Zimbabwe’s New Crypto Regulation Explained: Everything Virtual Asset Businesses Need to Know About S.I. 99 of 2026.

Part 1

Zimbabwe Has Finally Regulated Crypto. Here’s What It Means for the Industry.

For years, cryptocurrency in Zimbabwe operated in a legal grey area.

It was not expressly prohibited.

It was not expressly regulated.

It simply existed.

Crypto traders bought and sold Bitcoin through peer-to-peer platforms. Entrepreneurs built blockchain-based businesses. Zimbabweans used digital assets to hedge against inflation, preserve value, and move money across borders.

Meanwhile, regulators watched from the sidelines.

That era has now come to an end.

On 10 June 2026, the Government of Zimbabwe published Statutory Instrument 99 of 2026, officially titled:

The Money Laundering and Proceeds of Crime (Virtual Asset Service Providers Registration) Regulations, 2026.

For the first time in Zimbabwe’s history, businesses involved in virtual asset activities are subject to a formal regulatory framework.

The implications are enormous.

Whether you operate a crypto exchange, wallet service, blockchain payment platform, token issuance platform, DeFi protocol, crypto remittance service, OTC desk, or any other digital asset business, the regulatory landscape has fundamentally changed.

This is no longer a discussion about whether crypto should be regulated.

That debate is over.

The real question now is:

How do businesses comply with Zimbabwe’s new crypto regulations?

In this article, we break down the new framework in plain English and explain what founders, investors, exchanges, blockchain developers, and financial institutions need to know.

Why This Regulation Matters

Many people see S.I. 99 of 2026 as merely a registration requirement.

That interpretation misses the bigger picture.

The regulation represents Zimbabwe’s official recognition that virtual assets are now a permanent part of the financial ecosystem.

This is a major policy shift.

In 2018, Zimbabwe adopted a restrictive approach towards cryptocurrency activities.

Financial institutions were directed to avoid facilitating cryptocurrency transactions, creating significant uncertainty for crypto businesses.

As a result, much of Zimbabwe’s crypto activity moved underground.

Businesses struggled to obtain banking relationships.

Investors faced uncertainty.

Consumers lacked regulatory protections.

The new framework changes that.

Rather than attempting to suppress digital assets, Zimbabwe has chosen a different path:

Regulate them.

This approach is increasingly becoming the global standard.

Countries across Africa, Europe, Asia, and the Middle East are recognising that digital assets are here to stay.

The focus is no longer on prohibition.

The focus is on responsible regulation.

Zimbabwe has now joined that movement.

The Legal Foundation Behind Zimbabwe’s Crypto Regulation

S.I. 99 of 2026 was issued under the authority of the:

Money Laundering and Proceeds of Crime Act [Chapter 9:24].

The framework is administered by the:

Financial Intelligence Unit (FIU)

which operates under the Reserve Bank of Zimbabwe.

This distinction is important.

The regulations are primarily focused on:

• Anti-Money Laundering (AML)
• Counter-Terrorist Financing (CFT)
• Counter-Proliferation Financing (CPF)
• Customer Due Diligence
• Beneficial Ownership Transparency
• Risk Management

This means the FIU’s role is not simply to maintain a register.

It is to ensure that virtual asset businesses do not become vehicles for money laundering, terrorist financing, sanctions evasion, fraud, or other illicit financial activity.

The FIU therefore becomes the primary AML/CFT regulator for Virtual Asset Service Providers operating in Zimbabwe.

Who Must Register?

This is where the regulation becomes particularly interesting.

Many first-generation crypto regulations focus only on exchanges.

Zimbabwe takes a much broader approach.

The regulations apply to any person or business providing services relating to virtual assets.

This includes traditional crypto businesses such as:

Crypto Exchanges

Businesses facilitating:

• Fiat-to-Crypto transactions
• Crypto-to-Fiat transactions
• Crypto-to-Crypto transactions

Examples include platforms enabling users to buy Bitcoin, Ethereum, USDT, and other virtual assets.

