Self-custodial wallet / non-custodial software in North Macedonia
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 North Macedonia 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
- AML obligations do not attach to pure non-custodial wallet publishers because the publisher never holds, controls, or has access to user funds, and thus does not meet the VASP definition under the Law on Prevention of Money Laundering and Terrorist Financing (which covers exchange, transfer, and custody services).
- If the wallet software incorporated any exchange, fiat on/off-ramp, or custodial feature, the operator would become a VASP and would need mandatory registration with the Financial Intelligence Unit (FIU).
Key Restrictions
- The National Bank of North Macedonia (NBRSM) has issued official warnings that cryptocurrencies are not legal tender and has prohibited supervised financial institutions from dealing in crypto, but this does not apply to software publishers.
- Publishing non-custodial wallet software does not fall under the Law on Payment Services and Payment Systems, which regulates traditional payment services and fiat handling.
- No explicit consumer-protection or disclosure regime specifically governs non-custodial wallet software; general consumer protection laws would apply.
- The NBRSM has stated that crypto does not fall under its regulatory supervision, creating an unregulated gap that includes non-custodial software.
Key Risks
- Regulatory ambiguity: The NBRSM's warnings create a cautious and potentially hostile tone, which could lead to unpredictable enforcement or future legislative changes targeting software publishers.
- Enforcement risk from law enforcement (Ministry of Interior, Financial Police) targeting fraud schemes that leverage crypto — legitimate wallet software could be associated with illicit use, drawing scrutiny.
- No clear licensing or legal framework for non-custodial wallet publishers means there is no safe harbor — regulatory status could change overnight.
- Consumer complaints about fraud involving the wallet software could attract negative attention from the Public Prosecutor's Office even if the publisher is not at fault.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
NBRSM Official Statement (November 2021): https://www.nbrm.mk/ns-newsarticle-soopstenie_za_javnost-23112021.nspx (Macedonian)
Law on Prevention of Money Laundering and Terrorist Financing
Regulating Authority: Financial Intelligence Unit (FIU) of North Macedonia (Управата за финансиско разузнавање - УФР) is the primary authority for VASP registration and AML/CTF supervision.
Law on Payment Services and Payment Systems: This law regulates traditional payment services.
Regulator Name: National Bank of the Republic of North Macedonia (Народна банка на Република Северна Македонија - NBRSM)
Note: While not a direct "enforcement" with a penalty, this is the most significant regulatory action outlining the country's stance on crypto and warning against its use, serving as a basis for potential future enforcement.
Criminal investigations and prosecutions by law enforcement (Ministry of Interior, Financial Police, Public Prosecutor's Office) targeting activities such as fraud, money laundering, or illegal electricity usage for crypto mining.
Entity Targeted: General public, financial institutions under NBRSM supervision (banks, savings houses). Violation Type: While not a "violation" in the traditional sense, the NBRSM has consistently warned against the risks associated with cryptocurrencies and explicitly prohibited supervised financial institutions from dealing with them. This sets the regulatory boundary. Penalty Amount: N/A (This is a regulatory warning/stance, not a direct penalty for a specific breach by a regulated entity). Outcome: Heightened public awareness of crypto risks, reinforced prohibition for traditional financial institutions, setting a cautious regulatory tone. The NBRSM maintains that cryptocurrencies are not legal tender and do not fall under its regulatory supervision.
Outcome: Heightened public awareness of crypto risks, reinforced prohibition for traditional financial institutions, setting a cautious regulatory tone. The NBRSM maintains that cryptocurrencies are not legal tender and do not fall under its regulatory supervision.
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 — Publishers of non-custodial / self-custodial wallet software do not trigger VASP classification or AML obligations under current Macedonian law (since they never hold or control user funds), but operate in an unregulated gray area with no explicit legal framework, warnings from the National Bank against crypto use, and potential law enforcement scrutiny around fraud-related crypto activity.
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?