Self-custodial wallet / non-custodial software in Cabo Verde
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Cabo Verde without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML obligations attach to publishing self-custodial wallet software, because the publisher never holds, controls, or has access to user funds and does not qualify as a VASP under Lei n.º 1/IX/2021.
- Lei n.º 1/IX/2021 defines 'Virtual Asset Service Provider' and subjects VASPs to AML/CFT obligations, but only if the entity provides one or more covered services (exchange, transfer, custody, etc.).
- Solely publishing non-custodial software that enables users to self-manage their own private keys does not trigger CDD/KYC, STR, record-keeping, or other AML obligations.
- If the publisher were to offer any ancillary services (e.g., fiat on/off-ramp, swap aggregation with custody, or any intermediation), those activities could bring it within the scope of VASP obligations under Lei n.º 1/IX/2021.
Key Restrictions
- No dedicated licensing regime exists for self-custodial wallet software publishers.
- The BCV has repeatedly warned that cryptocurrencies are not legal tender and are high-risk; public statements may create reputational or consumer-protection expectations.
- General company registration under Cabo Verdean commercial law is required if the publisher incorporates locally, but this is a non-financial registration — not a financial license.
- If the software includes any built-in fiat-to-crypto conversion or custodial element, it may trigger existing BCV financial-services licensing requirements and AML obligations.
Key Risks
- Regulatory ambiguity: The BCV has not issued clear guidance distinguishing self-custodial software from VASP activities — future enforcement could take an expansive view.
- Consumer-protection exposure: If users lose funds due to software defects, and the publisher has no local presence or disclaimer, the BCV or courts could impose liability under general consumer law.
- Evolving FATF-driven framework: Cabo Verde is actively aligning with FATF recommendations; future amendments to Lei n.º 1/IX/2021 could broaden the definition of VASP to include non-custodial providers.
- Reputational risk: BCV has issued public warnings against crypto — association with an unregulated crypto product could attract regulatory attention even if no specific rule is violated.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
The Banco de Cabo Verde (BCV), the central bank, has repeatedly issued public warnings regarding the risks associated with cryptocurrencies.
It has clarified that cryptocurrencies are not legal tender in Cabo Verde.
The BCV has stated it does not authorize, supervise, or license entities that deal exclusively with virtual assets, but it has actively issued public warnings and interventions (e.g., regarding OPTCOIN), indicating some regulatory oversight through public communications and evolving legal frameworks for digital currency.
There are no specific laws or regulations that define a licensing framework for crypto exchanges, custody providers, or payment processors as distinct categories of financial institutions.
Neither a specific licensing nor a dedicated registration regime for Virtual Asset Service Providers (VASPs) exists in Cabo Verde.
Key Law: Lei n.º 1/IX/2021, de 16 de março, on the Prevention and Combat of Money Laundering and the Financing of Terrorism, explicitly defines "Ativo Virtual" (Virtual Asset) and "Prestador de Serviços de Ativos Virtuais" (Virtual Asset Service Provider) and subjects them to AML/CFT obligations.
Specific AML/CFT Requirements for VASPs (as "Reporting Entities"):
However, any entity providing services that involve holding or managing financial assets, even digital ones, could potentially be deemed to be operating within the scope of existing financial services laws and regulations. This might necessitate obtaining a general financial services license or authorization from the Banco de Cabo Verde (BCV) if their activities are interpreted to fall under the definition of banking, investment services, or payment services.
Regulatory Stance and Warnings (General "Actions"):
Outcome: Increased public awareness, deterring regulated financial institutions from dealing directly with unregulated crypto assets. The BCV has consistently advised caution.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — Publishing self-custodial wallet software in Cabo Verde does not trigger VASP classification or AML obligations under current law (Lei n.º 1/IX/2021), because the publisher never holds user funds or private keys; however, the BCV's general warnings against crypto create consumer-protection ambiguity, and future FATF-aligned rulemaking may expand the VASP definition.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?