Morocco's Exchange Office Targets Crypto Held Abroad Ahead of Regulatory Shift

Morocco’s Exchange Office (Office des Changes) has initiated enforcement proceedings against individuals holding crypto assets abroad, marking a notable escalation in oversight as the country transitions toward a formal regulatory framework for digital assets.

According to written notifications obtained by local outlet Le360, the authority identified Moroccan residents who constituted offshore crypto assets and conducted sales transactions between March and August 2025. Individuals have been given 30 days to provide explanations and supporting documentation, after which formal proceedings may be initiated.

Enforcement Highlights Longstanding Legal Ambiguity

The move underscores a structural contradiction in Morocco’s crypto stance. Since 2017, both the Office des Changes and Bank Al-Maghrib have classified crypto transactions as violations of foreign exchange regulations, as they involve the constitution of assets abroad without prior authorization.

Despite this, crypto usage has continued to expand informally, creating a growing base of users operating in a legal grey zone. The latest enforcement signals a shift toward active supervision—particularly targeting cross-border activity.

Draft Law 42.25 Signals Transition to Licensed Market Structure

The enforcement action comes as Morocco advances its first comprehensive crypto framework under draft law 42.25, published for consultation by the Secrétariat Général du Gouvernement.

The proposal draws from the European Union’s Markets in Crypto-Assets (MiCA), aiming to introduce licensing requirements, financial supervision, and user protection mechanisms.

If implemented, the framework would transition Morocco from a prohibition-based stance to a controlled and licensed crypto market.

UAE Parallel: Federal Digital Asset Framework Becomes More Structured

Morocco’s enforcement action comes as the United Arab Emirates advances a more structured phase of digital asset regulation under Resolution No. 04 of 2026, which establishes a federal framework for Virtual Asset Service Providers (VASPs) and trading infrastructure operators.

The framework introduces a modular regulatory system covering licensing, business conduct, and alternative trading systems. It defines regulated activities such as exchange services, custody, brokerage, advisory services, and trading venue operations, while also setting restrictions on certain asset categories including privacy tokens and algorithmic token-linked services.

It further formalizes listing rules by requiring approved trading venues to register virtual assets with the regulator, and contemplates a federal recognition structure for eligible assets.

Alongside federal-level structuring, activity-specific regulation is also tightening at the jurisdictional level. In Abu Dhabi, the Financial Services Regulatory Authority has recently finalized staking regulations, reinforcing a shift toward granular, activity-level oversight within licensed frameworks.

Converging Regulatory Direction Across Markets

While Morocco is still in the enforcement phase ahead of legalization, and the UAE is refining an already structured regulatory system, both jurisdictions reflect a broader regional shift.

Market participation is increasingly defined by formal authorization, licensing clarity, and regulated perimeter access, rather than informal participation or legacy grey-zone activity.

Central Bank Position: Controlled Market Integration

Abdellatif Jouahri has consistently framed crypto regulation as a balance between oversight and innovation, emphasizing the need to move beyond legal ambiguity while avoiding disruption to financial stability.

In parallel, Bank Al-Maghrib continues to explore a central bank digital currency (CBDC), reflecting a broader institutional approach that distinguishes between sovereign digital money and privately issued crypto assets.

Enforcement as a Pre-Regulatory Signal

While the current enforcement measures affect a limited number of individuals, their significance lies in timing.

They indicate that Morocco is actively asserting regulatory jurisdiction ahead of formal legalization, reinforcing the principle that future market participation will be defined by compliance with a licensed framework.

Together, both Morocco and UAE approaches reflect a broader regional convergence: crypto markets are moving from informal participation toward structured, regulated financial systems where access is permissioned, not open.