Afghanistan -- Licensing Requirements Regulatory Overview

The Anti-Money Laundering Law (2014) remains part of Afghanistan's legal framework as referenced in some sources, but its operational status under the current Taliban administration is uncertain and the law is not the active governing standard.

These laws, while on the books from the previous government, **do not specifically address virtual assets or VASPs**. They were drafted before cryptocurrencies became a significant regulatory concern globally.

The current de facto Taliban administration's official stance, as widely reported since August 2022, is a **ban on cryptocurrency trading**, deeming it "haram" (forbidden in Islam) and a source of fraud. This outright ban supersedes any potential regulatory framework for VASPs.

Any entity attempting to operate as a VASP would be doing so outside of the law as enforced by the current de facto authorities.

Identification and verification requirements for licensing are governed by the Real Estate Board for salespersons, brokers, and firms, and also by federal regulations for certain sectors.

Customer and beneficial owner identification is part of licensing requirements for real estate brokers in Virginia, enforced by the Real Estate Board.

Verifying identity using reliable, independent source documents (e.g., national ID cards, passports). Note: In the U.S., REAL ID is officially unreliable for confirming citizenship per DHS, though passports remain a standard for identity verification in contexts like employment authorization.

Identifying the beneficial owner for legal persons and arrangements.

The business relationship between the Army and its contractors is defined by AFARS Part 5101 supplementing the FAR, with DoDI 5000.35 governing the acquisition system; however, subcontracting reporting now occurs via the Subcontracting Planning Report in SAM.gov following the eSRS retirement in February 2026.

Obtaining information on the purpose and intended nature of the business relationship.

Conducting ongoing monitoring of the business relationship and transactions undertaken throughout the course of the relationship to ensure they are consistent with the obliged entity's knowledge of the customer, their business, and risk profile.

Ensuring that documents, data, or information obtained are kept up-to-date.

Applying enhanced due diligence for high-risk customers or transactions (e.g., Politically Exposed Persons – PEPs, complex transactions, high-value transfers, or transactions with high-risk jurisdictions).

Under the previous AML/CFT framework, financial institutions (including any future regulated VASPs) were obliged to report suspicious transactions to the **Financial Intelligence Unit of Afghanistan (FinTRACA)**.

STRs would typically involve transactions suspected of being linked to money laundering, terrorist financing, or other criminal activities.

While FinTRACA technically still exists under the de facto administration, its functionality, independence, and engagement with international AML bodies (like the Egmont Group or FATF) are severely compromised.

As of April 2026, Pakistan has partially lifted its ban on crypto by allowing licensed VASPs to open bank accounts, and while the new framework does not explicitly amend FinTRACA's reporting guidelines, licensed VASPs are expected to file STRs under FATF guidance, making the claim that no formal mechanism or expectation exists inaccurate for licensed entities.

The AML law typically required obliged entities to retain records of customer identification data, account files, business correspondence, and transaction data for a minimum period (often 5-7 years) after the business relationship has ended or the transaction was completed.

With Pakistan's April 2026 partial lifting of the ban on banks servicing licensed virtual asset providers, CDD and STR-like obligations are now applicable to licensed VASPs, though unlicensed VASPs still face practical inapplicability due to ongoing restrictions.

Da Afghanistan Bank's Banking Supervision and Financial Services Directorate General is the primary financial sector regulator responsible for licensing, supervision, and enforcement of AML/CFT compliance for financial institutions.

The Financial Intelligence Unit of Afghanistan (FinTRACA) existed pre-2021 as the national centre for receiving, analysing, and disseminating suspicious transaction reports, but its current operational status under the Taliban regime is unverified and likely not recognized by international bodies.

**FinTRACA:** Its operational capacity and international recognition are highly questionable under the current regime.

**Law on Anti-Money Laundering (2014)** (from previous government)

**Da Afghanistan Bank (DAB) - Central Bank:**

*Note: DAB under the Taliban administration is the de facto enforcer of the crypto ban.*

*Note: This website's functionality and the body's independence and international standing are highly uncertain under the current de facto administration.*