Stablecoin issuer / redeemer in Cote d'Ivoire

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

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.

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.

Capital requirements (significant).

High capital requirements.

Local presence and management.

Segregation of client funds.

Robust AML/KYC policies and procedures.

Strong internal controls and audit.

Current Status: No specific regulation. Might be viewed as a financial service, but without clear licensing paths.

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.

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

Example of reported BCEAO stance: "The Central Bank of West African States (BCEAO) has reiterated its warning against cryptocurrencies, emphasizing that they are not legal tender in the WAEMU region and are not regulated by the Central Bank. The BCEAO has consistently advised the public to exercise extreme caution with these digital assets due to their speculative nature and lack of regulatory oversight." (This general statement reflects numerous communiqués over the years).

Evidence fact ci.custody.bceao-cautious-stance-the-bceao not found (may have been renamed).

Segregation of Client Assets Rules:

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.

Qualified Custodian Definitions:

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.

Cold Storage Mandates:

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.

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.

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.

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).

Account files and business correspondence.

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.

The BCEAO has issued several communiqués warning against the use of cryptocurrencies (e.g., Communiqué du 12 décembre 2013, Communiqué du 05 décembre 2017, Communiqué du 22 mai 2018). These communiqués generally state that cryptocurrencies are not legal tender, are not regulated by the BCEAO, and carry significant risks. This stance means there is no formal licensing regime for VASPs in the UEMOA region, including Cote d'Ivoire, and operating in this space carries inherent regulatory ambiguity. However, the absence of specific regulation does not exempt entities from general AML/CFT obligations.

No specific legislation: As of the latest information, Côte d'Ivoire has not enacted specific laws or regulations solely dedicated to the taxation of cryptocurrencies or virtual assets.

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.