Custody Providers

Businesses that:

• Hold customer private keys
• Store customer digital assets
• Safeguard customer wallets

These entities are effectively the crypto equivalent of traditional financial custodians.

Transfer and Payment Providers

Platforms facilitating:

• Crypto remittances
• Blockchain payments
• Virtual asset transfers

These businesses move value from one person to another using blockchain technology.

Token Issuance Services

Businesses involved in:

• Token sales
• Token offerings
• Token distribution
• Virtual asset fundraising

may also fall within the scope of regulation.

The Most Important Development: DeFi Is Not Automatically Exempt

This is arguably the most significant aspect of the entire framework.

Historically, many blockchain entrepreneurs have assumed that decentralised finance (DeFi) automatically sits outside regulatory oversight.

Zimbabwe’s regulations challenge that assumption.

The law specifically extends regulatory obligations to persons who:

• Control software protocols;
• Operate smart contracts;
• Operate decentralised applications;
• Control governance mechanisms;
• Modify protocol logic;
• Determine economic parameters;
• Market themselves as service providers.

This is an extraordinarily important development.

The regulation does not attempt to regulate technology itself.

Instead, it regulates people who exercise meaningful control over that technology.

In other words:

If a protocol is genuinely decentralised and no identifiable person controls it, regulatory obligations may be difficult to impose.

However, where founders, developers, governance councils, treasury managers, or protocol operators retain significant control, the FIU may consider them to be operating a regulated virtual asset service.

This mirrors emerging international regulatory thinking.

It is also broadly consistent with guidance issued by the Financial Action Task Force (FATF), which has repeatedly stated that decentralisation alone does not automatically remove regulatory obligations.

For blockchain founders, this provision deserves careful legal analysis.

The Rise of the “Control Test”

One of the smartest features of Zimbabwe’s framework is its adoption of what lawyers often call a control test.

The question is no longer:

Is this DeFi?

Instead, the question becomes:

Who controls it?

The regulations identify several indicators of control.

Examples include:

Ability to Upgrade the Protocol

Can someone change the code?

Can someone alter how the protocol functions?

If the answer is yes, regulators may conclude that meaningful control exists.

Ability to Withdraw Assets

Can a founder, developer, multisig signatory, treasury manager, or governance committee move assets?

If so, regulatory obligations may arise.

Ability to Change Fees

Who decides:

• Transaction fees?
• Treasury allocations?
• Staking rewards?
• Economic incentives?

The answer may determine who regulators consider responsible.

Governance Influence

Can a specific group:

• Vote on upgrades?
• Direct protocol decisions?
• Influence operational outcomes?

If so, the FIU may view those persons as exercising sufficient control.

Commercial Representation

One particularly interesting provision concerns marketing.

If a person publicly markets or represents themselves as the operator of a protocol, regulators may view that person as the service provider.

This provision reflects a growing international regulatory trend.

Many businesses want the commercial benefits of appearing to operate a successful protocol while simultaneously claiming that nobody controls it.

Zimbabwe’s framework makes that position more difficult to sustain.

Why This Matters for Crypto Startups

Many founders focus on product development.

Few focus on regulatory strategy.

That can become a costly mistake.

A founder might genuinely believe they are building a decentralised platform while simultaneously:

• Maintaining upgrade keys;
• Controlling treasury wallets;
• Managing protocol parameters;
• Leading governance decisions;
• Marketing the platform.

From a regulator’s perspective, that looks very different from a fully decentralised system.

The result?

Potential registration obligations.

This is why every crypto startup operating in Zimbabwe should conduct a regulatory assessment before launching.

Waiting until regulators ask questions is rarely a good strategy.

Registration Is Mandatory, Not Optional

The regulations make it clear that registration is a legal requirement.

Operating a virtual asset business without registration creates regulatory risk.

The FIU is empowered to establish systems for identifying persons who:

• Provide virtual asset services without registration; or
• Purport to provide virtual asset services without registration.

Importantly, the FIU may share information regarding unregistered operators with:

• Competent authorities;
• Financial institutions;
• Other stakeholders.

