← Regulations / Zambia / Operating Models / Stablecoin issuer

Stablecoin issuer / redeemer in Zambia

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

Conditional AI-Generated · Unreviewed

Stablecoin issuer 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 obligations exist under Zambian law currently — the Anti-Money Laundering and Countering of Terrorism Act, No. 13 of 2010 does not explicitly cover virtual assets or VASPs (zm.aml.no-not-specifically-for-virtual)
  • If the stablecoin issuer were classified as a Payment Service Provider under the National Payment Systems Act, 2023, general AML/CFT obligations under the FIC Act, No. 4 of 2020 would apply, including suspicious transaction reporting to the Financial Intelligence Centre (zm.stablecoin.anti-money-laundering-aml-counter-financing-of, zm.licensing.anti-money-laundering-and-countering-the)
  • No Travel Rule obligations apply to VASPs yet — the FATF-compliant framework is still under development (zm.aml.while-zambia-is-committed-to, zm.aml.na-since-the-specific-framework)
  • ESAAMLG 2019 Mutual Evaluation Report identified significant gaps: VASPs not identified, not licensed, not subject to AML/CFT obligations (zm.aml.the-esaamlgs-2019-mutual-evaluation)

Key Restrictions

  • No dedicated stablecoin licensing regime exists — the issuer must be structured to fall under existing financial laws (zm.stablecoin.no-specific-stablecoin-issuer-licensing)
  • If the issuer engages in deposit-taking or banking services, it would need a license under the Banking and Financial Services Act, 2017 (zm.stablecoin.bankingfinancial-service-if-a-stablecoin)
  • If the stablecoin functions as a payment instrument, it would fall under the National Payment Systems Act, 2023, requiring BoZ licensing as a Payment Service Provider (zm.stablecoin.e-moneypayment-token-if-a-stablecoin, zm.licensing.national-payment-systems-act-no)
  • Cryptocurrencies are not legal tender in Zambia (zm.licensing.not-legal-tender-cryptocurrencies-are)
  • No specific reserve composition, segregation, or audit rules exist for stablecoin issuers (zm.stablecoin.no-specific-stablecoin-reserve-requirements)
  • BoZ has advised financial institutions against dealing in crypto assets due to regulatory gaps (zm.custody.the-boz-has-historically-advised)

Key Risks

  • Regulatory ambiguity risk: no explicit classification of stablecoins creates legal uncertainty across e-money, securities, and banking frameworks (zm.stablecoin.no-explicit-classification-the-bank)
  • Enforcement risk: BoZ may issue cease-and-desist orders or public warnings against unlicensed activity relying on a grey-market interpretation
  • Consumer/investor protection risk: holders have no statutory redemption rights — only contractual rights under general contract law with limited enforceability (zm.stablecoin.no-specific-stablecoin-redemption-rights, zm.stablecoin.contractual-basis-redemption-rights-would)
  • ESAAMLG/FATF pressure to regulate VASPs may lead to sudden regulatory changes that could retroactively impact operations (zm.aml.while-zambia-is-committed-to)
  • Active CBDC exploration by BoZ could result in competition or prohibitions on private stablecoins (zm.stablecoin.active-cbdc-exploration-zambia-is)
  • Tax classification risk: gains from stablecoin activities may be recharacterized as business income subject to corporate tax at 30% (zm.tax.companies-earning-profits-from-cryptocurrency)

Evidence

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

stablecoin 60% confidence

No Explicit Classification: The Bank of Zambia has not explicitly classified stablecoins as e-money, payment tokens, or securities under a specific stablecoin regulation.

stablecoin 60% confidence

E-money/Payment Token: If a stablecoin were to function as a store of value and a medium of exchange, facilitating payments, it could potentially be brought under the purview of the National Payment Systems Act, 2007 (and its amendments). This Act regulates payment systems and payment service providers. The BoZ has the authority to issue directives concerning payment instruments.

stablecoin 60% confidence

Security: If a stablecoin offered investment-like features, or if its backing involved assets that could be considered securities, it might potentially fall under the regulation of the Securities Act, 2016, administered by the Securities and Exchange Commission (SEC) Zambia. However, this is less likely for typical stablecoins designed for payments.

stablecoin 60% confidence

Banking/Financial Service: If a stablecoin issuer were to engage in deposit-taking or other traditional banking services, they would fall under the Banking and Financial Services Act, 2017.

stablecoin 60% confidence

Anti-Money Laundering (AML) / Counter-Financing of Terrorism (CFT): Regardless of classification, any entity dealing with stablecoins would be subject to Zambia's AML/CFT framework, primarily governed by the Financial Intelligence Centre Act, No. 4 of 2020.

stablecoin 60% confidence

No Specific Stablecoin Reserve Requirements: As there is no dedicated stablecoin regulation, there are no specific reserve requirements mandated for stablecoin issuers in Zambia.

stablecoin 60% confidence

No Specific Stablecoin Issuer Licensing: There is no dedicated licensing regime specifically for stablecoin issuers.

stablecoin 60% confidence

No Specific Stablecoin Redemption Rights Legislation: Without a dedicated framework, there are no legally enshrined redemption rights specifically for stablecoin holders in Zambia.

stablecoin 60% confidence

Contractual Basis: Redemption rights would currently be purely contractual, based on the terms and conditions set by the stablecoin issuer. The enforceability of these rights would depend on general contract law.

stablecoin 60% confidence

Active CBDC Exploration: Zambia is actively exploring the feasibility of introducing a Central Bank Digital Currency (CBDC). The Bank of Zambia has been conducting a feasibility assessment.

licensing 60% confidence

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."

licensing 60% confidence

Not Legal Tender: Cryptocurrencies are not recognized as legal tender in Zambia.

licensing 60% confidence

Anti-Money Laundering and Countering the Financing of Terrorism Act, 2010 (as amended):

aml 60% confidence

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).

aml 60% confidence

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.

aml 60% confidence

While Zambia is committed to implementing FATF standards, the specific legal and regulatory framework for virtual assets, including the Travel Rule, is still under development or consideration.

custody 60% confidence

The BoZ has historically advised financial institutions against dealing in crypto assets due to the lack of regulation and associated risks.

custody 60% confidence

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.

tax 60% confidence

Companies earning profits from cryptocurrency activities would be subject to the standard corporate income tax rate, which is generally 30%.

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 — stablecoin issuance in Zambia is legally grey; no dedicated framework exists, but issuance may be forced under the National Payment Systems Act (PSP licensing) or Banking and Financial Services Act if deposit-taking is involved, with no specific reserve, segregation, or redemption rules, and significant regulatory ambiguity and future compliance 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?