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Self-custodial wallet / non-custodial software in Algeria

Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.

Not permitted AI-Generated · Unreviewed

Self-custodial wallet 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 underlying activity (dealing with virtual currency) is prohibited by Article 51 bis of Law No. 18-10 on Money and Credit. No AML/CTF regime applies because no lawful crypto operation can exist.
  • In a hypothetical compliant world, strict AML/KYC procedures would be mandatory per dz.licensing.amlkyc-requirements-strict-anti-money-laundering, but this is moot given the prohibition.

Key Restrictions

  • Publishing self-custodial wallet software likely constitutes 'dealing with virtual currency' under the broad prohibition in Article 51 bis, Law No. 18-10.
  • Algeria's Loi de Finances 2018 (Article 117) and Law No. 18-10 prohibit any acquisition, disposal, management, use, possession, or dealing with virtual currency.
  • No registration or licensing pathway exists for any crypto-related business (dz.licensing.no-registration-businesses-cannot-register, dz.licensing.no-licensing-there-are-no).
  • Even non-custodial software that facilitates user access to virtual currencies is captured by the broad statutory language.

Key Risks

  • Criminal prosecution risk: Enforcement actions target individuals involved in cryptocurrency activities, including trading/mining, with arrests, seizures, and imprisonment (dz.enforcement.* facts).
  • No legal distinction between custodial and non-custodial services — the prohibition covers any 'dealing with' virtual currency, which could include publishing software that enables such dealing.
  • Regulatory ambiguity: No specific legal test exists for classifying tokens or software; the ban is blanket (dz.licensing.no-specific-test-algeria-does).
  • Bank of Algeria has consistently warned against virtual currencies and is exploring a CBDC (digital dinar), signalling continued hostility to private crypto (dz.custody.bank-of-algeria-statements-the).

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 60% confidence

Loi de Finances 2018 (2018 Finance Law), Article 117.

licensing 60% confidence

No registration: Businesses cannot register with any Algerian authority to legally offer crypto services.

licensing 60% confidence

No licensing: There are no licenses issued for crypto activities.

custody 20% confidence

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.

custody 20% confidence

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).

enforcement 50% confidence

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.

enforcement 50% confidence

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.

enforcement 50% confidence

Outcome: Arrest, seizure of assets/equipment, prosecution, and typically conviction leading to imprisonment and/or fines, based on the criminalization of these activities.

enforcement 50% confidence

Outcome: Arrests, dismantling of mining operations, seizure of expensive mining hardware, prosecution, and convictions leading to imprisonment and fines.

licensing 60% confidence

AML/KYC Requirements: Strict Anti-Money Laundering (AML) and Know Your Customer (KYC) procedures would be mandatory, aligning with international standards set by FATF (Financial Action Task Force). This would involve customer identification, transaction monitoring, and suspicious activity reporting.

licensing 60% confidence

No Specific Test: Algeria does not have a specific legal test for classifying cryptocurrency tokens as securities, or as anything else, because the very concept of "virtual currency" is banned. Therefore, there's no equivalent to the Howey test or any other specific framework for assessing the characteristics of a crypto asset.

custody 20% confidence

Bank of Algeria Statements: The Governor of the Bank of Algeria has, on several occasions, discussed the potential for a "digital dinar." This exploration, however, does not signify a change in the country's stance on privately issued cryptocurrencies. A CBDC would be a liability of the central bank, fundamentally different from decentralized cryptocurrencies like Bitcoin or Ethereum.

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 — self-custodial wallet software publishing is effectively prohibited in Algeria because the statutory ban on "any acquisition, disposal, management, use, possession, or dealing with virtual currency" (Article 51 bis, Law No. 18-10) is drafted broadly enough to capture any activity enabling virtual currency transactions, and no licensing or registration pathway exists to legally offer such services.

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?