Custodial wallet / SaaS in Algeria
Hosted wallet provider that holds keys on behalf of end users, often white-labeled to businesses (custody as a service).
Custodial SaaS is not permitted in Algeria.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Not applicable — the activity is prohibited; no AML regime applies to custodial wallet providers.
- Article 51 bis of Law No. 18-10 (2018) prohibits any acquisition, disposal, management, or dealing with virtual currency, making AML compliance moot for this model.
Key Restrictions
- Absolute prohibition: Article 51 bis of Law No. 18-10 explicitly prohibits any acquisition, disposal, management, use, possession, or dealing with virtual currency.
- No licensing framework exists for custodial wallet providers — no registration, no license, no legal path to operate.
- The 2018 Finance Law (Article 117) reinforces the ban; businesses cannot register with any Algerian authority to offer crypto services.
- There are no qualified-custodian definitions, no segregation or insurance rules, because the activity itself is illegal.
Key Risks
- Criminal enforcement risk: individuals and entities engaged in crypto activities (trading, mining, facilitation) have been arrested, prosecuted, and convicted with asset seizure and imprisonment.
- Regulatory ambiguity risk: no distinction is made between token types (utility, security, stablecoin, NFT); all are prohibited as virtual currencies.
- No pending or proposed legislation to legalize or regulate private crypto custody — only a CBDC ('digital dinar') is under discussion.
- Operators face immediate illegality — no transitional or grandfathering provisions exist.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Article 51 bis explicitly states: "Any acquisition, disposal, management, use, possession, or dealing with virtual currency is strictly prohibited." It also classifies transactions involving virtual currencies as offenses punishable by the penalties provided for in the laws and regulations in force.
Law No. 18-10 of August 2, 2018, on Money and Credit (Loi n° 18-10 du 2 août 2018 relative à la monnaie et au crédit).
Custodial License Requirements: There are no licenses for cryptocurrency custodians because the underlying activity of dealing with cryptocurrencies is prohibited.
Segregation of Client Assets Rules: Not applicable, as there are no legal entities permitted to custody client crypto assets.
Insurance/Bonding Requirements: Not applicable.
Cold Storage Mandates: Not applicable.
Qualified Custodian Definitions: There are no legal definitions for qualified custodians of cryptocurrencies, as their operation is illegal.
Pending Custody Legislation: There is no known pending legislation specifically for the custody of private cryptocurrencies. The focus remains on maintaining the prohibition.
Custody Providers: Prohibited.
No registration: Businesses cannot register with any Algerian authority to legally offer crypto services.
No licensing: There are no licenses issued for crypto activities.
Loi de Finances 2018 (2018 Finance Law), Article 117.
Article: Article 117 is the key provision.
Entity Targeted: Individuals engaged in buying, selling, or facilitating the exchange of cryptocurrencies, often referred to as "illegal traders" or "individuals involved in unauthorized virtual currency transactions." Specific names are rarely disclosed in initial reports. Violation Type: Illicit use, possession, buying, or selling of virtual currencies; violation of foreign exchange regulations; money laundering (often linked as an additional charge). These stem directly from Article 117 of the 2018 Finance Law and subsequent reinforcing legislation. Penalty Amount: Varies significantly based on the judge's decision, but often includes:. Outcome: Arrest, seizure of assets/equipment, prosecution, and typically conviction leading to imprisonment and/or fines, based on the criminalization of these activities.
Entity Targeted: Individuals or groups operating cryptocurrency mining farms. These operations are often targeted not only for the illicit use of cryptocurrency but also for illegal electricity consumption, which carries additional penalties. Violation Type: Illegal operation of virtual currency mining, illicit use of virtual currencies, unauthorized electricity consumption, money laundering. These charges are derived from the criminalization of cryptocurrency activities and related offenses. Penalty Amount: Similar to trading violations, penalties include:. Outcome: Arrests, dismantling of mining operations, seizure of expensive mining hardware, prosecution, and convictions leading to imprisonment and fines.
Outcome: Arrest, seizure of assets/equipment, prosecution, and typically conviction leading to imprisonment and/or fines, based on the criminalization of these activities.
Outcome: Arrests, dismantling of mining operations, seizure of expensive mining hardware, prosecution, and convictions leading to imprisonment and fines.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
No — custodial wallet / SaaS operations are prohibited outright in Algeria under Article 51 bis of Law No. 18-10 (2018), which criminalizes any dealing with virtual currencies, and there is no licensing path, no qualified-custodian framework, and active enforcement against crypto activities.
Questions this verdict aims to answer
- What custody license / qualified-custodian status applies?
- What segregation, insurance, and proof-of-reserves rules apply?
- What AML obligations attach to the SaaS vs the white-label client?