On-shore VASP in Tunisia

Cryptocurrencies are not recognized as legal tender in Tunisia.

Transactions involving cryptocurrencies are not authorized by the BCT.

Exchanges: There is no legal framework allowing the operation of crypto exchanges. Any attempt to operate one would be in violation of the BCT's stance and existing financial laws.

Custody Providers: Similarly, no specific license exists. Providing custody for virtual assets would fall into the same regulatory void/prohibition.

Payment Processors: Companies processing payments in or with cryptocurrencies would face the same regulatory hurdles as exchanges. Traditional payment service provider licenses (issued by the BCT for fiat currencies) would not extend to virtual assets given their non-recognition.

Local Presence: A physical presence in Tunisia, including a local registered office, and potentially local management and staff.

Capital Requirements: Substantial minimum capital requirements to ensure financial stability and cover operational risks.

Fit and Proper Requirements: For management, board members, and significant shareholders.

Banque Centrale de Tunisie (BCT) Official Website:

Law No. 2022-77 of December 26, 2022, on Combating Money Laundering and Terrorist Financing (Loi n° 2022-77 du 26 décembre 2022, relative à la lutte contre le blanchiment d'argent et le financement du terrorisme).

Definition of Virtual Asset Service Providers (VASPs): It explicitly includes VASPs as "reporting entities" (or "obliged entities" / "personnes assujetties"). While the law itself may not define all types of VASPs exhaustively, it typically covers entities that conduct one or more of the following activities for or on behalf of another natural or legal person:

Compliance Requirement: Tunisia is legally bound to implement UN Security Council (UNSC) resolutions that impose targeted financial sanctions. These primarily relate to counter-terrorism (e.g., against Al-Qaida, ISIL/Da'esh affiliates) and counter-proliferation of weapons of mass destruction. All financial institutions, including VASPs (once explicitly regulated or by analogy), must freeze assets and prevent funds/services from being made available to designated individuals and entities on the UN Consolidated Sanctions List.

Tunisia's Status: The MENAFATF's 2019 Mutual Evaluation Report (MER) for Tunisia highlighted that Tunisia needed to adopt legislative and regulatory measures to apply the FATF Recommendations to virtual assets and VASPs. While progress has been made, the underlying AML/CFT obligations apply.

Conduct customer due diligence (KYC).

Implement risk-based approaches.

Monitor transactions for suspicious activity.

Absence of a Legal Framework: There is no specific law or regulation defining cryptocurrencies, digital assets, or the services related to them (including custody).

Official Warnings: The BCT has issued several warnings against the use of cryptocurrencies, citing their speculative nature, lack of legal tender status, volatility, and risks associated with money laundering and terrorist financing. These warnings generally discourage engagement with these assets rather than regulate their operation.

No Licensing Regime for VASPs: Without a defined legal framework, there are no specific licensing requirements for Virtual Asset Service Providers (VASPs), including those offering custody services.

Entity Targeted: Iskander Najar (also sometimes reported as Islem Najar), a young Tunisian individual. Violation Type: Illegally using cryptocurrency to transfer money abroad, violating Tunisian foreign exchange laws (specifically, the prohibition on non-authorized transfers of foreign currency) and potentially money laundering charges. Penalty Amount: Initial sentence of two years in prison and a fine of 5,000 Tunisian Dinars (TND) (approximately $1,700 at the time). This sentence was later reduced on appeal. Specific details of the reduced fine are less widely reported than the prison sentence reduction.

Outcome: Najar was convicted and served time in prison. The case garnered significant international attention, with many advocating for his release and highlighting the severity of Tunisia's stance on crypto. His sentence was ultimately reduced on appeal, and he was released after serving part of his term. The outcome reinforced Tunisia's strict interpretation of its foreign exchange laws concerning digital assets.

There is currently no crypto-specific tax legislation in Tunisia.