New SI 99 requires VASPs to register with the FIU, but banking access remains blocked_
*HARARE* — Zimbabwe has enacted its first comprehensive rules for cryptocurrency businesses, giving legal clarity to a market that has operated largely underground since banks cut ties with exchanges in 2018.
Statutory Instrument 99 of 2026, gazetted in June, requires any company that facilitates the buying, selling, moving or storing of crypto to register with the Reserve Bank’s Financial Intelligence Unit. The annual fee is US$500. Operating without registration is now a criminal offence.
For individuals, the law changes little. Holding crypto in a personal wallet and trading peer-to-peer remain legal. The regulation targets exchanges, OTC desks and custodial wallet providers, not end users.
*Stablecoins fill the gap*
In practice, most Zimbabweans use stablecoins like USDT and USDC to store USD value, send remittances and pay for online services. With USD cash scarce and bank USD accounts restricted, stablecoins offer a dollar-pegged alternative that settles in minutes for cents in fees.
“Crypto in Zimbabwe grew because formal rails were slow, expensive, or closed,” said one trader active in Harare’s OTC market. “SI 99 is trying to bring some of that activity into the open without banning it.”
Traders estimate significant volumes still flow monthly through informal channels, often outpacing formal remittance providers on cost and speed.
*Registration ≠ protection*
The FIU has stressed that registration confirms only that a firm has filed anti-money-laundering paperwork. It does not insure customer funds or provide recourse if a platform collapses or users fall for a scam.
“‘Registered’ doesn’t mean ‘safe,’” the FIU noted in guidance accompanying the law. That leaves users exposed to the same risks that have plagued the market globally: phishing, fake investment schemes, and irreversible transactions.
*Banking remains the bottleneck*
The bigger unresolved issue is banking access. The 2018 RBZ circular that forced banks to sever ties with crypto exchange Golix has not been repealed. Without new guidance, a registered VASP may still be unable to open a bank account, forcing settlement in cash or stablecoins.
That keeps much of the market outside formal rails and limits the impact of the new rules. If the RBZ allows registered firms to bank, on/off ramps could expand quickly. If not, peer-to-peer and cash agents will likely remain dominant.
*What comes next*
The FIU is expected to release detailed compliance guidelines in the coming months, covering know-your-customer requirements and the travel rule for cross-border transfers. The move aligns Zimbabwe with Financial Action Task Force standards after the country’s removal from the grey list in 2022.
For fintech and regtech firms, the regulation creates immediate demand for AML tooling, identity verification and transaction monitoring. For users, the advice remains unchanged: use non-custodial wallets for small amounts, verify addresses, avoid “guaranteed return” schemes, and keep records for tax purposes.
S.I. 99 does not ban crypto. It defines who can legally act as a bridge between crypto and the formal economy. Whether that bridge gets built depends on the RBZ’s next move on banking.
_Fintech Review Africa will update this story as the FIU releases compliance guidelines and the RBZ clarifies banking policy._
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Francis
FintechReview Africa Contributor
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