This means operating outside the regulatory perimeter is likely to become increasingly difficult over time.

For legitimate businesses seeking long-term growth, registration should be viewed not as a burden but as an investment in credibility.

A regulated business is more likely to attract:

• Banking partners;
• Institutional investors;
• Corporate customers;
• Strategic partners.

That reality is becoming increasingly apparent across the global digital asset industry.

Zimbabwe’s Regulatory Philosophy

When reading S.I. 99 of 2026, one thing becomes clear.

The objective is not to kill innovation.

The objective is to create trust.

The regulation expressly identifies several guiding principles including:

• Market Integrity;
• Consumer Protection;
• Financial Stability;
• Innovation Enablement;
• Transparency;
• Accountability;
• Risk Management;
• Global Interoperability.

This is significant.

Rather than treating crypto as a threat, Zimbabwe is attempting to build a framework that allows innovation to coexist with regulatory oversight.

That balance is difficult.

Many jurisdictions struggle to achieve it.

Whether Zimbabwe ultimately succeeds will depend largely on implementation and supervisory practices.

However, the policy direction is clear:

Zimbabwe wants innovation.

But it wants responsible innovation.

And for crypto businesses seeking legitimacy, that may ultimately be good news.

In Part 2, we will examine the registration process itself, application requirements, fit-and-proper assessments, governance obligations, resident director requirements, AML/CFT compliance expectations, and the Travel Rule obligations that every VASP must understand before operating in Zimbabwe.

Part 2

The Registration Process, Travel Rule, Compliance Obligations, and What Every VASP Must Do Next

In Part 1 of this series, we explored Zimbabwe’s new cryptocurrency regulatory framework and examined how Statutory Instrument 99 of 2026 fundamentally changes the legal landscape for Virtual Asset Service Providers (VASPs).

We discussed:

• The purpose of the regulation;
• Who qualifies as a VASP;
• How DeFi protocols may fall within scope;
• The significance of the control test;
• Why is registration now mandatory?

But understanding who is regulated is only the beginning.

The next question is far more practical:

What must a crypto business actually do to become compliant?

For founders, exchanges, wallet providers, blockchain payment companies, token issuers, and crypto startups, this is where the real work begins.

Zimbabwe’s framework is not merely a registration exercise.

It requires businesses to establish governance structures, implement AML/CFT controls, assess risks, verify customers, maintain records, monitor transactions, and comply with Travel Rule obligations.

In many respects, the operational requirements resemble those imposed on regulated financial institutions.

Let’s examine what this means in practice.

Step 1: Registration Starts With Local Presence

One of the first things that stands out in S.I. 99 of 2026 is Zimbabwe’s emphasis on local accountability.

The regulations require every applicant to be incorporated or registered in Zimbabwe.

Foreign businesses cannot simply operate remotely while servicing Zimbabwean customers.

Instead, multinational groups must establish a Zimbabwean subsidiary through which regulated activities are conducted.

This requirement reflects a growing global trend.

Regulators increasingly want virtual asset businesses to have:

• A local legal entity;
• A local physical presence;
• Individuals who can be held accountable;
• Records that are accessible within the jurisdiction.

From a regulatory perspective, this makes sense.

A regulator cannot effectively supervise an entity that exists only on a website.

For international crypto businesses looking to enter Zimbabwe, local incorporation is therefore likely to be one of the first regulatory hurdles.

Step 2: The Registration Application Is More Extensive Than Many Founders Expect

Many entrepreneurs assume registration means filling out a short form and paying a fee.

That assumption would be incorrect.

The FIU requires extensive supporting documentation.

Applicants must provide:

Corporate Documents

Including:

• Certificate of incorporation;
• Establishing documents;
• Corporate information.

Ownership Information

Applicants must disclose:

• Beneficial owners;
• Directors;
• Principal officers;
• Ownership structures.

An ownership chart must also be submitted.

This reflects the global regulatory focus on beneficial ownership transparency.

Regulators increasingly want to know who ultimately controls a business.

Complex structures designed to obscure ownership are unlikely to be viewed favourably.

