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Created: 2025-06-26 13:19
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Executive Summary

As of June 2025, the regulatory landscape for retail cryptocurrency trading in Western Sahara remains largely unclear and highly complex, primarily due to the territory's disputed political status. While the Kingdom of Morocco administratively controls a significant portion of Western Sahara, this control is not universally recognized, and the territory is classified by the United Nations as a non-self-governing territory with unresolved sovereignty issues. This fundamental dispute directly translates into a lack of clear, unified regulatory authority across the entire territory, creating a fragmented and uncertain environment for cryptocurrency activities. While Morocco is actively developing a framework to legalize and regulate crypto by 2025, its direct applicability and enforcement throughout Western Sahara are inherently complicated by the ongoing political conflict. Conversely, the Sahrawi Arab Democratic Republic (SADR), proclaimed by the Polisario Front, has established its own "Central Reserve Authority of Western Sahara" which claims to issue financial licenses, including for crypto, further fragmenting any potential regulatory oversight.

As of June 2025, the regulatory landscape for retail cryptocurrency trading in Western Sahara remains largely unclear and highly complex, primarily due to the territory's disputed political status. While the Kingdom of Morocco administratively controls a significant portion of Western Sahara, this control is not universally recognized, and the territory is classified by the United Nations as a non-self-governing territory with unresolved sovereignty issues. This fundamental dispute directly translates into a lack of clear, unified regulatory authority across the entire territory, creating a fragmented and uncertain environment for cryptocurrency activities. While Morocco is actively developing a framework to legalize and regulate crypto by 2025, its direct applicability and enforcement throughout Western Sahara are inherently complicated by the ongoing political conflict. Conversely, the Sahrawi Arab Democratic Republic (SADR), proclaimed by the Polisario Front, has established its own "Central Reserve Authority of Western Sahara" which claims to issue financial licenses, including for crypto, further fragmenting any potential regulatory oversight.

Key Pillars

  • Moroccan-Administered Areas: In areas under Moroccan control, any forthcoming Moroccan crypto regulations would theoretically apply. Morocco has traditionally maintained a ban on cryptocurrency transactions since 2017, but is actively moving towards legalization and regulation. A new regulatory framework is nearing adoption as of June 2025, aiming to balance financial stability with innovation.

  • Polisario Front/SADR-Administered Areas: The Sahrawi Arab Democratic Republic (SADR) has established its own financial authority, the Central Reserve Authority of Western Sahara, which purports to regulate and issue licenses for financial services, including crypto, under its own laws. However, the international recognition and practical enforcement of these regulations within the disputed territory are limited.

  • Moroccan-Administered Areas: In areas under Moroccan control, any forthcoming Moroccan crypto regulations would theoretically apply. Morocco has traditionally maintained a ban on cryptocurrency transactions since 2017, but is actively moving towards legalization and regulation. A new regulatory framework is nearing adoption as of June 2025, aiming to balance financial stability with innovation.

  • Polisario Front/SADR-Administered Areas: The Sahrawi Arab Democratic Republic (SADR) has established its own financial authority, the Central Reserve Authority of Western Sahara, which purports to regulate and issue licenses for financial services, including crypto, under its own laws. However, the international recognition and practical enforcement of these regulations within the disputed territory are limited.

Landmark Laws

Forthcoming Moroccan Crypto Regulatory Framework
- Authority: Bank Al-Maghrib (BAM) and Moroccan Tax Administration (DGI)
- Date: Nearing adoption as of June 2025
- Summary: Morocco is in the process of finalizing a regulatory framework. This framework is being developed collaboratively by Bank Al-Maghrib (BAM) and the Moroccan Tax Administration (DGI). It aims to legalize cryptocurrency by 2025, moving away from the previous ban implemented in 2017 under foreign exchange regulations. The Finance Law of 2025 is anticipated to bring fiscal stability and incorporate provisions related to crypto taxation. The impact of this framework, once adopted, would be to transition from an outright prohibition to a regulated, taxable environment for crypto activities.

The Banking and Trust Act, 2017
- Authority: Central Reserve Authority of Western Sahara (SADR)
- Date: 2017
- Summary: The Central Reserve Authority of Western Sahara, established in 2017 by the SADR, claims to oversee the issuance and compliance supervision of various financial licenses, including those for crypto, under The Banking and Trust Act, 2017. The authority's mission is to position Western Sahara as an international financial hub by adhering to global compliance standards. However, the practical impact of this legislation is constrained by the SADR's limited international recognition and territorial control.

