Crypto ATM / kiosk operator in Zambia
Physical kiosks that exchange cash for crypto (and sometimes vice versa). High-cash AML risk profile.
Crypto ATM is conditionally permitted in Zambia with a local entity, subject to AML obligations and high licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- Yes
- Licensing burden
- High
- Last updated
- 2026-07-13
AML Obligations
- No specific VASP/AML framework exists for virtual assets — general AML/CFT obligations under the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010 apply only if the operator qualifies as a financial institution or DNFBP, which is unclear for crypto ATMs.
- No defined cash-transaction reporting threshold for crypto-to-cash operations — the existing AML framework does not explicitly cover virtual asset cash transactions.
- No Travel Rule obligations currently in effect — FATF standards for VASPs have not been transposed into Zambian law.
- If the operator is deemed a reporting entity, general suspicious transaction reporting (STR) obligations to the Financial Intelligence Centre (FIC) would apply under the 2010 AML Act.
- No enhanced-KYC obligations specific to cash-in/cash-out crypto transactions exist in current law.
Key Restrictions
- Cryptocurrencies are not recognized as legal tender in Zambia — a crypto ATM cannot offer cash-for-crypto services on a legal-tender basis.
- No licensing framework exists for crypto ATMs or VASPs — any operator would be in a legal grey area with no authorized license to apply for.
- Bank of Zambia has issued repeated public warnings that virtual asset activities are unregulated and consumers have no investor protection or recourse.
- The National Payment Systems Act, No. 2 of 2023 gives BoZ power to license payment service providers — this could be used to regulate crypto ATMs in the future but has not been applied yet.
- Any cash-handling activity may trigger general banking/financial services licensing requirements under the Banking and Financial Services Act, 2017 if deemed a financial service.
Key Risks
- High regulatory ambiguity risk — no clear legal path to operate, creating exposure to sudden enforcement or shutdown.
- Enforcement risk from BoZ warnings against unregulated financial activities — though no specific crypto enforcement actions exist, general fraud/money laundering law enforcement could apply.
- ESAAMLG mutual evaluation (2019) identified Zambia's lack of VASP regulation as a gap — FATF-driven regulatory changes could impose retroactive compliance burdens.
- Reputational and PR risk — BoZ's public warnings paint crypto activities as high-risk and unregulated, potentially deterring partners and customers.
- Cash-heavy nature of ATM operations amplifies AML risk exposure in a jurisdiction with no tailored AML framework for crypto cash transactions.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
Unregulated, but Not Banned: Crypto trading and the operation of crypto exchanges in Zambia are not explicitly illegal, but they are also not officially regulated or licensed by any specific framework for virtual assets. This places them in a "grey area."
Regulatory Warnings: The Bank of Zambia has repeatedly issued warnings to the public regarding the risks associated with investing in or trading cryptocurrencies. Key points of these warnings include:
Not Legal Tender: Cryptocurrencies are not recognized as legal tender in Zambia.
No Investor Protection: Since they are unregulated, consumers engaging in crypto transactions do so at their own risk, with no recourse to the BoZ or other regulatory bodies for protection against loss, fraud, or operational failures of exchanges.
National Payment Systems Act, No. 2 of 2023:
Banking and Financial Services Act, 2017:
Anti-Money Laundering and Countering the Financing of Terrorism Act, 2010 (as amended):
No, not specifically for virtual assets and VASPs. Zambia's primary AML/CFT legislation, the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010 (and its amendments), as well as associated regulations, does not explicitly extend to the comprehensive regulation of virtual assets or the oversight of VASPs as financial institutions or Designated Non-Financial Businesses and Professions (DNFBPs).
The ESAAMLG's 2019 Mutual Evaluation Report of Zambia highlighted significant gaps in this area. It noted that virtual assets were not adequately covered by the AML/CFT framework, and there was no specific licensing or registration regime for VASPs.
Which VASPs are Covered:
Currently, none are explicitly covered under a specific regulatory regime for virtual assets. As per the 2019 ESAAMLG MER, Zambia had not identified or defined VASPs under its AML/CFT laws, nor had it imposed AML/CFT obligations on them. Any entity operating with virtual assets in Zambia currently does so in a largely unregulated environment from an AML/CFT perspective, though the Bank of Zambia has issued warnings regarding the risks associated with cryptocurrencies.
Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010: This is Zambia's principal AML/CFT legislation. While it is the foundational law, it does not specifically address virtual assets or VASPs. Finding an official, up-to-date government-published link can be challenging, but it forms the basis of the Financial Intelligence Centre's (FIC) operations.
Financial Intelligence Centre (FIC) Zambia: The FIC is Zambia's financial intelligence unit and the primary body for AML/CFT oversight.
Caution and Warnings: The Bank of Zambia consistently advises against the use of cryptocurrencies due to risks and their unregulated status.
No Legal Tender Status: Cryptocurrencies are explicitly not recognized as legal tender in Zambia.
Lack of a Specific Regulatory Framework: As of now, there isn't a comprehensive regulatory framework specifically governing cryptocurrency exchanges or services that would allow for detailed enforcement actions akin to those seen in more established crypto jurisdictions.
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 — crypto ATM/kiosk operation in Zambia is neither explicitly banned nor regulated, operating in a legal grey area with no available license, no legal-tender status for crypto, and no VASP-specific AML framework; a local entity would be necessary but no formal licensing pathway exists, creating high legal and enforcement risk.
Questions this verdict aims to answer
- What money-transmitter / kiosk-specific license is required?
- What cash-transaction reporting thresholds apply?
- What enhanced-KYC obligations attach to cash-in / cash-out?