Self-custodial wallet / non-custodial software in Equatorial Guinea
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 not permitted in Equatorial Guinea.
Verdict Details
- Permitted
- no
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No specific AML obligations attach to this operating model because the activities are prohibited under BEAC Circular No. 001/GR/2022.
- General AML framework (Law N° 4/2004, Directive N° 01/03-UEAC-CM-300-CM-06) exists for financial sector entities but would not apply to a non-custodial software publisher that does not hold, control, or transact with crypto-assets.
- The prohibition means no VASP registration or AML compliance regime is available to be triggered.
Key Restrictions
- BEAC Circular No. 001/GR/2022 prohibits the issuance, trading, holding, and any other activities related to crypto-assets by persons or entities subject to the CEMAC financial regulatory framework.
- A self-custodial wallet publisher, if deemed to be engaging in activities related to crypto-assets within CEMAC territory, would likely fall under the prohibition.
- No licensing or registration pathway exists — the only legal status for crypto activity is prohibition.
- If the software simply provides a non-custodial tool and the publisher does not deal with, hold, or transact crypto professionally, there may be an argument the prohibition does not attach to pure software publishing; however, this is untested and ambiguous.
Key Risks
- Highly ambiguous scope — the prohibition targets 'activities related to crypto-assets' and 'any entity dealing with virtual assets in a professional capacity,' which could encompass software publishers providing tools for self-custody.
- No public enforcement precedent or clarifying guidance exists on whether non-custodial software falls within the prohibition.
- BEAC has taken a broadly cautious stance on crypto, and any crypto-adjacent activity could attract regulatory attention.
- No license available — if deemed prohibited, there is no compliance path to operate lawfully.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
A licensing regime for digital-asset services applies in Equatorial Guinea through directly applicable community law: article 144 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF du 21 juillet 2022 requires COSUMAF agrément as prestataire de services sur actifs numériques, and the Règlement Général COSUMAF du 23 mai 2023 supplies the framework, while no implementing instruction has been issued, no minimum capital is set and no agrément has been granted.
Licences for digital-asset services exist in CEMAC law and cover Equatorial Guinea: article 160 of Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF lists custody for third parties, purchase and sale against legal tender, platform operation, reception and transmission of orders, portfolio management, advice and placement, all subject to COSUMAF agrément, and no such agrément has yet been issued to any operator.
BEAC issued no Circular No. 001/GR/2022 of 29 June 2022 on the prohibition of crypto-assets; BEAC's register of Instructions, Circulaires et Règlements lists no 2022 crypto instrument, and the CEMAC measure of that period is Décision COBAC D-2022/071 du 6 mai 2022, binding supervised institutions only.
No CEMAC prohibition reaches the issuance, trading or holding of crypto-assets by any person: Décision COBAC D-2022/071 du 6 mai 2022 binds only institutions COBAC supervises, and Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024 instead treats virtual-asset service providers in Equatorial Guinea as regulated obliged entities subject to authorisation and AML/CFT duties.
Other VASPs: Any entity dealing with virtual assets in a professional capacity.
Virtual-asset service providers operating in Equatorial Guinea carry AML/CFT obligations directly under Règlement n° 02/24/CEMAC/UMAC/CM of 20 December 2024: article 6 lists them among the obliged entities, article 42 requires prior authorisation and the transmission of originator and beneficiary information above 500 000 FCFA for occasional transactions, and article 39 sets a ten-year record-retention period, while no CEMAC text fixes a minimum capital for PSAN.
No PSAN application process operates in Equatorial Guinea because COSUMAF has issued no implementing instruction and granted no agrément, while the licensing obligation itself exists in force under Règlement n° 01/22/CEMAC/UMAC/CM/COSUMAF and the Règlement Général COSUMAF du 23 mai 2023.
Obligation to Report: VASPs must establish systems to detect and report suspicious transactions.
Evidence fact gq.aml.supervisory-authority-broader-financial-sector not found (may have been renamed).
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- low
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Not permitted — Equatorial Guinea (CEMAC zone) has a general prohibition on crypto-asset activities under BEAC Circular No. 001/GR/2022 with no licensing regime available; a non-custodial wallet publisher would face significant legal ambiguity as to whether pure software publishing falls within the prohibition's scope, and no compliance pathway exists if it does.
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?