{"as_of":"2026-10-31","note":"A pointer to each regulator's own documents, not legal advice. Facts marked read: false were not read from here (the hosts are denied from our build sandbox): the instrument's name and date as published, to confirm in the document. Where we hold no primary source the answer is not_established, with the reason. Crypto licensing and exchange control are separate questions; a licensed provider does not make a company's cross-border payment lawful under exchange control.","countries":[{"country":"ZA","name":"South Africa","answer":"restricted","summary":"Crypto asset services need an FSCA licence; a company's cross-border payment over a stablecoin has no provided path in exchange control, and the 2026 drafts would keep companies out.","conditions":["Through a crypto asset service provider licensed by the FSCA (crypto assets are a financial product under FAIS).","Exchange control: under the April and August 2026 drafts as published, only individuals may move crypto abroad through an authorised CASP; a company has no provided path. Until the drafts are final, ask your authorised dealer before any stablecoin leg."],"exchange_control":"Currency and Exchanges Act and the SARB's Currency and Exchanges Manual; a company's crypto leg is not provided for.","facts":[{"text":"The FSCA declared crypto assets a financial product under the Financial Advisory and Intermediary Services Act (declaration published 19 October 2022), so a business offering crypto asset services needs an FSP licence.","source":{"authority":"Financial Sector Conduct Authority","title":"Declaration of crypto assets as a financial product under FAIS","url":"https://www.fsca.co.za/","url_kind":"regulator","date":"2022-10-19","read":false,"how":"Not read from here: fsca.co.za is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}},{"text":"Draft Capital Flow Management Regulations treat crypto as capital for exchange control.","source":{"authority":"National Treasury and SARB","title":"Draft Capital Flow Management Regulations","url":"https://www.treasury.gov.za/public%20comments/CapFlow/Draft%20Capital%20Flow%20Management%20Regulations%202026%20April.pdf","url_kind":"document","date":"2026-04-17","read":false,"how":"Recorded in lib/regulatory/events.ts without a note of when the document was read; shown as not read.","event_id":"za-capital-flow-management-draft"}},{"text":"Draft Cross-Border Activities manual: CASPs apply to the SARB's Financial Surveillance Department to move crypto across the border; as drafted, companies are not among those who may.","source":{"authority":"National Treasury and SARB Financial Surveillance Department","title":"Draft Crypto Asset Manual for Cross-Border Activities","url":"https://www.treasury.gov.za/comm_media/press/2026/2026080301%20MEDIA%20STATEMENT%20-%20DRAFT%20CRYPTO%20ASSET%20MANUAL%20FOR%20CROSS-BORDER%20ACTIVITIES%20(002).pdf","url_kind":"document","date":"2026-08-03","read":false,"how":"Recorded in lib/regulatory/events.ts without a note of when the document was read; shown as not read.","event_id":"za-sarb-crossborder-crypto-manual-draft"}}],"reason":null,"checked_on":"2026-10-31"},{"country":"MZ","name":"Mozambique","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"Banco de Moçambique administers the foreign exchange law; how it treats a stablecoin leg is not established.","facts":[],"reason":"No Banco de Moçambique rule licensing crypto or stablecoin service providers, or allowing a business to settle a cross-border payment with one, was read: bancomoc.mz is denied from the build sandbox and no such instrument is held here.","checked_on":"2026-10-31"},{"country":"ZM","name":"Zambia","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"Zambia has no exchange controls on current payments as far as we hold; whether a stablecoin leg is treated as a payment service needing Bank of Zambia designation is not established.","facts":[],"reason":"No Bank of Zambia or Securities and Exchange Commission instrument that licenses crypto service providers or allows a business to settle a cross-border payment over a stablecoin was read: boz.zm is denied from the build sandbox and no such instrument is held here.","checked_on":"2026-10-31"},{"country":"ZW","name":"Zimbabwe","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"Exchange Control Act (Chapter 22:05) and the RBZ's exchange control directives govern cross-border payments; their treatment of a stablecoin leg is not established.","facts":[],"reason":"No Reserve Bank of Zimbabwe instrument allowing a business to settle a cross-border payment over crypto or a stablecoin was read: rbz.co.zw is denied from the build sandbox.","checked_on":"2026-10-31"},{"country":"MW","name":"Malawi","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"The Reserve Bank of Malawi administers exchange control; its treatment of a stablecoin leg is not established.","facts":[],"reason":"No Reserve Bank of Malawi instrument licensing crypto service providers or allowing a business to use one for a cross-border