Stablecoin issuer / redeemer in Eswatini

Eswatini has no legal classification of stablecoins: no Eswatini statute, regulation or supervisory instrument defines a stablecoin or assigns it to a category of electronic money, payment token or security. The National Payments System Act 2023 provides for licensing of payment-system categories at section 9 and for licensing or registration of money- or value-transfer service providers at sections 10(1) and 16, and establishes no stablecoin or virtual-asset issuer category, while the Central Bank of Eswatini's 2023 notice records that crypto investments or assets are currently unregulated in Eswatini.

The Central Bank of Eswatini's 2023 notice 'Considerations for Dealing in Cryptocurrencies' states that cryptocurrencies are not legal tender in Eswatini and that crypto investments or assets are currently unregulated, so holders receive none of the legal protection attaching to regulated instruments or products. The notice addresses cryptocurrencies and crypto assets as one class and singles out no stablecoin, and no Eswatini instrument treats a stablecoin as electronic money, as a payment instrument or as legal tender.

Eswatini imposes no reserve, backing, segregation or audit duty on stablecoin issuers, because no Eswatini statute or Central Bank of Eswatini instrument creates a stablecoin issuer category at all; the Bank's 2023 notice records that crypto investments or assets are currently unregulated in Eswatini. Eswatini's monetary anchor is the lilangeni, introduced in 1974 at par with the South African rand through the Common Monetary Area and still tied to it at one-to-one, which is a currency arrangement rather than a reserve rule binding a private issuer.

Stablecoin issuance in Eswatini sits outside the prudential perimeter. The Central Bank of Eswatini regulates commercial banks, foreign-exchange bureaux, money- or value-transfer service providers and money remittances under the Central Bank Order 1974, the Financial Institutions Act 2005, the Exchange Control Order 1974 and the Money Laundering and Financing of Terrorism (Prevention) Act 2011, and none of those instruments reaches virtual assets: the 2011 Act as amended to 2016 uses none of the terms virtual asset, virtual currency, crypto, digital currency or electronic money. No reserve-backing, capital or audit requirement therefore applies to a stablecoin issuer in Eswatini.

Eswatini operates no licensing regime for stablecoin issuers: neither the Central Bank of Eswatini nor the Financial Services Regulatory Authority publishes a virtual-asset or stablecoin licence, licence class, minimum capital floor, fee schedule or application process. Eswatini was rated Non-Compliant on FATF Recommendation 15 in the ESAAMLG mutual evaluation adopted in June 2022, and Recommendation 15 was not among the fifteen recommendations re-rated in the August 2025 enhanced follow-up report, so that rating stands.

A prospective stablecoin issuer can obtain no authorisation from either Eswatini regulator. The Central Bank of Eswatini licenses banks, foreign-exchange bureaux and money- or value-transfer providers, the Financial Services Regulatory Authority licenses non-bank financial services, and neither issues a licence covering the issuance of a stablecoin or any other virtual asset. Admission to the Bank's FinTech Regulatory Sandbox, established under guidelines of May 2020 and confined to products and business models already regulated by the Bank, is a time-limited testing arrangement decided within 21 working days and is not a licence; those guidelines use none of the words crypto, cryptocurrency, virtual currency, virtual asset or stablecoin, and no participant register is published.

Eswatini law confers no redemption right on the holder of a stablecoin: no Eswatini instrument creates a par-value redemption duty, a redemption deadline, a fee prohibition or a claim against an issuer's reserves, because Eswatini has enacted no stablecoin, e-money-token or asset-referenced-token regime. The Central Bank of Eswatini's 2023 notice records that crypto investments or assets are currently unregulated in Eswatini and that holders receive none of the legal protection associated with regulated instruments or products.

Contractual Basis Only: Any redemption rights would solely depend on the terms and conditions set forth by the stablecoin issuer and the contractual agreement (if any) between the issuer and the holder. Given the unregulated nature, enforcement of such contractual rights could be challenging.