Forthcoming Moroccan Crypto Regulatory Framework
- Authority: Bank Al-Maghrib (BAM) and Moroccan Tax Administration (DGI)
- Date: Nearing adoption as of June 2025
- Summary: Morocco is in the process of finalizing a regulatory framework. This framework is being developed collaboratively by Bank Al-Maghrib (BAM) and the Moroccan Tax Administration (DGI). It aims to legalize cryptocurrency by 2025, moving away from the previous ban implemented in 2017 under foreign exchange regulations. The Finance Law of 2025 is anticipated to bring fiscal stability and incorporate provisions related to crypto taxation. The impact of this framework, once adopted, would be to transition from an outright prohibition to a regulated, taxable environment for crypto activities.

The Banking and Trust Act, 2017
- Authority: Central Reserve Authority of Western Sahara (SADR)
- Date: 2017
- Summary: The Central Reserve Authority of Western Sahara, established in 2017 by the SADR, claims to oversee the issuance and compliance supervision of various financial licenses, including those for crypto, under The Banking and Trust Act, 2017. The authority's mission is to position Western Sahara as an international financial hub by adhering to global compliance standards. However, the practical impact of this legislation is constrained by the SADR's limited international recognition and territorial control.

Considerations

  • Asset Classification: In the context of Morocco's proposed framework, cryptocurrencies are likely to be regarded as digital assets for taxation purposes once regulations are underway. Specific guidance on Decentralized Finance (DeFi) and Non-Fungible Tokens (NFTs) remains largely unclear.

  • Taxation: Morocco's proposed tax regime for crypto, expected to be implemented by 2025, includes tiered taxation:Capital Gains: Anticipated at 15-30% for crypto trading profits.Income Tax: Progressive rates from 10-38% for activities like mining and staking.Corporate Tax: 20-31% for businesses involved in crypto.Value-Added Tax (VAT) exemptions are being considered, but strict transaction reporting requirements are expected.The tax implications in SADR-controlled areas are less clear, though its financial licensing body suggests a framework for business operations.

  • Sovereignty and Enforcement: The core challenge is the contested sovereignty of Western Sahara. Under international law, Western Sahara is considered a non-self-governing territory, and Morocco's annexation is largely unrecognized. This means that while Moroccan laws might be enforced de facto in areas it controls, their legal standing across the entire territory is disputed. Conversely, the SADR's regulatory efforts face challenges in terms of international recognition and effective implementation beyond its de facto administered areas.

  • Foreign Exchange Controls: Morocco's initial ban on crypto in 2017 was rooted in foreign exchange regulations, and authorities have been investigating crypto-enabled property purchases to bypass these controls. This indicates a continued focus on controlling capital flows, which will likely persist even with legalization.

  • Asset Classification: In the context of Morocco's proposed framework, cryptocurrencies are likely to be regarded as digital assets for taxation purposes once regulations are underway. Specific guidance on Decentralized Finance (DeFi) and Non-Fungible Tokens (NFTs) remains largely unclear.

  • Taxation: Morocco's proposed tax regime for crypto, expected to be implemented by 2025, includes tiered taxation:Capital Gains: Anticipated at 15-30% for crypto trading profits.Income Tax: Progressive rates from 10-38% for activities like mining and staking.Corporate Tax: 20-31% for businesses involved in crypto.Value-Added Tax (VAT) exemptions are being considered, but strict transaction reporting requirements are expected.The tax implications in SADR-controlled areas are less clear, though its financial licensing body suggests a framework for business operations.

  • Sovereignty and Enforcement: The core challenge is the contested sovereignty of Western Sahara. Under international law, Western Sahara is considered a non-self-governing territory, and Morocco's annexation is largely unrecognized. This means that while Moroccan laws might be enforced de facto in areas it controls, their legal standing across the entire territory is disputed. Conversely, the SADR's regulatory efforts face challenges in terms of international recognition and effective implementation beyond its de facto administered areas.

  • Foreign Exchange Controls: Morocco's initial ban on crypto in 2017 was rooted in foreign exchange regulations, and authorities have been investigating crypto-enabled property purchases to bypass these controls. This indicates a continued focus on controlling capital flows, which will likely persist even with legalization.

Notes

  • Moroccan Regulatory Evolution: Morocco's shift from a ban to a regulated environment signifies a recognition of the growing interest in crypto (with an estimated 6 million Moroccans owning or using crypto in 2024 despite the ban) and a strategic move to prevent illicit activities and position itself as a fintech hub. The framework is being developed with technical assistance from the International Monetary Fund (IMF) and the World Bank.

  • Bitcoin Mining Project Controversy: A proposed wind-powered Bitcoin mining farm in Dakhla, within Moroccan-controlled Western Sahara, has been embroiled in controversy due to its location on disputed land. The project, led by Soluna Technologies, has reportedly stalled amid financial issues and criticism regarding the exploitation of resources in an occupied territory without the consent of the Sahrawi people. This exemplifies the practical difficulties and ethical concerns surrounding economic activities, including crypto, in the region.

