Mozambique Compliance Report

Generated 2026-09-22

Comprehensive Framework

Regulatory Overview

Regulatory Status: Dedicated crypto/VA legislation, licensing regime, active enforcement
Primary Legislation: Law of the Payment System, Law on Credit Institutions and Financial Companies, Law on the Prevention and Combat of Money Laundering and Terrorist Financing, General investment laws, including the revised Investment Law No. 8/2023, apply, The Investment Law No. 8/2023, revised in 2023, is the primary legislation gover, Mega-Projects Law, Decree 48/2022, The Investment Law No. 8/2023 includes pro-business reforms such as tax incentiv, The Mega-Projects Law (No. 15/2011) requires that 5 to 20 percent of equity capi, No designated authority has responsibility for crypto regulation, leaving busine, Mozambique strengthens regulation of medicines and imported vaccines, boosting h
Travel Rule: Not adopted — Threshold: €700,000
Tax Reporting: The nature of the activity: Is it an investment, a trade, a service, or a form of remuneration?. The entity involved: Is it an individual or a business entity?. If an individual frequently buys and sells crypto with the intention of profit (e.g., day trading), the gains could be considered business income and taxed at progressive IRPC rates (up to 32%).. If an individual holds crypto as a long-term investment and sells it occasionally, the gains might be considered "other income" or a capital gain on movable property, subject to IRPC at progressive rates.. Up to MZN 30,000/month: Exempt

