blockade: Local banks are generally restricted from processing crypto-related transfers due to BCEAO directives, forcing traders to use P2P methods or mobile money.",
      "Tax Liability: Despite the lack of consumer protection or licensing, traders are legally obligated to pay 15% capital gains tax.",
      "AML Reporting: Crypto businesses (VASPs) operating in Senegal are technically required to report to CENTIF under the 2024 law, creating a compliance paradox where they must report but cannot obtain an operating license.",
      "Regional Dependency: Senegal cannot unilaterally legalize crypto as legal tender due to its membership in the WAEMU zone; it must wait for a regional framework."
    ],
    "key_regulatory_pillars": [
      "BCEAO (Central Bank of West African States): Sets monetary policy and restricts banking sector interaction with crypto assets.",
      "CENTIF (National Financial Intelligence Processing Unit): Enforces AML/CFT rules; VASPs are now considered \u0027obliged entities\u0027 for reporting suspicious transactions.",
      "Ministry of Finance and Budget: Oversees taxation of crypto assets under the General Tax Code."
    ],
    "landmark_legislation": [
      {
        "date_enacted": "2024-02-02",
        "identifier": "Law No. 02/2024",
        "name": "Law No. 02/2024 on the Fight Against Money Laundering, Terrorist Financing and Proliferation",
        "summary": "A uniform law adopted by the National Assembly that explicitly expands the scope of AML/CFT obligations to include Virtual Asset Service Providers (VASPs). It requires VASPs to conduct due diligence and report suspicious activities to CENTIF, effectively recognizing their existence without yet providing a licensing license.",
        "url": "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"
      },
      {
        "date_enacted": "2022-01-01",
        "identifier": "Tax Circular (2022)",
        "name": "General Tax Code Circular on Cryptocurrency Taxation",
        "summary": "Clarifies the tax treatment of cryptocurrencies, classifying them as movable property. It imposes a 15% capital gains tax on sales and a 30% tax on mining activities (considered business income).",
        "url": null
      },
      {
        "date_enacted": "2018-03-01",
        "identifier": "Various Press Releases",
        "name": "BCEAO Public Warnings on Cryptocurrency",
        "summary": "Repeated warnings from the regional central bank stating that cryptocurrencies are not legal tender, are not regulated, and that financial institutions should refrain from facilitating related transactions.",
        "url": "https://www.bceao.int/"
      }
    ],
    "notes_and_comments": "Senegal\u0027s regulatory environment is heavily dependent on the regional body WAEMU. While national laws (Tax, AML) have moved ahead to capture revenue and mitigate risk, the \u0027operational\u0027 permission (banking access, licensing) is stalled at the regional central bank level. The 2024 AML law is a strong indicator that full regulation is the end goal.",
    "primary_sources": [
      {
        "date": "2024-02-02",
        "key_quote": "Extending the scope of the law to virtual asset service providers (Psav)... On 2 February 2024, the Senegalese National Assembly adopted Bill 02/2024.",
        "source_type": "law_text",
        "title": "Adoption of the new uniform law on AML/CFT/FP (Law No. 02/2024)",
        "url": "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"
      },
      {
        "date": "2021-05-01",
        "key_quote": "The BCEAO has issued warnings about the risks of cryptocurrency use... and advised citizens to be cautious.",
        "source_type": "regulator",
        "title": "BCEAO Website - Financial Stability \u0026 Warnings",
        "url": "https://www.bceao.int/"
      },
      {
        "date": "2024-05-01",
        "key_quote": "The enactment of AML/CFT/PWMD Law n\u00b02024-08 has enabled Senegal to mostly meet the requirements... business practice and those that may arise from VASP-related activities have not been assessed.",
        "source_type": "official_government",
        "title": "GIABA Follow-Up Report Senegal 2024",
        "url": "https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GIABA-FUR-Senegal-2024.pdf.coredownload.inline.pdf"
      }
    ],
    "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."
    ],
    "secondary_sources": [
      {
        "date": "2024-12-07",
        "key_quote": "In 2022, the Senegalese tax authority issued a circular... Sale of Cryptocurrencies: Subject to a 15% capital gains tax.",
        "source_type": "analysis",
        "title": "Senegal Crypto Adoption and Tax Rules",
        "url": "https://upay.best/blog/crypto-adoption-senegal/"
      },
      {
        "date": "2025-11-05",
        "key_quote": "Law No. 02/2024... Expanded the list of reporting entities to include... virtual asset service providers (VASPs).",
        "source_type": "analysis",
        "title": "KYC Compliance in Senegal: 2025 Guide",
        "url": "https://voveid.com/blog/kyc-compliance-senegal-2025-fintechs"
      }
    ],
    "status": "Gray-Zone"
  }
}