Crypto ATM / kiosk operator in 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.

Central African Republic has not established functional licensing or supervision of VASPs; rather, it has embraced opaque, unregulated cryptocurrency schemes that risk state asset capture by criminal organizations, with no effective AML/CFT compliance or VASP oversight.

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.

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

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).

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.

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

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.

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

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

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.

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.

Entity Targeted: The Government of the Central African Republic (specifically its law adopting Bitcoin as legal tender).

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.

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.