Identification Documents

The FIU requires:

• Certified identification documents;
• Proof of residence;
• Police clearance certificates.

These requirements apply to beneficial owners, directors, and principal officers.

This demonstrates that Zimbabwe is treating VASPs much like traditional financial institutions.

Tax Compliance

Applicants must submit:

• Valid tax clearance certificates.

This requirement reinforces the government’s broader objective of bringing digital asset businesses into the formal economy.

Business Model Information

Applicants must explain:

• Nature of services;
• Scope of activities;
• Underlying technology;
• Delivery methods;
• Virtual assets involved.

This information allows regulators to understand how the business operates and what risks may arise.

The Risk Assessment Requirement

One of the most important documents required during registration is the entity-specific risk assessment.

Many startups underestimate the significance of this requirement.

The FIU expects applicants to identify and assess risks relating to:

• Money laundering;
• Terrorist financing;
• Proliferation financing.

More importantly, businesses must explain how those risks will be:

• Identified;
• Assessed;
• Understood;
• Monitored;
• Mitigated;
• Reported.

This is no longer a simple compliance exercise.

It is a risk-management exercise.

Businesses that cannot demonstrate a mature understanding of their risk exposure may struggle to convince regulators that they are ready to operate.

Cybersecurity Is No Longer Optional

The regulations also require applicants to submit information relating to:

• Data protection;
• Information security;
• Confidentiality;
• Cybersecurity safeguards.

This is particularly important.

Crypto businesses are frequent targets of:

• Hacks;
• Phishing attacks;
• Wallet compromises;
• Smart contract exploits;
• Insider threats.

A weak cybersecurity posture creates risks not only for customers but also for the broader financial system.

Zimbabwe’s framework therefore places cybersecurity alongside AML/CFT as a core regulatory expectation.

This is increasingly consistent with international standards.

The Fit and Proper Test

One of the most significant parts of the registration process is the fit and proper assessment.

This assessment applies to:

• Beneficial owners;
• Directors;
• Principal officers;
• Key controllers.

The objective is simple.

The regulator wants to ensure that persons controlling virtual asset businesses are trustworthy.

When conducting this assessment, the FIU may consider:

1. Financial Standing: Does the individual demonstrate financial responsibility?
2. Qualifications and Experience: Do they possess relevant knowledge and expertise?
3. Integrity and Character: Can they be trusted to manage regulated activities responsibly?
4. Criminal History: Have they been involved in criminal conduct?
5. Regulatory History: Have they previously been sanctioned by regulators? Have they had licences refused or revoked elsewhere?

These questions are increasingly common across global crypto licensing frameworks.

The message is clear:

The quality of management matters.

Why Governance Matters More Than Ever

Historically, many crypto startups were built around small founding teams.

Governance often developed later.

Regulators no longer accept that approach.

Zimbabwe’s framework imposes specific governance obligations.

These include:

Compliance Officer

Every VASP must appoint a resident compliance officer.

This individual must have:

• Authority;
• Independence;
• Responsibility for AML/CFT oversight.

The role cannot be merely symbolic.

The compliance officer is expected to actively monitor and oversee compliance activities.

Resident Directors

Every VASP must maintain at least:

Two resident directors.

This requirement is significant.

It reinforces local accountability and ensures there are individuals physically present within Zimbabwe who can engage with regulators when necessary.

For international operators, this may require substantial restructuring.

Registered Office

Every VASP must maintain:

• A registered office;
• A place of business in Zimbabwe.

The days of operating exclusively through anonymous online structures are rapidly disappearing.

The Travel Rule: The Most Important Operational Requirement

Without question, the most technically demanding aspect of the regulation is the Travel Rule.

Many businesses underestimate how transformative this requirement can be.

The Travel Rule originates from FATF Recommendation 16 and has become one of the defining compliance obligations for virtual asset businesses worldwide.

Its purpose is straightforward:

To ensure that information about the sender and recipient accompanies virtual asset transfers.

In traditional banking, this information travels with wire transfers.

The Travel Rule extends similar principles to crypto transactions.

What Information Must Be Collected?

