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Virtual assets pose several advantages and challenges. On one hand, they make payments simpler, faster, cheaper, and enhance financial inclusion by providing alternative methods for persons without access to basic financial products and services . While on the other hand they have the potential to become worthless and are vulnerable to cyber-attacks and scams.
The absence of regulation for virtual assets presents a safe space for the financial transactions of criminals and terrorists. Given that the majority of countries worldwide are yet to implement effective regulations on virtual assets, the ensuing gap in the global regulatory environment has created a large lacuna in financial integrity to be exploited by terrorists, criminals, and rogue regimes.
This article applauds and highlights the beneficial elements of the current confident regulatory and legal framework adopted by the country in progressing the use of virtual assets.
Existing law defines a Virtual Asset Service Provider (VASP) as any natural or legal person who is not covered elsewhere under the Financial Action Task Force Recommendations, and as a business conducts one or more of the following activities or operations for or on behalf of another natural or legal person:
- exchange between virtual assets and fiat currencies;
- exchange between one or more forms of virtual assets;
- transfer of virtual assets;
- safekeeping and administration of virtual assets or instruments enabling control over virtual assets; and
- participation in and provision of financial services related to an issuer's offer or sale of a virtual asset;1
The Financial Action Task Force (FATF) defines virtual assets as any digital representation of value that can be digitally traded, transferred, or used for payment. It does not include digital representation of fiat currencies.2 Virtual assets are widely understood to be a synonym for crypto assets.
On 22 December 2025 the Bank of Ghana (BoG) issued a Press Release3 to notify the public that the Parliament of Ghana had passed the Virtual Assets Service Providers (VASP) Bill, 2025. On 30 December 2025 it was announced that the President, John Dramani Mahama, has assented to the Bill thereby making it an Act with the force of law.
The VASP Act ushers in a watershed in the life of the virtual asset ecosystem in Ghana. Legitimising virtual assets in Ghana through a comprehensive regulatory and licensing framework birthed by the VASP Act provides a gateway to foster trust, enhance innovation, and provide global relevance. It also positions Ghana well to tap into abundant opportunities.
Ghana's expanding electricity coverage , increasing internet penetration, usage, and affordability will allow it to better take full advantage of virtual asset services in the country. Over the last decade, Ghana has consistently maintained electricity access rates above the regional average rates. Given that access to electricity powers communication infrastructure necessary to connect to the internet, end users of virtual assets will continue to efficiently enjoy the services following the implementation of the VASP Act. It has been reported that Ghana's electricity access rate surpasses that of Cote d'Ivoire and Kenya, and is very close to the global average share of about 90%4.
In addition, compared to a 64.4% world average share of individuals using the internet, Ghana fared better at 69.9%.5 This means that, when the VASP Act drives up demand and supply of virtual assets due to actual and perceived legitimacy, the ecosystem will rely on the current commendable electricity and internet access rates to better deliver the service.
Internet affordability has also improved over time, albeit remaining disproportionately high for low income users. The cost of connecting to the internet in Ghana is slightly greater than the global average of 1.2% of Gross National Income.
Ghana boasts of an impressive performance in digital trade (international trade that is digitally ordered and/or digitally delivered). The country is a major exporter of digitally delivered services, with exports amounting to USD 6.2 billion in 2024, surpassing Kenya (USD 2 billion) and Nigeria (USD 1.4 billion).6 The main push for Ghana's export growth in 2024 included research and development services, and professional services such as legal, management consulting, advertising and market research services.
It is estimated that Ghana's enhanced digital connectivity will serve as a catalyst for the country's growing participation in virtual asset trade particularly following the implementation of the VASP Act.
Ghana's leadership deserves recognition for its commendable policy and legal stance on virtual assets. Inaction would have unearthed underground markets, undermined consumer protection and risked reputational loss. The positive evolution of the BoG, Financial Intelligence Centre (FIC), and Securities and Exchange Commission (SEC) from caution to confidence is a positive development. The current position of confidence has been demonstrated by the BoG's November 2025 policy position7 and the VASP Act, 2025.
The VASP Act introduces a comprehensive legal and regulatory framework covering qualification requirements for licensing and registration, clarity around the coordinated and overlapping roles of the BoG and SEC, enforcement of the Travel Rule8, consumer protection, and AML/CFT integration.
The object of the VASP Act, 2025 is to regulate the provision of virtual asset services in or from the country. As recognised by the Act, the virtual asset economy in Ghana is already redefining finance in a speedy, informal, and often invisible way. The country ranks 29th globally from a cryptocurrency adoption standpoint, with 3.1 million users. Stablecoins - cryptocurrencies designed to maintain a stable value relative to a certain asset9 for example USDT and USDC - act as de facto foreign exchange instruments, peer-to-peer groups facilitate unregulated transfers, and end users in the country interact with virtual asset platforms without any institutional or regulatory guidance.
