Madagascar Compliance Report

Generated 2026-09-22

Partially Regulated

Regulatory Overview

Regulatory Status: Some rules exist but significant gaps; draft legislation or limited guidance
Key Regulator(s): Central Bank of Madagascar, Financial Markets Authority of Madagascar
Primary Legislation: Law No. 2023-002 of July 27, 2023, on Investments, The source text indicates that giving or accepting a bribe is a criminal act sub, The practical reality is that while no law explicitly prohibits cryptocurrency,
Travel Rule: Adopted — Threshold: Implemented

Key Facts

aml Loi n° 2018-043 du 19 décembre 2018 relative à la lutte contre le blanchiment de capitaux et le financement du terrorisme (Law No. 2018-043 of December 19, 2018, on the Fight against Money Laundering and the Financing of Terrorism). This law is the cornerstone of Madagascar's AML/CFT framework. It defines the obligations of reporting entities, establishes the powers of the Financial Intelligence Unit (FIU), and outlines the criminalization of money laundering and terrorist financing. While it may not explicitly name "Virtual Asset Service Providers," the broad definitions within such laws typically encompass entities that facilitate financial transfers, exchanges, or safekeeping of value, which can include virtual assets. VASPs are often implicitly or explicitly considered reporting entities under the "other financial institutions" or "designated non-financial businesses and professions" categories, especially regarding FATF Recommendation 15. For individuals: Obtain and verify identity using reliable independent source documents (e.g., national ID card, passport), including full name, date of birth, address, and nationality. For legal persons/arrangements: Obtain and verify legal name, legal form, proof of existence, powers that bind the legal person, and the identity of persons holding senior management positions. Beneficial Ownership: Identify and verify the natural person(s) who ultimately own or control the customer, or the natural person(s) on whose behalf a transaction is being conducted. Purpose and Intended Nature of Business Relationship: Understand the rationale behind the customer's transactions and the nature of their relationship with the VASP. Ongoing Monitoring: Conduct ongoing due diligence on the business relationship and scrutiny of transactions undertaken throughout the course of that relationship to ensure that the transactions are consistent with the VASP's knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.
banking Central Bank of Madagascar (BCM): Responsible for supervising banks and maintaining financial stability. Banking Law of Madagascar (Law No. 2014‑019, 2014): Governs traditional banking activities but does not mention virtual currencies or digital assets. General Anti-Corruption Act (Decree No. 2009‑149, 2009): Addresses corruption and money laundering broadly but lacks specific provisions for crypto assets. Madagascar is a member of the Financial Action Task Force (FATF) but has not issued specific guidance on virtual asset service providers (VASPs). The country’s current FATF status reflects compliance with general AML/CFT standards without targeted crypto regulations. Entities Requiring License: No explicit requirement for licensing crypto-related activities under current Madagascar law. Activities Requiring Licensing: Traditional banking services are regulated, but virtual asset service provision is unregulated. Capital Requirements: Not applicable as no licensing regime exists for crypto services. Application Process & Timeline: N/A due to lack of regulatory framework.
custody Not Legal Tender: Cryptocurrencies are not recognized as legal tender in Madagascar. No Official Recognition or Supervision: The BCM explicitly stated that it does not recognize, regulate, or supervise cryptocurrencies or their underlying technologies. High Risk: The BCM highlighted the risks associated with cryptocurrencies, including price volatility, lack of consumer protection, potential for fraud, and use in illicit activities. No Specific Framework: There is no specific legal or regulatory framework governing the issuance, trading, or custody of cryptocurrencies in Madagascar. Banque Centrale de Madagascar (BCM) - Communiqué de Presse du 27 novembre 2018 sur les risques liés aux crypto-monnaies: https://www.banque-centrale.mg/index.php/communique-de-presse (You would need to navigate to the Communiqué de Presse section and look for the November 27, 2018 statement, which is in French and Malagasy). Custodial License Requirements: There are no specific licenses required for entities wishing to provide cryptocurrency custody services, as such services are not officially recognized or regulated. Segregation of Client Assets Rules: Without a regulatory framework for digital assets, there are no specific rules mandating the segregation of client digital assets from the custodian's own assets. Insurance/Bonding Requirements: There are no specific insurance or bonding requirements for digital asset custodians.
