Crypto ATM / kiosk operator in Libya

Central Bank of Libya (CBL) Circular No. 2 of 2018:

Content: This is the most significant directive. It explicitly warned against dealing in virtual currencies due to the absence of a regulatory framework, high risks, and potential for fraud, money laundering, and terrorism financing. It effectively banned commercial banks and other financial institutions from processing transactions related to cryptocurrencies.

General Prohibition: All virtual currencies are generally subject to the same prohibitory or highly restrictive guidance issued by the CBL. The CBL does not distinguish based on the underlying nature or rights conferred by the token; rather, it focuses on the medium of exchange itself being unregulated and risky.

Unregulated and Discouraged: The CBL has consistently warned against engaging in any form of dealing, exchanging, or trading of virtual currencies.

CBL Warnings: The Central Bank of Libya has consistently issued strong warnings to financial institutions and the public against dealing with virtual currencies. These warnings constitute the primary enforcement mechanism, deterring widespread adoption and use.

None Exist: There are no established registration or exemption requirements for token issuers in Libya. This is primarily because the issuance or facilitation of trading such tokens is not a recognized or permitted activity under current regulations. The CBL's guidance effectively makes it unfeasible or illegal for entities to operate in this space.

Lack of Legal Basis: Without a legal framework that recognizes and regulates crypto assets, there is no mechanism for issuers to seek registration or exemptions.

AML/CFT Prosecution: Any use of cryptocurrencies in illicit activities (e.g., money laundering, financing terrorism, fraud) would fall under Libya's existing Anti-Money Laundering and Combating the Financing of Terrorism laws. While these laws are not crypto-specific for securities classification, they provide a legal basis for prosecuting individuals involved in illicit financial activities, regardless of the asset used.

Absence of regulatory oversight and legal framework.

Outcome: Cryptocurrencies remain illegal in Libya.

Date: The initial ban was issued in 2018, and it has been reaffirmed multiple times since. There is no indication it has been lifted in the last three years.

Report mentioning the 2018 ban and the CBL's stance:

Law No. 1 of 2021 on Anti-Money Laundering and Combating the Financing of Terrorism (Amending and replacing earlier laws like Law No. 2 of 2005).

VASPs, if regulated, would be obliged to report any suspicious transactions to the Financial Intelligence Unit (FIU).

Reporting Obligation: Any transaction, attempted transaction, or activity that raises suspicions of money laundering or terrorist financing must be reported promptly.