The letter is boring, almost mundane in form. Dated April 28, 2026, signed by the head of the Exchange Office’s Inspection Division, it amounts to just a few lines.
Its recipient is informed that an infraction has been recorded against him: the constitution of foreign assets in the form of crypto-assets, which gave rise to sales benefiting Moroccan residents, for a countervalue of 408,620.51 dirhams. Thirty days to provide explanations. Beyond that deadline, contentious proceedings. The tone is that of an administration that knows exactly what it is looking for, and that has found it.
This document, which TelQuel was able to consult, immediately fueled speculation in Moroccan crypto circles. Not so much for the sanctions it announces, as for what it reveals: the Exchange Office evidently has access to information that many thought was beyond the reach of Moroccan authorities. Balances. Transactions. Precise amounts on international platforms domiciled abroad.
The mystery of detection
How did the Office come to know this data? The question nags even sector experts. « We wonder if there might be an information exchange between international platforms and Moroccan authorities, » confides Badr Bellaj, a blockchain expert. « It’s difficult for the Exchange Office to know the balance of an account on a platform if it’s not that platform that shared the information. »
These platforms are subject to anti-money-laundering rules, which require them to transmit data under very specific conditions, but which ones, and at whose request?
Contacted by TelQuel, the Exchange Office partially lifts the veil. The identification of assets held abroad, including in the form of crypto-assets, rests, according to it, on « the cross-referencing and analysis of data from multiple sources, notably information transmitted by financial institutions as well as exchanges of information with foreign partners within the framework of international financial transparency mechanisms. »
The institution further specifies that the notifications sent to certain users « result from work cross-referencing information and analyzing risks, » falling within a supervisory framework that is « intelligent, selective, and risk-oriented. »
The Office further indicates that it set up, in April 2026, a service dedicated to combating money laundering and terrorism financing, thereby strengthening its surveillance capacities.
An infraction, but which one?
The letter itself sheds light on the logic of the proceedings. The Exchange Office is not targeting the holding of crypto-assets as such. It is targeting investment abroad, a notion well-rooted in current exchange regulations, regardless of the nature of the asset.
« For the Office, crypto is just a detail. What is in violation is international investment, regardless of the nature of the asset, » specifies Badr Bellaj. Buying Bitcoin on a foreign platform using dollars is, in the Office’s eyes, an unauthorized exchange operation, on the same footing as an investment in the stock market in New York or in real estate in Dubai.
This reading is not without internal coherence. But it raises a contradiction that the expert points to: how can one prosecute, in the name of exchange regulations, an asset whose legal framework the same State is currently preparing? Preliminary draft bill 42-25, developed by the Ministry of the Economy and Finance in coordination with Bank Al-Maghrib and the AMMC, aims precisely to pull crypto-assets out of this gray zone. But on closer inspection, the exit is more limited than it appears.
A law that brings no freedom
Draft bill 42-25, inspired by the European MiCA regulation (Markets in Crypto-Assets), does not legalize the holding of cryptocurrencies in the broad sense. It creates a framework for licensed local platforms under the joint supervision of the Moroccan Capital Market Authority (AMMC) and Bank Al-Maghrib. Crypto-assets are defined therein as financial assets, not as a legal means of payment. And above all: operations will remain subject to the Moroccan exchange regime, which means that investing via an international platform, in dollars, will remain prohibited even after the law is adopted.
For the roughly six million Moroccans who currently hold crypto-assets, or nearly 16% of the population according to estimates, the prospect is therefore not one of regularization. It is one of a legal framework that does not concern them, because they operate precisely where the law will not look: on foreign platforms, outside the banking circuit, outside of oversight. Until a letter arrives.
And behind this letter, sanctions that are not merely symbolic. The Exchange Office confirms it itself: by virtue of the Dahir of August 30, 1949, offenders face financial penalties that can reach six times the body of the offense. In the most serious cases, notably where organized schemes or links to money-laundering circuits are involved, criminal proceedings can also be initiated.
As for a possible regularization, the door is closed for now. The voluntary disclosure mechanisms put in place in 2014, 2020, and 2024 are closed, and no equivalent mechanism is currently open. The Office indicates that it remains « open to examining individual situations, » without further details. On the question of an amnesty within the framework of the future legal arrangement, the response is equally cautious: the framework in preparation « does not, at this stage, provide for a general amnesty mechanism. » The « at this stage » leaves a door ajar — but for how long?
Written in French by Safae Hadri, edited in English by Eric Nielson
