Central African Republic

**Law No. 22.006 of April 27, 2022, on the Regulation of Cryptocurrencies in the Central African Republic:**

The 2022 law initially made Bitcoin legal tender in Central African Republic, but was later amended to revoke Bitcoin's legal tender status, while subsequent legislation enabled tokenization of land and natural resources.

It mandates that all virtual asset activities, including those carried out by VASPs, must comply with national and international AML/CFT standards. It establishes a requirement for licensing and supervision of VASPs.

While it creates the framework, it generally defers to further decrees or existing AML/CFT laws for specific requirements.

**BEAC Regulation No. 01/17/CEMAC/UMAC/CM of March 30, 2017, on the Prevention and Suppression of Money Laundering and Terrorist Financing in the CEMAC Zone:**

As a member of the Economic and Monetary Community of Central Africa (CEMAC), CAR is bound by regional regulations issued by the Banque des États de l'Afrique Centrale (BEAC).

This regulation provides the comprehensive AML/CFT framework for financial institutions within the CEMAC zone. While it predates the explicit regulation of VASPs, the CAR's 2022 crypto law implies that VASPs should adhere to the same stringent AML/CFT requirements as traditional financial institutions, as per FATF Recommendation 15.

This regulation covers customer due diligence, suspicious transaction reporting, and record-keeping obligations for all regulated entities.

**Law No. 00-010 of May 8, 2000, on Money Laundering and Terrorist Financing:**

This is the general national AML/CFT law in CAR. While the BEAC regional regulation often takes precedence for financial institutions, this law provides the overarching legal basis for combating financial crime at a national level.

Collecting and verifying the identity of customers (natural and legal persons) using reliable, independent source documents, data, or information. This includes full name, date of birth, nationality, physical address, and identification numbers (e.g., passport, national ID card).

For legal entities, this includes verifying the legal form, name, address, directors, and beneficial owners.

**Understanding the Nature of Business:** Understanding the purpose and intended nature of the business relationship.

**Ultimate Beneficial Ownership (UBO):** Identifying and taking reasonable measures to verify the identity of the beneficial owner(s) of customers, especially for legal persons and arrangements.

**Ongoing Monitoring:** Continuously monitoring the business relationship and transactions undertaken throughout the course of the relationship to ensure they are consistent with the VASP's knowledge of the customer, their business, and risk profile.

**Enhanced Due Diligence (EDD):** Applying enhanced measures for higher-risk categories, such as politically exposed persons (PEPs), cross-border correspondent relationships, or transactions involving high-risk jurisdictions or products.

**Source of Funds/Wealth:** For high-risk clients or large transactions, inquiring about the source of funds or wealth.

**Obligation to Report:** VASPs are obligated to report any suspicious transactions, regardless of the amount involved, to the national Financial Intelligence Unit (FIU).

**Reporting Body:** The national FIU in the Central African Republic is the **Cellule Nationale de Traitement des Informations Financières (CENTIF)**.

Reports must be made promptly when a VASP knows, suspects, or has reasonable grounds to suspect that funds are the proceeds of a criminal activity or are related to terrorist financing.

Tipping-off is strictly prohibited, meaning VASPs must not inform the customer or any third party that an STR has been filed.

**CDD Information:** All documents and information obtained during the CDD process (identification documents, verification records).

**Transaction Records:** Records of all transactions, including sender and recipient information, amounts, dates, and types of virtual assets involved.

**STRs:** Copies of all suspicious transaction reports filed.

**Duration:** Records must generally be kept for a minimum of **five (5) years** after the business relationship has ended or after the date of the transaction.

**National Agency for the Regulation of Virtual Assets (ANRVA):** Law No. 22.001 mandated the creation of a "national agency for the regulation of virtual assets." While its establishment has been reported, details on its full operational capacity, staffing, and public-facing functions remain limited. It is intended to be the primary national regulator for crypto activities.

The Law No. 22.006 of April 27, 2022, provides for the establishment of a national body responsible for the regulation, supervision, and licensing of virtual asset service providers. This entity, once fully operational, will be the primary authority for crypto-specific compliance.

*Note: As of now, the full operationalization and specific structure of this agency are still developing.*

**Cellule Nationale de Traitement des Informations Financières (CENTIF):**

**Role:** The FIU responsible for receiving, analyzing, and disseminating suspicious transaction reports. CENTIF plays a crucial role in the operational AML/CFT framework.

