Guinea Cryptocurrency Regulation: Article 101 Puts Approval Before Business
Read Guinea’s express VASP approval requirement, preventive AML duties and the remaining checks on application procedures and provider permissions.
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Guinea’s AML law expressly addresses professional virtual-asset services. Article 101 requires approval or authorisation from the Banque Centrale de la République de Guinée before carrying on that activity.
The practical task is to connect that rule with current application instructions and the permission held by the actual company.
Our Africa cryptocurrency regulation directory helps compare those requirements across African markets.
What does Article 101 establish?
The 2021 AML/CFT law published by BCRG, Article 101, prohibits professional VASP activity without BCRG approval or authorisation. It also addresses identifying unauthorised operators and applying sanctions referenced in the provision.
This is an express market-entry rule. The existence of crypto trading or an accessible app does not establish compliance with it.
Read Article 101 alongside the statutory definitions and current implementing instruments. A legal review should address the company’s actual services rather than rely on its chosen marketing label.
Which activities does the law cover?
Article 6 defines VASPs by activities conducted commercially for customers. The definition covers fiat–crypto exchange, crypto–crypto exchange, transfers, custody or administration and certain issuer-related financial services.
The activity matters. A business using several entities should identify which one carries out each function.
A payment partner’s permission does not answer the separate approval question for the company selling or holding crypto.
Who supervises VASPs?
Article 97 assigns BCRG responsibility for regulating and supervising VASP compliance with the law’s AML/CFT obligations. Article 101 separately establishes the approval requirement.
The BCRG AML implementation instruction dated 11 January 2023, No. 109, expressly includes VASPs in Article 3. Its requirements cover risk-based controls and customer due diligence. An operator should review the instruction alongside the law.
These are concrete obligations. They do not establish that a particular exchange has approval or that a complete public application route is available.
What AML duties are explicit?
Articles 58–60 address risk controls, customer due diligence and other preventive obligations for VASPs. Article 59 includes an occasional-transaction threshold of GNF 10 million, or a threshold set by BCRG.
Instruction No. 109, Article 8, also sets GNF 10 million for occasional transactions under Article 25(2). That is not a general exemption from checks below that amount. The same article addresses identification of permanent and occasional customers, with risk-based requirements.
A provider should map the complete obligations, including the provisions incorporated by reference. Record how the service collects information, monitors activity and handles reporting.
What does the newer follow-up add?
GIABA’s November 2025 follow-up report concerns technical-compliance progress. Its re-rating scope focuses on Recommendations 28 and 34.
It should not be described as a new VASP licence or a complete reassessment of the crypto sector. A country-level AML assessment and a company-specific approval answer different questions.
The report is useful context. It does not replace BCRG’s current instructions or an operator’s approval decision.
Is the current application process confirmed?
This review did not independently verify a complete current public VASP application pack, a named approval or a universal minimum capital amount.
That is an evidence limitation, not a reason to omit Article 101. A business should obtain instructions from BCRG before treating market entry as available.
| Review item | Evidence needed |
|---|---|
| Activity classification | Analysis against the statutory VASP definition |
| Application process | Current BCRG instructions and supporting forms |
| Permission | Decision naming the serving company and services |
| AML controls | Risk assessment and implemented procedures |
| Capital | Applicable instrument and service-specific amount |
The table is a planning aid. It is not a confirmed regulator checklist.
What should customers ask?
Start with the legal name in the account agreement. Ask for the approval reference and the authority that issued it.
Check whether the permission covers the company that owes the withdrawal. Read how balances are held, which fees apply and where a complaint can be filed.
For a transfer, identify the crypto provider and the local payment provider separately. Preserve transaction receipts and the terms accepted at account opening.
For regional context, read Sierra Leone’s cryptocurrency licensing rule, Liberia’s crypto regulation and banking restrictions and Senegal’s cryptocurrency authorisation analysis.
Research scope and limits
Research reviewed 6 November 2026. Sources include the BCRG-hosted 2021 law, Instruction No. 109 of 11 January 2023 and GIABA’s 2025 follow-up scope. The approval requirement and published AML duties were verified in those texts. A complete current VASP application pack, a provider approval register and a universal VASP minimum capital amount were not independently established. No provider is certified by this review. Obtain current BCRG confirmation for a proposed service.
