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The growing global adoption of crypto assets is no longer something that governments around the world can ignore.
Quick summary
- Bitcoin is considered legal tender in only one country: El Salvador.
- Among the six countries whose regulatory policies we took a closer look at, Singapore has the most progressive regulation.
- And of those six countries, only Australia, Canada and Singapore have a regulated and publicly traded Bitcoin ETF (exchange-traded fund).
- The number of crypto-related bills proposed in the US House of Representatives has increased dramatically since 2014.
- The governments or central banks of 18 countries have placed an explicit ban on cryptocurrencies.
- The governments or central banks of about 40% of the countries in the world consider cryptocurrencies to be a mostly legal investment.
Regulatory policy from the governments and central banks of certain countries, including El Salvador, the United Arab Emirates and Singapore has both favored and embraced Bitcoin and other cryptocurrencies:
- The government of El Salvador has deemed Bitcoin (BTC) legal tender.
- The government of the United Arab Emirates is in the process of setting up the world’s first authority that focuses solely on digital assets.
- And Singapore has crafted such a clear and progressive regulatory policy around crypto that some countries have used Singapore’s crypto laws as a template for their own.
However, a number of countries have implemented either explicit or implicit bans on crypto:
- The governments of China, Egypt and Bolivia have forbidden crypto trading, transactions and services within these countries.
- And a number of governments and central banks in Northern Africa, the Middle East and Central Asia have issued stern warnings to their citizens about investing in and transacting with crypto assets. The authorities in these countries have all but completely outlawed cryptocurrencies.
In this report, we take a close look at crypto regulations in six specific countries before offering an overview of what crypto regulation looks like in more than 160 countries around the world.
Up close: Cryptocurrency regulation in 6 jurisdictions
We analyzed how the governments and central banks of Australia, the United States, the United Kingdom, Canada, Singapore and New Zealand are coming along regarding the regulation of crypto assets.
The regulatory state surrounding cryptocurrencies in these jurisdictions is constantly changing, but the following is an overview as of early 2023.
Singapore is out in front by developing and implementing a regulatory framework around crypto. Meanwhile, the United States and Canada are in similar phases of developing and implementing their crypto frameworks, as are Australia and the UK.
And New Zealand is lagging most when it comes to regulating crypto.
Countries with a spot Bitcoin ETF
Of the six jurisdictions we’ve discussed, only three — Australia, Canada and Singapore — have a regulated and publicly-traded spot Bitcoin ETF.
US crypto regulation
In the United States, a number of agencies are in the process of deciding who will oversee the different types of crypto assets.
The Securities and Exchange Commission (SEC), the Treasury’s Financial Crimes Enforcement Network (FinCEN), the Federal Reserve Board and the Commodity Futures Trading Commission (CFTC) have each issued different interpretations of how to classify and regulate crypto assets.
In 2015, the CFTC defined Bitcoin (BTC) and all other cryptocurrencies as commodities.
However, current SEC Chair Gary Gensler has said that only Bitcoin (BTC) should be considered a commodity and that he sees all other crypto assets as securities. Gensler’s views are not law, though.
Since 2014, both the House of Representatives and the Senate have increased the number of bills they’ve introduced related to crypto.
Government agencies around the world have eyes on the financial regulatory agencies of the United States as it attempts to develop a regulatory framework around the crypto asset class.
Matt Blumenfeld, Web3 and digital asset lead at PricewaterhouseCoopers US, believes this framework is sorely needed.
“Trust is broken in the space right now,” says Blumenfeld. “While regulation alone will not solve that, clarity across terminology and application of regulation, along with enhancements to risk management capabilities and procedures, is a good starting point.”
UK crypto regulation
The UK’s Cryptoassets Taskforce comprises the UK Financial Conduct Authority (FCA), HM Treasury and the Bank of England.
Since 2018, this task force has looked at the risks and benefits associated with the crypto asset class. Its public aims are to protect consumers, ensure regulatory standards in financial markets and guard against threats of financial stability.
A main rule set by the task force is that crypto companies must register with the FCA.
The British government has said that further regulation is coming down the pipeline and that the Bank of England is considering a central bank digital currency (CBDC) — a central bank-issued digital currency that isn’t pegged to a commodity — that it plans to call “Britcoin.”
UK Prime Minister Rishi Sunak has said that he’s a fan of crypto but that the industry around the asset class needs to be better regulated.
Laura Talvitie, senior manager of digital assets regulation at PricewaterhouseCoopers UK, seems to agree with Sunak.