  • Lack of Unified Authority: The fundamental issue remains the absence of a single, internationally recognized regulatory body for the entire territory. This means that any activity involving cryptocurrencies in Western Sahara carries inherent legal and political risks due to the fragmented and uncertain nature of governance.

  • Moroccan Regulatory Evolution: Morocco's shift from a ban to a regulated environment signifies a recognition of the growing interest in crypto (with an estimated 6 million Moroccans owning or using crypto in 2024 despite the ban) and a strategic move to prevent illicit activities and position itself as a fintech hub. The framework is being developed with technical assistance from the International Monetary Fund (IMF) and the World Bank.

  • Bitcoin Mining Project Controversy: A proposed wind-powered Bitcoin mining farm in Dakhla, within Moroccan-controlled Western Sahara, has been embroiled in controversy due to its location on disputed land. The project, led by Soluna Technologies, has reportedly stalled amid financial issues and criticism regarding the exploitation of resources in an occupied territory without the consent of the Sahrawi people. This exemplifies the practical difficulties and ethical concerns surrounding economic activities, including crypto, in the region.

  • Lack of Unified Authority: The fundamental issue remains the absence of a single, internationally recognized regulatory body for the entire territory. This means that any activity involving cryptocurrencies in Western Sahara carries inherent legal and political risks due to the fragmented and uncertain nature of governance.

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Full Analysis Report

Report on Retail Cryptocurrency Trading Status in Western Sahara

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 (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

Section: Retail_Trading_Status

1. Identified Current Status: Unclear

2. Detailed Narrative Explanation:

The status of retail cryptocurrency trading in Western Sahara is best described as 'Unclear' due to the territory's complex and disputed political situation, and the evolving regulatory landscape in Morocco, which administers a large portion of the territory. There is no distinct, functioning, and internationally recognized regulatory body for Western Sahara that has issued specific laws or guidelines on cryptocurrencies for the entire territory.

A. Influence of Moroccan Regulatory Stance:

For the majority of the population residing in the Moroccan-administered parts of Western Sahara, Moroccan law is de facto applicable. Morocco's stance on cryptocurrencies has been historically restrictive but is currently in a state of transition.

  • Historical Ban: In 2017, Moroccan authorities, including the Ministry of Economy and Finance, Bank Al-Maghrib (the central bank), and the Moroccan Capital Market Authority (AMMC), issued a joint statement banning cryptocurrency transactions. This ban cited risks such as lack of consumer protection, volatility, and use in illicit activities. The Exchange Office also specified that such transactions violate foreign exchange regulations and are subject to penalties.
  • Ongoing Shift Towards Regulation: Despite the ban, there's significant cryptocurrency adoption and peer-to-peer trading in Morocco. Recognizing this, Moroccan authorities have been working on a regulatory framework for crypto-assets.
    • In June 2022, Bank Al-Maghrib (BAM) announced plans for a cryptocurrency regulation bill, engaging with the IMF and World Bank for its development.
    • In late 2024 (November/December), the Governor of Bank Al-Maghrib, Abdellatif Jouahri, announced that a draft law to regulate crypto-assets was ready and in the adoption process. The aim is to balance innovation with risk management and user protection.
    • As of April 2025, the crypto draft law was reportedly with the Ministry of Economy and Finance for submission to a technical committee to oversee its adoption.
    • Some sources indicate that draft legislation in 2025 proposes licensing for exchanges under BAM supervision and that Morocco now "cautiously... permits some cryptocurrency trading through licensed platforms approved by Bank Al-Maghrib," though restrictions on commercial payments remain. However, another part of one of these same sources states, "Since 2017, all cryptocurrency trading has been prohibited under Morocco's foreign exchange regulations. While some peer-to-peer trading occurs discreetly, authorized platforms don't exist and penalties apply for any transactions." This highlights the ongoing ambiguity even within Morocco.

The timeline for the full implementation of this new regulatory framework in Morocco, and by extension its application in the Moroccan-administered parts of Western Sahara, is not yet definitive. This transitional phase contributes to the 'Unclear' status.

B. Sahrawi Arab Democratic Republic (SADR) Assertions:

The Polisario Front, which claims sovereignty over Western Sahara as the Sahrawi Arab Democratic Republic (SADR), has entities that purport to regulate financial activities, including cryptocurrencies, in the territory it controls or claims.

  • Sources linked to SADR interests mention a "Central Reserve Authority of Western Sahara" and a "Crypto Company Act 2020," suggesting a framework for crypto licensing. These entities claim to oversee the licensing and regulation of cryptocurrency activities.
  • However, the de facto control of most of Western Sahara's territory and population by Morocco, and the limited international recognition of SADR's governing institutions, make the practical enforceability and widespread applicability of such regulations highly uncertain. The economic activities in the region are predominantly controlled by the Moroccan government.

