Sierra Leone Cryptocurrency Regulation: Section 103 Already Requires VASP Licensing
Read Sierra Leone’s enacted VASP licensing requirement, AML and transfer duties, and the distinction between the law and operational approval evidence.
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Sierra Leone has an enacted licensing requirement for virtual-asset service providers. Section 103(3)(b) of its 2024 AML law requires registration and a licence before operations begin.
The next question is practical: what permission does the company serving you actually hold?
Our Africa cryptocurrency regulation directory helps compare national rules and the evidence still needed for market entry.
What does Section 103 require?
The 2024 Act on the Financial Intelligence Agency’s legal-framework page includes a section headed “Virtual assets”. The official copy records presidential signature on 13 May 2024 and gazette publication on 6 June 2024.
Section 103 addresses risk controls, licensing and transfer information. Subsection (3)(c) requires originator and beneficiary information to reach the receiving provider or reporting entity immediately and securely. It must also be available to the FIA or supervisor on request.
Read the official Act, Section 103, printed pages 106–108 before designing a service. Subsection (4) makes breaches of subsection (3) criminal offences, with fines, imprisonment or both. Subsection (8) extends the Act’s reporting and monitoring duties to the sector.
A proposed service should receive an assessment based on its actual functions. Identify the company contracting with customers, the party controlling crypto and the party handling fiat payments.
What did GIABA establish?
GIABA’s fourth follow-up report, adopted in November 2024, identifies the Bank of Sierra Leone as the licensing supervisor under criterion 15.4.
Its criterion 15.6 records that no VASP had yet been licensed and that sector-specific supervisory tools remained incomplete. Criterion 15.7 records an outstanding need for guidance. The report considers progress up to 15 May 2024.
These are historical findings. They do not establish how many licences exist today.
FATF also lists a fifth follow-up report from November 2025. Its page directs readers to request a copy from GIABA. We did not independently retrieve that report’s full text, so this article does not attribute later findings to it.
Is a current VASP application route confirmed?
This review did not independently verify a complete current public VASP application procedure or an individual provider’s approval.
That evidence gap does not remove the statutory duty. A business should obtain current instructions from the BSL and reconcile them with the Act before beginning operations.
Ask for the relevant application forms, legal instruments and approval conditions. Identify which entity receives the permission and whether it covers the proposed exchange, custody, transfer or payment activity.
| Review item | Evidence to request |
|---|---|
| Market entry | Current BSL application instructions and applicable rules |
| Provider permission | Decision naming the legal entity and permitted services |
| Ownership and management | Required ownership disclosures and suitability checks |
| Customer assets | Custody rights, reconciliation and withdrawal arrangements |
| Compliance | Risk assessment, reporting procedures and transfer-data workflow |
Treat this table as a due-diligence checklist. It is not a confirmed BSL application pack.
Does the sandbox establish a crypto licence?
The BSL’s sandbox programme page describes testing innovative financial products within specified parameters and a timeframe before market launch.
The page does not establish that a named crypto provider has unrestricted permission to operate. If a company cites sandbox participation, request its admission letter, approved activities, customer limits and expiry date.
Check how a trial transitions to any permission required for wider operations. A general programme announcement cannot answer those company-specific questions.
What should a transfer workflow cover?
As a practical design exercise, map how customer information travels between the sending and receiving businesses. Identify who collects it, who checks it and who can retrieve it for compliance work.
Document how the service handles missing information, rejected transfers and returned funds. Reconcile the workflow with the full Act and any current supervisory directions.
Keep a record of which rules and versions informed the design. A diagram alone cannot establish legal compliance.
What is the minimum capital?
No universal current VASP capital threshold was independently verified in this review. A market-entry budget should use the rule for the particular activity and the authority responsible for it.
Keep regulatory own funds, application charges, operating liquidity and customer property separate. Ask for the legal instrument and effective date supporting any quoted capital amount.
What should customers check?
Start with the legal name in the customer agreement. Compare it with the entity named in any claimed permission.
Read the withdrawal terms, fees, complaint route and governing law. Ask what happens if the service suspends a payment or becomes insolvent. Keep copies of the documents available when the account is opened.
For regional context, read Ghana’s cryptocurrency regulation and licensing analysis, Nigeria’s cryptocurrency regulatory framework and The Gambia’s crypto licensing evidence review.
Research scope
Reviewed 6 November 2026 using the enacted law, the 2024 GIABA report, FATF’s newer report listing and BSL public materials. A complete current application route, named VASP approvals and a universal capital requirement were not independently confirmed. No claim is made that the older licence count remains current.
