Custodial wallet / SaaS in Cote d'Ivoire

The BCEAO's official website (https://www.bceao.int/) designates its "Publications" and "News" sections, primarily in French, as the official channels for updates on its stance regarding digital currencies. No direct "custody regulation" document exists on the site as of this date.

There are no specific BCEAO licensing requirements for crypto custody, as cryptocurrencies are not recognized or regulated by the BCEAO. However, entities engaged in activities that intersect with traditional financial services (e.g., handling fiat currency, money transfers, or operating as a bank or payment institution) are subject to existing WAEMU financial licensing requirements, including AML/KYC obligations under the BCEAO's regulatory framework. National-level business licensing (e.g., registration with the Commercial Court in Côte d'Ivoire) also applies.

The BCEAO's regulatory framework does not include specific rules for the segregation of cryptocurrency assets. While BCEAO regulations mandate segregation for fiduciaires in the traditional financial system (e.g., for securities maintained by investment service providers), these regulations explicitly exclude digital assets not recognized as financial instruments. Entities holding crypto assets may still be subject to general consumer protection or business contract laws at the national level in Côte d'Ivoire, but no specific segregation mandate from the BCEAO exists.

The BCEAO has not issued any mandates requiring insurance or bonding for digital asset custodians. This is consistent with the broader lack of regulation for crypto assets. However, entities that also operate as traditional financial institutions may be subject to existing insurance/bonding requirements for their licensed activities (e.g., operational risk insurance for banks), but these do not specifically cover crypto custody. The absence of such protections increases risk for users in the event of loss, theft, or custodian insolvency.

The BCEAO has not issued any specific mandates for cold storage or any other method of storing digital assets. This reflects the broader absence of a regulated crypto custody framework. In contrast, traditional financial institutions are subject to BCEAO prudential rules for the safekeeping of physical assets (e.g., cash in vaults, securities held by depositories), but no equivalent exists for unregulated digital assets.

No specific definition for crypto assets. The concept of a "qualified custodian" as defined in jurisdictions like the US (e.g., under the Advisers Act) does not exist for digital assets in Cote d'Ivoire, as there's no framework to define or regulate such entities.

Côte d’Ivoire, as a member of WAEMU, is subject to Regulation 06/2024/CM/WAEMU of December 20, 2024, which establishes dedicated exchange control rules for virtual assets, effectively creating a regulatory framework for virtual assets in the WAEMU zone.

Required Licenses: Approval as a Payment Institution or Electronic Money Issuer (EME) from the BCEAO.

Directive No. 03/2018/CM/UEMOA on the harmonization of the regulation of payment services in the UEMOA region.

Instruction No. 002/2019/RB/UEMOA relating to the approval of payment institutions and electronic money institutions.

Required Compliance: Entities, even if not explicitly licensed for crypto, should adhere to general AML/CFT obligations if they deal with financial transactions. Once a specific VASP framework is established, these will be mandatory.

Directive No. 02/2015/CM/UEMOA on the fight against money laundering and terrorist financing in the UEMOA region.

Required Registration: Registration with the commercial registry (RCCM - Registre du Commerce et du Crédit Mobilier) and relevant tax authorities in Cote d'Ivoire.

Capital requirements (significant).

Local presence and management.

Ordonnance n°2019-1089 du 18 décembre 2019 portant modification de la Loi n°2014-393 du 20 juin 2014 relative à la lutte contre le blanchiment de capitaux et le financement du terrorisme.

This law defines "obliged entities" (assujettis) which include financial institutions, and potentially DNFBPs. While VASPs are not explicitly named, depending on the services offered, they could fall under these broad categories, particularly if they facilitate exchanges, transfers, or safekeeping of assets.

Règlement n°07/2002/CM/UEMOA du 19 septembre 2002 relatif à la lutte contre le blanchiment de capitaux dans les États membres de l'UEMOA.

Identification and Verification of Identity:

For Legal Persons/Entities (e.g., businesses): Obtaining and verifying the company's name, legal form, address of registered office, registration number, articles of incorporation, bylaws, and identifying the directors and persons authorized to represent the legal person.

Beneficial Ownership: Identifying and taking reasonable measures to verify the identity of the beneficial owner(s) (i.e., the natural person(s) who ultimately own or control the customer, or on whose behalf a transaction is being conducted). For legal persons, this typically involves identifying individuals holding 25% or more of the shares or voting rights, or otherwise exercising control.

Ongoing Monitoring: Conducting ongoing due diligence on the business relationship and scrutinizing transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the obliged entity's knowledge of the customer, their business, and risk profile.

Enhanced Due Diligence (EDD): Applying EDD measures in higher-risk situations, including:

Obligation to Report: Obliged entities must report any transaction (or attempted transaction) that they suspect is linked to money laundering or terrorist financing to the Financial Intelligence Unit (FIU).

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

Entity Targeted: General public and financial institutions operating within the UEMOA zone (including Côte d'Ivoire). Violation Type: While not a "violation" in the traditional sense, the BCEAO's consistent stance warns against the use, holding, or facilitation of transactions involving cryptocurrencies, emphasizing their speculative nature, lack of regulatory oversight, and potential for fraud and money laundering. It effectively "enforces" a non-recognition policy. Penalty Amount: Not applicable, as this is a general regulatory stance and warning, not a specific penalty against an entity. Outcome: A clear declaration that cryptocurrencies are not legal tender, are not regulated, and pose significant risks. Financial institutions are generally dissuaded from engaging with them. This discourages formal crypto operations.

Outcome: A clear declaration that cryptocurrencies are not legal tender, are not regulated, and pose significant risks. Financial institutions are generally dissuaded from engaging with them. This discourages formal crypto operations.

Côte d’Ivoire is subject to FATF recommendations and was assessed in an IMF-led 2023 report for compliance with FATF AML/CFT standards. It is also listed as a jurisdiction under increased FATF monitoring as of October 2025, indicating that FATF influence is already driving concrete actions to address strategic AML/CFT deficiencies, including for the regulation of VASPs.