C. International Context and Geopolitical Complexity:

Western Sahara is a disputed territory. The United Nations lists it as a non-self-governing territory. This ongoing political conflict means there isn't a single, universally recognized governing and regulatory body for the entire territory. Financial regulations, therefore, are fragmented and their applicability depends on which authority exerts control over a specific area and how international actors view that control. The European Union, for example, has had legal challenges regarding the applicability of its agreements with Morocco to Western Sahara, emphasizing the territory's "separate and distinct" status and the need for the consent of its people.

D. Lack of Specific, Verifiable Information for Retail Users in Western Sahara:

While there is information on Morocco's evolving crypto regulations and SADR's asserted regulatory framework, specific, verifiable information on how these directly translate to the ability of individual retail traders within Western Sahara to legally buy, sell, and hold cryptocurrencies, and the precise KYC/AML requirements they face from accessible platforms, remains scarce and often conflated with the Moroccan situation without explicit reference to the unique territorial context.

The development of a wind farm project in Dakhla (a city in Moroccan-administered Western Sahara) intended for Bitcoin mining further illustrates the complex interplay of economic interests and the disputed status, but does not clarify the retail trading situation.

Conclusion of Narrative:

Given that:
1. Moroccan law, which is de facto applicable in large parts of Western Sahara, is itself in a state of significant transition regarding cryptocurrencies (moving from a ban towards a regulated environment, the full scope and enforcement of which is not yet clear).
2. The asserted regulatory framework by the SADR has limited practical enforceability over the majority of the territory and population.
3. There is a lack of specific, unified, and internationally recognized financial regulations pertaining to retail cryptocurrency trading for Western Sahara as a whole.

The most accurate status is 'Unclear'. Individual residents may be subject to the evolving Moroccan framework, face a de facto unregulated environment, or encounter conflicting assertions of regulatory authority, depending on their specific location and the platforms they attempt to use. Until Morocco finalizes and fully implements its crypto-asset regulations and their applicability to Western Sahara is clarified, or until there is a clear, enforceable regulatory regime established by a recognized authority for Western Sahara, the situation will remain ambiguous for retail crypto traders.

3. Specific, Relevant Text Excerpts:

  • Regarding Moroccan influence and evolving regulation:

    • "In 2017, the Moroccan central bank known as the Bank Al-Maghrib (BAM), cited significant risks for users when it placed a permanent ban. However, in 2022, the Moroccan government exhibited strong efforts at creating a regulatory framework for crypto business in the country." (EMURGO Africa)
    • "The Governor of Bank Al-Maghrib (BAM), Abdellatif Jouahri, has announced that a legal framework regulating crypto-assets in Morocco is nearing adoption. The aim of this framework is to manage the use of crypto-assets while encouraging financial innovation." (Morocco World News, Dec 2024)
    • "Cautiously, Morocco has modified its position slightly and now permits some cryptocurrency trading through licensed platforms approved by Bank Al-Maghrib. While this is a deviation from the blanket ban issued in 2017, restrictions still apply preventing the use of digital assets for commercial payments or settlements." (Coinfomania, June 2025)
    • However, the same Coinfomania article also states in a Q&A: "Since 2017, all cryptocurrency trading has been prohibited under Morocco's foreign exchange regulations. While some peer-to-peer trading occurs discreetly, authorized platforms don't exist and penalties apply for any transactions." This contradiction highlights the unclear current enforcement.
    • "At Gitex Africa 2025, the General Director of Bank Al Maghrib, Mr. Abderrahim Bouazza noted that the crypto draft law is now at the Ministry of Economy and Finance, who will then submit it to a technical committee to oversee its adoption process." (LARA on the Block, April 2025)
    • "The Ministry of Economy and Finance, Bank Al-Maghrib and the Moroccan Capital Market Authority draw public attention to the risks associated with the use of virtual currencies..." (Bank Al-Maghrib, undated but referencing the 2017 ban)

  • Regarding Western Sahara's disputed status and SADR assertions:

    • "The state of cryptocurrency in Western Sahara is complex. Western Sahara is the largest UN-recognized, non-governing territory, currently under the territorial control of Morocco, despite ongoing movement for independent sovereignty." (Freeman Law)
    • "The regulatory authority for cryptocurrency in Western Sahara is the Central Reserve Authority of Western Sahara. This body oversees the licensing and regulation of cryptocurrency activities within the region." (Tetra Consultants, referencing SADR institutions)
    • "The Crypto Company Act 2020." (Sahrawi Arab Democratic Republic Financial Licenses, listing it as a regulatory law)
    • "The region's economic activities are predominantly controlled by the Moroccan government... the investment climate is hindered by the territory's disputed status..." (KnowYourCountry)
    • "Under international law, Western Sahara is not a legal part of Morocco, and it remains under the international laws of military occupation." (Wikipedia, citing sources on political status)