“Cryptocurrencies may have been originally created to operate free from control,” says Talvite. “But the lack of a robust global regulatory framework is harmful for the sector, innovation and consumer protection.”
Canada crypto regulation
All crypto assets in Canada are regulated as securities.
The regulatory bodies Canadian Securities Administration (CSA) and the Investment Industry Regulatory Organization of Canada (IIROC) issue guidance on crypto assets and to crypto platforms in Canada. These two agencies also enforce the country’s anti-money laundering and counter-terrorist financing rules.
In 2021, Canada adopted a clear registration process for trading platforms that offer custodial services.
Ontario is Canada’s most heavily regulated province, with the Ontario Securities Commission (OSC) responsible for enforcing action on unregistered foreign crypto exchanges that attempt to operate in the region.
Australia crypto regulation
Australia has been updating its crypto regulations since 2018, when the Australian Transactions Reports and Analysis Centre (AUSTRAC), the country’s financial intelligence agency and its anti-money laundering (AML) and counter-terrorism financing regulator, required that all crypto platforms register and implement know your customer — better known as KYC — policies, report suspicious transactions and comply with AML legislation, according to Thompson Reuters.
The Australian government announced in 2021 that it would launch a CBDC as part of an overhaul of its payment system.
In 2022, Josh Frydenberg, the former treasurer of Australia, said that the government would look into further regulating crypto businesses that provide custodial services for its customers.
Sagan Rajbhandary, director of crypto assets for PricewaterhouseCoopers Australia, believes that Australian crypto firms wanting to win more of the crypto market share in Australia should take the responsibility of providing users with trustworthy services into their own hands.
“Firms waiting for regulatory clarity are likely to be left behind by those forging ahead and proactively providing stakeholders with assurance over their governance, risk management and transparency, using both traditional methods as well as real-time, on-chain evidence,” says Rajbhandary.
In 2023, Australia’s new prime minister, Anthony Albanese, and his new government announced that it planned to implement “token mapping,” which will “uncover the characteristics of all digital asset tokens available in Australia” and “include the type of crypto asset, their underlying code and any other defining technological features,” according to the Sydney Morning Herald.
The main purpose of token mapping is to determine which tokens are subject to existing financial services laws and which may require new legislation crafted specifically for them.
Singapore crypto regulation
The crypto ownership rate in Singapore was 19% as of November 2022.
This may be, in part, a result of the Singapore government’s pro-crypto stance.
Crypto is governed by the Money Authority of Singapore (MAS), which has developed crypto regulation that other countries and jurisdictions have emulated.
In January 2020, the MAS introduced the Payment Services Act (PSA), which is a regulatory structure that brings traditional and cryptocurrency exchanges under the same regulatory roof, according to Thompson Reuters. The legislation detailed money-laundering compliance standards for exchanges.
In May 2020, the MAS issued the Securities and Futures Act (FSA), which provides guidelines for determining which crypto tokens were capital market products.
And in February 2022, MAS issued guidelines to discourage cryptocurrency trading by the general public. In it, the agency stated that digital payment token (DPT) service providers should not market their products to the general public.
Singapore’s detailed cryptocurrency regulations are often used as a model for crypto regulation across the globe, partly because of how clearly the laws are worded.
New Zealand crypto regulation
New Zealand is a “technology-neutral jurisdiction,” meaning cryptocurrency in the country is subject to regulation and laws that weren’t designed for crypto assets, according to CoinTelegraph.
The Financial Markets Authority of New Zealand (FMA) classifies cryptocurrency as property for tax purposes, and citizens of New Zealand pay capital gains tax on profits derived from trading crypto assets.
In 2021, the FMA made it clear that cryptocurrencies are not considered legal tender.
New Zealand has initiated the process of creating a regulatory framework specific to cryptocurrency but hasn’t offered details of what this might look like.