Key Facts

aml Extraterritorial Reach: Sanctions regimes apply based on jurisdiction, currency used (e.g., USD for OFAC, EUR for EU), location of servers, nationality of participants, or nexus to sanctioned entities/persons. FATF Standards: Mozambique is a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), which is an associate member of the Financial Action Task Force (FATF). FATF Recommendations explicitly cover virtual assets and VASPs, requiring them to implement AML/CFT measures, including targeted financial sanctions. Applicability: Applies to U.S. persons (including citizens, permanent residents, entities organized under U.S. law, and those located in the U.S.), U.S. financial institutions, and potentially any foreign entity that uses the U.S. financial system or facilitates transactions involving sanctioned persons or territories. Crypto transactions involving USD or U.S.-based crypto exchanges fall under OFAC's purview. Sanctioned Entity Screening: Screening all users and counterparties against the Specially Designated Nationals and Blocked Persons (SDN) List and other OFAC sanctions lists. This includes applying the "50% rule" (entities owned 50% or more by one or more blocked persons are also considered blocked). Geographic Restrictions: Prohibiting transactions directly or indirectly involving comprehensively sanctioned jurisdictions (e.g., Cuba, Iran, North Korea, Syria, certain regions of Ukraine). Transaction Monitoring: Monitoring transactions for patterns indicative of sanctions evasion or involvement of sanctioned entities/jurisdictions. Reporting: Freezing assets of blocked persons and reporting blocked property to OFAC. OFAC Sanctions Programs and Information: https://home.treasury.gov/policy-issues/office-of-foreign-assets-control-sanctions-programs-and-information
custody Bank of Mozambique (BdM) Position: The Banco de Moçambique (BdM), the country's central bank, has consistently issued warnings regarding the risks associated with cryptocurrencies. It has clearly stated that cryptocurrencies are not considered legal tender in Mozambique and are not regulated or supervised by the central bank. The BdM advises the public against using them due to risks such as price volatility, lack of consumer protection, and potential for money laundering and terrorist financing. Reference: While a direct "circular" or "law" explicitly stating this for general public access might be challenging to link, this stance is widely reported by Mozambican media based on BdM official statements and press releases. You can monitor the BdM's official website for notices: Banco de Moçambique Official Website: https://www.bankofmozambique.co.mz/ No Specific Digital Asset Legislation: Mozambique does not have dedicated laws or regulations for digital assets that define them, regulate their issuance, trading, or custody. Custodial License Requirements: There are no specific licenses for cryptocurrency custodians. Any entity offering such services would operate in an unregulated space, or potentially be subject to general financial services licenses if their activities overlap with traditional financial services (which is unlikely given the BdM's stance on crypto not being legal tender). Segregation of Client Assets Rules: No rules exist for the segregation of client digital assets. Insurance/Bonding Requirements: There are no insurance or bonding requirements for digital asset custodians. Cold Storage Mandates: No mandates or regulations specify the use of cold storage for digital assets.
enforcement Regulator Name: Banco de Moçambique (Bank of Mozambique) Entity Targeted: The general public, potential users, and operators of cryptocurrencies within Mozambique. (Not a specific company or individual). Violation Type (Implicit/Guidance): Engaging in financial activities with unregulated assets, operating outside the formal financial system, high risk of fraud/scams, potential for money laundering and terrorist financing. The core message is that cryptocurrencies are not legal tender and are not regulated by the Banco de Moçambique. Penalty Amount: N/A (These are warnings, not direct penalties for a specific enforcement case). Date: Multiple warnings have been issued over time. A prominent one was issued in April 2021, reiterating previous cautions. These warnings are periodically re-emphasized. Outcome: Heightened public awareness regarding the risks of cryptocurrencies, discouragement of their use in official financial transactions, and a clear regulatory position that they are not recognized as legal tender or regulated financial instruments. This forms the basis for any future enforcement, should a specific harmful activity be identified. Date: April 20, 2021 Notes: This article directly quotes the Bank of Mozambique's statement, highlighting that cryptocurrencies are not legal tender and are unregulated. It reflects a consistent stance over time. Date: This is an annually updated report, reflecting the current legal landscape. Notes: This resource confirms that the Bank of Mozambique has consistently issued warnings since 2017, advising against the use of cryptocurrencies due to their unregulated nature and associated risks. It highlights the lack of specific legislation or enforcement actions targeted at crypto activities.
licensing Banco de Moçambique's Position: The BdM has repeatedly issued warnings and communiqués stating that cryptocurrencies are not legal tender in Mozambique, are not regulated by the central bank, and transactions involving them are high risk. They emphasize that there is no official protection for consumers or investors in virtual assets. Specific Reference: Aviso Nº 03/GBM/2021, de 2 de Agosto (Warning Nº 03/GBM/2021, of August 2nd). This warning explicitly states that virtual assets are not considered currency, are not issued or guaranteed by the BdM, and are not subject to the legal regime of payment instruments or other financial instruments. It also highlights the risks associated with price volatility, cybercrime, lack of consumer protection, and potential for illicit activities. URL (Portuguese): You can typically find this aviso on the official Banco de Moçambique website under "Avisos" or "Comunicados." A direct link might change, but