Clause 6 of the VASP Bill sets out the requirements for providing virtual assets services. It limits qualified persons to those registered under the Bill, holding a virtual asset service license or sandbox license issued under the Bill or having been granted a waiver by the relevant regulatory authority. All other persons are prohibited from providing virtual asset services. To qualify for registration, a virtual asset licence, or a waiver a person must be a company incorporated under the Companies Act, 2019 (Act 992), a partnership established under the Incorporated Private Partnerships Act, 1962 (Act 152), an external company registered under the Companies Act, 2019 (Act 992), or a non-Ghanaian company as defined under the Companies Act, 20199 (Act 992). Individuals are prohibited from providing virtual asset services.
Clause 13 provides that a registration shall be subject to renewal after a twelve-month validity period.
Under clause 21 of the Bill, a VASP must have a registered office in Ghana and provide documents, statements, and any other information that may be required by a relevant regulator to enable the regulator to effectively perform its functions under the Bill.
Under clause 23, a VASP must have at least three directors including not less than one independent director who has no vested interest in the VASP while clause 24 requires shareholders, senior officers, trustees, beneficial owners, must be fit and proper persons.
Clauses 29 and 30 provide that a VASP must prepare accounts annually in line with internationally accepted accounting standards adopted by the Institute of Chartered Accountants, Ghana and any other accounting rules determined by the relevant regulatory authority. The VASP must also ensure that its accounts are audited annually or as specified by the relevant regulatory authority.
Clauses 33 and 34 highlight the Anti-Money Laundering(AML)/Combatting of Financial Terrorism(CFT)/Proliferation of Weapons of Mass Destruction (P) and consumer protection/whistleblowing obligations of the VASP. VASPs must comply with the Anti-Money Laundering Act, 2020 (Act 1044) and any other law that combats money laundering, financial terrorism and proliferation. VASPs must also implement arrangements which enable its employees to report to the relevant regulatory authorities any breaches of obligations, fraud, corruption, etc.
Clause 42 stipulates the condition precedent for the acquisition, disposal or transfer of 5% or more outstanding shares in a VASP - the relevant regulatory authority's approval in writing.
Clause 44 provides that if a relevant regulatory authority determines that a virtual asset service represents an innovative use of technology, uses an innovative method of delivery which requires supervision not provided under a licence or registration under the Bill, or it is in the best interest of the public, supervised persons, virtual asset service licence holders, registered persons or the financial markets for a virtual asset service to be restricted, the regulatory authority is empowered to direct specified persons to apply for a sandbox licence instead.
It is expected that the VASP Act will create a legitimate atmosphere for stakeholders of the ecosystem to continue engaging in the several use cases of virtual assets including speed and cheaper costs. For example, a Ghanaian exporter of fresh fruits and vegetables can send stablecoins to a Moroccan importer without incurring delays in the traditional banking system which relies on the correspondent banking system to effect international payments. The use of stablecoins also usually comes at a cheaper cost compared to a SWIFT10 transfer through an authorised commercial bank. Already, the country remains an active hub for virtual assets. From period 2023 to 2024 the country recorded USD 3 billion in cryptocurrency transactions. This remarkable volume of transactions is attributed to 3 million users making up 17% of the population.11
It is suggested that as soon as possible, the National Virtual Assets Initiative (NaVALI) be established in line with the BoG's recommendation in the November 2025 Policy Position on Virtual Assets in Ghana. NaVALI will be a partnership birthed by the BoG, SEC, the Ministry of Education, civil society, and private sector stakeholders. The partnership aims to build public awareness, prevent scams, and promote responsible adoption. This move will complement the work of advocacy groups such as the Chamber of Digital Assets and Blockchain Innovation (CDABI-GH).
The implementation of the licensing framework under the Act is expected to rake in gains for stakeholders. The government will benefit from increased tax revenue from the proper taxation of virtual asset transactions, the ecosystem will benefit from improved market access, and both the demand and supply side of virtual assets will enjoy safe, transparent and financially inclusive transactions. Investors can now confidently pour capital into the Ghanaian virtual asset ecosystem given the regulatory and legal clarity around virtual assets.
It is recommended that lawyers, regulators, compliance professionals, innovators, and end users collaborate to shape Ghana's digital asset future through trusted innovation.
Footnotes
1. Section 63 of Anti-Money Laundering Act 2020 (Act 1044)
3. PRESS-RELEASE-PASSAGE-OF-THE-VIRTUAL-ASSET-SERVICE-PROVIDERS-BILL221225-1.pdf
4. https://www.wto.org/english/tratop_e/serv_e/digitaltradeforafrica_e.htm
5. International Telecommunications Union (ITU) Datahub The world's richest source of ICT statistics and regulatory information - ITU DataHub
6. 2025 Digital Trade for Africa (DTA) World Bank - World Trade Organisation Joint Project
7. Ghanas-Policy-Position-on-Virtual-Assets-and-Service-Providers.pdf
8. Crypto Travel Rule Guide 2025: Global Regulations Explained | The Sumsuber
9. What to Know About Stablecoins | J.P. Morgan Global Research
10. Society for Worldwide Interbank Financial Telecommunications
11. Ghana legalizes crypto trading with new law, plans to explore gold-backed stablecoins | The Block
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