**Commission Bancaire de l'Afrique Centrale (COBAC):**

**Role:** The banking supervisory body for the CEMAC zone, which includes CAR. COBAC oversees prudential regulation for traditional financial institutions. While not directly supervising VASPs *yet*, its regional AML/CFT directives (like the BEAC Regulation) apply, and it may play an increasing role in broader financial stability aspects related to virtual assets.

**Banque des États de l'Afrique Centrale (BEAC):** The regional central bank for the CEMAC zone (which includes CAR). BEAC is the most significant challenge to CAR's crypto adoption, as it controls monetary policy and banking supervision in the region and has issued a directive banning crypto.

**Role:** The central bank for the CEMAC zone. BEAC is responsible for monetary policy and issuing the regional AML/CFT regulations that impact all financial institutions, including, by extension, VASPs under the CAR's crypto law.

**Evolving Landscape:** The regulatory environment for virtual assets in CAR is dynamic and still developing. VASPs should monitor official pronouncements and new decrees closely.

**FATF Standards:** Given CAR's commitment to international AML/CFT standards and its participation in regional bodies that adhere to FATF recommendations, VASPs should align their practices with the latest FATF guidance on virtual assets.

**Sanctions Compliance:** VASPs must also comply with national and international sanctions regimes.

**National Level (CAR): Comprehensive (in intent) and embrace:** The CAR government has officially embraced cryptocurrencies, particularly Bitcoin, and has laid down a legal framework intended to regulate their use. It aims for a comprehensive system covering legal tender, tokenization, and a digital economy.

**Regional Level (CEMAC/BEAC): Ban:** However, the country is part of the Economic and Monetary Community of Central Africa (CEMAC) and relies on its regional central bank, the Banque des États de l'Afrique Centrale (BEAC). BEAC has explicitly **prohibited** cryptocurrencies within the entire CEMAC zone, creating a direct conflict with CAR's national laws.

**National Regulatory Bodies (Central African Republic):**

**Ministry of Finance and Budget:** Responsible for overall economic policy and oversight of financial matters, including the implementation of the crypto laws.

**Ministry of Digital Economy, Posts and Telecommunications:** Likely involved in the technical and infrastructural aspects of digital asset integration.

**Regional (and Oppositional) Regulatory Body:**

**Law No. 22.001 concerning the regulation of cryptocurrencies in the Central African Republic**

**Key Provisions:** This is the landmark law that officially made Bitcoin legal tender in CAR, alongside the CFA franc. It also defined cryptocurrencies as "decentralized digital values" and "intangible assets," and established a regulatory framework for their use, including a provision for the creation of a national agency to regulate virtual assets.

**Reference/URL (Official text is hard to find directly online, but reputable sources confirm its existence and content):**

**Law No. 22.015 of 27 June 2022 on the tokenization of natural resources, land, and digital services**

**Key Provisions:** This law underpins the "Sango Project" and the "Sango Coin." It allows for the tokenization of the country's natural resources (minerals, oil, diamonds), land, and other assets to attract investment and build a blockchain-based digital economy. It explicitly supports the creation of the "Sango Coin" as the national cryptocurrency of CAR.

**Reference/URL (Information is widely reported, but direct official text is scarce):**

Africanews Report on Sango Coin launch: https://www.africanews.com/2022/07/04/central-african-republic-launches-sango-coin//

Sango Project Website (historical, as the project's status is uncertain): https://sango.org/

**BEAC Instruction No. 001/GR/2022 prohibiting crypto assets in the CEMAC region**

**Date:** May 6, 2022 (shortly after CAR's Bitcoin law)

**Key Provisions:** This directive from the regional central bank prohibits financial institutions in the CEMAC zone from holding or dealing in cryptocurrencies. It explicitly warns against their use due to risks related to financial stability, money laundering, and monetary sovereignty. This instruction directly contradicts CAR's national laws and creates significant hurdles for its implementation.

**Reference/URL (News reports confirm the directive):**

**Legally (CAR National Law):** Crypto trading and the operation of exchanges are **permitted and encouraged** under CAR's national legal framework, especially for Bitcoin, which is legal tender. The laws envision a vibrant crypto economy. The Sango project aimed to create an ecosystem for trading and utilizing the Sango Coin.

**Practically (Regional & Infrastructure):** In reality, the situation is extremely challenging.

**Banking Ban:** The BEAC's directive effectively **bans traditional banks** within the CEMAC zone from facilitating crypto transactions. This means local bank accounts cannot be easily used to fund crypto purchases or off-ramp crypto into fiat, severely hindering the operation of local exchanges or even the seamless use of international exchanges by CAR residents.

**Lack of Infrastructure:** CAR lacks the developed digital infrastructure, internet penetration, and financial services ecosystem necessary to support widespread crypto adoption and robust exchange operations.