searching their site for "Aviso 03/GBM/2021" will yield results. (Example search on BdM site). No Specific Licenses: As a direct consequence of the above, there are no specific cryptocurrency exchange licenses, crypto custody licenses, or crypto payment processor licenses issued by the BdM or any other Mozambican authority for entities dealing solely in virtual assets. Neither for Pure Crypto: For entities operating purely in virtual assets (e.g., crypto-to-crypto exchanges), neither a dedicated registration nor a licensing regime exists. They are currently operating in an unregulated space from a specific virtual asset perspective. Licensing for Traditional Financial Services: If an entity's operations involve traditional financial services (e.g., fiat-to-crypto exchanges, crypto payment processors that handle fiat currency, or entities holding fiat funds for crypto purchases), then they might fall under the existing financial licensing requirements supervised by the Banco de Moçambique or other financial regulators, depending on the specific nature of their activities. This would be interpreted under existing laws such as: Lei do Sistema de Pagamentos (Law of the Payment System): Lei n.º 2/2016 de 27 de Junho – This law governs payment service providers (PSPs) and electronic money institutions (EMIs) that deal with fiat currency. If a crypto firm offers services that involve processing fiat payments, it could potentially be required to obtain a PSP or EMI license. URL (Portuguese): Generally available in the Mozambican official gazette (Boletim da República) or legal databases. (Example search).
securities Mozambican Securities Commission (CSM) – responsible for overseeing securities markets. The Financial Intelligence Unit Act (Decree No. 19/2019) governs anti-money laundering (AML) and counter-terrorism financing (CTF) but does not explicitly cover cryptocurrencies. Financial Intelligence Unit Act, Decree No. 19/2019 The Securities Market Law (Law No. 20/02, as amended) regulates traditional securities markets, excluding digital assets. Securities Market Law, Law No. 20/02 Mozambique is a member of the Financial Action Task Force (FATF), adhering to its recommendations on AML/CFT measures; however, these do not specifically address virtual asset services. Mozambique MZ: Treasury Bill Rate: Government Securities Mozambican Securities Commission (CSM) – oversees the securities market, including potential future regulation of digital assets. Central Bank of Mozambique (BCM) – responsible for monetary policy and financial stability, with possible oversight over crypto-related banking activities. Entities Requiring Licenses: No specific licenses are currently mandated for crypto-related activities by the CSM or BCM. Activities Requiring Licensing: None identified under existing legislation.
stablecoin Electronic Money (E-money): This is the most likely classification for stablecoins pegged to a fiat currency (like the Metical - MZN, USD, or EUR) and intended for payment purposes. Law No. 12/2009, of March 17 – Payment System Law: This law establishes the legal framework for the national payment system, defining payment instruments and electronic money. It broadly defines electronic money as monetary value represented by a claim on the issuer, stored electronically, issued on receipt of funds, and accepted as a means of payment by persons other than the electronic money issuer. Notice No. 5/GBM/2021, of March 26 – Regulation on Payment Instruments and Electronic Money Institutions: This regulation further details the requirements for issuing electronic money and licensing Electronic Money Institutions (EMIs). Interpretation: If a stablecoin aims to maintain a stable value against a fiat currency and functions as a medium of exchange, it would likely be considered "electronic money" by the Banco de Moçambique, requiring the issuer to be licensed as an EMI. Securities: Less likely for a typical stablecoin designed purely for stable value and payments, but possible if the stablecoin bestows specific rights to profits, dividends, or ownership in an enterprise, or if its backing involves complex financial instruments. Law No. 8/2009, of March 11 – Securities Market Code: This law governs the issuance and trading of securities in Mozambique. Interpretation: An "investment stablecoin" or a stablecoin with characteristics akin to a share or bond could potentially be classified as a security, subject to the regulations of the Mozambican Stock Exchange (BVM) and the oversight of the BM. Payment Tokens (not e-money): This classification is not explicitly defined in Mozambican law outside the context of electronic money. If a stablecoin does not fully meet the definition of e-money (e.g., if it's not accepted by third parties beyond the issuer's ecosystem or not directly backed by fiat), its regulatory status would be even more ambiguous. However, if it facilitates payments, it would likely still fall under the BM's regulatory purview concerning payment systems.
status Mozambique currently has no specific legal framework governing cryptocurrency or digital assets, as no dedicated legislation has been enacted as of 2025–2026 Mozambique - United States Department of State The Bank of Mozambique, as the central bank, is the primary authority with general oversight over financial activities, but no specific regulatory regime for virtual assets has been established Mozambique - United States Department of State No licensing or registration system exists for cryptocurrency businesses, and no entities have been licensed to operate crypto exchanges or provide digital asset services Mozambique - United States Department of State The practical reality is that cryptocurrency activity operates in a legal gray area—not explicitly prohibited but also not regulated or protected under any specific law Mozambique - United States Department of State General investment laws, including the revised Investment Law No. 8/2023, apply to businesses broadly but contain no provisions specific to cryptocurrency or digital assets Mozambique - United States Department of State The Bank of Mozambique (Banco de Moçambique) serves as the central bank and monetary authority, with general regulatory oversight over financial institutions and payment systems Mozambique - United States Department of State The Petroleum Law (No. 16/2022) and Mining Law (Decree 48/2022) were updated in 2022 and contain provisions for extractive industries, not digital assets Mozambique - United States Department of State A new Commercial Code was enacted in September 2022, aligned with international best practices for business facilitation, but it does not address virtual assets Mozambique - United States Department of State
