Self-custodial wallet / non-custodial software in Zambia
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Zambia without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No specific AML/CFT obligations attach to a self-custodial wallet publisher under current Zambian law — the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010 does not explicitly extend to virtual assets or VASPs (zm.aml.no-not-specifically-for-virtual)
- The 2019 ESAAMLG Mutual Evaluation Report confirmed that Zambia had not identified or defined VASPs under its AML/CFT laws and had not imposed AML/CFT obligations on them (zm.aml.the-esaamlgs-2019-mutual-evaluation)
- If the publisher were determined to be a financial institution or DNFBP under existing law, general AML obligations (customer due diligence, suspicious transaction reporting to the FIC) could theoretically apply, but this has not been tested for non-custodial software (zm.aml.which-vasps-are-covered)
- No Travel Rule applies — the specific framework for virtual asset Travel Rule has not been adopted, so there is no effective date, threshold, or technical implementation requirement (zm.aml.na-since-the-specific-framework, zm.aml.na-without-specific-legislation-covering, zm.aml.na-as-the-travel-rule)
Key Restrictions
- Self-custodial wallet software publishing does not currently trigger any financial-services licensing requirement because the publisher never holds, controls, or accesses user funds (zm.custody.currently-there-are-no-specific)
- Cryptocurrencies are not recognized as legal tender in Zambia — the BoZ has repeatedly warned the public that using virtual assets carries no legal protection (zm.licensing.not-legal-tender-cryptocurrencies-are)
- No investor protection applies — consumers transacting with or through unregulated crypto services have no recourse to BoZ or other regulators (zm.licensing.no-investor-protection-since-they)
- The National Payment Systems Act, No. 2 of 2023 may in the future extend to certain payment-related crypto services, but does not currently cover non-custodial software publishers (zm.licensing.national-payment-systems-act-no)
Key Risks
- Regulatory ambiguity — the legal status of non-custodial wallet software is untested; a future regulator could reclassify publishing as a 'payment service' under the National Payment Systems Act or as a financial service under the Banking and Financial Services Act (zm.licensing.banking-and-financial-services-act)
- BoZ has signalled intent to develop a comprehensive virtual-asset framework, including potential licensing for all crypto-related services, which could retroactively capture wallet publishers (zm.custody.bank-of-zambias-fintech-regulatory-sandbox-and-virtual-assets-framework)
- Widespread public warnings from BoZ create a negative perception risk for any entity associating itself with crypto in Zambia (zm.enforcement.caution-and-warnings-the-bank)
- ESAAMLG pressure to comply with FATF Recommendation 15 could force Zambia to regulate VASPs including wallet providers, imposing AML/CFT obligations retroactively (zm.aml.while-zambia-is-committed-to)
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."
National Payment Systems Act, No. 2 of 2023:
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.
Banking and Financial Services Act, 2017:
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:
N/A. Since the specific framework for virtual assets and the Travel Rule has not been adopted, there is no effective date.
N/A. Without specific legislation covering VASPs, there are no defined threshold amounts for the Travel Rule. For traditional wire transfers, the threshold amounts for originator and beneficiary information requirements would typically follow existing AML/CFT regulations.
N/A. As the Travel Rule has not been formally adopted for VASPs, there are no specific technical implementation requirements.
Currently, there are no specific licenses for crypto asset custodians in Zambia. Financial institutions dealing with traditional securities or funds require licensing from the Bank of Zambia or the Securities and Exchange Commission, but these licenses do not extend to, nor are there separate licenses for, digital asset custody.
Evidence fact zm.custody.bank-of-zambias-fintech-regulatory-sandbox-and-virtual-assets-framework not found (may have been renamed).
Caution and Warnings: The Bank of Zambia consistently advises against the use of cryptocurrencies due to risks and their unregulated status.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- high
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — publishing self-custodial wallet software does not currently trigger VASP/MSB classification, AML obligations, or licensing requirements in Zambia because the jurisdiction has no specific regulatory framework for virtual assets and VASPs, but this operates in a legal grey area where the regulator has warned the public against crypto use and future regulation is likely.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?