**Limited Adoption:** Despite the legal tender status, practical adoption of Bitcoin for everyday transactions remains very low due to these significant infrastructural and regional financial hurdles.

**Uncertainty for Exchanges:** While no national law explicitly bans crypto exchanges, any entity attempting to operate a formal exchange within CAR would face immense difficulty with banking partnerships and regulatory clarity given the BEAC's stance. Most trading is likely to occur via P2P networks or international exchanges that may have limited or no direct integration with the CAR's local financial system.

**Regulation No. 04/22/CM/UMAC/CM of 21 December 2022** concerning the regulation of Virtual Asset Service Providers (VASPs) in the CEMAC zone.

This regulation is further complemented by an instructional circular from the Banking Commission of Central Africa (COBAC), which is the primary supervisor for financial institutions in CEMAC:

**Instruction No. 001/GR/2023 of 31 January 2023** from COBAC on the practical implementation of certain provisions of Regulation No. 04/22/CM/UMAC/CM.

Regulation No. 04/22/CM/UMAC/CM came into effect upon its publication on **21 December 2022**.

The COBAC Instruction No. 001/GR/2023, providing implementation guidance, was effective from **31 January 2023**.

While national transposition into CAR-specific law might still be ongoing or subject to internal processes, the regional directive and COBAC's instruction mandate compliance from VASPs operating in CAR as of these dates.

**Exceeds EUR 1,000** (or its equivalent in XAF or other currency) for transactions conducted by VASPs.

This threshold applies to both single transactions and linked transactions.

Exchange between virtual assets and fiat currencies.

Exchange between one or more forms of virtual assets.

Safekeeping and/or administration of virtual assets or instruments enabling control over virtual assets.

Participation in and provision of financial services related to an issuer's offer and/or sale of a virtual asset.

**Collect and retain** the following information for transactions above the threshold:

**Originator Information:** Name, physical address, national identity number (or customer identification number), date and place of birth, and virtual asset wallet address (or unique transaction identifier).

**Beneficiary Information:** Name, physical address, virtual asset wallet address (or unique transaction identifier).

**Transmit** this information to the beneficiary VASP, where applicable, immediately and securely.

**Maintain records** of all collected information for at least five (5) years.

**Implement risk-based procedures** to identify and verify the identity of customers, especially for higher-risk transactions or relationships.

While specific technical protocols (e.g., TRISA, Sygna) are not explicitly mandated by the CEMAC framework, VASPs are expected to adopt secure and interoperable solutions for information exchange.

**Administrative sanctions:** Fines, injunctions, public reprimands.

**Withdrawal or suspension of operating licenses** for VASPs.

**Referral to national judicial authorities** for criminal prosecution under national AML/CFT laws, which can lead to imprisonment and substantial monetary fines for individuals and legal entities.

The specific penalties are generally outlined in the national AML/CFT laws of CEMAC member states, as well as COBAC's supervisory powers.

**CEMAC Regulation No. 04/22/CM/UMAC/CM:** (French)

A full official link might be harder to find publicly and consistently, as these documents are often distributed to member states and regulated entities. However, news outlets and legal summaries often reference it:

**COBAC Instruction No. 001/GR/2023:** (French)

Often circulated internally within the CEMAC financial sector.

*Example mention/summary of its content:* https://www.coinfirm.com/blog/african-countries-travel-rule-implementation/

*Official COBAC communications often mention such instructions, though direct PDF links can be ephemeral.* The COBAC website (www.cobac.org) is the primary source, but direct links to specific instructions may change.

**Key Resolutions:** UNSCR 2127 (2014) established the initial sanctions, which have been subsequently updated by resolutions like 2399 (2018), 2454 (2019), 2507 (2020), 2566 (2021), 2605 (2021), 2648 (2022), and 2693 (2023).

**Arms Embargo:** Prohibits the supply, sale, or transfer of arms and related materiel to the CAR, with certain exemptions for UN missions and CAR security forces under strict conditions.

The Central African Republic sanctions regime includes a travel ban on designated persons, imposed both by the UN Security Council Sanctions Committee for CAR and independently by the UK Secretary of State.

**Asset Freeze:** Requires all UN Member States to freeze funds and other financial assets belonging to or controlled by individuals and entities designated by the Committee. These designations target those engaging in or supporting acts that undermine peace and stability, violating the arms embargo, or involved in human rights abuses.

**Compliance Requirements for VASPs:** VASPs globally must screen their customers (KYC/CDD) and transactions against the **UN Security Council Consolidated Sanctions List**. Any transaction involving a designated individual or entity, or facilitating prohibited activities (e.g., arms embargo circumvention), is strictly prohibited.

