Remote VASP serving residents in Jordan
Foreign-incorporated entity that offers exchange, custody, or transfer services to residents of a jurisdiction without establishing a local entity or office.
Remote VASP is conditionally permitted in Jordan without local incorporation, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- Customer Due Diligence (CDD): Identify and verify customers (name, DOB, nationality, ID, address, occupation) under AML/CFT Law No. 20 of 2021
- Beneficial Ownership Identification: Identify natural persons who ultimately own/control legal entity customers
- Ongoing Transaction Monitoring: Scrutinize transactions against customer risk profile; apply Enhanced Due Diligence (EDD) for PEPs, high-risk jurisdictions, complex/unusual transactions
- Suspicious Transaction Reporting (STR): Report any suspected money laundering or terrorist financing to the Financial Intelligence Unit (FIU-Jordan) immediately
- No Tipping-Off: Prohibit disclosure to customers that an STR has been submitted
- Record-Keeping: Maintain CDD documents, transaction records, business correspondence, and STR copies for a minimum of 5 years
- Travel Rule Compliance (CBJ Circular 10/2022): Collect, transmit, verify, and store originator and beneficiary information for virtual asset transfers; adopt interoperable compliance solutions
- Internal AML/CFT Program: Appoint a designated compliance officer, develop written policies/procedures, deliver employee training, and conduct regular independent audits
Key Restrictions
- CBJ has repeatedly and consistently warned that dealing in cryptocurrencies is prohibited — no licensing regime exists for VASPs
- Financial institutions under CBJ supervision (banks, payment service providers) are prohibited from facilitating any crypto transactions
- Virtual assets are explicitly stated as not legal tender in Jordan
- No framework for a foreign VASP to be licensed or registered; operating from abroad to serve residents carries legal risk under CBJ prohibitions
- Travel Rule (CBJ Circular 10/2022) applies to any VASP activity touching Jordan, but compliance is technically impossible without a recognized regulatory pathway
Key Risks
- Enforcement risk: CBJ has repeatedly warned the public and enforced against crypto-related activities; individuals involved in fraud/scams/money laundering via crypto may face law enforcement action
- Regulatory ambiguity: The CBJ prohibits crypto dealing by financial institutions and warns the public, but does not have a clear prohibition order specifically targeting foreign remote VASPs — creating gray-area exposure
- Banking/fintech isolation: Local financial institutions are directed not to deal with crypto, making on-ramps/off-ramps difficult or impossible
- High reputational risk: Operating in a jurisdiction where the central bank publicly warns citizens against crypto could attract negative regulatory attention and consumer distrust
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Repeated warnings and clarifications of the prohibition.
Law enforcement action against individuals involved in fraud, scams, or money laundering where crypto is a component.
Directives to financial institutions to not deal with crypto.
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.
Warnings to the Public: The CBJ has consistently warned the public about the high risks associated with dealing in virtual assets, including price volatility, lack of consumer protection, cybersecurity risks, and potential use in illicit activities.
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.
Overseas Operators: While Jordanian citizens might interact with international crypto platforms, these platforms are not licensed or regulated by Jordanian authorities.
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.
Anti-Money Laundering and Counter-Terrorist Financing Law (Law No. 20 of 2021):
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.
Identification and Verification of Customers:
Identification of Beneficial Ownership: For legal entities or arrangements, identifying and verifying the identity of the natural persons who ultimately own or control the customer, or the natural person on whose behalf a transaction is being conducted.
Ongoing Monitoring: Continuously scrutinizing transactions undertaken by customers to ensure they are consistent with the VASP’s knowledge of the customer, their business, and risk profile, including (where necessary) the source of funds.
Enhanced Due Diligence (EDD): Applying stricter measures for higher-risk situations, such as:
Report Suspicious Activities: Immediately report any suspicious transaction or activity (including attempted transactions) that they know, suspect, or have reasonable grounds to suspect involves money laundering or terrorist financing to the Financial Intelligence Unit (FIU-Jordan).
No Tipping-Off: Prohibit the disclosure to the customer or any third party that a suspicious transaction report has been or will be submitted.
Retention Period: Records must typically be kept for a minimum period of five (5) years after the business relationship has ended or after the date of an occasional transaction.
Designated AML/CFT Compliance Officer: Appointing a senior-level compliance officer responsible for overseeing the AML/CFT program.
Internal Policies and Procedures: Developing and implementing comprehensive AML/CFT policies and procedures tailored to their specific risks and operations.
Employee Training: Providing ongoing training to all relevant employees on AML/CFT laws, regulations, internal policies, and how to recognize and report suspicious activities.
Independent Audit: Conducting regular independent audits of their AML/CFT programs to assess their effectiveness.
Central Bank of Jordan (CBJ) Circular No. 10/2022:
Collect required information: Obtain and hold accurate and meaningful originator information and required beneficiary information for virtual asset transfers.
Transmit required information: Submit the required originator and beneficiary information to the beneficiary VASP (or to the originator VASP in the case of a receipt).
Verify information: Conduct verification of customer identity as part of their Customer Due Diligence (CDD) process.
Record-keeping: Maintain records of all transaction information and CDD data for a specified period (typically 5-10 years).
Monitor and report: Implement systems for ongoing monitoring of transactions and reporting of suspicious transactions (STRs) to Jordan's Anti-Money Laundering and Counter-Terrorist Financing Unit (AMLCFTU).
Penalties for Non-Compliance:
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.
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 — a foreign remote VASP cannot be licensed in Jordan (no licensing regime exists) and CBJ has prohibited financial institutions from facilitating crypto and warned the public, but the direct legality for a non-resident provider serving residents remotely remains legally ambiguous; Travel Rule and AML obligations under Law No. 20 of 2021 would apply if operating, yet compliance is practically difficult without a recognized regulatory pathway, and enforcement action against individuals involved in crypto-related fraud/money laundering is possible.
Questions this verdict aims to answer
- May a non-resident provider serve residents from abroad?
- Does cross-border service trigger licensing, registration, or AML obligations?
- What enforcement risk exists for unlicensed remote operators?