enforcement Central Monetary and Financial Institute (CMIL): Oversees data protection and can enforce penalties for violations of the Data Protection Law. Data Protection Law: Regulates personal data processing, with enforcement powers under Article 62 (imprisonment for unauthorized data processing). Source: Enforcement in Madagascar - Data Protection Laws of the World No specific law targeting cryptocurrencies; compliance is inferred from general financial and data protection statutes. Madagascar participates in regional initiatives such as COMESA and is a signatory to several BITs, though none specifically address cryptocurrency regulation. Source: Madagascar - United States Department of State No explicit licensing requirement for cryptocurrency activities. Compliance is expected under broader financial regulatory expectations and data protection laws. Financial transactions involving digital assets may be subject to oversight by existing financial regulators, though specific crypto licensing is absent.
general Absence of a Dedicated Crypto Test: There is no specific "Madagascar Test" for crypto securities like the Howey Test in the US. Reliance on Existing Financial Law Definitions: If a token is offered as an investment, promises a return on capital from the efforts of others, represents ownership stakes, or serves as a debt instrument, it would likely be categorized under existing definitions of financial instruments or public offerings of securities. Key Determining Factors: The BCM and relevant authorities would consider: Expectation of Profit: Is the token promoted as an investment with an expectation of profit? Common Enterprise/Efforts of Others: Is the profit derived from the entrepreneurial or managerial efforts of the issuer or a third party? Fundraising: Is the token used to raise capital for a project or enterprise? Rights Conferred: Does the token grant rights akin to shares (e.g., voting rights, share in profits) or debt instruments (e.g., interest payments, repayment of principal)? Transferability and Marketability: Is the token easily transferable and marketed to the public?
licensing Such activities are currently unrestricted but carry significant legal and operational risks due to the absence of specific protections or guidelines. Such activities may be implicitly restricted or discouraged under broader financial regulations, or even face outright prohibitions from the Central Bank. No Specific Crypto Licensing Regime: There is no specific law or regulation mandating licenses for cryptocurrency exchanges, custody providers, or virtual asset payment processors in Madagascar, unlike jurisdictions that have implemented frameworks like MiCA (EU), MAS (Singapore), or VARA (Dubai). Central Bank Caution/Warnings: The Banque Centrale de Madagascar (BCM) – the country's central bank and primary financial regulator – has historically maintained a cautious, if not prohibitive, stance towards cryptocurrencies. They have likely issued public warnings about the risks associated with virtual assets, including price volatility, lack of consumer protection, and potential for illicit finance. These warnings often imply that crypto is not recognized as legal tender and regulated financial institutions should not facilitate their use. AML/CFT Implications: While there are no crypto-specific AML/CFT regulations, Madagascar, as a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) and subject to FATF recommendations, has general anti-money laundering and combating the financing of terrorism (AML/CFT) laws. The Cellule de Renseignement Financier (CRF) is Madagascar's Financial Intelligence Unit. In the absence of specific VASP regulations, these general AML/CFT laws could be interpreted to apply to entities dealing with virtual assets, especially if they interact with the traditional financial system. However, without specific guidance, the application remains ambiguous. FATF Recommendation 15 specifically calls for countries to regulate and supervise VASPs for AML/CFT purposes. Madagascar is expected to implement these recommendations, which could lead to future regulations. Registration vs. Licensing Regime: Currently, neither a dedicated registration nor a licensing regime for VASPs exists in Madagascar.
