- Introduction
Rwanda has taken a major step towards regulating cryptocurrencies and virtual assets by introducing a comprehensive legal framework for virtual asset businesses. The new rules through the adoption of Law Nº 023/2026 of 25 May 2026 Regulating Virtual Asset Business aims to create a safer, more transparent digital asset market while supporting innovation and investment in the Country’s growing digital economy
Prior to this regulatory innovation, there has been no dedicated legal framework regulating how these businesses operate in Rwanda
2) Understanding of Virtual assets
Virtual assets are digital representations of value that can be traded, transferred, or used for investment and payment purposes using electronic networks, often based on blockchain technology.
In order words, digital assets can be digitally traded or transferred and can be used for payment or investment purposes. Examples of virtual assets includes:
Bitcoin, Ethereum, USDT, BNB, Non-fungible tokens (NFTS) used for investment trading, certain tokenized assets that represent ownership rights or economic value.
3) Importance of the introduction of Law Nº 023/2026 of 25 May 2026 Regulating Virtual Asset Business in Rwanda’s Economy
Through the introduction of the aforementioned legal framework, the Rwanda Government’s objectives aims to:
-Protect consumers from fraud, scams, and pyramid schemes.
-Prevent money laundering, terrorist financing, and cybercrime.
-Increase market transparency and investor confidence.
-Encourage responsible innovation in financial technology and digital assets.
4) The Regulatory Authority for Virtual Assets in Rwanda
The primary Regulator is the Capital Market Authority, which oversees licensing, supervision, and enforcement of virtual asset businesses. The National Bank of Rwanda will also play an important role, particularly regarding financial stability and the payment ecosystem.
5) Applicability of Law Nº 023/2026 of 25 May 2026 Regulating Virtual Asset Business
The introduction of the new regulation is applicable to any Company that is desirous of operating or providing virtual asset services in Rwanda. A licence must be obtained before operation. This includes businesses involved in:
-Cryptocurrency exchanges.
-Virtual asset trading platforms.
-Custody and safekeeping of digital assets.
-Transfer services involving virtual assets.
-Other virtual asset service activities conducted on behalf of clients.
Operating without the required license exposes businesses to regulatory sanctions and penalties in Rwanda.
6) Important Restrictions
According to the Regulatory framework, virtual assets are not recognized as legal tender in Rwanda. Certain activities such as crypto mining operations, crypto ATMs and mixer/tumbler services are prohibited unless specifically authorized by Regulators
7) Opportunities for Businesses and Investors in Rwanda’s Fintech Ecosystem
The new framework provides:
– Greater legal certainty for crypto businesses
– Improved investor protection.
-Potential growth in blockchain and digital finance innovation.
-Increased attractiveness of Rwanda as a regional fintech hub.
8) Key Compliance Requirements
Rwanda’s new virtual asset regulation marks a significant shift from a largely unregulated environment to a structured legal framework. Virtual Asset Service Providers (VASPs) will be expected to:
-Implement anti-money laundering (AML) controls.
-Conduct customer due diligence and identity verification (KYC).
-Maintain adequate records and reporting systems.
-Meet capital and operational requirements set by the Regulator.
-Establish cybersecurity and consumer protection measures.
The new Regulation is designed to balance innovation with consumer protection and financial integrity. For cryptocurrency exchanges, blockchain startups, investors, and other virtual asset businesses, understanding and complying with these requirements is a pre-requisite for operating legally and successfully in Rwanda.
However, although the law has entered into force, Regulators are still developing some of the detailed implementation rules and licensing procedures.
9) The Role of OL & PARTNERS
One of the primary roles of our fintech experts is advising Virtual Asset Service Providers (VASPs) and ensuring that virtual asset companies operate efficiently while minimizing legal risks:
a) Ensuring Regulatory Compliance and Licensing:
-Interpreting cryptocurrency and virtual asset laws;
-Assisting businesses in obtaining licenses and regulatory approvals;
-Ensuring compliance with anti-money laundering (AML) and know-your-customer (KYC) requirements;
-Advising on reporting and disclosure obligations.
b) Business Structuring and Corporate Governance:
-Choosing appropriate legal structures;
-Drafting corporate governance policies;
-Advising directors and shareholders on legal responsibilities;
-Structuring investment and fundraising transactions.
c)Contract Drafting and Review of Contracts to protect clients’ interests and reduce the likelihood of disputes:
-Exchange user agreements;
-Smart contract terms and conditions;
-Partnership agreements;
-Investment and token purchase agreements.
d)Anti-Money Laundering (AML) and Financial Crime Prevention :
-Designing AML compliance programs;
-Conducting legal risk assessments;
-Advising on sanctions compliance;
-Supporting suspicious transaction reporting obligations;
-Training staff on financial crime prevention requirements.
e) Risk Management and Legal Due Diligence:
-Cryptocurrency trading platforms;
-Token offerings;
-Blockchain projects;
-Mergers and acquisitions involving virtual asset businesses.
f) Tax Advisory Services:
– Capital gains taxation;
-Corporate tax obligations;
-Cross-border tax issues;
-Reporting requirements for digital asset transactions.
g) Data Protection and Privacy Compliance:
-Conducting legal research on emerging technologies.
-Data protection laws;
-Privacy regulations;
-Cybersecurity obligations;
-Consumer protection requirements.