For each virtual asset transfer, the Ordering VASP must collect information regarding the originator.

This includes:

• Full legal name;
• Wallet address;
• Physical address;
• National ID or passport number;
• Date and place of birth.

The VASP must also collect beneficiary information, including:

• Full legal name;
• Wallet address;
• Country and city of residence.

This information must be verified before the transfer is executed.

This is not optional.

It is a regulatory requirement.

Why IVMS-101 Matters

One of the most interesting aspects of Zimbabwe’s framework is its explicit reference to:

IVMS-101

The InterVASP Messaging Standard.

Many jurisdictions discuss Travel Rule compliance but never specify technical interoperability standards.

Zimbabwe does.

This demonstrates that the drafters understood that compliance requires more than legal obligations.

It requires technical infrastructure.

Businesses that have not implemented Travel Rule technology may need significant investment before they can operate compliantly.

The Crackdown on Anonymous Transfers

Perhaps the most controversial aspect of the regulations relates to self-hosted wallets.

For transfers exceeding USD 1,000 involving unhosted wallets, VASPs must conduct:

Wallet Ownership Proof

Examples include:

• Cryptographic signatures;
• Satoshi Tests.

The objective is simple.

Regulators want assurance that customers actually control the wallets to which funds are being transferred.

This provision is intended to reduce:

• Sanctions evasion;
• Money laundering;
• Anonymous movement of funds.

Expect this area to generate significant discussion within the industry.

Customer Due Diligence Is Now Mandatory

The regulations require Customer Due Diligence (CDD) for transactions equal to or exceeding USD 1,000.

This means VASPs must:

1. Identify Customers: Know who they are dealing with.
2. Verify Customers: Use reliable and independent documentation.
3. Identify Beneficial Owners: Understand who ultimately controls an account.
4. Understand Purpose: Determine the intended nature of the business relationship.
5. Monitor Transactions: Ensure activity aligns with customer risk profiles.
6. Apply Enhanced Due Diligence: For higher-risk customers and jurisdictions.

These obligations mirror international AML/CFT standards and place Zimbabwe firmly within the global compliance landscape.

Record Keeping and Suspicious Transaction Reporting

The regulations require VASPs to retain records for a minimum of:

Five years

after the end of a business relationship.

This includes:

• Customer information;
• Verification documents;
• Transaction records.

In addition, suspicious activity must be reported promptly.

Staff must be trained to identify red flags associated with:

• Money laundering;
• Terrorist financing;
• Proliferation financing;
• Other illicit activity.

Compliance is therefore not limited to technology.

It also requires people, processes, and ongoing training.

What Happens If You Ignore the Rules?

The FIU has extensive enforcement powers.

Registration may be:

• Suspended;
• Revoked;
• Refused.

Grounds include:

• False information;
• AML violations;
• Failure to satisfy regulatory requirements;
• Loss of fit and proper status;
• Conduct contrary to the public interest.

In serious circumstances, registration may be revoked without prior notice.

This gives the FIU significant supervisory authority.

Businesses should not assume enforcement will be passive.

What Should Crypto Businesses Do Right Now?

If you operate a crypto business in Zimbabwe, the time to prepare is now.

Immediate priorities should include:

1. Conduct a Regulatory Gap Assessment: Identify areas of non-compliance.
2. Map Business Activities: Determine whether your activities qualify as regulated services.
3. Assess DeFi Exposure: Evaluate whether protocol control creates regulatory obligations.
4. Prepare Governance Structures: Appoint directors and compliance personnel.
5. Develop AML/CFT Frameworks: Implement policies and procedures.
6. Implement Travel Rule Solutions: Assess technology providers and integration requirements.
7. Prepare Registration Documentation: Begin assembling required information and supporting materials.

Businesses that act early will be significantly better positioned than those waiting until enforcement begins.

Final Thoughts

Zimbabwe’s S.I. 99 of 2026 represents far more than a registration requirement.

It signals the beginning of a regulated digital asset ecosystem.

For some businesses, the regulations will create additional compliance costs.

For others, they will create opportunities.

