Stablecoin issuer / redeemer in Angola

No specific classification: Stablecoins are not specifically classified as e-money, payment tokens, or securities under Angolan law because there is no dedicated stablecoin regulation.

Aviso n.º 03/2018 do Banco Nacional de Angola (Notice No. 03/2018 of the National Bank of Angola) - 27 March 2018:

Implication for Stablecoins: While stablecoins are not explicitly named, the broad prohibition against "cryptocurrencies" (moedas virtuais) is generally understood to include stablecoins. This effectively shuts out traditional financial institutions from interacting with stablecoins.

The requirement for stablecoin issuers to be licensed as Electronic Money Institutions (EMIs) under the Payment Services Law (Lei n.º 05/2018) may have changed due to recent legislative developments in Angola.

No specific requirements for stablecoins: As stablecoins are not regulated or recognized, there are no specific reserve requirements for them in Angola.

No specific rules for stablecoins: There are no specific legal provisions regarding redemption rights for stablecoin holders in Angola due to the lack of regulation. Any redemption would depend solely on the terms and conditions set by the private issuer, without regulatory backing.

Notice No. 03/2019: Prohibited Angolan financial institutions (banks, payment service providers, etc.) from carrying out any transactions involving virtual assets, holding them, or providing services related to them.

Notice No. 04/2018: Warned the public about the risks associated with virtual currencies, stating that they are not legal tender, are not issued or guaranteed by the BNA, and are not regulated by the BNA or any other Angolan entity.

BNA's Prohibitions: The most significant "enforcement" has been the BNA's direct prohibition on financial institutions from engaging with crypto assets (Notice No. 03/2019). This is a preventative regulatory action rather than a reactive enforcement against a specific violation.

Lei n.º 5/20, de 27 de Janeiro – Lei sobre a Prevenção e Combate ao Branqueamento de Capitais, Financiamento do Terrorismo e Proliferação de Armas de Destruição em Massa (Law No. 5/20, of January 27 – Law on the Prevention and Combat of Money Laundering, Financing of Terrorism and Proliferation of Weapons of Mass Destruction).

Identification and Verification:

Risk-Based Approach: Apply CDD measures on a risk-sensitive basis. More intense measures should be applied to higher-risk situations (e.g., complex transactions, non-face-to-face relationships, clients from high-risk jurisdictions, transactions involving large sums).

Politically Exposed Persons (PEPs): Implement specific procedures to determine if a customer or beneficial owner is a PEP, and apply enhanced CDD (ECDD) measures, including senior management approval for establishing or continuing relationships with PEPs, and reasonable measures to establish the source of wealth and funds.

Sanctions Screening: Screen clients against national and international sanctions lists (e.g., UN Security Council sanctions).

Ongoing Monitoring: Continuously monitor the business relationship and transactions to ensure consistency with the institution's knowledge of the customer, their business, risk profile, and, where necessary, the source of funds.

Obligation to Report: Any transaction, attempted transaction, or activity that raises suspicion of money laundering, terrorist financing, or proliferation financing must be reported.

Promptness: Reports must be made promptly, typically within a few days of forming a suspicion.

No Tipping-Off: Reporting entities and their employees are prohibited from disclosing to the customer or third parties that an STR is being or has been filed.

Immunity: Reporting in good faith provides protection from legal liability.

Customer Identification Records: All documents and information obtained during the CDD process (e.g., copies of identification documents, business registration documents, beneficial ownership information).

Transaction Records: Details of all financial transactions, including amounts, currencies, dates, parties involved, and any specific notes or instructions.

STRs and Related Information: Copies of all suspicious transaction reports filed and any internal analysis or documentation supporting the suspicion.

Duration: Records must typically be kept for a minimum of five to seven years after the business relationship has ended or after the date of an occasional transaction.

Unidade de Informação Financeira (UIF) – Financial Intelligence Unit:

Technology-Specific CDD: For VASPs, this would include verifying wallet ownership where practical and maintaining transaction traceability.