Crypto ATM / kiosk operator in Morocco

2017 Warnings: Bank Al-Maghrib (BAM - Morocco's central bank) and the Moroccan Exchange Office issued strong warnings against the use of cryptocurrencies.

The Moroccan Exchange Office (Office des Changes) explicitly declared that engaging in cryptocurrency transactions constitutes a violation of the current foreign exchange regulations, which stipulate that foreign exchange transactions must be conducted through authorized intermediaries and in currencies listed by BAM.

Bank Al-Maghrib reiterated its stance, highlighting the risks associated with virtual currencies, including lack of legal protection, price volatility, and potential use for illicit activities.

Result: This effectively made the use of cryptocurrencies for transactions or business operations illegal in Morocco under existing laws, with no legal pathway for VASP operations.

No Specific Licenses: Because there is no specific virtual asset regulatory framework in place, there are no specific licenses required or available for:

Cryptocurrency Exchanges: There's no licensing regime for operating a crypto exchange.

Custody Providers: No specific license exists for virtual asset custody services.

Payment Processors: Companies processing payments using virtual assets would face the same regulatory hurdles as exchanges, as the underlying assets are not recognized for such purposes.

Moot Point: This distinction is currently moot as neither a registration nor a licensing regime exists for virtual assets in Morocco. Any future framework would likely determine which approach (or a hybrid) is adopted based on the level of risk and oversight deemed necessary. Given Morocco's conservative financial regulatory approach, a comprehensive licensing regime for VASPs is highly probable once the framework is established.

No Enacted Law Yet: Despite these efforts, the proposed law has not yet been finalized, approved by the government, or published in the Official Bulletin. Therefore, the historical warnings remain the de facto regulatory environment.

Intention to Regulate: Recognizing the global rise of cryptocurrencies and the need to address them, Bank Al-Maghrib has publicly announced its intention to introduce a regulatory framework for virtual assets.

Local Presence: Foreign entities wishing to operate in Morocco would almost certainly be required to establish a local legal entity (e.g., a subsidiary) and have a physical presence, management, and staff in Morocco.

AML/KYC Obligations: This is virtually guaranteed. Morocco already has robust anti-money laundering and combating the financing of terrorism (AML/CFT) laws (e.g., Law No. 43-05 as amended). Any regulated VASP would be subject to strict AML/CFT obligations, including:

Customer Due Diligence (CDD) / Know Your Customer (KYC) procedures.

Ongoing monitoring of transactions.

Suspicious Activity Reporting (SAR) to the Financial Intelligence Unit (FIU) – L'Unité de Traitement du Renseignement Financier (UTRF).

Prohibition/Lack of Legal Framework: BAM views cryptocurrencies as operating outside of the legal and regulatory framework for financial transactions in Morocco, exposing users to significant risks. This means that operating a Virtual Asset Service Provider (VASP) or conducting significant crypto-related business within Morocco itself could be deemed illegal or at least highly unregulated and risky.

Sanctioned Entity Screening: VASPs must screen all customers, beneficial owners, and transaction counterparties against OFAC's Specially Designated Nationals and Blocked Persons (SDN) List and other relevant sanctions lists.

EU Financial Sanctions Map (Consolidated List): EU Sanctions Map