Ghana
Retail_Trading_Status
Status Changed
Previous status: Gray-Zone
Reconciled from live analysis after human review confirmed status as Allowed-UnRegulated. Original new analysis incorrectly classified as Gray-Zone, but the live analysis, prioritized as source of truth, establishes that retail trading is allowed but unregulated, with pending regulatory developments not yet finalized. New information from latest analysis, such as the registration exercise and VASP Bill submission, supports the transitional nature but does not alter the current unregulated status.
- Analysis ID
- #880
- Version
- Latest
- Created
- 2025-12-13 07:46
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- 3c5faffb...
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- Workflow Stage
- Reconciled
Executive Summary
Retail cryptocurrency trading in Ghana is 'Allowed-UnRegulated,' with no explicit legal prohibitions but no formal regulatory oversight. The Bank of Ghana (BoG) and Securities and Exchange Commission (SEC) do not recognize cryptocurrencies as legal tender and have issued warnings about associated risks. Draft guidelines released in August 2024 aim to regulate Virtual Asset Service Providers (VASPs), and as of late 2025, a mandatory registration exercise for VASPs was completed in August 2025 and a 'Virtual Asset Service Providers Bill' was submitted to Parliament in October 2025 targeting enactment by December 2025. However, until finalized, the existing restrictions on banks and payment service providers facilitating crypto transactions remain in effect, pushing activity to P2P methods, and the sector remains unregulated.
Key Pillars
- Primary regulator: Bank of Ghana (BoG) and Securities and Exchange Commission (SEC), though currently without direct regulatory oversight of crypto.
- Core compliance requirements: The draft guidelines propose AML/CFT obligations, including KYC procedures and transaction monitoring for VASPs.
- Licensing: The draft guidelines propose that VASPs will need to obtain authorization from either the BoG or SEC; a mandatory registration exercise was completed in August 2025, but this does not constitute a license.
- Pending legislation: Virtual Asset Service Providers (VASP) Bill submitted to Parliament in October 2025, aiming to establish a licensing regime.
Landmark Laws
- SEC/PN/003/03/2019 (SEC Public Notice): Clarifies that the SEC does not regulate cryptocurrency offerings or platforms.
- BG/GOV/SEC/2022/03 (BoG Notice): Prohibits banks and payment service providers (PSPs) from facilitating cryptocurrency transactions.
- Bank of Ghana Draft Guidelines on Digital Assets (August 2024): Aims to regulate digital assets, including cryptocurrencies, requiring VASPs to obtain authorization and adhere to AML/CFT obligations.
- Virtual Asset Service Providers (VASP) Bill (Draft Bill 2025): Submitted to Parliament in October 2025, targeting enactment by December 2025 to license and supervise VASPs.
Considerations
- Cryptocurrencies are not recognized as legal tender in Ghana.
- The BoG and SEC have warned of risks like volatility, fraud, and money laundering.
- Banks and PSPs are prohibited from facilitating crypto transactions, leading to P2P workarounds.
- The draft guidelines and pending VASP Bill indicate a transition towards formal regulation, but until enacted, the sector remains unregulated.
- A mandatory registration exercise for VASPs was completed in August 2025, but this does not constitute licensing or legal recognition.
- Banking restrictions remain in place until the VASP Act is passed and operational.
Notes
- Historically, the BoG and SEC have adopted a cautious stance, issuing warnings about the risks of cryptocurrency investments.
- The draft guidelines from August 2024 and the subsequent VASP Bill submission in 2025 signal a potential shift towards a formal regulatory framework.
- Until the regulatory framework is formally adopted and published, the existing prohibition preventing banks and licensed PSPs from facilitating crypto transactions remains in effect.
- The sector is in transition, with a target for regulation by late 2025, but as of the analysis period, it remains unregulated, indicating a future move to 'Allowed-Regulated'.