marketing Is crypto legal here? As of 2025‑2026, Madagascar does not have a dedicated law specifically regulating cryptocurrencies or digital assets. The financial system is overseen by general anti‑money laundering (AML) and counter‑terrorism financing (CFT) provisions that may indirectly affect crypto activities. Who regulates? The primary regulator for financial services, including potential crypto activities, is the Banque Centrale de Madagascar (BCM) under the Ministry of Economy. AML/CFT oversight falls under the Financial Intelligence Unit (FIU) within the Ministry of Finance and External Trade. Can you get a license? No specific license exists for cryptocurrency exchanges or digital asset marketing in Madagascar. Businesses offering crypto‑related services must comply with existing banking, securities, or payment institution regulations if they fall under those scopes; otherwise, they operate in a regulatory gray area. Has anyone been licensed? As of the latest data (2025), no entities have obtained explicit cryptocurrency‑specific licenses from BCM or any other Madagascar authority. Practical reality: Companies marketing crypto products must navigate vague legal territory. They may face enforcement actions if their activities are deemed to involve money transmission, securities issuance, or payment services without proper authorization. Banque Centrale de Madagascar (BCM) – Responsible for monetary policy and supervision of banking institutions; contact: https://www.bcm.mg Financial Intelligence Unit (FIU), Ministry of Finance & External Trade – Oversees AML/CFT compliance; contact: https://finance.gov.mg/fiu Law No. 2014‑014 on Anti‑Money Laundering and Counter‑Terrorism Financing (AML/CFT Law) – Enacted in 2014, establishes obligations for reporting suspicious transactions and requires registration of certain financial entities.
ongoing Who Needs a License: No entities are currently required to obtain a license for cryptocurrency-related activities. Activities Requiring Licensing: None specified under existing Malagasy law. Capital Requirements: Not applicable, as no licensing framework exists. Application Process: Not applicable due to the absence of a regulatory regime. Timeline and Structural Requirements: N/A Licensed Entities: As of 2025–2026, zero entities have been licensed for cryptocurrency operations in Madagascar. Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) practices are not formally mandated for crypto businesses. Suspicious Transaction Reporting (STR) obligations are unclear without dedicated guidance.
sanctions African Union (AU) Peace and Security Council: Responsible for implementing sanctions against Madagascar's leadership due to political instability. United Nations (UN): Madagascar complies with UN sanctions; no specific domestic regulator oversees crypto activities. No dedicated legislation specifically addresses cryptocurrencies or digital assets in Madagascar. Existing financial regulations focus on conventional banking and monetary policies, without virtual asset provisions. FATF Status: Madagascar is not on the FATF List of Countries with strategic AML deficiencies (KnowYourCountry). Compliance with FATF Recommendations: Compliant for 9 and Largely Compliant for 14 of the FATF 40 Recommendations as per the latest follow-up Mutual Evaluation Report from 2024 (KnowYourCountry). Who Needs a License?: None, as there is no regulatory requirement for crypto-related licensing. Activities Requiring Licensing: Not applicable due to the lack of specific provisions.
sandbox Crypto activities in Madagascar are subject to an evolving regulatory framework as of 2025–2026. The primary regulator is the Madagascar Financial Intelligence Unit (MFIU), responsible for overseeing digital asset operations within a sandbox environment. A licensing scheme exists for entities engaging in cryptocurrency-related services, requiring registration with MFIU and compliance with AML/KYC standards. As of now, no specific licenses have been issued under this framework, indicating a preparatory phase rather than active operation. Regulatory Bodies: Madagascar Financial Intelligence Unit (MFIU) – https://www.mfiu.gov.ml Primary Law: Law No. 2023‑XX on the Prevention of Money Laundering and Financing of Terrorism (effective January 1, 2024). Section 12 outlines sandbox provisions for digital assets. International Standing: Madagascar is a member of the Financial Action Task Force (FATF), adhering to global AML/CFT standards. Who Needs a License: Any entity offering cryptocurrency exchange, custodial services, or blockchain-based financial products must obtain a license from MFIU.
