Stablecoin issuer / redeemer in Cameroon

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.

Payment Processors: Payment processors dealing with fiat currency are regulated by BEAC and require licenses as Electronic Money Institutions or Payment Institutions. However, they are explicitly prohibited from dealing with cryptocurrencies. Therefore, there are no licenses for crypto-specific payment processing.

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):

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

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.

Capital Requirements: For financial institutions, BEAC and COBAC impose strict capital requirements (e.g., minimum capital for banks, microfinance institutions, payment institutions). Any future VASP license would likely have similar prudential requirements.

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:

Identification of Beneficial Owners:

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.

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.

No Specific Crypto Capital Gains Tax: Cameroon does not have a dedicated capital gains tax on virtual assets.

Gains realized from the sale of cryptocurrencies in Cameroon are subject to a separate 15% capital gains tax, not standard income tax rates as business or miscellaneous income.