On-shore VASP in Cameroon

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

Cryptocurrency Exchanges: There is no legal framework to license or regulate cryptocurrency exchanges. Any entity attempting to operate an exchange would face severe challenges in accessing banking services and could be deemed to be operating outside the established financial regulatory framework.

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.

BEAC Communiqué on Cryptocurrencies (December 10, 2021):

In May 2022, the Banque des États de l'Afrique Centrale (BEAC), the central bank for the CEMAC region (Cameroon, Central African Republic, Chad, Congo, Equatorial Guinea, Gabon), issued a Communiqué (No. 003/GR/2022) that formally banned all cryptocurrency activities in the zone. This communiqué prohibits the holding, buying, selling, and facilitation of transactions involving cryptocurrencies, effectively precluding the legal operation of VASPs.

Violation of the BEAC Cryptocurrency Ban: Operating any virtual asset service provider or engaging in virtual asset transactions in the CEMAC region, including Cameroon, is a violation of the BEAC communiqué. While the communiqué itself might not detail specific penalties, it refers to existing monetary and financial regulations. This could lead to:

Imprisonment (under general financial crime laws).

Confiscation of assets.

Freezing of accounts.

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.

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.

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:.

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.

Outcome: The founder, Emile Parfait Mbori, and several accomplices were arrested and detained. The company's operations were shut down. Legal proceedings are continuing in Cameroonian courts, aiming for convictions and potentially restitution for victims. This case sent a strong signal against unregulated investment schemes, particularly those leveraging the allure of cryptocurrency.