4. Direct, Accessible URL Links to Sources:

  1. Current time information in EH (Not directly relevant to regulation but used by the search tool): https://www.google.com/search?q=time+in+EH
  2. Freeman Law - Western Sahara and Cryptocurrency: https://freemanlaw.com/western-sahara-cryptocurrency-laws/
  3. Coinfomania - Cryptocurrency Regulations in Morocco (June 2025): https://coinfomania.com/cryptocurrency-regulations-in-morocco/
  4. EMURGO Africa - Morocco's Crypto Thrives Amid Regulation Uncertainty (Feb 2024): https://emurgo.africa/moroccos-crypto-thrives-amid-regulation-uncertainty/
  5. Morocco World News - Jouahri: Morocco’s New Crypto Framework to Balance Regulation, Innovation (Dec 2024): https://www.moroccoworldnews.com/2024/12/369888/jouahri-moroccos-new-crypto-framework-to-balance-regulation-innovation
  6. African Law & Business - Moroccan central bank plans to legalise cryptoassets (Nov 2024): https://www.africanlawbusiness.com/news/19085-moroccan-central-bank-plans-to-legalise-cryptoassets
  7. CoinStats - Cryptocurrency Regulations in Morocco: https://coinstats.app/blog/cryptocurrency-regulations-in-morocco/ (Content appears very similar to)
  8. Tetra Consultants - Western Sahara Crypto License: https://www.tetraconsultants.com/registrations/crypto-license/western-sahara/
  9. LARA on the Block - Morocco's Bank Al Maghrib Director says crypto regulation now at Ministry of Economy to oversee adoption process (April 2025): https://laraontheblock.com/moroccos-bank-al-maghrib-director-says-crypto-regulation-now-at-ministry-of-economy-to-oversee-adoption-process/
  10. Digital Policy Alert - DPA Digital Digest: Morocco [2025 Edition] (April 2025): https://digitalpolicyalert.org/countries/morocco/notes/2025-04-09
  11. The Arab Weekly (AW) - Moroccan Central Bank preparing law to allow cryptocurrencies (Nov 2024): https://thearabweekly.com/moroccan-central-bank-preparing-law-allow-cryptocurrencies
  12. Sahrawi Arab Democratic Republic Financial Licenses - About Us (April 2025): https://www.sadr-financiallicenses.com/about-us
  13. Digital Watch Observatory - Draft crypto law signals shift in Morocco’s policy (Nov 2024): https://dig.watch/updates/draft-crypto-law-signals-shift-in-moroccos-policy
  14. MIPA Institute - The Missing Block: Bitcoin & Blockchain policy in Morocco (July 2022): https://mipainstitute.org/the-missing-block-bitcoin-blockchain-policy-in-morocco/
  15. Walaw - Morocco’s Shift from Cryptocurrency Ban to Regulation (Dec 2024): https://www.walaw.co/moroccos-shift-from-cryptocurrency-ban-to-regulation/
  16. MoroccoLatestNews.com - Morocco Moves to Regulate Cryptocurrencies with Draft Law (Nov 2024): https://moroccolatestnews.com/morocco-moves-to-regulate-cryptocurrencies-with-draft-law/
  17. SADR Management and Advisory Corporation - Crypto license - Western Sahara: https://www.sadr-management.com/crypto-license-western-sahara
  18. Bank Al-Maghrib - Virtual currency: https://www.bkam.ma/en/FAQ/FAQ-LIST/Virtual-currency
  19. KnowYourCountry - Western Sahara: https://www.knowyourcountry.com/western-sahara
  20. European Council on Foreign Relations (ECFR) - Western Sahara, Morocco, and the EU: How good law makes good politics (Sept 2021): https://ecfr.eu/article/western-sahara-morocco-and-the-eu-how-good-law-makes-good-politics/
  21. International Monetary Fund (IMF) - Africa’s Growing Crypto Market Needs Better Regulations (Nov 2022): https://www.imf.org/en/Blogs/Articles/2022/11/21/chart-of-the-week-112222-africa-crypto (Provides general context for Africa, not specific to Western Sahara)
  22. Wikipedia - Legality of cryptocurrency by country or territory: https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory (General reference)
  23. CURIA - Documents (Western Sahara Campaign UK, Jan 2018): https://curia.europa.eu/juris/document/document.jsf?text=&docid=198539&pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&cid=208003 (Legal context of EU-Morocco agreements regarding Western Sahara)
  24. ResearchGate - Cryptocurrency regulation in Africa... (Jan 2025): https://www.researchgate.net/publication/388302099_Cryptocurrency_regulation_in_Africa_advantages_motivation_regulatory_models_challenges_consequences_and_principles_vs_rules-based_regulation (General African context)
  25. Spanish Yearbook of International Law - Morocco, occupying power of Western Sahara... (Undated): https://www.sybil.es/index.php/sybil/article/view/706/619 (Political and legal context)
  26. Security Council Report - Western Sahara, April 2025 Monthly Forecast (March 2025): https://www.securitycouncilreport.org/monthly-forecast/2025-04/western-sahara-18.php (Political context)
  27. Wikipedia - Political status of Western Sahara: https://en.wikipedia.org/wiki/Political_status_of_Western_Sahara
  28. Foreign Policy In Focus - Morocco and Western Sahara (Undated, appears older but provides historical context): https://fpif.org/morocco_and_western_sahara/

Report on Retail Cryptocurrency Trading Status in Western Sahara

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 (e.g., KYC/AML requirements imposed on platforms, general warnings issued).

