On-shore VASP 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.

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 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).

Robust AML/KYC policies and procedures.

Consumer protection safeguards.

Local presence and management.

Insurance for client assets.

Segregation of client funds.

Strong internal controls and audit.

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.

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.

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.

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.

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:

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).

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).

Adopted: Yes, primarily through the UEMOA regional framework and subsequent BCEAO instructions.

BCEAO Instruction No. 003/2022/RB of 17 November 2022 relating to the prevention of money laundering and terrorist financing by entities subject to the control of the BCEAO. This instruction specifically integrates "virtual asset service providers (PSAVs)" into the scope of regulated entities and details their AML/CFT obligations.

For cross-border transfers: The Travel Rule information (originator and beneficiary details) must be transmitted for transfers exceeding EUR 1,000 (or equivalent). Below this threshold, VASPs are still required to collect and hold the information but may not be required to send it with the transfer itself to the beneficiary VASP, unless deemed suspicious.

Collect and retain accurate and meaningful originator and beneficiary information for all virtual asset transfers. This information typically includes:

Transmit this information to the beneficiary VASP immediately and securely, along with the virtual asset transfer itself, or through a secure messaging system that ensures the information is received before or at the time of the transfer.

Maintain records of all transactions and customer information for at least five years.

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):

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.

All tax matters related to cryptocurrencies are therefore subject to interpretation under the Code Général des Impôts (CGI), whose provisions are continuously evolving due to regular updates, including annual finance laws and new editions for years like 2025 and 2026, covering income tax, corporate tax, VAT, and other duties.

If a business holds and sells cryptocurrencies in Côte d’Ivoire, any short-term gains realized from their sale are subject to a specific capital gains tax rate of 20.0%, rather than the standard Impôt sur les Sociétés (IS - Corporate Income Tax) rate.