Centralized exchange in Libya
Order-book exchange that takes custody of user assets and matches trades between users.
CEX is not permitted in Libya.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No specific AML obligations for VASPs exist — the CBL has banned all cryptocurrency activity via Circular No. 2 of 2018, making any VASP operation unlawful.
- If illicit crypto activity were prosecuted, Law No. 1 of 2021 AML/CFT obligations (CDD, ongoing monitoring, STR reporting to LFIU) would theoretically apply, but no lawful pathway to comply exists for a VASP.
- Suspicious Transaction Reports (STRs) would need to be filed with the Libyan Financial Intelligence Unit (LFIU) under Law No. 1 of 2021, but this is moot for an unlicensed activity.
Key Restrictions
- All cryptocurrency dealing, trading, exchanging, and possession is effectively illegal — CBL Circular No. 2 of 2018 explicitly bans financial institutions and individuals from dealing in virtual currencies.
- No licensing or registration framework exists for VASPs, exchanges, or any crypto-asset service providers.
- Commercial banks and other financial institutions are prohibited from facilitating any cryptocurrency-related transactions.
- There is no mechanism for legal incorporation or operation of a centralized exchange in Libya.
Key Risks
- Criminal exposure — engaging in crypto exchange activity could be prosecuted under existing AML/CFT laws or general financial crime statutes.
- Regulatory ambiguity is low because the ban is clear, but enforcement transparency is limited and legal recourse unpredictable.
- Absence of any legal framework means zero consumer protection or dispute resolution mechanisms for users.
- Libya's divided political landscape and security situation create additional operational and reputational risks.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Central Bank of Libya (CBL) Circular No. 2 of 2018:
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.
Outcome: Cryptocurrencies remain illegal in Libya.
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.
No Specific Rules: Similarly, there are no specific rules governing the secondary trading of cryptocurrency tokens. Any attempt to engage in such trading would fall under the general prohibitions or warnings issued by the CBL regarding cryptocurrency transactions.
VASPs, if regulated, would be obliged to report any suspicious transactions to the Financial Intelligence Unit (FIU).
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.
Entity Targeted: All individuals and financial institutions within Libya (general ban, not a specific entity). Violation Type: Dealing in, trading, or possessing cryptocurrencies. Penalty Amount: Not applicable to the ban itself, but potential penalties under Libyan law for illegal financial activities could include fines and imprisonment.
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 — a centralized exchange cannot lawfully operate in Libya because the Central Bank of Libya has explicitly banned all dealing in virtual currencies via Circular No. 2 of 2018, and no licensing or regulatory framework exists for VASPs.
Questions this verdict aims to answer
- What exchange / VASP license applies?
- What custody segregation rules apply to user assets?
- What market-conduct and listing rules apply?
- What travel-rule obligations apply on withdrawals?