← Regulations / Tunisia / Operating Models / Stablecoin issuer

Stablecoin issuer / redeemer in Tunisia

Issues a fiat-pegged stablecoin to the public, operates redemption, and holds reserves backing the float.

Not permitted AI-Generated · Unreviewed

Stablecoin issuer is not permitted in Tunisia.

Verdict Details

Permitted
no
Local entity required
Yes
Licensing burden
High
Last updated
2026-07-13

AML Obligations

  • Customer due diligence (KYC) under Law No. 2022-77 (replacing Law No. 2015-26).
  • Risk-based approach to AML/CFT compliance.
  • Transaction monitoring for suspicious activity.
  • Reporting suspicious transactions to the Commission Tunisienne des Analyses Financières (CTAF) — Tunisia's FIU.
  • Compliance with UN Security Council targeted financial sanctions (e.g., Al-Qaida/ISIL, DPRK, Iran) incorporated into Tunisian law.
  • Compliance with FATF Recommendation 15 on virtual assets and VASPs (Tunisia assessed via MENAFATF).
  • Sanctions screening against UN Consolidated Sanctions List, and where nexus exists, EU and OFAC SDN lists.

Key Restrictions

  • No specific licensing regime exists for stablecoin issuers — issuance is not legally recognized.
  • Stablecoin issuance would likely be treated as an unauthorized financial service under Law No. 2016-71 on Payment Institutions.
  • The Banque Centrale de Tunisie (BCT) has explicitly warned against cryptocurrencies and deems them unauthorized — stablecoins are not distinguished from other crypto.
  • Cryptocurrencies are not recognized as legal tender in Tunisia.
  • If a stablecoin is pegged to the Tunisian Dinar, it would likely fall under e-money laws requiring BCT authorization, which is highly improbable to obtain.
  • No specific reserve, segregation, or audit requirements exist for stablecoin issuers under Tunisian law.

Key Risks

  • High enforcement risk — BCT has repeatedly warned that dealing in virtual currencies is unauthorized and engages enforcement exposure.
  • Legal void — no clear classification of stablecoins; any activity could be deemed an unlicensed financial service.
  • No redemption rights are legally mandated; contractual rights may be unenforceable if the operation is deemed illegal.
  • Tax treatment is entirely undefined — income from stablecoin issuance cannot be reported under existing tax rules, creating tax compliance risk.
  • No pathway to licensing or authorization from the BCT for private stablecoin issuance is evident.
  • Potential conflict with any future Tunisian CBDC (e-Dinar) issuance, which would likely displace private stablecoins.

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

stablecoin 60% confidence

No explicit classification: Tunisian law does not explicitly classify stablecoins as e-money, payment tokens, or securities.

stablecoin 60% confidence

Likely Default Treatment: Due to the absence of specific legislation, stablecoins are generally treated as unregulated and unauthorized financial instruments.

stablecoin 60% confidence

Potential "e-money" conflict: If a stablecoin were pegged to the Tunisian Dinar or aimed to function as a payment instrument, it would likely fall under the scope of laws governing electronic money and payment services. However, without explicit BCT authorization (which is highly unlikely given their current stance), such an operation would be considered illegal. The primary legislation in this area is:

stablecoin 60% confidence

Loi n° 2016-71 du 30 septembre 2016, relative aux établissements de paiement (Law No. 2016-71 of September 30, 2016, on Payment Institutions). This law defines electronic money and regulates the issuance of electronic money by authorized payment institutions. Stablecoins, particularly fiat-backed ones, could conceptually fit some aspects of this definition if they were recognized and licensed, but currently, they are not.

stablecoin 60% confidence

No Specific License: There is no specific licensing regime for stablecoin issuers in Tunisia.

stablecoin 60% confidence

General Prohibition: Any entity seeking to issue or facilitate the use of stablecoins for payment purposes within Tunisia would likely be seen as operating an unauthorized financial service, potentially violating existing laws related to currency issuance and payment services.

stablecoin 60% confidence

BCT Authorization: Under Law 2016-71, any entity providing payment services or issuing electronic money requires explicit authorization from the BCT. It is highly improbable that the BCT would grant such authorization for stablecoin issuance.

stablecoin 60% confidence

No Mandated Rights: Due to the lack of specific regulation, there are no legally mandated redemption rights for stablecoin holders in Tunisia.

stablecoin 60% confidence

None Specified: As stablecoins are not explicitly regulated or authorized, there are no specific reserve requirements for stablecoin issuers under Tunisian law.

licensing 60% confidence

Cryptocurrencies are not recognized as legal tender in Tunisia.

licensing 60% confidence

Transactions involving cryptocurrencies are not authorized by the BCT.

licensing 60% confidence

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.

licensing 60% confidence

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.

aml 20% confidence

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).

aml 20% confidence

Definition of Virtual Assets: The law generally adopts a broad definition consistent with FATF standards, recognizing them as a digital representation of value that can be digitally traded or transferred and used for payment or investment purposes.

aml 20% confidence

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:

aml 60% confidence

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.

tax 60% confidence

There are no specific capital gains tax rates for cryptocurrencies in Tunisia.

tax 60% confidence

There is no specific income tax regime for income derived from cryptocurrency activities (e.g., mining, staking, trading income, salaries paid in crypto).

custody 20% confidence

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

custody 20% confidence

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.

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.

Not permitted — stablecoin issuance is not legally recognized or authorized under Tunisian law; no licensing pathway exists, the BCT prohibits crypto-related financial services, and any attempt to issue a stablecoin would likely be treated as an unauthorized financial service carrying enforcement risk.

Questions this verdict aims to answer

  • What e-money or banking license is required to issue?
  • What reserve composition, segregation, and audit rules apply?
  • What redemption rights must be granted to holders?
  • Are foreign-issued stablecoins permitted for use locally?