From Prohibition to Regulation: Morocco’s Policy Reversal
Since 2017, Bank Al-Maghrib had warned against cryptocurrency transactions, creating a de facto prohibition that pushed Moroccan crypto activity underground. Bill 42.25, currently in parliamentary review, marks a historic reversal: Morocco will establish a comprehensive regulatory framework for crypto-asset service providers (CASPs) modeled on the EU’s MiCA regulation.
Key Provisions of Bill 42.25
The draft law introduces three licensing categories: crypto-asset custody providers (licensed by BAM), crypto-asset exchange platforms (licensed by AMMC, the securities regulator), and crypto-asset issuers conducting public offerings of crypto-assets (requiring an approved white paper filed with AMMC). Stablecoins pegged to foreign currencies require additional BAM authorization given their monetary policy implications.
AML/CFT and Consumer Protection Requirements
All CASPs must implement FATF-compliant AML/CFT programs, including Travel Rule compliance for crypto transfers, enhanced due diligence for transactions above MAD 50,000, real-time transaction monitoring, and suspicious activity reporting to UTRF (Morocco’s financial intelligence unit). Consumer protection rules include mandatory disclosure of risks, segregation of client assets, and liability for cybersecurity breaches.
Market Entry Strategy for International CASPs
Foreign platforms seeking Moroccan authorization should anticipate a 12-18 month licensing timeline, capital requirements of MAD 5-10 million depending on activity scope, and mandatory local management presence. The law’s passage is expected in Q2 2026, with implementing regulations following within 6 months.
Lafrouji Avocats monitors Bill 42.25 and advises fintech companies on positioning for Morocco’s crypto regulatory opening.