Remaining Uncertainties
- Exact date of Parliamentary approval for the VASP Bill
- Timeline for the issuance of the first actual licenses following the Act's passage
- Specific capital requirements for VASPs in the final version of the Bill
Detailed Explanation
Detailed Explanation
In Ghana, the retail trading of cryptocurrency is currently in a state of 'Allowed-Unregulated.' This means there are no explicit legal prohibitions against individuals buying, selling, or holding cryptocurrencies, but there is also no formal regulatory framework providing oversight or consumer protection. The Bank of Ghana (BoG) and the Securities and Exchange Commission (SEC) are the primary financial authorities, but they do not recognize cryptocurrencies as legal tender and have consistently issued public warnings about the associated risks of volatility, fraud, and money laundering. A significant restriction shaping the market is the BoG's notice BG/GOV/SEC/2022/03, which explicitly prohibits banks and licensed payment service providers (PSPs) from facilitating cryptocurrency transactions. This has effectively pushed trading activity towards peer-to-peer (P2P) methods, operating outside the formal banking system. The regulatory landscape is, however, in a clear transition towards formal oversight. In August 2024, the Bank of Ghana released draft guidelines aimed at regulating Virtual Asset Service Providers (VASPs), proposing that they obtain authorization from either the BoG or SEC and adhere to Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) obligations, including KYC procedures. Following this, a mandatory registration exercise for VASPs was completed in August 2025, though this was a data-gathering step and not a licensing regime. The most significant development is the submission of the 'Virtual Asset Service Providers Bill' to Parliament in October 2025, with a target for enactment by December 2025. This pending legislation aims to establish a formal licensing and supervisory framework. Crucially, until this VASP Bill is passed and becomes operational, the existing prohibition on banks and PSPs remains in full effect, and the cryptocurrency sector, despite the preparatory steps, remains officially unregulated.
Summary Points
I. Regulatory Status
* Status: Allowed-Unregulated
* There is no explicit prohibition on retail cryptocurrency trading.
* There is currently no formal regulatory oversight or consumer protection framework.
* The sector is in a transitional phase with pending legislation aiming to establish a regulated regime.
II. Key Regulatory Bodies
* Bank of Ghana (BoG): The central bank; does not recognize crypto as legal tender and has prohibited banks from facilitating crypto transactions.
* Securities and Exchange Commission (SEC): The capital markets regulator; has clarified it does not regulate cryptocurrency offerings.
* Both the BoG and SEC are the proposed co-regulators under the draft framework, with VASPs requiring authorization from one of them.
III. Important Legislation
* SEC/PN/003/03/2019 (SEC Public Notice): Clarified that the SEC does not regulate cryptocurrency offerings or platforms.
* BG/GOV/SEC/2022/03 (BoG Notice): Prohibits banks and licensed payment service providers (PSPs) from facilitating cryptocurrency transactions.
* Bank of Ghana Draft Guidelines on Digital Assets (August 2024): Proposed framework requiring VASP authorization and AML/CFT compliance.
* Virtual Asset Service Providers (VASP) Bill (Draft Bill 2025): Submitted to Parliament in October 2025, targeting enactment by December 2025 to establish a formal licensing regime.
IV. Compliance Requirements
* Under the draft guidelines and pending VASP Bill, future requirements for authorized VASPs are proposed to include:
* Obtaining authorization from either the BoG or SEC.
* Implementing AML/CFT obligations, including KYC procedures and transaction monitoring.
* A mandatory registration exercise for VASPs was completed in August 2025, but this was for data collection and does not constitute a license.
V. Notable Restrictions or Limitations
* Cryptocurrencies are not recognized as legal tender.
* Banks and licensed PSPs are prohibited from facilitating crypto transactions (per BoG Notice BG/GOV/SEC/2022/03).
* This banking restriction remains in effect until the VASP Act is passed and becomes operational, forcing most trading to P2P channels.
* The BoG and SEC have repeatedly issued public warnings about the risks of cryptocurrency investments.
VI. Recent Developments or Notes
* The regulatory trajectory indicates a clear move from an unregulated to a regulated environment.
* Key milestones include the draft guidelines (August 2024), the VASP registration exercise (completed August 2025), and the VASP Bill submission to Parliament (October 2025).
* The banking prohibition remains a critical constraint on the market until the new law is enacted.
* The anticipated enactment of the VASP Bill by end-2025 would likely change the status from 'Allowed-Unregulated' to 'Allowed-Regulated'.
Full Analysis Report
Full Analysis Report
Report on the Current Status of Retail Cryptocurrency Trading in Ghana
Date: 2025-12-12
Topic: Retail_Trading_Status
Description: Assess whether individual citizens and residents in Ghana are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity.
1. Identified Current Status:
Allowed-UnRegulated
2. Detailed Narrative Explanation:
As of late 2025, retail cryptocurrency trading in Ghana is classified as 'Allowed-UnRegulated.' This indicates that while no explicit laws prohibit individuals from engaging in crypto transactions, this activity takes place without a comprehensive regulatory framework. The Bank of Ghana (BoG) and the Securities and Exchange Commission (SEC) do not recognize cryptocurrencies as legal tender and have issued public warnings about risks such as volatility, fraud, and money laundering. Key regulatory notices include SEC Public Notice SEC/PN/003/03/2019, which clarifies that the SEC does not regulate cryptocurrency offerings or platforms, and BoG Notice BG/GOV/SEC/2022/03, which prohibits banks and payment service providers from facilitating crypto transactions, pushing activity to peer-to-peer (P2P) methods.