Regulation often brings legitimacy.

Legitimacy attracts banking relationships.

Banking relationships attract investment.

Investment drives growth.

The businesses that thrive in Zimbabwe’s next phase of crypto development are likely to be those that embrace compliance rather than resist it.

The era of operating in a regulatory grey zone is ending.

A new era of accountability, transparency, and structured growth has begun.

In Part 3, we will analyse the broader implications of Zimbabwe’s crypto framework for exchanges, DeFi protocols, token issuers, investors, banks, foreign operators, and the future of virtual asset regulation across Africa.

Part 3

What the New Law Means for Exchanges, DeFi Protocols, Investors, Banks, Foreign Companies, and the Future of Crypto Regulation in Africa

When Zimbabwe introduced Statutory Instrument 99 of 2026, many people viewed it as a simple registration framework for crypto businesses.

That interpretation misses the bigger picture.

The regulations are not merely about registration.

They represent Zimbabwe’s first serious attempt to integrate virtual assets into the country’s formal financial system.

In doing so, the Government has sent a clear message:

Crypto is no longer operating outside the regulatory perimeter.

It is becoming part of the regulated financial ecosystem.

For entrepreneurs, investors, exchanges, financial institutions, and blockchain innovators, the implications extend far beyond compliance.

The regulations will influence:

• How crypto businesses are structured;
• How investors assess opportunities;
• How banks interact with digital asset companies;
• How foreign firms enter Zimbabwe;
• How DeFi projects are designed;
• How regulators across Africa may approach future crypto regulation.

In this final part of our series, we explore the broader impact of Zimbabwe’s new crypto framework and what it means for the future of the industry.

Why Regulatory Clarity Matters

One of the biggest obstacles facing crypto businesses globally is uncertainty.

Entrepreneurs can usually adapt to strict rules.

What they struggle with is not knowing which rules apply.

Investors face the same challenge.

Institutional capital rarely enters markets where the legal framework is unclear.

Banks are also reluctant to onboard businesses where regulatory expectations remain undefined.

This is why regulatory clarity matters.

Before S.I. 99 of 2026, Zimbabwe’s virtual asset sector existed in a space that was neither fully prohibited nor fully recognised.

Now there is a framework.

Businesses know:

• Who regulates them;
• What registration is required;
• What compliance obligations exist;
• What conduct may trigger enforcement action.

That certainty creates confidence.

And confidence attracts capital.

What the Regulations Mean for Crypto Exchanges

Crypto exchanges are likely to be the most directly affected participants in the ecosystem.

Many of the regulations appear specifically designed with exchanges in mind.

Why?

Because exchanges represent the primary gateway between:

• Fiat currencies;
• Virtual assets;
• Retail consumers;
• Financial institutions.

Exchanges therefore sit at the centre of AML/CFT risks.

The new framework requires exchanges to:

Conduct Customer Due Diligence

Customers can no longer simply create anonymous accounts and transact freely.

Exchanges must know who they are dealing with.

Monitor Transactions

Activity must be assessed against customer risk profiles.

Unusual transactions must be investigated.

Implement Travel Rule Controls

Information must accompany virtual asset transfers.

This creates both compliance and technology obligations.

Maintain Records

Customer and transaction records must be retained and made available when required.

Report Suspicious Activity

Suspicious Transaction Reports (STRs) become a core compliance responsibility.

For exchanges already operating to international standards, these requirements may not be particularly burdensome.

For informal operators, however, the adjustment could be substantial.

The End of Anonymous Crypto Businesses

One of the clearest messages emerging from the regulations is that anonymity is no longer compatible with operating a regulated virtual asset business.

Consider what must now be disclosed:

• Beneficial owners;
• Directors;
• Principal officers;
• Ownership structures;
• Compliance officers;
• Physical business premises.

This level of transparency is intentional.

Historically, regulators have struggled with crypto businesses operating through opaque structures.

Zimbabwe’s framework attempts to eliminate that problem from the outset.

Businesses seeking to conceal ownership are likely to face significant regulatory challenges.

