Chad Cryptocurrency Regulation: A New AML Report Is Not an Exchange Licence
Read Chad’s regional VASP approval rule, banking restrictions and the limits of its March 2026 AML follow-up before trusting a crypto licence claim.
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Chad’s cryptocurrency regulation includes an express regional requirement for prior VASP approval. Country assessments and a company’s actual permission remain separate questions.
An updated anti-money-laundering report can show progress in selected areas. It does not grant a crypto exchange a licence.
Our Africa cryptocurrency regulation directory separates restrictions, approval requirements and unresolved evidence.
What prior-approval rule applies?
GABAC publishes CEMAC Regulation No. 02/24 on anti-money laundering and terrorist and proliferation financing.
Article 42 requires prior approval or authorisation for professional VASP activity, in accordance with the specific rules in force. It refers to the competent authority of the State where the activity is to occur and also covers agents operating in a CEMAC member State.
It requires relevant preventive measures. For crypto transfers, originator and beneficiary information must be collected, retained and securely transmitted as specified in the regulation.
The text is dated 20 December 2024. Article 184 provides for entry into force on signature. The French version prevails if interpretations diverge.
An approval requirement is not proof that an application route is fully operational or that a named company has approval. The competent authority, implementing rules and provider decision still need to be established for the service proposed.
What did the earlier assessment find?
GABAC’s mutual evaluation adopted in April 2023 reflects an onsite visit from 9 to 27 May 2022. It identifies virtual-asset gaps under Recommendation 15. Criterion 15.4 found no specific requirement meeting the assessed VASP licensing or registration standard.
That is an assessment of the framework at the time. It must not become an undated claim that a business now needs no permission.
A virtual asset service provider, or VASP, may perform services such as exchange, transfers or custody for customers. The exact activity and legal entity still need review.
What does the March 2026 follow-up establish?
GABAC’s first enhanced follow-up report dated March 2026 states that it examines progress through September 2025.
The review covers Recommendations 6, 7, 10, 12, 14, 19, 20, 22, 23 and 33. Six ratings improved; four were maintained. Recommendation 15 was not among those re-rated.
The report also says it does not assess improvements in effectiveness. Its date therefore cannot be used to claim that VASP supervision was fully tested in March 2026.
How do banking restrictions affect a proposed service?
The IMF’s 2025 paper on digital payments, Annex 11, recalls COBAC’s 6 May 2022 decision banning banks from using cryptoassets.
A bank’s participation is consequently a separate issue from whether a crypto platform accepts a Chadian customer.
The scope of a supervised-institution restriction should not be confused with a verified blanket prohibition on every individual.
Is there a regional approval framework?
COSUMAF’s General Regulation of 23 May 2023 contains a section on digital-asset service providers, or PSAN.
Article 336 sets resource, own-funds, security and control requirements. Articles 338–339 address the application file and AML arrangements. Article 341 requires a written application, while Article 343 describes examination within 60 working days of a complete file. That is not automatic approval.
The October 2026 market-regulation amendment changes private-placement provisions in Articles 88–91. It is not a general crypto-service authorisation.
The regional instruments and the historical assessment need to be read together. A licensing claim should be checked through COSUMAF’s approval-verification service and the relevant authorities, matching the entity and service.
What would establish a credible licensing claim?
Ask the provider to identify its legal entity before reviewing its brand name.
Then connect the claimed permission to the service actually supplied.
| Evidence | What it should show |
|---|---|
| Regulator’s decision | Authorised entity, services and conditions |
| Current legal instrument | Applicable rules and effective date |
| Banking arrangement | Lawful role of the payment institution |
| Customer agreement | Who owes money or assets to the customer |
| Withdrawal policy | How funds can be returned and complaints handled |
An overseas registration does not automatically settle the local position.
What remains unresolved on capital?
Article 336 requires sufficient own funds relative to the services and risks. A universal numeric VASP minimum was not independently verified.
Do not use an ordinary company’s registered capital, a bank threshold or another CEMAC country’s article as a substitute. Any figure needs an applicable rule and activity category.
A claimed approval also needs verification of its current validity. A certificate issued to another entity is not enough.
For comparison, read Cameroon’s cryptocurrency banking restrictions, Gabon’s crypto approval and implementation gaps and Central African Republic cryptocurrency regulation after the legal-tender reversal.
Sources and review limits
Reviewed 6 November 2026. The historical assessment, the follow-up’s cut-off and scope, the published regional AML regulation and COSUMAF’s provider provisions were checked.
GABAC’s official English version of the AML regulation was reviewed; the French text prevails under its Article 183. This article does not treat the 2026 follow-up as a new VASP assessment.
A complete current Chad-specific implementation file, authority designation and provider-specific approval were not independently established. The existence of an approval rule does not confirm a named provider, and a dated assessment gap does not establish general permission.