**UNSC CAR Sanctions Committee:** https://www.un.org/securitycouncil/sanctions/2127

**UN Consolidated Sanctions List:** https://www.un.org/securitycouncil/content/un-sc-consolidated-list

**Basis:** Executive Orders, such as E.O. 13645 ("Blocking Property of Certain Persons Contributing to the Conflict in the Central African Republic") and E.O. 13667, target individuals and entities involved in the CAR conflict.

**Scope:** These EOs authorize the blocking of property and interests in property of designated individuals and entities, and prohibit U.S. persons from engaging in transactions with them.

**Compliance Requirements for U.S. VASPs (and those dealing in USD):**

**Sanctioned Entity Screening:** U.S. VASPs must screen all customers and transactions against OFAC's **Specially Designated Nationals and Blocked Persons (SDN) List** and other relevant OFAC lists. Any entity on these lists with a CAR nexus, or generally, is a prohibited counterparty.

**Prohibition on Transactions:** U.S. persons (including U.S. companies and their foreign branches) and transactions touching the U.S. financial system are generally prohibited from engaging in any direct or indirect dealings with designated individuals or entities, or property in which they have an interest.

**Geographic Restrictions:** While there isn't a comprehensive country-wide embargo on CAR, transactions with or for the benefit of specifically designated individuals and entities within CAR are prohibited.

**OFAC Central African Republic Sanctions Program:** https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/central-african-republic-sanctions

The EU implements UNSC resolutions concerning CAR through Council Decisions and Regulations, now updated by Council Decision (CFSP) 2025/1341 (amending earlier 2023 measures) and continuing associated regulations, including the extension of EU Military Training Mission in CAR (EUTM RCA) until 19 September 2026.

**Scope:** The EU sanctions mirror the UN sanctions, including an arms embargo, a travel ban, and an asset freeze on designated individuals and entities undermining peace, security, or stability in the CAR.

**Compliance Requirements for EU VASPs:**

**Sanctioned Entity Screening:** EU VASPs must screen customers and transactions against the **EU Consolidated List of persons, groups, and entities subject to EU financial sanctions**.

**Prohibition on Transactions:** Any direct or indirect provision of funds or economic resources to, or for the benefit of, designated persons/entities is prohibited.

**EU Sanctions Map (search "Central African Republic"):** https://www.sanctionsmap.eu/

**Council Regulations/Decisions:** Search EUR-Lex (e.g., https://eur-lex.europa.eu/) for the latest CAR-specific Council Decisions and Regulations.

**Continuous Screening:** VASPs must implement robust systems to screen all prospective and existing customers (including beneficial owners) and their transaction counterparties against the UN Consolidated Sanctions List, OFAC SDN List, EU Consolidated List, and any other relevant national sanctions lists.

**Risk-Based Approach:** Given the CAR's instability and the potential for illicit financial flows, an enhanced due diligence (EDD) approach may be necessary for transactions involving high-risk entities or individuals in CAR, even if not directly sanctioned.

**Ongoing Monitoring:** Transactions should be continuously monitored for red flags indicating potential sanctions evasion or links to sanctioned parties.

**Targeted Restrictions:** While there is no full crypto embargo on CAR as a country, transactions are prohibited if they involve specific individuals or entities designated by the UN, OFAC, or EU, regardless of their physical location within CAR.

**High-Risk Jurisdiction:** CAR's political instability and specific crypto legal tender status (which could be perceived as a mechanism for sanctions circumvention by some regulators) may lead financial institutions and VASPs to categorize CAR as a higher-risk jurisdiction, triggering EDD requirements.

Directly or indirectly providing any virtual asset services (e.g., exchange, transfer, custody) to designated individuals or entities.

Facilitating any transaction that would violate the arms embargo or provide economic resources to designated parties.

Engaging in any activity that could be seen as circumvention of sanctions, including through the use of virtual assets.

**Bitcoin as Legal Tender:** In April 2022, the CAR adopted Law No. 0.040, making Bitcoin legal tender alongside the CFA franc. It also established a regulatory framework for virtual assets. This law, however, does **not** exempt CAR from international sanctions obligations.

**Sango Project:** The CAR government launched the "Sango" project, including a national cryptocurrency (Sango Coin), aiming to tokenize its natural resources.

**Conflict with Regional Authority:** The adoption of Bitcoin as legal tender has been opposed by the Bank of Central African States (BEAC), the regional central bank for the CEMAC (Economic and Monetary Community of Central Africa) zone, which includes CAR. BEAC views this as undermining regional monetary stability.

