Custodial wallet / SaaS in Cameroon

Custody Providers: Similar to exchanges, no specific license exists. Financial institutions are prohibited from holding or facilitating virtual assets, making traditional custody services for crypto impossible within the regulated sector.

Neither a specific registration nor a licensing regime for VASPs exists in Cameroon. The current environment is effectively one of prohibition for regulated financial entities, without a corresponding framework for independent crypto businesses.

Entities seeking to operate in the crypto space would likely face a lack of legal recognition and significant operational hurdles, particularly concerning banking relationships.

Local Presence: For most regulated financial activities in Cameroon, a local corporate entity and physical presence are mandatory. This would likely extend to any future crypto licensing.

BEAC Communiqué on Cryptocurrencies (December 10, 2021):

Lack of Legal Tender Status: Cryptocurrencies are not recognized as legal tender within the CEMAC zone.

CEMAC Regulation No. 02/CEMAC/UMAC/CM/22 on the Fight Against Money Laundering and the Financing of Terrorism in the CEMAC Zone, with Specific Provisions for Virtual Assets: This is the most critical piece of legislation. Adopted in 2022, it explicitly defines "virtual assets" and "virtual asset service providers" and subjects VASPs to the same AML/CFT obligations as traditional financial institutions. It transposes the FATF Recommendations concerning virtual assets.

Law No. 2016/007 of July 12, 2016, on the fight against money laundering and terrorist financing in Cameroon: This national law provides the general framework for AML/CFT in Cameroon, defining obliged entities, establishing the Financial Intelligence Unit (ANIF), and outlining sanctions. While it predates explicit VASP definitions, the CEMAC regulation extends its principles to VASPs.

Identification and Verification of Customers:

Identifying the natural person(s) who ultimately own or control the customer (typically 25% ownership or more, or effective control).

Assessing the risk profile of the customer based on this information.

Continuously monitoring business relationships and transactions to ensure they are consistent with the VASP's knowledge of the customer, their business, and their risk profile, including, where necessary, the source of funds.

Applying EDD measures for high-risk situations, including:

Reporting Obligation: VASPs must report any transaction (or attempted transaction) that they suspect, or have reasonable grounds to suspect, is related to money laundering or terrorist financing, regardless of the amount.

Reporting Body: Reports must be made to the Agence Nationale d'Investigation Financière (ANIF), Cameroon's FIU.

Timing: Reports must be submitted "without delay" once suspicion is formed.

The CEMAC-wide Ban on Crypto-Assets by BEAC: This is a foundational regulatory action that makes all crypto-related activities illegal and provides the basis for enforcement.

Enforcement against crypto-related Ponzi schemes/fraudulent operations.

Date: May 6, 2022

Outcome: Established a clear and comprehensive prohibition on all crypto-asset related activities across the CEMAC region. This makes any operation of a cryptocurrency exchange, mining operation, or widespread trading highly illegal and subject to enforcement by national authorities (police, judiciary, financial intelligence units) in each CEMAC member state, including Cameroon.

Entity Targeted: Global Investment Trading (GIT) and its founder, Emile Parfait Mbori, along with several associates. Violation Type: Operating an illegal financial scheme (Ponzi scheme), fraud, illegal public offering of financial products, money laundering. Although often marketed as "crypto" (sometimes involving Mofor Coin), the core violation was operating an unregistered and fraudulent investment scheme. Penalty Amount: Not a final judicial penalty yet, as legal proceedings are ongoing. However, significant actions include:.