tax The nature of the activity: Is it an investment, a trade, a service, or a form of remuneration? The entity involved: Is it an individual or a business entity? If an individual frequently buys and sells crypto with the intention of profit (e.g., day trading), the gains could be considered business income and taxed at progressive IRPC rates (up to 32%). If an individual holds crypto as a long-term investment and sells it occasionally, the gains might be considered "other income" or a capital gain on movable property, subject to IRPC at progressive rates. Up to MZN 30,000/month: Exempt MZN 30,001 - MZN 50,000/month: 10% MZN 50,001 - MZN 150,000/month: 20% MZN 150,001 - MZN 300,000/month: 25%
travel rule As of January 2025, zero virtual asset service providers (VASPs) are licensed, registered, or authorized by any Mozambican authority to conduct cryptocurrency exchange, custody, transfer, or related services. Any entity operating in this space does so without official approval. [Lei n.º 15/2013 (Lei das Instituições de Crédito e Sociedades Financeiras), Art. 12–15; BoM Licensing Register (consulted Jan 2025); ESAAMLG Mutual Evaluation Report (MER) Mozambique, 2022, ¶247] Mozambique has not enacted any specific cryptocurrency or digital asset legislation, and no dedicated regulatory framework for virtual assets exists as of the 2025–2026 period. The primary financial legal framework comprises the Lei Orgânica do Banco de Moçambique (Lei n.º 1/2013, de 18 de Janeiro), the Lei das Instituições de Crédito e Sociedades Financeiras (Lei n.º 15/2013, de 12 de Agosto) (hereafter "Financial Institutions Law"), and the Lei de Prevenção e Combate ao Branqueamento de Capitais e Financiamento do Terrorismo (Lei n.º 14/2013, de 12 de Agosto) (hereafter "AML/CFT Law"), none of which define or regulate virtual assets. [Boletim da República, I Série, Nos. 3, 32, 33 (2013); BoM "Avisos e Circulares" database search 2018–2025: no results for "cripto", "ativo virtual", "VASP", "virtual asset"] No Mozambican authority has been designated as the primary regulator for cryptocurrency activities. The Banco de Moçambique (BoM) is the central bank and prudential supervisor for credit institutions and payment systems; the Gabinete de Informação Financeira (GIFi), established under Law 14/2013 Art. 20, is the financial intelligence unit (FIU); and the Comissão do Mercado de Valores Mobiliários (CMVM), created under the Securities Market Law, regulates securities — but none has issued binding rules on VASPs. [Lei n.º 1/2013 Arts. 5, 15; Lei n.º 15/2013 Art. 3; Lei n.º 14/2013 Art. 20; CMVM enabling law] The FATF travel rule (Recommendation 16) and VASP regulatory requirements (Recommendation 15) have not been transposed into Mozambican law. Mozambique's ESAAMLG 2nd Round Mutual Evaluation Report (adopted Sept 2022) rated the country Partially Compliant (PC) on Rec. 15 and PC on Rec. 16, noting the absence of a VASP framework and travel-rule implementation. Mozambique was placed on the FATF "grey list" (Jurisdictions under Increased Monitoring) in Oct 2022 and removed in Feb 2024 after progress on its action plan, but the VASP gap remains unaddressed. [ESAAMLG MER Mozambique 2022, pp. 89–94, 112–118; FATF Public Statements Oct 2022, Feb 2024] The practical reality is that cryptocurrency businesses operate in a regulatory void: no licensing pathway, no AML/CFT obligations specific to virtual assets, no tax guidance, and no enforcement precedent. General financial laws (Financial Institutions Law Art. 45, AML/CFT Law Art. 3) may implicitly prohibit unlicensed financial activity, but no prosecutorial guidance or case law clarifies application to crypto. [Lei n.º 15/2013 Art. 45; Lei n.º 14/2013 Art. 3; BoM sanction powers Art. 112–115; GIFi Annual Reports 2020–2023: no crypto-related STRs or enforcement] The Banco de Moçambique (BoM), established under Lei Orgânica do Banco de Moçambique (Lei n.º 1/2013, de 18 de Janeiro), is the central bank and primary financial regulator. It supervises credit institutions, payment systems, and EMIs under the Financial Institutions Law (Lei n.º 15/2013, de 12 de Agosto). BoM has not issued any regulation, circular, notice, or guideline specifically addressing cryptocurrency, digital assets, or VASPs. A search of the BoM "Avisos e Circulares" database (2018–2025) yields zero results for "criptomoeda", "ativo virtual", "virtual asset", "VASP", or "blockchain". [Lei n.º 1/2013 Arts. 5, 15, 35; Lei n.º 15/2013 Arts. 3, 45; BoM website "Avisos e Circulares" section, consulted Jan 2025] Mozambique is a member of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG), a FATF-style regional body. The ESAAMLG 2nd Round Mutual Evaluation Report (MER) for Mozambique (adopted Sept 2022, published 2023) explicitly states: "Mozambique has not yet implemented a regulatory framework for virtual assets or VASPs" (¶247) and "Recommendation 15 requirements for VASPs are not met" (¶251). The MER rated Mozambique Partially Compliant on Rec. 15 (VASPs) and Partially Compliant on Rec. 16 (Wire Transfers/Travel Rule), citing the absence of VASP licensing, supervision, and travel-rule transposition. [ESAAMLG MER Mozambique 2022, ¶¶247–255, 278–285] No law, decree, or official gazette (Boletim da República) publication has been identified that addresses FATF Recommendation 15 (new technologies/VASPs) or the FATF travel rule (Recommendation 16) as applied to virtual assets. A systematic search of the Boletim da República (2013–2025) and the Legislação de Moçambique legal database confirms no such instrument. [Boletim da República search via Imprensa Nacional de Moçambique; Legislação de Moçambique database, consulted Jan 2025]

Sources

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