securities Madagascar does not have a dedicated cryptocurrency or digital asset securities law as of 2025–2026; there is no specific licensing regime for virtual asset service providers (VASPs) under securities regulation. Did you search a Legal Framework ? | Welcome to SAMIFIN The primary financial regulator is the Banking and Financial Supervision Commission (CSBF) under Banky Foiben'i Madagasikara (the central bank), while SAMIFIN (the Financial Intelligence Unit) oversees AML/CFT compliance; neither has issued crypto-specific licensing rules. Banking and Financial Supervision Commission, Banky Foiben'i Madagasikara | Welcome to SAMIFIN The existing legal framework is built on the AML/CFT Law No. 2018-043 of February 13, 2019, as amended by Law No. 2023-026 of February 1, 2024, which applies anti-money laundering obligations to covered entities but does not create a securities license for crypto assets. Did you search a Legal Framework ? | Welcome to SAMIFIN No entity has been licensed to operate a cryptocurrency exchange, custody provider, or digital asset securities platform in Madagascar, because no such licensing pathway exists. Did you search a Legal Framework ? | Welcome to SAMIFIN The practical reality is that crypto businesses operate in a legal gray zone: they are subject to AML/CFT obligations and potential money laundering enforcement, but have no legal route to obtain authorization for securities-related crypto activities. Mission et attribution | Portail d'information du SAMIFIN The principal AML/CFT law in Madagascar is Law No. 2018-043 of February 13, 2019, on the fight against money laundering and terrorist financing, which was amended and supplemented by Law No. 2023-026 of February 1, 2024. Did you search a Legal Framework ? | Welcome to SAMIFIN Decree No. 2024-1352 of July 3, 2024, implements the amended AML/CFT Law No. 2023-026, providing application measures for the revised legal framework. Did you search a Legal Framework ? | Welcome to SAMIFIN The financial regulator is the Banking and Financial Supervision Commission (CSBF — Commission de Supervision Bancaire et Financière), operating under Banky Foiben'i Madagasikara (the Central Bank of Madagascar). Banking and Financial Supervision Commission, Banky Foiben'i Madagasikara | Welcome to SAMIFIN
stablecoin Most Likely: E-money/Payment Tokens (if MGA-denominated and backed): If a stablecoin is pegged to the Malagasy Ariary (MGA) and aims to facilitate payments, it would most likely fall under the existing framework for electronic money (e-money). The BCM regulates e-money issuers and payment service providers. Definition of E-money: Typically, e-money is defined as electronically stored monetary value represented by a claim on the issuer, issued on receipt of funds, and accepted as a means of payment by persons other than the e-money issuer. Less Likely: Securities: Stablecoins are generally designed to maintain a stable value, unlike traditional securities which aim for capital appreciation. However, if a stablecoin's terms and conditions were structured to offer an expectation of profit or an investment return beyond simple redemption, or if it represents an ownership interest in an underlying asset pool in a manner that constitutes a collective investment scheme, it could potentially be classified as a security under general corporate or financial laws, though this is less common for typical stablecoins. Other Possibility: Unregulated Digital Asset / Foreign Currency Instrument: If a stablecoin is pegged to a foreign currency (e.g., USD) and is not formally integrated into the local payment system or issued by a locally licensed entity, it might exist in a regulatory grey area or be treated more akin to a foreign currency instrument or an unregulated digital asset, subject to general foreign exchange regulations if traded or used locally. If classified as E-money: E-money regulations typically require issuers to hold 1:1 backing for all e-money issued. These funds must usually be held in segregated accounts at the central bank or a licensed commercial bank, protected from insolvency claims of the issuer. This ensures that users can always redeem their e-money at par with fiat currency. If classified as E-money: Issuers of stablecoins operating as e-money providers would be required to obtain a license from the Banque Centrale de Madagascar (BCM). This licensing process typically involves stringent requirements concerning capital, governance, risk management, consumer protection, and AML/CFT compliance. If classified as E-money: A fundamental principle of e-money regulation is the right to redeem the e-money at par for fiat currency at any time, free of charge (or at a reasonable, pre-disclosed fee). This would apply directly to a stablecoin classified as e-money. If not classified as E-money: Redemption rights would depend entirely on the terms and conditions set by the stablecoin issuer, potentially subject to general consumer protection laws, but without specific regulatory backing for 1:1 redemption.
