Stablecoin issuer / redeemer in Zimbabwe

E-money/Payment Token: If a stablecoin is designed to facilitate payments and is redeemable 1:1 for a fiat currency (or another stable asset) on demand, it would most likely be classified as e-money or a payment token under the National Payment Systems Act [Chapter 24:23]. This framework regulates payment service providers and e-money issuers.

Securities: If a stablecoin represents an ownership interest in an underlying asset, provides rights to a share of profits, or promises a return beyond simply holding its pegged value, it could be classified as a security under the Securities Act [Chapter 24:25] and regulated by the Securities and Exchange Commission of Zimbabwe (SECZ). This is less likely for standard fiat-backed stablecoins.

For E-money/Payment Tokens: If a private stablecoin is classified as e-money, it would be subject to stringent reserve requirements similar to traditional e-money issuers. This typically involves:

1:1 Backing: The issuer must hold assets equivalent to 100% of the value of outstanding e-money.

Segregation: Customer funds/reserves must be held in segregated accounts, distinct from the operational funds of the issuer, usually at a licensed bank, to protect users in case of issuer insolvency.

Prudential Supervision: The RBZ would supervise these reserves to ensure their quality, liquidity, and security.

For Private Stablecoins (if permitted): Any entity wishing to issue a stablecoin that functions as e-money or a payment token would almost certainly require a license from the Reserve Bank of Zimbabwe (RBZ) as an E-money Issuer or Payment Service Provider under the National Payment Systems Act [Chapter 24:23].

The licensing process is rigorous, requiring applicants to demonstrate robust capital, governance, risk management frameworks, AML/CFT compliance, and IT security.

Securities Issuers: If classified as a security, the issuer would need to comply with the Securities Act [Chapter 24:25] and potentially obtain licenses from the SECZ.

For E-money/Payment Tokens: A fundamental principle of e-money regulation is the right of the holder to redeem their e-money for fiat currency (or the asset it's pegged to) at par value at any time. This right would extend to any stablecoin classified as e-money. Terms and conditions for redemption must be clear and transparent.

Impact on Private Stablecoins: The introduction of ZiG significantly impacts the potential for private stablecoins. By providing a central bank-issued, asset-backed digital alternative for stability, the RBZ has effectively filled much of the space that private stablecoins might occupy. This suggests that the RBZ might view private stablecoins as redundant or potentially disruptive to its own stability efforts, making it harder for them to gain approval.

Future Interaction: Any future private stablecoins would likely need to demonstrate clear value-add beyond what ZiG offers, operate within the strict regulatory parameters set by the RBZ, and potentially interact with ZiG or the broader national payment system as defined by the central bank.

Virtual Asset Service Provider (VASP) License: This is the most common umbrella term. It would likely cover:

Issuers: Entities launching new virtual assets (Initial Coin Offerings, etc.).

Licensing: This typically involves a comprehensive application, detailed due diligence, meeting stringent capital, operational, and compliance requirements, and ongoing supervision. Zimbabwe is expected to adopt a full licensing regime for commercial VA operations to ensure financial stability, consumer protection, and AML/CFT compliance.

Likely to be prescribed minimum capital thresholds, which may vary depending on the type and scale of VA services offered, reflecting the inherent risks. This ensures financial stability and ability to absorb operational shocks.

AML/KYC (Anti-Money Laundering / Know Your Customer):

This will be a paramount requirement. Virtual asset service providers will be designated as "reporting entities" and will be subject to the provisions of Zimbabwe's Money Laundering and Proceeds of Crime Act (Chapter 9:24) and regulations issued by the Financial Intelligence Unit (FIU).

Requirements will include:

Customer due diligence (CDD) procedures for all users.

Ongoing monitoring of transactions.

Reporting suspicious transactions (STRs) to the FIU.

Appointment of a dedicated AML Compliance Officer.

Robust internal AML/CFT policies and controls.

FATF (Financial Action Task Force) standards, which Zimbabwe is expected to comply with, will heavily influence these requirements.

It is highly probable that licensed entities will need to be domiciled in Zimbabwe (i.e., incorporated locally).

Requirements may include a physical office, local directors, and locally-based key personnel (e.g., CEO, Compliance Officer).

Partially (Framework for VASPs): Zimbabwe, as an FATF member, is committed to implementing FATF Recommendations. In October 2022, Zimbabwe promulgated the Money Laundering and Proceeds of Crime Amendment Act (No. 6 of 2022), which for the first time designated VASPs as "financial institutions" for AML/CFT purposes. This means VASPs are now subject to general AML/CFT obligations such as customer due diligence (CDD), record-keeping, and suspicious transaction reporting (STR).

Not Adopted (Travel Rule Specifics): While VASPs are regulated, the specific requirements of the FATF Travel Rule – mandating the collection and sharing of originator and beneficiary information for virtual asset transfers – have not yet been specifically legislated or enforced. The FATF's Mutual Evaluation Report for Zimbabwe (October 2022) highlighted this as an area needing improvement, stating that measures to implement the Travel Rule were not yet in place.

General VASP Regulation: The Money Laundering and Proceeds of Crime Amendment Act (No. 6 of 2022) became effective upon its gazetting in October 2022. This is the effective date for VASPs to be considered reporting entities under Zimbabwe's AML/CFT framework.

Which VASPs are Covered:

Exchange between virtual assets and fiat currencies.

Evidence fact zw.aml.safekeepingandor-administration-of-virtual not found (may have been renamed).

Participation in and provision of financial services related to an issuer’s offer and/or sale of a virtual asset.

Essentially, any entity in Zimbabwe that performs these services professionally and for financial gain is considered a VASP and falls under the purview of the AML/CFT Act.

For General AML/CFT: VASPs, as regulated financial institutions, are generally required to have internal systems and controls for:

Customer Due Diligence (KYC processes).

Risk-based assessment and management.

Record-keeping of transactions and customer data.

Monitoring transactions for suspicious activities.

Reporting suspicious transactions to the Financial Intelligence Unit (FIU).

Having an appointed AML/CFT Compliance Officer.

Segregation of Client Assets Rules:

No Specific Rules: As there are no specific custodial licenses or regulatory frameworks, there are no explicit rules mandating the segregation of client digital assets from a custodian's proprietary assets. Best practices in traditional finance would suggest segregation, but this is not legally mandated for crypto custody in Zimbabwe.