Tunisia's Crypto Ban Faces Potential Shift With Regulatory Sandbox

Tunisia has maintained a restrictive stance on cryptocurrency since 2018, when the Central Bank of Tunisia (BCT) issued a directive prohibiting any transactions involving virtual money without state authorization. This ban encompasses public trading, exchange services, and the acceptance of crypto payments. The regulatory framework is overseen by key institutions including the BCT, the Ministry of ICT & Digital Economy, and the Financial Market Council (CMF), which would regulate tokenized securities if the ban were lifted.

The historical context of cryptocurrency in Tunisia reveals a period of regulatory ambiguity from 2013 to 2017, during which Bitcoin trading occurred largely in peer-to-peer chat rooms. In May 2018, the BCT formally banned crypto transactions due to concerns over capital flight and money laundering, leading banks to block card purchases at foreign exchanges. The introduction of an E-Dinar CBDC in 2019 was quickly ruled out by the BCT, but it signaled growing institutional interest. Since 2020, the BCT has operated a regulatory sandbox, indicating a shift in attitude towards innovation, although the ban remains in place. A high-profile case in 2021, where a teenager was jailed for exchanging a small amount of cryptocurrency, sparked discussions at the cabinet level about decriminalization, which have yet to materialize.

The regulatory framework in Tunisia is stringent. The BCT determines monetary policy, upholds the crypto ban, and runs the fintech sandbox. The CMF, as the capital-markets watchdog, would oversee any future security-token offerings. The National Anti-Money-Laundering Commission (CTAF) monitors AML requirements in financial establishments. Tunisia does not issue licenses to exchanges, custodians, or token-issuance platforms. Blockchain or payment pilots must apply to the BCT sandbox for temporary, limited-scope testing. Banks are required to deny crypto-related transfers, and sandbox participants must conduct thorough customer identification, maintain detailed ledgers, and file Suspicious Transaction Reports with CTAF. Since trading is illegal, Tunisia lacks a specific crypto tax code, and any profits discovered are considered illegal and can be seized. Companies are not allowed to record crypto assets on local books. ICOs are not permitted to be public, and security tokens would be subject to CMF prospectus requirements, which have not been approved. Utility tokens are not permitted to be released until tested in a sandbox and limited to closed-loop pilots.

Crypto policies in Tunisia are clear: all crypto payments are illegal, and merchants are not allowed to accept digital assets as payment. Mining activities, including importing ASIC rigs and exchanging mined coins into dinar, violate the 2018 directive and can result in equipment seizure by customs authorities. The BCT has developed an in-house E-Dinar Proof-of-concept, but no external pilot is available. Blockchain technology is listed under the Digital Tunisia 2025 project for transparency in supply chain and record-keeping, specifically on permissioned ledgers. Violations of currency-control regulations can result in fines and up to five years in jail.

The BCT Regulatory Sandbox allows small groups of fintechs to test blockchain payments, remittances, and traceability platforms in a controlled environment. Local start-ups, such as VFunder, Hydro E-Blocks, and No Phobos, often host their infrastructure in other countries and take advantage of sandbox exemptions for research. Mainstream usage remains fragile, with even a handful of e-commerce platforms experimenting with cryptocurrency pricing but ending up offshore. Government pilots focus on land-registry digitization and the distribution of targeted subsidies through privately managed blockchains.

Challenges in Tunisia's approach to crypto innovation include regulatory inconsistency, enforcement difficulties, and public perception. The coexistence of a complete ban on trading with an innovation-friendly sandbox is confusing and deters high-scale investors. Peer-to-peer applications and foreign exchanges operate discreetly, making it hard to monitor AML. Media portrayals of cryptocurrency vacillate between opportunity and threat, with the 2021 teen-arrest case lingering in public memory and deterring both casual users and banks.

Recent regulatory trends indicate that parliamentary committees are considering a draft bill to decriminalize possession and implement a license regime on FATF travel-rule lines. The BCT has hinted that second-generation sandbox cohorts may involve tokenized-bond pilots in climate-finance projects. Projections suggest partial legalization within 24 months, with conditional exchange licenses, mandatory on-shore KYC, and restricted corporate mining permits. Tax regulations are expected to follow, with crypto profits defined as taxable income after the legalization of trading. The move in Tunisia from a controlled market to a complete ban may influence other Francophone North-African countries, providing a middle-way solution to balance capital control and technology innovation.

Tunisia has not officially changed its stance on open-market use of cryptocurrency, but the sandbox and legal discussions indicate a shift towards tightly controlled acceptance. For investors and developers, understanding the current penalties and impending policy changes is crucial for risk management and initial-stage positioning.