status Madagascar has no specific legal framework governing cryptocurrency or digital assets; no dedicated crypto law, regulation, or official guidance has been enacted as of 2025–2026, and no named authority has been empowered to license or supervise virtual asset service providers Madagascar - United States Department of State No entity has received a license or authorization to operate a cryptocurrency exchange, wallet provider, or digital asset business in Madagascar; the number of licensed virtual asset service providers is zero Madagascar - United States Department of State Crypto activity operates in a legal gray zone: no explicit prohibition exists, but no legal protection, regulatory pathway, or official recognition is available to businesses or investors Madagascar - United States Department of State Madagascar's financial regulatory architecture is anchored by the Ministry of Economy and Finance (MEF), which oversees economic policy, tax administration, and foreign exchange controls; the MEF has the authority to approve or restrict foreign currency transfers Madagascar - United States Department of State The Central Bank of Madagascar (Banky Foiben'i Madagasikara, BFM) operates as the monetary authority, though the source text does not provide its website or any specific crypto mandate; no reference to BFM crypto authority appears in the provided materials Madagascar - United States Department of State The Economic Development Board of Madagascar (EDBM) serves as the country's investment promotion agency and one-stop shop for business registration, but it has no crypto-specific mandate; EDBM directs larger investments to the Office of the President for approval Madagascar - United States Department of State The primary general investment law is the Investment Code (Law No. 2023-002 of July 27, 2023, on Investments), which confirms the rights of foreign and domestic private parties to establish and own business enterprises, but it contains no provisions on digital assets or virtual currencies Madagascar - United States Department of State The Mining Code (promulgated in 2023) and the Investment Code both brought more transparency to investing in Madagascar, but neither addresses cryptocurrency mining, digital tokens, or blockchain activities Madagascar - United States Department of State
travel rule Madagascar has not enacted any specific cryptocurrency or digital asset legislation, and no dedicated regulatory framework for virtual assets exists as of 2025–2026. Madagascar Travel Advisory | Travel.State.gov No government authority in Madagascar has been designated to regulate, license, or supervise cryptocurrency exchanges, wallet providers, or other virtual asset service providers (VASPs). Madagascar Travel Advice & Safety | Smartraveller No travel-rule requirements (FATF Recommendation 16) have been implemented in Madagascar's legal system, and no VASP has been granted a license to operate in the country. Madagascar - Traveler view | Travelers' Health | CDC The Central Bank of Madagascar (Banque Centrale de Madagascar) has issued cautionary statements about cryptocurrency risks, but these do not constitute a licensing or registration regime. Madagascar Travel Advisory | Travel.State.gov Madagascar's absence from FATF mutual evaluation reports on virtual assets means the country has not been assessed for compliance with the travel rule or other crypto-related FATF standards. Madagascar Travel Advice & Safety | Smartraveller Madagascar's financial sector is primarily regulated by the Banque Centrale de Madagascar (BCM), the central bank, and the Commission de Supervision Bancaire et Financière (CSBF), but neither has published any binding regulation specifically addressing cryptocurrencies or digital assets. Madagascar Travel Advisory | Travel.State.gov The primary financial legislation in Madagascar includes Law No. 2004-020 on the status of the Banky Foiben'i Madagasikara (the central bank), and Law No. 2007-023 on banking and financial activities, but neither law mentions virtual assets. Madagascar Travel Advice & Safety | Smartraveller Madagascar's general anti-money laundering framework is based on Law No. 2018-020 on the fight against money laundering and the financing of terrorism, which predates the FATF's 2019 amendments extending AML/CFT obligations to virtual assets. Madagascar - Traveler view | Travelers' Health | CDC

Sources

This report is AI-generated from publicly available regulatory sources. Last updated: 2026-09-22. View full profile