What This Means for DeFi Founders

Perhaps no group should pay closer attention to these regulations than DeFi founders.

For years, decentralised finance has raised one central regulatory question:

Who is responsible?

Zimbabwe’s answer is relatively straightforward.

Where identifiable persons exercise meaningful control over a protocol, regulatory obligations may arise.

This creates important considerations for:

• DAO founders;
• Governance councils;
• Treasury managers;
• Multisig signatories;
• Protocol developers;
• Token issuers.

Founders must now carefully evaluate:

Governance Structures

• Who controls upgrades?
• Who controls treasury funds?
• Who controls economic parameters?

Administrative Keys

• Can someone pause the protocol?
• Can someone change how it operates?
• Can someone access assets?

Commercial Positioning

• How is the project marketed?
• Who is represented as operating the platform?
• These questions increasingly determine regulatory exposure.

The future of DeFi compliance may depend less on technical architecture and more on practical control.

The Impact on Token Issuers

Token issuance is another area likely to face increased scrutiny.

Historically, many token projects focused primarily on technology and fundraising.

Regulatory considerations were often secondary.

That approach is becoming increasingly difficult to sustain.

Token issuers should consider:

• Whether their activities fall within VASP definitions;
• Whether customer onboarding processes are sufficient;
• Whether AML/CFT controls are adequate;
• Whether beneficial ownership information is maintained;
• Whether governance structures are transparent.

Projects seeking long-term credibility should view regulation as part of the business model rather than an afterthought.

What Banks Should Be Doing Right Now

Banks are among the most important stakeholders affected by these regulations.

Many financial institutions have historically approached crypto businesses cautiously.

The reasons are understandable.

Banks face:

• AML risks;
• Reputational risks;
• Regulatory risks;
• Correspondent banking risks.

A clear registration framework changes the conversation.

Rather than asking:

Is this crypto company legitimate?

Banks can ask:

Is this crypto company registered and compliant?

That distinction is important.

The regulations create a mechanism for identifying regulated participants.

This may make it easier for banks to develop:

• Crypto onboarding policies;
• Risk assessment frameworks;
• Customer acceptance criteria.

In the long term, regulated crypto businesses are generally more attractive banking clients than unregulated ones.

Why Investors Should Welcome Regulation

Some people assume regulation is bad for crypto.

In reality, serious investors often think the opposite.

Professional investors prefer environments where:

• Rules are clear;
• Compliance standards exist;
• Regulatory expectations are understood;
• Enforcement mechanisms are available.

Why?

Because uncertainty creates risk.

And risk increases the cost of capital.

The introduction of Zimbabwe’s framework may therefore encourage greater interest from:

• Venture capital firms;
• Private equity investors;
• Strategic investors;
• Institutional participants.

Regulation does not eliminate risk.

But it does reduce uncertainty.

That distinction matters.

What Foreign Crypto Companies Need to Know

Many international businesses may view Zimbabwe as an emerging opportunity.

The country has:

• High digital asset awareness;
• Strong remittance demand;
• Growing fintech adoption;
• Increasing regulatory clarity.

However, foreign companies should not assume they can service Zimbabwean customers remotely without consequences.

The regulations clearly favour local accountability.

Foreign operators will likely need:

• Local incorporation;
• Local governance structures;
• Local compliance arrangements;
• Local representation.

Businesses planning regional expansion should incorporate these requirements into their market entry strategies.

Zimbabwe’s Position Within Africa’s Regulatory Landscape

One of the most interesting aspects of S.I. 99 of 2026 is where it positions Zimbabwe within the broader African regulatory landscape.

Historically, African crypto regulation has been fragmented.

Some countries prohibited crypto activity.

Others ignored it.

Others issued warnings without creating clear frameworks.

That situation is gradually changing.

Across Africa we are seeing increasing regulatory activity.

Countries are beginning to recognise that virtual assets are becoming a permanent feature of financial markets.

Zimbabwe’s framework contributes to that trend.

Importantly, it does so using internationally recognised concepts.

