Chad -- Custody Regulations Regulatory Overview

Chad, as a member state of the Central African Economic and Monetary Community (CEMAC), falls under the monetary and financial regulatory authority of the Bank of Central African States (Banque des États de l'Afrique Centrale - BEAC). The BEAC has adopted a highly restrictive, largely prohibitive stance on cryptocurrencies and digital assets.

Consequently, there is no specific, detailed regulatory framework for cryptocurrency/digital asset custody in Chad, primarily because the activities themselves are either prohibited or heavily discouraged for regulated financial institutions. Instead of creating rules for how to custody digital assets, the BEAC's directives have focused on warning against or preventing engagement with them by financial entities under its supervision.

Here's a breakdown based on the BEAC's general stance:

• Custodial License Requirements:

  • No specific custodial license requirements exist for digital assets. This is not because the activity is unregulated, but because regulated financial institutions are generally warned against or prohibited from engaging in activities involving crypto assets.
  • The BEAC views cryptocurrencies as inconsistent with the CEMAC monetary policy and the stability of its financial system. Engaging in such activities would likely be seen as a violation of existing banking and financial regulations rather than an activity requiring a specific crypto license.

• Segregation of Client Assets Rules:

  • No specific rules exist. Since regulated financial institutions are not encouraged to hold or custody digital assets, there are no established rules for segregating client assets in this context.

• Insurance/Bonding Requirements:

  • None. As institutional custody is not permitted, no insurance or bonding requirements have been established.

• Cold Storage Mandates:

  • None.

• Qualified Custodian Definitions:

  • None. The concept of a "qualified custodian" for digital assets is not defined in Chadian or BEAC regulations.

• Pending Custody Legislation:

  • There is no publicly available information indicating pending legislation specifically addressing cryptocurrency custody in Chad or at the CEMAC level that would enable regulated entities to provide such services.
  • The prevailing sentiment from the BEAC has been one of caution and prohibition, focusing on financial stability risks, money laundering, and terrorist financing concerns associated with crypto assets.

Specific Regulatory References

The primary directive from the BEAC regarding cryptocurrencies is:

• BEAC Circular No. 001/GR/2022 (and related directives in 2021-2022): This circular reportedly warned financial institutions in the CEMAC zone against engaging in crypto-asset-related activities, citing risks to financial stability, money laundering, and consumer protection. While an official English version directly from the BEAC's website can be difficult to locate, its content has been widely reported by financial news outlets.

  • Reference (News Reporting on BEAC Stance):
    • Reuters: https://www.reuters.com/markets/currencies/cemac-central-bank-warns-against-cryptocurrencies-financial-transactions-2022-05-09/
    • Ecofin Agency: https://www.ecofinagency.com/finance/0905-43615-beac-bans-cryptocurrency-transactions-in-cemac

In summary: Chad does not have a regulatory framework for crypto custody. The regional central bank (BEAC) has taken a prohibitive stance, making institutional digital asset custody largely an unauthorized activity for regulated financial entities. Therefore, the specific requirements requested (licensing, segregation, insurance, etc.) do not exist.