Custodial wallet / SaaS in Jordan
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 Jordan.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Unable to lawfully operate — no AML regime is available for VASPs because virtual asset services are prohibited.
- If one were to hypothetically operate (illegally), AML Law No. 20 of 2021 would require CDD (full name, date of birth, nationality, address, national ID for individuals; legal form, proof of existence, directors, beneficial ownership for entities).
- Beneficial ownership identification required for legal entity customers.
- Ongoing transaction monitoring to detect unusual patterns.
- Enhanced Due Diligence for PEPs, high-risk jurisdictions, complex/unusually large transactions.
- Suspicious transaction reporting to FIU-Jordan with no tipping-off obligations.
- Record-keeping for minimum 5 years after business relationship ends.
- Designated AML/CFT compliance officer, internal policies, employee training, and independent audit required.
Key Restrictions
- Complete prohibition: the Central Bank of Jordan has repeatedly warned against dealing in cryptocurrencies and directed financial institutions not to handle crypto transactions.
- No licensing regime exists for VASPs — neither registration nor comprehensive licensing is available.
- Financial institutions under CBJ supervision are prohibited from facilitating crypto transactions or providing related services.
- Virtual assets are not recognized as legal tender in Jordan.
- Any entity seeking to serve Jordanian residents or work with Jordanian financial institutions would violate CBJ directives.
Key Risks
- Enforcement exposure: law enforcement action has been taken against individuals involved in crypto-related fraud and money laundering.
- Regulatory ambiguity: the CBJ's position is a flat prohibition rather than a regulated framework — no path to compliance exists.
- Operational risk: cannot use Jordanian banking system for fiat on/off ramps; financial institutions are barred from cooperating.
- Reputational risk: operating in Jordan despite clear public warnings would be openly defiant of the central bank.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Regulator Name: Central Bank of Jordan (CBJ)
Not Legal Tender: Virtual assets (like Bitcoin) are explicitly stated not to be legal tender in Jordan.
Prohibition for Regulated Entities: Financial institutions operating under CBJ supervision (banks, payment service providers, etc.) are generally prohibited from dealing with virtual assets, facilitating transactions involving them, or providing services related to them to customers. This effectively means that regulated financial entities cannot offer crypto services.
No Specific Licenses Exist: There are no prescribed licenses for these activities because the CBJ has not opened the market for them.
Implied Prohibition: Any entity seeking to operate these services within Jordan and deal with Jordanian residents or financial institutions would likely run afoul of CBJ directives.
Neither is in place for VASPs: Jordan currently operates neither a registration-only regime nor a comprehensive licensing regime specifically for virtual asset service providers. The approach is more restrictive.
Repeated warnings and clarifications of the prohibition.
Directives to financial institutions to not deal with crypto.
Entity Targeted: General public, financial institutions, and anyone contemplating dealing in cryptocurrencies. Violation Type: Dealing in, trading, or promoting cryptocurrencies within the Jordanian financial system is prohibited and deemed risky. The CBJ considers cryptocurrencies to carry high risks due to their volatile nature, lack of regulatory oversight, potential for money laundering and terrorist financing, and cyber risks. Penalty Amount: Not applicable to a general warning/prohibition. However, engaging in prohibited activities could lead to legal repercussions under existing financial and anti-money laundering laws, though specific penalties for crypto dealing outside of fraud aren't often publicized for individuals. Licensed financial institutions found violating CBJ directives could face regulatory penalties. Outcome: Maintenance of a strict prohibitory environment, discouraging financial institutions from engaging in crypto-related activities and warning the public against associated risks.
Outcome: Maintenance of a strict prohibitory environment, discouraging financial institutions from engaging in crypto-related activities and warning the public against associated risks.
Anti-Money Laundering and Counter-Terrorist Financing Law No. 20 of 2021: This is the most recent comprehensive law that aligns Jordan's framework more closely with international standards, including FATF recommendations. While it doesn't explicitly detail VASP licensing, it broadens the scope of entities subject to AML/CFT obligations and strengthens preventative measures. It aims to cover all financial institutions and designated non-financial businesses and professions (DNFBPs) that might be exposed to ML/TF risks.
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.
Not permitted — Jordan's Central Bank has issued a de facto prohibition on all virtual asset services, with no licensing path for VASPs, no legal recognition of virtual assets, and directives to financial institutions to block crypto activity.
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?