payment is held here; none was found on rbm.mw's home page from here.","checked_on":"2026-10-31"},{"country":"NA","name":"Namibia","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"Exchange control in the Common Monetary Area, administered by the Bank of Namibia; its treatment of a stablecoin leg is not established.","facts":[{"text":"The Virtual Assets Act, 2023 (Act No. 10 of 2023) makes the Bank of Namibia the regulator that licenses virtual asset service providers.","source":{"authority":"Bank of Namibia","title":"Virtual Assets Act, 2023 (Act No. 10 of 2023)","url":"https://www.bon.com.na/","url_kind":"regulator","date":"2023","read":false,"how":"Not read from here: bon.com.na is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":"Namibia licenses virtual asset service providers, but whether a business may settle a cross-border payment over a stablecoin under the Common Monetary Area's exchange control is not established from a primary source held here.","checked_on":"2026-10-31"},{"country":"BW","name":"Botswana","answer":"permitted_with_conditions","summary":"Lawful through a virtual asset service provider licensed by NBFIRA; Botswana has no exchange controls.","conditions":["Through a virtual asset service provider licensed by NBFIRA under the Virtual Assets Act, 2022.","Anti-money-laundering duties of the provider apply (customer identification, travel of payer and payee information)."],"exchange_control":"None: Botswana abolished exchange controls in February 1999.","facts":[{"text":"The Virtual Assets Act, 2022 requires virtual asset service providers to be licensed by the Non-Bank Financial Institutions Regulatory Authority (NBFIRA).","source":{"authority":"Non-Bank Financial Institutions Regulatory Authority","title":"Virtual Assets Act, 2022","url":"https://www.nbfira.org.bw/","url_kind":"regulator","date":"2022","read":false,"how":"Not read from here: nbfira.org.bw is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}},{"text":"Exchange controls were abolished in February 1999.","source":{"authority":"Bank of Botswana","title":"Abolition of exchange controls","url":"https://www.bankofbotswana.bw/","url_kind":"regulator","date":"1999-02","read":false,"how":"Not read from here: bankofbotswana.bw is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":null,"checked_on":"2026-10-31"},{"country":"KE","name":"Kenya","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"None on current payments (liberalised in the 1990s); the Central Bank of Kenya's foreign exchange guidelines apply to banks and bureaus.","facts":[{"text":"The Virtual Asset Service Providers Act, 2025 sets licensing of virtual asset service providers by the Central Bank of Kenya and the Capital Markets Authority.","source":{"authority":"Central Bank of Kenya and Capital Markets Authority","title":"Virtual Asset Service Providers Act, 2025","url":"https://www.centralbank.go.ke/","url_kind":"regulator","date":"2025","read":false,"how":"Not read from here: centralbank.go.ke is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":"Kenya enacted a licensing law for virtual asset service providers in 2025, but whether licences are being issued, and so whether a licensed route exists for a business today, is not established from a primary source read here.","checked_on":"2026-10-31"},{"country":"NG","name":"Nigeria","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"CBN Foreign Exchange Manual (4th edition, 2026) governs eligible transactions through authorised dealers; a stablecoin leg is not provided for in what we hold.","facts":[{"text":"The CBN's circular of 22 December 2023 lets banks open accounts for and serve virtual asset service providers, lifting the February 2021 restriction.","source":{"authority":"Central Bank of Nigeria","title":"Guidelines on operations of bank accounts for virtual asset service providers","url":"https://www.cbn.gov.ng/","url_kind":"regulator","date":"2023-12-22","read":false,"how":"Not read from here: cbn.gov.ng is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}},{"text":"The Investments and Securities Act, 2025 treats digital assets as securities under the SEC's regulation.","source":{"authority":"Securities and Exchange Commission Nigeria","title":"Investments and Securities Act, 2025","url":"https://sec.gov.ng/","url_kind":"regulator","date":"2025-03","read":false,"how":"Not read from here: sec.gov.ng is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":"Digital asset service providers are registered by the SEC and banks may serve them, but whether a business may settle an import or other cross-border payment over a stablecoin under the CBN's foreign exchange rules is not established from a primary source read here.","checked_on":"2026-10-31"},{"country":"GH","name":"Ghana","answer":"not_established","summary":"Not established: we hold no primary source that answers this for a business.","conditions":[],"exchange_control":"The Bank of Ghana's foreign exchange rules govern cross-border payments (e.g. its rules on advance payments