Section: Retail_Trading_Status

1. Identified Current Status: Unclear

2. Detailed Narrative Explanation:

The status of retail cryptocurrency trading in Western Sahara is best described as 'Unclear' due to the territory's complex and disputed political situation, and the evolving regulatory landscape in Morocco, which administers a large portion of the territory. There is no distinct, functioning, and internationally recognized regulatory body for Western Sahara that has issued specific laws or guidelines on cryptocurrencies for the entire territory.

A. Influence of Moroccan Regulatory Stance:

For the majority of the population residing in the Moroccan-administered parts of Western Sahara, Moroccan law is de facto applicable. Morocco's stance on cryptocurrencies has been historically restrictive but is currently in a state of transition.

  • Historical Ban: In 2017, Moroccan authorities, including the Ministry of Economy and Finance, Bank Al-Maghrib (the central bank), and the Moroccan Capital Market Authority (AMMC), issued a joint statement banning cryptocurrency transactions. This ban cited risks such as lack of consumer protection, volatility, and use in illicit activities. The Exchange Office also specified that such transactions violate foreign exchange regulations and are subject to penalties.
  • Ongoing Shift Towards Regulation: Despite the ban, there's significant cryptocurrency adoption and peer-to-peer trading in Morocco. Recognizing this, Moroccan authorities have been working on a regulatory framework for crypto-assets.
    • In June 2022, Bank Al-Maghrib (BAM) announced plans for a cryptocurrency regulation bill, engaging with the IMF and World Bank for its development.
    • In late 2024 (November/December), the Governor of Bank Al-Maghrib, Abdellatif Jouahri, announced that a draft law to regulate crypto-assets was ready and in the adoption process. The aim is to balance innovation with risk management and user protection.
    • As of April 2025, the crypto draft law was reportedly with the Ministry of Economy and Finance for submission to a technical committee to oversee its adoption.
    • Some sources indicate that draft legislation in 2025 proposes licensing for exchanges under BAM supervision and that Morocco now "cautiously... permits some cryptocurrency trading through licensed platforms approved by Bank Al-Maghrib," though restrictions on commercial payments remain. However, another part of one of these same sources states, "Since 2017, all cryptocurrency trading has been prohibited under Morocco's foreign exchange regulations. While some peer-to-peer trading occurs discreetly, authorized platforms don't exist and penalties apply for any transactions." This highlights the ongoing ambiguity even within Morocco.

The timeline for the full implementation of this new regulatory framework in Morocco, and by extension its application in the Moroccan-administered parts of Western Sahara, is not yet definitive. This transitional phase contributes to the 'Unclear' status.

B. Sahrawi Arab Democratic Republic (SADR) Assertions:

The Polisario Front, which claims sovereignty over Western Sahara as the Sahrawi Arab Democratic Republic (SADR), has entities that purport to regulate financial activities, including cryptocurrencies, in the territory it controls or claims.

  • Sources linked to SADR interests mention a "Central Reserve Authority of Western Sahara" and a "Crypto Company Act 2020," suggesting a framework for crypto licensing. These entities claim to oversee the licensing and regulation of cryptocurrency activities.
  • However, the de facto control of most of Western Sahara's territory and population by Morocco, and the limited international recognition of SADR's governing institutions, make the practical enforceability and widespread applicability of such regulations highly uncertain. The economic activities in the region are predominantly controlled by the Moroccan government.

C. International Context and Geopolitical Complexity:

Western Sahara is a disputed territory. The United Nations lists it as a non-self-governing territory. This ongoing political conflict means there isn't a single, universally recognized governing and regulatory body for the entire territory. Financial regulations, therefore, are fragmented and their applicability depends on which authority exerts control over a specific area and how international actors view that control. The European Union, for example, has had legal challenges regarding the applicability of its agreements with Morocco to Western Sahara, emphasizing the territory's "separate and distinct" status and the need for the consent of its people.

D. Lack of Specific, Verifiable Information for Retail Users in Western Sahara:

While there is information on Morocco's evolving crypto regulations and SADR's asserted regulatory framework, specific, verifiable information on how these directly translate to the ability of individual retail traders within Western Sahara to legally buy, sell, and hold cryptocurrencies, and the precise KYC/AML requirements they face from accessible platforms, remains scarce and often conflated with the Moroccan situation without explicit reference to the unique territorial context.