Crypto regulation around the world — by country
Country | Regulation ranking | Cryptocurrency regulation landscape |
---|---|---|
Afghanistan | 1. Explicit ban |
|
Albania | 4. Mostly legal investment |
|
Algeria | 1. Explicit ban |
|
Andorra | 4. Mostly legal investment |
|
Angola | 3. Significant concerns or restrictions |
|
Antigua and Barbuda | 4. Mostly legal investment |
|
Arab Republic of Egypt | 1. Explicit ban |
|
Argentina | 4. Mostly legal investment |
|
Australia | 4. Mostly legal investment |
|
Austria | 4. Mostly legal investment |
|
Azerbaijan | 4. Mostly legal investment |
|
The Bahamas | 4. Mostly legal investment |
|
Bahrain | 2. Implicit ban |
|
Bangladesh | 1. Explicit ban |
|
Belarus | 4. Mostly legal investment |
|
Belgium | 4. Mostly legal investment |
|
Belize | 3. Significant concerns or restrictions |
|
Benin | 3. Significant concerns or restrictions |
|
Bhutan | 4. Mostly legal investment |
|
Bolivia | 1. Explicit ban |
|
Botswana | 3. Significant concerns or restrictions |
|
Brazil | 4. Mostly legal investment |
|
Brunei Darussalam | 3. Significant concerns or restrictions |
|
Bulgaria | 4. Mostly legal investment |
|
Burkina Faso | 3. Significant concerns or restrictions |
|
Burundi | 2. Implicit ban |
|
Cambodia | 3. Significant concerns or restrictions |
|
Cameroon | 1. Explicit ban |
|
Canada | 4. Mostly legal investment |
|
Central African Republic | 4. Mostly legal investment |
|
Chad | 3. Significant concerns or restrictions |
|
Chile | 4. Mostly legal investment |
|
China | 1. Explicit ban |
|
Colombia | 3. Significant concerns or restrictions |
|
Congo | 1. Explicit ban |
|
Costa Rica | 4. Mostly legal investment |
|
Côte d'Ivoire | 3. Significant concerns or restrictions |
|
Croatia | 4. Mostly legal investment |
|
Cuba | 3. Significant concerns or restrictions |
|
Cyprus | 4. Mostly legal investment |
|
Czech Republic | 4. Mostly legal investment |
|
Democratic Republic of the Congo | 2. Implicit ban |
|
Denmark | 4. Mostly legal investment |
|
Dominican Republic | 3. Significant concerns or restrictions |
|
Ecuador | 3. Significant concerns or restrictions |
|
El Salvador | 5. Legal tender |
|
Equatorial Guinea | 3. Significant concerns or restrictions |
|
Eritrea | 3. Significant concerns or restrictions |
|
Estonia | 4. Mostly legal investment |
|
Eswatini | 3. Significant concerns or restrictions |
|
Ethiopia | 1. Explicit ban |
|
Finland | 4. Mostly legal investment |
|
France | 4. Mostly legal investment |
|
Gabon | 3. Significant concerns or restrictions |
|
Georgia | 2. Implicit ban |
|
Germany | 4. Mostly legal investment |
|
Ghana | 3. Significant concerns or restrictions |
|
Greece | 4. Mostly legal investment |
|
Greenland (Den.) | 4. Mostly legal investment |
|
Guatemala | 3. Significant concerns or restrictions |
|
Guyana | 2. Implicit ban |
|
Haiti | 3. Significant concerns or restrictions |
|
Honduras | 3. Significant concerns or restrictions |
|
Hong Kong, SAR | 3. Significant concerns or restrictions |
|
Hungary | 4. Mostly legal investment |
|
Iceland | 4. Mostly legal investment |
|
India | 3. Significant concerns or restrictions |
|
Indonesia | 3. Significant concerns or restrictions |
|
Iraq | 1. Explicit ban |
|
Ireland | 4. Mostly legal investment |
|
Islamic Republic of Iran | 1. Explicit ban |
|
Israel | 4. Mostly legal investment |
|
Italy | 4. Mostly legal investment |
|
Jamaica | 3. Significant concerns or restrictions |
|
Japan | 4. Mostly legal investment |
|
Jordan | 2. Implicit ban |
|
Kazakhstan | 4. Mostly legal investment |
|
Kenya | 4. Mostly legal investment |
|
Kuwait | 2. Implicit ban |
|
Kyrgyz Republic | 4. Mostly legal investment |
|
Lao People’s Democratic Republic | 3. Significant concerns or restrictions |
|
Latvia | 4. Mostly legal investment |
|
Lebanon | 2. Implicit ban |
|
Lesotho | 1. Explicit ban |
|
Liberia | 2. Implicit ban |
|
Libya | 2. Implicit ban |
|
Liechtenstein | 4. Mostly legal investment |
|
Lithuania | 4. Mostly legal investment |
|
Luxembourg | 4. Mostly legal investment |
|
Macau, SAR | 3. Significant concerns or restrictions |
|