for imports); their treatment of a stablecoin leg is not established.","facts":[],"reason":"No Bank of Ghana or SEC Ghana instrument licensing virtual asset service providers, or allowing a business to settle a cross-border payment over a stablecoin, was read: bog.gov.gh is denied from the build sandbox and no such instrument is held here.","checked_on":"2026-10-31"},{"country":"NL","name":"Netherlands and the EU","answer":"permitted_with_conditions","summary":"Lawful through a crypto-asset service provider authorised under MiCA, with a stablecoin that is an e-money token from an EU-authorised issuer; the travel rule applies.","conditions":["Through a crypto-asset service provider authorised under MiCA (in the Netherlands by the AFM; the Dutch transition for registered providers ended on 30 June 2025).","The stablecoin must be an e-money token or asset-referenced token whose issuer is authorised in the EU (MiCA Titles III and IV); a provider may not offer a non-compliant one to EU clients.","The Transfer of Funds Regulation's travel rule: payer and payee information travels with every crypto-asset transfer."],"exchange_control":"None.","facts":[{"text":"MiCA: crypto-asset service providers are authorised by a national authority; the transition for providers already registered ends by 1 July 2026 at the latest, earlier where a member state chose.","source":{"authority":"European Parliament and Council","title":"MiCA (EU) 2023/1114: end of the transition for crypto-asset service providers","url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114","url_kind":"document","date":"2023-05-31","read":true,"how":"Read 2026-10-18: Articles 143 and 149 of the text on EUR-Lex","event_id":"eu-mica-casp-transition-end"}},{"text":"Transfer of Funds Regulation: payer and payee information on crypto-asset transfers.","source":{"authority":"European Parliament and Council","title":"Transfer of Funds Regulation (EU) 2023/1113 (travel rule)","url":"https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1113","url_kind":"document","date":"2023-05-31","read":true,"how":"Read 2026-10-18: Article 40 of the text on EUR-Lex","event_id":"eu-transfer-of-funds-regulation"}},{"text":"The Netherlands set a six-month transition: providers registered with DNB had until 30 June 2025 to hold a MiCA authorisation from the AFM.","source":{"authority":"Autoriteit Financiële Markten","title":"MiCA authorisation for crypto-asset service providers","url":"https://www.afm.nl/","url_kind":"regulator","date":"2025-06-30","read":false,"how":"Not read from here: afm.nl is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":null,"checked_on":"2026-10-31"},{"country":"HK","name":"Hong Kong","answer":"permitted_with_conditions","summary":"Lawful through an SFC-licensed virtual asset trading platform; fiat-referenced stablecoin issuers need an HKMA licence. No exchange controls.","conditions":["Through a virtual asset trading platform licensed by the SFC.","A fiat-referenced stablecoin offered in Hong Kong comes from an issuer licensed by the HKMA under the Stablecoins Ordinance."],"exchange_control":"None.","facts":[{"text":"The Stablecoins Ordinance (Cap. 656) commenced on 1 August 2025: issuing fiat-referenced stablecoins in or into Hong Kong needs an HKMA licence.","source":{"authority":"Hong Kong Monetary Authority","title":"Stablecoins Ordinance (Cap. 656)","url":"https://www.hkma.gov.hk/","url_kind":"regulator","date":"2025-08-01","read":false,"how":"Not read from here: hkma.gov.hk is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}},{"text":"Virtual asset trading platforms are licensed by the SFC under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance since 1 June 2023.","source":{"authority":"Securities and Futures Commission","title":"Licensing regime for virtual asset trading platforms","url":"https://www.sfc.hk/","url_kind":"regulator","date":"2023-06-01","read":false,"how":"Not read from here: sfc.hk is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":null,"checked_on":"2026-10-31"},{"country":"CN","name":"China (mainland)","answer":"prohibited","summary":"Virtual currency business activities are illegal financial activities on the mainland; no lawful stablecoin route for a business.","conditions":[],"exchange_control":"SAFE's foreign exchange administration governs cross-border payments through banks.","facts":[{"text":"The People's Bank of China and nine other authorities' notice of September 2021 (Yinfa [2021] No. 237) declares virtual currency business activities illegal financial activities.","source":{"authority":"People's Bank of China","title":"Notice on further preventing and disposing of the risks of virtual currency trading speculation (Yinfa [2021] No. 237)","url":"http://www.pbc.gov.cn/","url_kind":"regulator","date":"2021-09","read":false,"how":"Not read from here: pbc.gov.cn is denied from the build sandbox (31 Oct 2026). Instrument name, number and date as published; confirm in the document before relying on it."}}],"reason":null,"checked_on":"2026-10-31"}]}