Crypto-funded debit card in Yemen

Yemen does not have dedicated laws or regulations specifically addressing virtual assets, cryptocurrencies, or Virtual Asset Service Providers (VASPs).

The use of cryptocurrencies in Yemen is often discussed in the context of remittances, circumventing sanctions, or as an alternative store of value, rather than a regulated financial activity.

None Specific for Virtual Assets.

Payment Processors: Could be viewed as an unauthorized payment service provider or a money transmitter.

De Facto Prohibition/High Risk: Without a clear legal framework, engaging in such activities carries significant legal risk, including potential penalties for operating an unlicensed financial service, confiscation of assets, or criminal charges, depending on how authorities might interpret activities. It is more likely to be viewed with suspicion than to be regulated.

No specific requirements for virtual assets.

AML/KYC (Anti-Money Laundering/Know Your Customer): Yemen has general AML/CFT (Combating the Financing of Terrorism) laws, even if their enforcement is challenging and fragmented.

Operating without explicit AML/KYC protocols would be a significant red flag and expose operators to severe legal and reputational risks.

Local Presence: If a licensing regime were to be established, a local presence (e.g., registered entity, physical office, local management) would almost certainly be a requirement, as is common for financial services firms in most jurisdictions.

Law No. 1 of 2010 on Combating Money Laundering and Terrorism Financing: This is the primary AML/CFT law in Yemen. It establishes the legal framework for identifying, freezing, and confiscating illicit funds, and mandates reporting obligations for financial institutions.

Central Bank of Yemen Regulations: The CBY issues various regulations and instructions to financial institutions (banks, money exchangers, insurance companies) regarding the implementation of the AML/CFT law. These would cover traditional financial services.

Identification and Verification: Obtaining and verifying the identity of customers (individuals and legal entities) using reliable, independent source documents, data, or information. This includes name, address, date of birth/incorporation, nationality, identification numbers.

Beneficial Ownership: Identifying and verifying the beneficial owner(s) of legal entities.

Purpose and Nature of Business Relationship: Understanding the purpose and intended nature of the business relationship or occasional transaction.

Ongoing Monitoring: Conducting ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the obliged entity's knowledge of the customer, their business, and risk profile.

Enhanced Due Diligence (EDD): For higher-risk customers, politically exposed persons (PEPs), or complex transactions, more rigorous checks would be required. Given the illegal status of crypto, any involvement would inherently be high-risk.

Obligation to Report: Financial institutions and designated non-financial businesses and professions (DNFBPs) are legally obliged to report any suspicious transactions or activities to the Financial Information Unit (FIU).

Definition of Suspicious Transaction: Any transaction that gives rise to a suspicion of money laundering or terrorism financing, regardless of the amount.

Virtual Assets: Given the outright ban, any transaction involving virtual assets would inherently be considered suspicious and a potential predicate offense under the AML/CFT law.

Duration: Financial institutions are required to maintain records of customer identification data, account files, business correspondence, and transaction data for a period of at least five (5) years after the business relationship has ended or the transaction has been completed.

Accessibility: Records must be maintained in a way that allows for rapid retrieval by competent authorities upon request.

Central Bank of Yemen (CBY): The CBY is the primary financial sector regulator and supervisor responsible for overseeing AML/CFT compliance of banks and other financial institutions. Due to the ongoing conflict, there are effectively two CBYs:

Central Bank of Yemen (Aden-based): This is the internationally recognized CBY and the one that issued the crypto ban.

Financial Information Unit (FIU): This unit is responsible for receiving, analyzing, and disseminating suspicious transaction reports (STRs) to law enforcement agencies. The FIU in Yemen operates under the umbrella of the government's financial oversight mechanisms.