Malawi | 3. Significant concerns or restrictions |
|
Malaysia | 4. Mostly legal investment |
|
Mali | 3. Significant concerns or restrictions |
|
Malta | 4. Mostly legal investment |
|
Mauritius | 3. Significant concerns or restrictions |
|
Mexico | 3. Significant concerns or restrictions |
|
Moldova | 2. Implicit ban |
|
Mongolia | 4. Mostly legal investment |
|
Montenegro | 4. Mostly legal investment |
|
Morocco | 1. Explicit ban |
|
Myanmar | 1. Explicit ban |
|
Namibia | 3. Significant concerns or restrictions |
|
Nepal | 1. Explicit ban |
|
The Netherlands | 4. Mostly legal investment |
|
New Zealand | 4. Mostly legal investment |
|
Nicaragua | 3. Significant concerns or restrictions |
|
Niger | 3. Significant concerns or restrictions |
|
Nigeria | 3. Significant concerns or restrictions |
|
Norway | 4. Mostly legal investment |
|
Oman | 2. Implicit ban |
|
Pakistan | 2. Implicit ban |
|
Palau | 2. Implicit ban |
|
Panama | 4. Mostly legal investment |
|
Paraguay | 3. Significant concerns or restrictions |
|
Peru | 4. Mostly legal investment |
|
The Philippines | 4. Mostly legal investment |
|
Poland | 4. Mostly legal investment |
|
Portugal | 4. Mostly legal investment |
|
Qatar | 1. Explicit ban |
|
R. B. de Venezuela | 4. Mostly legal investment |
|
Republic of Korea (South Korea) | 4. Mostly legal investment |
|
Romania | 4. Mostly legal investment |
|
Russian Federation | 3. Significant concerns or restrictions |
|
Rwanda | 3. Significant concerns or restrictions |
|
Saint Kitts and Nevis | 4. Mostly legal investment |
|
Saint Lucia | 4. Mostly legal investment |
|
Samoa | 4. Mostly legal investment |
|
Saudi Arabia | 3. Significant concerns or restrictions |
|
Senegal | 3. Significant concerns or restrictions |
|
Serbia | 4. Mostly legal investment |
|
Seychelles | 4. Mostly legal investment |
|
Sierra Leone | 1. Explicit ban |
|
Singapore | 4. Mostly legal investment |
|
Slovak Republic (Slovakia) | 4. Mostly legal investment |
|
Slovenia | 4. Mostly legal investment |
|
South Africa | 4. Mostly legal investment |
|
South Sudan | 3. Significant concerns or restrictions |
|
Spain | 4. Mostly legal investment |
|
Sri Lanka | 4. Mostly legal investment |
|
Sweden | 4. Mostly legal investment |
|
Switzerland | 4. Mostly legal investment |
|
Taiwan | 4. Mostly legal investment |
|
Tajikistan | 2. Implicit ban |
|
Tanzania | 3. Significant concerns or restrictions |
|
Thailand | 4. Mostly legal investment |
|
Togo | 3. Significant concerns or restrictions |
|
Tunisia | 1. Explicit ban |
|
Turkey | 3. Significant concerns or restrictions |
|
Turkmenistan | 2. Implicit ban |
|
Uganda | 3. Significant concerns or restrictions |
|
Ukraine | 4. Mostly legal investment |
|
United Arab Emirates | 4. Mostly legal investment |
|
United Kingdom | 4. Mostly legal investment |
|
United States of America | 4. Mostly legal investment |
|
Uruguay | 4. Mostly legal investment |
|
Uzbekistan | 4. Mostly legal investment |
|
Vietnam | 4. Mostly legal investment |
|
Zambia | 3. Significant concerns or restrictions |
|
Zimbabwe | 2. Implicit ban |
|
Regulation ranking methodology
The countries in this report have been classified into one of the following five categories:
- Explicit ban. Governments have deemed cryptocurrencies illegal in these countries.
- Implicit ban. Governments and central banks have issued stern warnings about investing in crypto and in using the assets in transactions. These countries haven’t outright banned crypto, but they’ve stated they do not support crypto assets and that investing in them is highly risky.
- Significant concerns or restrictions. Crypto assets are legal in these countries, but regulatory agencies have expressed concerns about the proliferation of these assets or have yet to issue a proper framework for them.
- Mostly legal investment. It’s legal to invest in most crypto assets in these countries. Crypto investments are mostly deemed either commodities, securities or property in these countries.
- Legal tender. Bitcoin (BTC) is a legal tender in these countries.
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