In August 2024, the BoG released draft guidelines for digital assets, proposing a regulatory framework for Virtual Asset Service Providers (VASPs) with AML/CFT obligations and licensing requirements. Building on this, in 2025, the BoG completed a mandatory registration exercise for VASPs by August 15, 2025, but emphasized that registration does not constitute a license (BoG news, 2025-07-10). Subsequently, the 'Virtual Asset Service Providers (VASP) Bill' was submitted to Parliament in October 2025, with a target for enactment by December 2025 (GNA, 2025-10-02; TradingView, 2025-10-16).
However, as of the analysis date, this legislation is not yet in force, and no licenses have been issued. Therefore, the sector remains unregulated, with banking restrictions still effective. The ongoing developments indicate a clear transition towards an 'Allowed-Regulated' status, but until the framework is finalized, retail trading is allowed but unregulated.
3. Specific, Relevant Text Excerpts:
- From SEC Notice: "Clarifies that the SEC does not regulate cryptocurrency offerings or platforms."
- From BoG Notice: "Prohibits banks and payment service providers (PSPs) from facilitating cryptocurrency transactions."
- From BoG Draft Guidelines: "The Bank of Ghana issues draft guidelines on digital assets... to expose the Bank's proposed regulatory measures and solicit feedback."
- From BoG Registration Notice: "This registration does not amount to a licence to operate."
- From VASP Bill News: "The Bank of Ghana has completed the drafting of the Virtual Asset Service Providers (VASP) Bill... and is now progressing through the processes leading to consideration by Parliament."
- From Governor's Statement: "That bill is on its way to parliament, hopefully before the end of December, we should be able to regulate cryptocurrencies in Ghana."
4. Direct, Accessible URL Links to Specific Sources:
- SEC Public Notice: [No specific URL provided]
- BoG Notice: [No specific URL provided]
- Draft Guidelines: https://www.bog.gov.gh/wp-content/uploads/2024/08/Draft-Guidelines-on-Digital-Assets.pdf
- BoG Registration Notice: https://www.bog.gov.gh/news/mandatory-registration-of-virtual-asset-service-providers-operating-in-ghana/
- GNA Article: https://gna.org.gh/2025/10/bog-completes-virtual-asset-draft-bill/
- TradingView Article: https://www.tradingview.com/news/cointelegraph:76466e336094b:0-ghana-central-bank-targets-december-to-have-crypto-regulations-in-place/
**Report on the Current Status of Retail Cryptocurrency Trading in Ghana** **Date:** 2025-12-12 **Topic:** Retail_Trading_Status **Description:** Assess whether individual citizens and residents in Ghana are legally permitted to buy, sell, and hold cryptocurrencies. Detail the regulatory environment surrounding this activity. **1. Identified Current Status:** Allowed-UnRegulated **2. Detailed Narrative Explanation:** As of late 2025, retail cryptocurrency trading in Ghana is classified as 'Allowed-UnRegulated.' This indicates that while no explicit laws prohibit individuals from engaging in crypto transactions, this activity takes place without a comprehensive regulatory framework. The Bank of Ghana (BoG) and the Securities and Exchange Commission (SEC) do not recognize cryptocurrencies as legal tender and have issued public warnings about risks such as volatility, fraud, and money laundering. Key regulatory notices include SEC Public Notice SEC/PN/003/03/2019, which clarifies that the SEC does not regulate cryptocurrency offerings or platforms, and BoG Notice BG/GOV/SEC/2022/03, which prohibits banks and payment service providers from facilitating crypto transactions, pushing activity to peer-to-peer (P2P) methods. In August 2024, the BoG released draft guidelines for digital assets, proposing a regulatory framework for Virtual Asset Service Providers (VASPs) with AML/CFT obligations and licensing requirements. Building on this, in 2025, the BoG completed a mandatory registration exercise for VASPs by August 15, 2025, but emphasized that registration does not constitute a license (BoG news, 2025-07-10). Subsequently, the 'Virtual Asset Service Providers (VASP) Bill' was submitted to Parliament in October 2025, with a target for enactment by December 2025 (GNA, 2025-10-02; TradingView, 2025-10-16). However, as of the analysis date, this legislation is not yet in force, and no licenses have been issued. Therefore, the