Self-custodial wallet / non-custodial software in Jordan
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 Jordan 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 because a self-custodial wallet publisher does not hold, control, or have access to user funds, and is not classified as a VASP or MSB under Jordanian law.
- The CBJ has not designated software publishers as regulated financial entities; the AML/CFT Law No. 20 of 2021 applies to financial institutions and any future VASPs, not to non-custodial software publishers.
- If the publisher had any custody or facilitation role, it would be subject to CDD, ongoing monitoring, EDD for high-risk situations, STR filing to FIU-Jordan, record-keeping for 5 years, appointment of a compliance officer, employee training, and independent audit requirements.
Key Restrictions
- The publisher cannot market or promote the software as a financial service, payment method, or investment vehicle to Jordanian residents, as any dealing in or promotion of cryptocurrencies within Jordan is prohibited by the CBJ.
- The publisher must not engage with Jordanian financial institutions (banks, payment service providers) for on-ramp/off-ramp or payment processing related to the software, as those institutions are prohibited from facilitating crypto transactions.
- The publisher cannot operate a node, staking service, or any value-transfer facilitation that could be construed as 'dealing in cryptocurrencies' under CBJ warnings.
- No licensing requirement exists for software publishers because the CBJ has not opened any licensing pathway for crypto activities—the market is effectively closed.
Key Risks
- Enforcement risk: While CBJ enforcement has targeted fraud/scam cases and financial institutions, there is ambiguity about whether a non-custodial software publisher could attract enforcement attention for 'facilitating' crypto access even without custody.
- Regulatory ambiguity: No VASP classification exists, so a self-custodial publisher's legal status is untested—could be deemed to be 'dealing' in crypto by implication.
- Distribution risk: Providing the software to Jordanian residents via app stores or direct download could be interpreted as promoting crypto activities, which the CBJ warns against.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Repeated warnings and clarifications of the prohibition.
Directives to financial institutions to not deal with crypto.
Regulator Name: Central Bank of Jordan (CBJ)
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.
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.
Not Legal Tender: Virtual assets (like Bitcoin) are explicitly stated not to be legal tender in Jordan.
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.
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 self-custodial wallet publisher is not classified as a VASP or MSB under Jordanian law because it never holds or controls user funds, so no AML obligations or licensing requirements attach; however, the publisher must avoid marketing the software as a financial service, must not integrate with Jordanian financial institutions (which are prohibited from dealing with crypto), and faces ambiguity over whether distribution to Jordanian residents could be construed as prohibited crypto activity under the CBJ's blanket warnings.
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?