Centralized exchange 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.

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.

Ongoing Work: BAM has been working in consultation with international bodies like the International Monetary Fund (IMF) and the World Bank to draft a comprehensive bill. This work has been ongoing since at least late 2022 and throughout 2023.

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.

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.

Historical Prohibition: An official ban on the use and trading of cryptocurrencies.

Lack of Legal Tender Status: Cryptocurrencies are not recognized as legal tender.

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.

No Direct Implementation for VASPs: However, Morocco has not formally adopted specific legislation to regulate Virtual Asset Service Providers (VASPs) or directly implement the FATF Travel Rule for them. This is because the Moroccan financial authorities have largely prohibited the use and trading of cryptocurrencies and virtual assets within the official financial system.

Official Stance: Bank Al-Maghrib (BAM), the central bank, and the Moroccan Capital Market Authority (AMMC), in conjunction with the Ministry of Economy and Finance, have repeatedly issued warnings against the use of cryptocurrencies, stating that they are not legal tender, lack legal backing, and pose significant risks. This effectively means there are no licensed or regulated VASPs in Morocco to whom the Travel Rule would apply.

Since there is no specific regulatory framework for VASPs or a direct implementation of the Travel Rule, there is no effective date for its application in Morocco.

Foreign VASPs serving Moroccan customers would be operating in a legal grey area, as their services are considered non-compliant with Moroccan financial regulations.

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.