Bosnia and Herzegovina’s three jurisdictions treat crypto differently, and no text reviewed mentions crypto ATMs

Bosnia and Herzegovina has no state-level crypto licensing regime. Republika Srpska keeps a register of providers, which listed three firms on 16 June 2026. The Federation has only draft laws. The AML law applies everywhere, and none of the texts reviewed mentions crypto ATMs.

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Bosnia and Herzegovina has no state-level crypto licensing regime. Republika Srpska keeps a register of providers, which listed three firms on 16 June 2026.^5,6 The Federation has only draft laws.⁸ The AML law applies everywhere, and none of the texts reviewed mentions crypto ATMs.^1,2,3

Last updated: October 2026

Regulatory Framework

The country has three jurisdictions with separate legislation: the Federation of Bosnia and Herzegovina (FBiH), Republika Srpska (RS) and the Brčko District. The state-level AML law is the only rule that applies in all three.

The Law on the Prevention of Money Laundering and Financing of Terrorist Activities was published in the Official Gazette of BiH No. 13/24 on 19 February 2024. Article 4 defines virtual currency and a provider of virtual currency services, whose services include custody, operating trading platforms, exchange for legal tender or another virtual currency, and transfers. Article 5 lists such providers as obliged entities. Article 19(5)(c) requires virtual currency providers to identify and monitor clients for occasional transactions above KM 1,000, instead of the general thresholds in Article 12.¹ The part of the law that names the supervisor of these providers and any registration duty was not part of the text reviewed. The text reviewed does not mention ATMs.¹

Republika Srpska

An amendment to the Securities Market Law of Republika Srpska, signed on 23 June 2022, defines virtual currency and six services: wallet custody, operating a trading platform, exchange for legal tender, exchange for another virtual currency, transfer, and offering or sale. The Securities Commission supervises AML compliance of providers and keeps a register. Providers must notify the Commission within 30 days of being founded, and an unregistered entity may not provide the services (Articles 3 and 4). The law sets penalties of removal from the register for one year, or permanently for a repeat offence (Article 8).² The Commission's rulebook on the register was reported in January 2023.¹¹

The Commission told the news site Detektor in May 2026 that no crypto licence exists, and that it supervises providers' AML compliance. It said that since the register was set up, one application had been rejected as improperly filed, three had been withdrawn and four were pending.⁵

The article that reports the removal of Tesla Trade does not give the date of the decision or an official reason.⁶ The Commission's register itself could not be opened.

Federation of BiH

The Federation has no law on crypto providers in force. In a statement reported in June 2024, the Federal Ministry of Finance said it does not regulate crypto exchange offices and does not recognise cryptocurrencies as a means of payment. The Federal Tax Administration said that trading is not covered by a separate tax law.⁹

On 13 August 2026 a news site reported that the Federal Ministry of Finance had pre-drafts of a Law on Providers of Services Related to Virtual Assets and Cryptocurrencies and a Law on the Capital Market, in public consultation. The stated aim was to send them to the formal legislative procedure in September. The article does not name a supervisor and does not mention ATMs. The texts of the drafts were not reviewed.⁸

Brčko District

The Brčko District Assembly adopted a new Law on the Securities Market on 4 March 2026. Article 2 defines virtual currency and a provider of services related to virtual currencies, covering the conversion of virtual currencies into legal tender and custody for clients. The excerpt reviewed refers to Article 172, which was not available.³ No implementing rules were found.

FATF Listing

On 19 June 2026 the FATF named Bosnia and Herzegovina, together with Iraq, among the jurisdictions under increased monitoring. The statement says the country made a high-level political commitment in June 2026 to work with the FATF and MONEYVAL, and has a nine-point action plan.⁴

Crypto ATMs

None of the legal texts reviewed mentions crypto ATMs or machines.^1,2,3 A directory lists five machines, in Brčko, Mostar, Tuzla and two in Sarajevo, with no date and no named operator.¹⁰ One of the Sarajevo addresses, Kranjčevićeva 33, was reported in 2024 as sealed after the machine had operated in early 2023. The report attributes the sealing to the Federal Ministry of Finance or the Tax Administration.⁹ The directory is therefore not reliable as a current count. The RS list of services includes exchange for legal tender, and the sources do not say whether the Commission treats a machine operator as a provider.

What Is Not Known

The Official Gazette text of the RS amendment, the Commission register and the current number of licensed firms were not checked at the source. The supervisor and registration duty under the state AML law, fines under the AML law, the text of the Federal drafts, the content of Article 172 of the Brčko law and the number of working machines were not confirmed. Fees, processing times and bank access for operators were not found. These are questions for counsel in the relevant entity.

Sources and references

1. Law on the Prevention of Money Laundering and Financing of Terrorist Activities, Official Gazette of BiH No. 13/24, 19 February 2024, text published by a law portal (PRIMARY text, accessed 9 October 2026) | advokat-prnjavorac.com
2. Law amending the Securities Market Law of Republika Srpska, signed 23 June 2022, text published by BiH Pravo (PRIMARY text, accessed 9 October 2026) | bih-pravo.org
3. Law on the Securities Market of the Brčko District of BiH, adopted 4 March 2026 (PRIMARY, excerpt, accessed 9 October 2026) | skupstinabd.ba
4. FATF, Jurisdictions under Increased Monitoring, 19 June 2026 (PRIMARY, accessed 9 October 2026) | fatf-gafi.org
5. Detektor, Suspicious firms, crypto business and entry in the Republika Srpska register, 28 May 2026 (SECONDARY, accessed 9 October 2026) | detektor.ba
6. Detektor, Tesla Trade removed from the register for crypto trading in Republika Srpska, 16 June 2026 (SECONDARY, accessed 9 October 2026) | detektor.ba
7. Srpskainfo, Šljivar and Kremenović lost the crypto licence, 25 May 2026 (SECONDARY, accessed 9 October 2026) | srpskainfo.com
8. Faktor, Cryptocurrencies under law for the first time in FBiH, 13 August 2026 (SECONDARY, accessed 9 October 2026) | faktor.ba
9. Fokus.ba, Haven for money laundering: why FBiH still has not recognised cryptocurrencies, 19 June 2024 (SECONDARY, accessed 9 October 2026) | fokus.ba
10. Bitomat, map of Bitcoin ATMs in Bosnia, undated (SECONDARY, directory, accessed 9 October 2026) | bitomat.com
11. Biznis.rs, Register of cryptocurrency traders established, 21 January 2023 (SECONDARY, accessed 9 October 2026) | biznis.rs

Legal Disclaimer: This article by GENERAL BYTES is for informational purposes only and does not constitute formal legal, financial, or investment advice. Rules may change; always consult specialised local legal counsel and confirm the current position with the relevant authority in the entity concerned before considering market entry.