The development of a wind farm project in Dakhla (a city in Moroccan-administered Western Sahara) intended for Bitcoin mining further illustrates the complex interplay of economic interests and the disputed status, but does not clarify the retail trading situation.

Conclusion of Narrative:

Given that:
1. Moroccan law, which is de facto applicable in large parts of Western Sahara, is itself in a state of significant transition regarding cryptocurrencies (moving from a ban towards a regulated environment, the full scope and enforcement of which is not yet clear).
2. The asserted regulatory framework by the SADR has limited practical enforceability over the majority of the territory and population.
3. There is a lack of specific, unified, and internationally recognized financial regulations pertaining to retail cryptocurrency trading for Western Sahara as a whole.

The most accurate status is 'Unclear'. Individual residents may be subject to the evolving Moroccan framework, face a de facto unregulated environment, or encounter conflicting assertions of regulatory authority, depending on their specific location and the platforms they attempt to use. Until Morocco finalizes and fully implements its crypto-asset regulations and their applicability to Western Sahara is clarified, or until there is a clear, enforceable regulatory regime established by a recognized authority for Western Sahara, the situation will remain ambiguous for retail crypto traders.

3. Specific, Relevant Text Excerpts:

  • Regarding Moroccan influence and evolving regulation:

    • "In 2017, the Moroccan central bank known as the Bank Al-Maghrib (BAM), cited significant risks for users when it placed a permanent ban. However, in 2022, the Moroccan government exhibited strong efforts at creating a regulatory framework for crypto business in the country." (EMURGO Africa)
    • "The Governor of Bank Al-Maghrib (BAM), Abdellatif Jouahri, has announced that a legal framework regulating crypto-assets in Morocco is nearing adoption. The aim of this framework is to manage the use of crypto-assets while encouraging financial innovation." (Morocco World News, Dec 2024)
    • "Cautiously, Morocco has modified its position slightly and now permits some cryptocurrency trading through licensed platforms approved by Bank Al-Maghrib. While this is a deviation from the blanket ban issued in 2017, restrictions still apply preventing the use of digital assets for commercial payments or settlements." (Coinfomania, June 2025)
    • However, the same Coinfomania article also states in a Q&A: "Since 2017, all cryptocurrency trading has been prohibited under Morocco's foreign exchange regulations. While some peer-to-peer trading occurs discreetly, authorized platforms don't exist and penalties apply for any transactions." This contradiction highlights the unclear current enforcement.
    • "At Gitex Africa 2025, the General Director of Bank Al Maghrib, Mr. Abderrahim Bouazza noted that the crypto draft law is now at the Ministry of Economy and Finance, who will then submit it to a technical committee to oversee its adoption process." (LARA on the Block, April 2025)
    • "The Ministry of Economy and Finance, Bank Al-Maghrib and the Moroccan Capital Market Authority draw public attention to the risks associated with the use of virtual currencies..." (Bank Al-Maghrib, undated but referencing the 2017 ban)

  • Regarding Western Sahara's disputed status and SADR assertions:

    • "The state of cryptocurrency in Western Sahara is complex. Western Sahara is the largest UN-recognized, non-governing territory, currently under the territorial control of Morocco, despite ongoing movement for independent sovereignty." (Freeman Law)
    • "The regulatory authority for cryptocurrency in Western Sahara is the Central Reserve Authority of Western Sahara. This body oversees the licensing and regulation of cryptocurrency activities within the region." (Tetra Consultants, referencing SADR institutions)
    • "The Crypto Company Act 2020." (Sahrawi Arab Democratic Republic Financial Licenses, listing it as a regulatory law)
    • "The region's economic activities are predominantly controlled by the Moroccan government... the investment climate is hindered by the territory's disputed status..." (KnowYourCountry)
    • "Under international law, Western Sahara is not a legal part of Morocco, and it remains under the international laws of military occupation." (Wikipedia, citing sources on political status)

