DeFi protocol frontend in Cote d'Ivoire

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.

BCEAO's Cautious Stance: The BCEAO has historically adopted a cautious, and at times prohibitive, stance towards cryptocurrencies due to concerns about monetary stability, consumer protection, money laundering, and illicit financing. They have issued warnings to financial institutions and the public about the risks associated with cryptocurrencies.

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.

Current Status: Largely unregulated for pure crypto-to-crypto exchanges. However, if they facilitate fiat-to-crypto or crypto-to-fiat transactions, they may face pressure from traditional banks (who are regulated by BCEAO) regarding AML/CFT compliance and potentially be required to obtain a Payment Institution license.

Local presence and management.

Capital requirements (significant).

Côte d’Ivoire has data protection obligations under Law 2013-450 and is actively strengthening cybersecurity through ARTCI and ANSSI, but implementation faces coordination challenges and security gaps, indicating measures are still being developed rather than already strong.

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 Ordinance modified and strengthened the earlier Law n°2014-393, bringing it more in line with international standards set by FATF. It is the core legal text for AML/CFT.

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.

Identification and Verification of Identity:

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.

Purpose and Nature of the Business Relationship: Understanding the purpose and intended nature of the business relationship or occasional transaction.

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).

Reporting Mechanism: Reports are made to CELLIF (see below).

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.

All customer identification data (e.g., copies of identification documents).

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.

Overall Regulatory Stance (BCEAO):

A widely cited stance, though not a specific custody rule, is their consistent warning against crypto:

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.

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.