**FATF Implications:** While CAR is not currently on the FATF grey list or black list, its move to adopt Bitcoin as legal tender without a robust, internationally compliant AML/CFT framework specifically for virtual assets could raise concerns with the Financial Action Task Force (FATF) and regional bodies like GABAC (Groupe d'Action contre le Blanchiment d'Argent en Afrique Centrale), potentially leading to increased scrutiny.

**No Specific CAR Crypto Sanctions List:** As of my last update, the Central African Republic does **not** maintain its own publicly accessible, specific sanctions list targeting individuals or entities for crypto-related activities. Its regulatory focus has been on adopting crypto, not sanctioning it internally beyond general AML/CFT.

**Regional AML/CFT Framework:** CAR, as a CEMAC member, is subject to the AML/CFT framework supervised by COBAC (Commission Bancaire de l'Afrique Centrale) and GABAC. These bodies generally follow FATF recommendations, which include requirements for VASPs.

**Civil Penalties:** Can range from hundreds of thousands to millions of dollars per violation, depending on the severity and whether it was a deliberate act.

**Criminal Penalties:** For willful violations, individuals can face substantial fines and imprisonment (up to 20 years), while corporations can face multi-million dollar fines.

**Legal Reference:** OFAC's Enforcement Information and Guidelines: https://home.treasury.gov/policy-issues/financial-sanctions/civil-penalties-and-enforcement-information

Penalties are set by individual EU Member States but are typically significant, including fines, confiscation of assets, and imprisonment for serious breaches.

**Reputational Damage:** Beyond legal and financial penalties, violating sanctions can severely damage a VASP's reputation, leading to loss of trust from customers, banking partners, and regulators.

**Regulator Name:** Bank of Central African States (BEAC), the regional central bank for the six-nation Economic and Monetary Community of Central Africa (CEMAC), which includes CAR.

**Violation Type:** Violation of regional monetary policy uniformity, potential for financial instability, money laundering, and illicit financing risks as perceived by BEAC. BEAC argued that the CAR's law violated CEMAC conventions, particularly regarding a unified monetary policy.

**Penalty Amount:** No direct monetary penalty. The "penalty" was intense regulatory pressure, a demand for the law's repeal, and warnings to financial institutions within the CEMAC zone regarding engagement with cryptocurrencies. It represented significant political and economic pressure on CAR.

**Date:** Immediately following CAR's adoption of Bitcoin as legal tender in April 2022. BEAC issued strong statements and a warning circular in May 2022.

**Outcome:** CAR did not repeal its Bitcoin legal tender law, leading to a standoff with BEAC. However, the practical implementation of Bitcoin as legal tender has been largely ineffective, partly due to the lack of infrastructure and the regulatory friction with BEAC. BEAC continued to advise against the use of cryptocurrencies in the CEMAC zone.

**Regulator Name:** International Monetary Fund (IMF) – acting in an advisory and surveillance capacity, not a direct enforcement role but exerting significant policy pressure.

**Violation Type:** Concerns over governance issues, transparency, economic risks, financial stability, and potential for illicit finance associated with the Sango Coin project and the adoption of Bitcoin as legal tender. The IMF repeatedly warned that these initiatives could undermine economic stability and complicate aid efforts.

**Penalty Amount:** No direct monetary penalty or fine. The "penalty" was the withholding of financial support, conditionalities on aid, and strong public statements that could deter foreign investment and lead to a lack of international financial sector integration.

**Date:** Multiple instances, particularly throughout 2022 and 2023, following the launch of Sango Coin and the Bitcoin law. For example, the IMF issued a staff report in July 2022 and continued to raise concerns.

**Outcome:** The Sango Coin project faced significant delays, lack of widespread adoption, and a de-facto scaling back of its ambitious initial vision. While CAR did not abandon its crypto plans, the IMF's warnings contributed to the project's difficulties in attracting investment and achieving its goals. The project appears largely dormant or significantly scaled back in 2024.

**IMF (Press Release / Staff Statement):** https://www.imf.org/en/News/Articles/2022/07/26/pr22262-car-imf-staff-concludes-2022-article-iv-consultation (See paragraphs on crypto risks)

**Reuters (reporting on IMF stance):** https://www.reuters.com/markets/currencies/imf-urges-central-african-republic-reconsider-bitcoin-law-2022-05-24/

**Cointelegraph (reporting on Sango struggles):** https://cointelegraph.com/news/central-african-republic-s-sango-coin-project-hits-turbulence