Examples include:

• FATF standards;
• Beneficial ownership transparency;
• Risk-based supervision;
• Travel Rule compliance;
• Customer Due Diligence.

This makes the framework more compatible with international expectations.

How Zimbabwe Compares to More Mature Jurisdictions

Although Zimbabwe’s framework is sophisticated, it remains fundamentally a registration regime.

It is not yet comparable to fully developed licensing frameworks such as:

• Dubai VARA;
• ADGM FSRA;
• DIFC DFSA;
• Singapore PSA;
• European Union MiCA.

Those frameworks include additional requirements relating to:

• Capital adequacy;
• Prudential supervision;
• Client asset protection;
• Market conduct;
• Operational resilience;
• Governance frameworks;
• Custody safeguards.

Zimbabwe has not yet reached that stage.

However, the current framework provides a strong foundation upon which future regulation can be built.

In many respects, it represents the first phase of a much larger regulatory journey.

What Could Come Next?

If Zimbabwe continues developing its virtual asset regulatory framework, future reforms could include:

1. Capital Requirements: Minimum financial resources for VASPs.
2. Custody Rules: Specific safeguards for customer assets.
3. Stablecoin Frameworks: Requirements for issuance and reserve management.
4. Market Conduct Rules: Measures addressing manipulation and abusive practices.
5. Prudential Supervision: Ongoing regulatory oversight of licensed entities.
6. Token Issuance Regulation: Requirements for public token offerings.
7. Virtual Asset Legislation: A comprehensive digital asset law replacing or supplementing the current framework.

Many jurisdictions have followed a similar path.

Registration is often the first step.

Comprehensive regulation follows later.

The Bigger Picture: Why This Matters for Africa

Zimbabwe’s framework is important not only for Zimbabwe.

It is important for Africa.

Across the continent, policymakers face a common challenge.

How do you support innovation while protecting consumers and preserving financial integrity?

There is no perfect answer.

But there is growing recognition that prohibition is rarely effective.

Digital assets do not disappear simply because regulators ignore them.

Markets continue to develop.

Technology continues to evolve.

Consumer demand continues to grow.

The more sustainable approach is often responsible regulation.

That is what Zimbabwe appears to be attempting.

Whether the framework ultimately succeeds will depend on implementation, supervision, enforcement, and industry cooperation.

But the direction is clear.

Crypto is moving from the shadows into the mainstream.

Final Thoughts

Zimbabwe’s Statutory Instrument 99 of 2026 marks a significant milestone in the country’s digital asset journey.

For the first time, virtual asset businesses have a clear regulatory pathway.

The framework introduces:

• Registration requirements;
• Governance obligations;
• AML/CFT controls;
• Travel Rule compliance;
• Customer Due Diligence standards;
• Transparency requirements;
• Enforcement mechanisms.

For some businesses, these obligations may appear demanding.

For others, they represent an opportunity.

History shows that sustainable financial innovation rarely thrives in regulatory uncertainty.

It thrives in environments where trust exists.

Trust attracts users.

Trust attracts investors.

Trust attracts banking partners.

And trust ultimately supports long-term growth.

Zimbabwe has now taken an important step toward creating that trust.

The businesses that recognise this early—and build compliance into their strategy from day one—are likely to be the businesses best positioned to succeed in the next chapter of Zimbabwe’s digital asset economy.

About CRYPTOVERSE Legal Consultancy

CRYPTOVERSE Legal Consultancy advises virtual asset businesses, fintech companies, blockchain projects, exchanges, token issuers, payment providers, and investors on digital asset regulation, AML/CFT compliance, licensing, governance, and cross-border regulatory strategy.

For assistance with Zimbabwe VASP registration, crypto regulatory compliance, AML/CFT framework development, Travel Rule implementation, governance structuring, or virtual asset licensing across Africa, the Middle East, and other jurisdictions, professional legal advice should be sought based on your specific business model and regulatory exposure.

Disclaimer: This article is provided for informational purposes only and does not constitute legal advice. Regulatory requirements may change, and businesses should obtain jurisdiction-specific legal advice before undertaking regulated activities.

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