sector remains unregulated, with banking restrictions still effective. The ongoing developments indicate a clear transition towards an 'Allowed-Regulated' status, but until the framework is finalized, retail trading is allowed but unregulated. **3. Specific, Relevant Text Excerpts:** - From SEC Notice: "Clarifies that the SEC does not regulate cryptocurrency offerings or platforms." - From BoG Notice: "Prohibits banks and payment service providers (PSPs) from facilitating cryptocurrency transactions." - From BoG Draft Guidelines: "The Bank of Ghana issues draft guidelines on digital assets... to expose the Bank's proposed regulatory measures and solicit feedback." - From BoG Registration Notice: "This registration does not amount to a licence to operate." - From VASP Bill News: "The Bank of Ghana has completed the drafting of the Virtual Asset Service Providers (VASP) Bill... and is now progressing through the processes leading to consideration by Parliament." - From Governor's Statement: "That bill is on its way to parliament, hopefully before the end of December, we should be able to regulate cryptocurrencies in Ghana." **4. Direct, Accessible URL Links to Specific Sources:** - SEC Public Notice: [No specific URL provided] - BoG Notice: [No specific URL provided] - Draft Guidelines: https://www.bog.gov.gh/wp-content/uploads/2024/08/Draft-Guidelines-on-Digital-Assets.pdf - BoG Registration Notice: https://www.bog.gov.gh/news/mandatory-registration-of-virtual-asset-service-providers-operating-in-ghana/ - GNA Article: https://gna.org.gh/2025/10/bog-completes-virtual-asset-draft-bill/ - TradingView Article: https://www.tradingview.com/news/cointelegraph:76466e336094b:0-ghana-central-bank-targets-december-to-have-crypto-regulations-in-place/
Source Evidence
Primary and secondary sources cited in this analysis
"Clarifies that the SEC does not regulate cryptocurrency offerings or platforms."
"Prohibits banks and payment service providers (PSPs) from facilitating cryptocurrency transactions."
"The Bank of Ghana issues draft guidelines on digital assets... to expose the Bank's proposed regulatory measures and solicit feedback."
"The Bank of Ghana requires all Virtual Asset Service Providers (VASPs) operating within the jurisdiction of the Republic of Ghana to register with the Bank... This registration does not amount to a licence to operate."
"The Bank of Ghana has completed the drafting of the Virtual Asset Service Providers (VASP) Bill... and is now progressing through the processes leading to consideration by Parliament."
"That bill is on its way to parliament, hopefully before the end of December, we should be able to regulate cryptocurrencies in Ghana."
Web Sources (14)
Sources discovered via web search grounding
Search queries used (8)
- is crypto trading legal in Ghana 2025
- Bank of Ghana cryptocurrency circular 2024
- Ghana cryptocurrency regulation status 2024 2025
- list of licensed crypto exchanges in Ghana 2025
- SEC Ghana digital assets guidelines 2024
- Has Ghana passed the Virtual Asset Service Providers Act 2025
- Bank of Ghana crypto registration deadline August 2025 outcome
- Ghana Virtual Asset Service Providers Bill status December 2025
https://blog.ueex.com/best-crypto-exchanges-in-ghana/
https://citinewsroom.com/2025/07/bank-of-ghana-orders-digital-asset-firms-to-register-by-august-15/
https://coingeek.com/ghana-finalizes-crypto-bill-kenya-advances-vasp-law/
https://www.ghanaweb.com/GhanaHomePage/business/BoG-sets-August-15-deadline-for-VASP-registration-1991274
https://www.gbcghanaonline.com/news/business/bank-of-ghana-7/2024/
https://www.ainvest.com/news/ghana-regulate-crypto-september-2025-surging-adoption-hits-17-2507/
https://dig.watch/updates/ghana-plans-to-regulate-digital-assets-with-new-legislation
https://www.tradingview.com/news/cointelegraph:3b545421a094b:0-ghana-central-bank-targets-december-to-have-crypto-regulations-in-place/
https://www.myjoyonline.com/bog-advances-virtual-asset-regulation-with-draft-vasp-bill/
https://iclg.com/briefing/21994-regulatory-update-on-digital-assets-in-ghana
https://lexafrica.com/2025/06/ghana-cryptocurrency-regulation-vasp-law-september-2025/
https://lexafrica.com/2025/06/ghana-cryptocurrency-regulation-vasp-law-september-2025/
https://coinpost.ai/en/topics/59168
https://www.gbcghanaonline.com/news/business/bog-to-regulate-virtual-assets-under-new-vasp-bill/2025/