The Central Bank of Eswatini's standing crypto-asset consumer communication is 'Considerations for Dealing in Cryptocurrencies' (2023), which states that cryptocurrencies are not legal tender in Eswatini, that crypto investments or assets are currently unregulated there, and that investors accordingly receive none of the legal protection associated with regulated instruments or products; it directs the public to confirm with the Central Bank of Eswatini and the Financial Services Regulatory Authority whether a firm is registered to provide financial services in Eswatini. The Bank's earlier April 2018 statement announced research into cryptocurrency and was not a warning.

Proceeds of Crime Act, 2009 (as amended):

Financial Services Regulatory Authority (FSRA) Act, 2010:

An investment of money or assets: The investor commits capital to acquire the token.

In a common enterprise: The investment is pooled with others, or the value of the token is tied to a broader project or business venture managed by others.

With an expectation of profits: The investor anticipates financial gain (e.g., capital appreciation, dividends, revenue sharing, or other forms of return) from holding the token.

Derived solely or substantially from the efforts of others: The profits are expected to come from the managerial or entrepreneurial efforts of a third party (the issuer, promoter, or other entities), rather than the investor's own efforts.

Prospectus Requirements: For public offerings of securities, a comprehensive prospectus must be prepared and registered with the FSRA. This prospectus must disclose all material information relevant to the investment, risks, and the issuer.

Licensing: Issuers, promoters, or financial intermediaries involved in offering or distributing securities may need to be licensed by the FSRA as financial services providers (e.g., investment advisors, brokers, collective investment scheme managers).

Eswatini's Financial Services Regulatory Authority licenses no virtual-asset trading platform and operates no securities-exchange licence class that reaches crypto-asset trading; the Central Bank of Eswatini's 2023 notice records that cryptocurrencies are not legal tender in Eswatini and that crypto investments or assets are currently unregulated there, so no Eswatini instrument makes crypto trading either licensable or unlawful. A digital-asset regulatory framework administered by a body called the FSRA belongs to the Abu Dhabi Global Market, not to Eswatini.

Eswatini operates no virtual-asset licensing regime: neither the Central Bank of Eswatini nor the Financial Services Regulatory Authority licenses virtual asset service providers, and the only hook is AML-side, created by the Anti-Money Laundering, Counter-Financing of Terrorism and Counter-Proliferation Financing (Miscellaneous Amendments) Act 2024, which directs supervisory authorities to establish a framework to regulate VASPs and under which VASPs are treated as accountable institutions registering with the Eswatini Financial Intelligence Centre.

Eswatini's primary AML/CFT statute is the Money Laundering and Financing of Terrorism (Prevention) Act, 2011 (Act 6 of 2011), as amended by Act 5 of 2016, whose section 19 establishes the financial intelligence body first named the Swaziland Financial Intelligence Unit and now operating as the Eswatini Financial Intelligence Centre; Eswatini has no Financial Intelligence Unit Act, the Prevention of Organised Crime Act 2018 deals with organised crime and confiscation rather than accountable-institution duties, and the 2011 Act as consolidated carries no definition of virtual assets, VASPs, cryptocurrency or digital currency.

FATF Recommendations: Eswatini, through its membership in ESAAMLG, is expected to continue enhancing its legal framework to fully comply with FATF Recommendation 15 on new technologies and Virtual Asset Service Providers (VASPs). This implies that future amendments or new regulations could introduce more specific requirements for VASPs, which might eventually encompass more detailed aspects of custody.

ISIL (Da'esh) & Al-Qaida Sanctions List: Maintained by the 1267/1989/2253 Committee.

Eswatini's AML statute is the Money Laundering and Financing of Terrorism (Prevention) Act, 2011 (Act 6 of 2011), amended by Act 5 of 2016, and the Prevention of Organised Crime Act, 2018 supplies asset-recovery powers, but United Nations Security Council targeted financial sanctions are given domestic effect by the Anti-Money Laundering (United Nations Security Council Resolutions) Regulations, 2016 together with the Suppression of Terrorism Act as amended by Act No. 11 of 2017, with the Ministry of Foreign Affairs and International Cooperation acting as the gateway for UNSC 1267 and 1373 listings; section 19 of the 2011 Act establishes the financial intelligence unit as the Swaziland Financial Intelligence Unit, the single body that now operates as the Eswatini Financial Intelligence Centre, and Eswatini was rated Non-Compliant on Recommendations 6 and 7 in the June 2022 ESAAMLG mutual evaluation.