Bank of Ghana’s Directive on Cryptocurrency in Ghana: What It Means for the Public

The Bank of Ghana (BoG), in collaboration with the Securities and Exchange Commission (SEC) and the Financial Intelligence Centre (FIC), has solidified Ghana’s policy position on Virtual Assets (VAs) and Virtual Asset Service Providers (VASPs). While the Bank previously issued strong cautions, the new framework, detailed in the November 2025 policy document, signals a notable shift toward developing a comprehensive regulatory structure rather than imposing a ban.

This comprehensive approach comes as the country’s virtual asset ecosystem has expanded substantially, now encompassing more than 3 million users. This regulatory shift has several crucial implications for the Ghanaian public.

The Context: Why Regulation is Necessary

The Bank, SEC, and FIC concur that virtual assets can no longer remain outside of Ghana’s financial regulatory purview. The expansion of VAs and VASPs in Ghana’s financial sector raises significant concerns regarding consumer protection, market integrity, anti-money laundering (AML), financial crime prevention, and overall financial stability.

A 2024 National Anti Money Laundering, Countering the Financing of Terrorism and Proliferation Financing (AML CFT CPF) Risk Assessment revealed that VAs have gained significant traction, particularly in banking and securities. The assessment observed that VASPs offering services like exchange, wallet management, custody, and transfer are currently operating in Ghana with little to no regulatory oversight. These new technologies are inherently susceptible to use in money laundering and terrorist financing (ML FT).

In response, a mandatory registration exercise in July 2025 recorded over 100 VASPs providing various virtual asset services, including payments, exchange, brokerage, and investment advisory, providing baseline information on these activities.

Maintaining the Legal Status of Virtual Assets

Despite the intention to regulate the industry, the Bank is maintaining its longstanding position regarding the official status of VAs:

• VAs are Not Legal Tender: The policy explicitly recommends maintaining the stance that virtual assets are not recognised as legal tender.
• VAs are Not Accepted for Settlement: VAs are generally not accepted for settlement in Ghana.

The BoG had previously cautioned financial institutions and the public in 2018 and 2022 that VAs were not legal tender and were not regulated under the Payment Systems Act, 2019 (Act 987). The new policy confirms that this stance remains.

The Policy Shift: From Caution to Oversight

In a shift from previous directives that required regulated financial institutions to refrain from facilitating virtual asset activities, the Bank issued Draft Guidelines on Virtual Assets in August 2024, signalling the intent to develop a comprehensive framework.

Ghana has chosen not to impose an outright ban on VAs. This position is strategic, aligning with Financial Action Task Force (FATF) guidance, which cautioned against banning VA-related activities, noting that prohibition tends to push activity into informal, unregulated channels, thereby increasing risks of financial crime and consumer abuse.

Instead, Ghana is pursuing a risk-based regulatory framework. This framework aims to balance the potential benefits of blockchain and virtual assets, such as financial inclusion, remittances efficiency, and innovation, with the necessary safeguards for monetary stability, consumer protection, and financial crime mitigation. Regulatory actions will be proportionate to the risks posed by specific VA activities, rather than employing a one-size-fits-all approach.

Consumer Protection through Regulation and Licensing

The new framework directly impacts public safety by establishing clear oversight responsibilities for VASPs:

• Mandatory Licensing and Registration: Entities offering virtual asset services must now be defined as VASPs and must be licensed or registered with the relevant regulatory authorities (either the Bank or SEC). This licensing requirement is activity-based, depending on the function performed (e.g., custody, trading, payments).
• Clear Regulatory Roles: The Bank of Ghana (BoG) will oversee activities related to payments, custody, and any activity with potential implications for monetary policy, financial stability, or payment system integrity. The SEC will oversee the offering, trading, and investment of virtual assets. The FIC will oversee AML CFT compliance.

Addressing Public Vulnerability through Literacy

A cornerstone of the new policy and arguably the most direct benefit to the public is the focus on financial literacy. The BoG also acknowledges that low levels of digital financial literacy are a main reason why consumers are vulnerable to unscrupulous VASPs when attempting to buy virtual assets or other financial assets online.

To combat this vulnerability, the policy recommends launching the National Virtual Assets Literacy Initiative (NaVALI). Given Ghana’s high youth participation in VA markets, the BoG, SEC, and the Ministry of Education are urged to partner with various stakeholders to:

• Build public awareness.
• Prevent scams.
• Promote responsible adoption.

Strengthening digital financial literacy levels will assist consumers in the safer and informed use of digital financial products and services, including virtual assets.

In essence, the Bank of Ghana’s policy shift means that while the underlying legal tender status of virtual assets remains unchanged, the activities surrounding them are now being brought out of the shadows. The public benefits from this move through a regulatory structure designed to protect consumers and mitigate crime risks by mandating registration for service providers and prioritising widespread financial education.

This policy acts like establishing traffic laws and mapping systems for a previously unregulated territory. Before, participants were driving on unpaved ground with no rules, relying on good faith and luck. Now, the government is defining the roads (licensing), setting speed limits and checkpoints (AML CFT compliance and regulatory oversight), and providing driver education (NaVALI) to ensure safer passage for everyone navigating the virtual asset space.