4. Direct, Accessible URL Links to Sources:

  1. Current time information in EH (Not directly relevant to regulation but used by the search tool): https://www.google.com/search?q=time+in+EH
  2. Freeman Law - Western Sahara and Cryptocurrency: https://freemanlaw.com/western-sahara-cryptocurrency-laws/
  3. Coinfomania - Cryptocurrency Regulations in Morocco (June 2025): https://coinfomania.com/cryptocurrency-regulations-in-morocco/
  4. EMURGO Africa - Morocco's Crypto Thrives Amid Regulation Uncertainty (Feb 2024): https://emurgo.africa/moroccos-crypto-thrives-amid-regulation-uncertainty/
  5. Morocco World News - Jouahri: Morocco’s New Crypto Framework to Balance Regulation, Innovation (Dec 2024): https://www.moroccoworldnews.com/2024/12/369888/jouahri-moroccos-new-crypto-framework-to-balance-regulation-innovation
  6. African Law & Business - Moroccan central bank plans to legalise cryptoassets (Nov 2024): https://www.africanlawbusiness.com/news/19085-moroccan-central-bank-plans-to-legalise-cryptoassets
  7. CoinStats - Cryptocurrency Regulations in Morocco: https://coinstats.app/blog/cryptocurrency-regulations-in-morocco/ (Content appears very similar to)
  8. Tetra Consultants - Western Sahara Crypto License: https://www.tetraconsultants.com/registrations/crypto-license/western-sahara/
  9. LARA on the Block - Morocco's Bank Al Maghrib Director says crypto regulation now at Ministry of Economy to oversee adoption process (April 2025): https://laraontheblock.com/moroccos-bank-al-maghrib-director-says-crypto-regulation-now-at-ministry-of-economy-to-oversee-adoption-process/
  10. Digital Policy Alert - DPA Digital Digest: Morocco [2025 Edition] (April 2025): https://digitalpolicyalert.org/countries/morocco/notes/2025-04-09
  11. The Arab Weekly (AW) - Moroccan Central Bank preparing law to allow cryptocurrencies (Nov 2024): https://thearabweekly.com/moroccan-central-bank-preparing-law-allow-cryptocurrencies
  12. Sahrawi Arab Democratic Republic Financial Licenses - About Us (April 2025): https://www.sadr-financiallicenses.com/about-us
  13. Digital Watch Observatory - Draft crypto law signals shift in Morocco’s policy (Nov 2024): https://dig.watch/updates/draft-crypto-law-signals-shift-in-moroccos-policy
  14. MIPA Institute - The Missing Block: Bitcoin & Blockchain policy in Morocco (July 2022): https://mipainstitute.org/the-missing-block-bitcoin-blockchain-policy-in-morocco/
  15. Walaw - Morocco’s Shift from Cryptocurrency Ban to Regulation (Dec 2024): https://www.walaw.co/moroccos-shift-from-cryptocurrency-ban-to-regulation/
  16. MoroccoLatestNews.com - Morocco Moves to Regulate Cryptocurrencies with Draft Law (Nov 2024): https://moroccolatestnews.com/morocco-moves-to-regulate-cryptocurrencies-with-draft-law/
  17. SADR Management and Advisory Corporation - Crypto license - Western Sahara: https://www.sadr-management.com/crypto-license-western-sahara
  18. Bank Al-Maghrib - Virtual currency: https://www.bkam.ma/en/FAQ/FAQ-LIST/Virtual-currency
  19. KnowYourCountry - Western Sahara: https://www.knowyourcountry.com/western-sahara
  20. European Council on Foreign Relations (ECFR) - Western Sahara, Morocco, and the EU: How good law makes good politics (Sept 2021): https://ecfr.eu/article/western-sahara-morocco-and-the-eu-how-good-law-makes-good-politics/
  21. International Monetary Fund (IMF) - Africa’s Growing Crypto Market Needs Better Regulations (Nov 2022): https://www.imf.org/en/Blogs/Articles/2022/11/21/chart-of-the-week-112222-africa-crypto (Provides general context for Africa, not specific to Western Sahara)
  22. Wikipedia - Legality of cryptocurrency by country or territory: https://en.wikipedia.org/wiki/Legality_of_cryptocurrency_by_country_or_territory (General reference)
  23. CURIA - Documents (Western Sahara Campaign UK, Jan 2018): https://curia.europa.eu/juris/document/document.jsf?text=&docid=198539&pageIndex=0&doclang=EN&mode=lst&dir=&occ=first&part=1&cid=208003 (Legal context of EU-Morocco agreements regarding Western Sahara)
  24. ResearchGate - Cryptocurrency regulation in Africa... (Jan 2025): https://www.researchgate.net/publication/388302099_Cryptocurrency_regulation_in_Africa_advantages_motivation_regulatory_models_challenges_consequences_and_principles_vs_rules-based_regulation (General African context)
  25. Spanish Yearbook of International Law - Morocco, occupying power of Western Sahara... (Undated): https://www.sybil.es/index.php/sybil/article/view/706/619 (Political and legal context)
  26. Security Council Report - Western Sahara, April 2025 Monthly Forecast (March 2025): https://www.securitycouncilreport.org/monthly-forecast/2025-04/western-sahara-18.php (Political context)
  27. Wikipedia - Political status of Western Sahara: https://en.wikipedia.org/wiki/Political_status_of_Western_Sahara
  28. Foreign Policy In Focus - Morocco and Western Sahara (Undated, appears older but provides historical context): https://fpif.org/morocco_and_western_sahara/