Crypto Assets – Treatment Around The World

The Financial Action Task Force (FATF) is the global money laundering and terrorist financing watchdog. As a policy-making body, the FATF works to generate the necessary political will to bring about national legislative and regulatory reforms in these areas.

The FATF launched regulations for virtual assets in June 2019, called Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers. This guidance aimed to help countries and virtual asset service providers understand their AML and counter-terrorist financing obligations, and effectively implement the FATF’s requirements as they apply to the virtual asset sector. The FATF strengthened its standards to clarify the application of AML and counter terrorist financing requirements on virtual assets and virtual asset service providers. Countries are now required to (i) assess and mitigate their risks associated with virtual asset financial activities and providers; (ii) license or register providers; and (iii) subject them to supervision or monitoring by competent national authorities. Virtual asset service providers are subject to the same FATF measures that apply to financial institutions.

In view of the above, countries are now obligated to comply with all FATF requirements, as otherwise there is a risk of being included in the grey list of countries.

The below table provides a list of countries which have introduced regulations governing crypto assets, and names of the regulatory authorities in such countries1 :

Sr. No.Country NamePrimary Regulatory BodyCurrent Status
as of 31 December 2020
1 Argentina (G20)2Comisión Nacional de Valores (CNV) / Central Bank of ArgentinaPartly Regulated
2Australia (G20) Australian Government (AUSTRAC) Regulated
3 Brazil (G20)3Comissao De Valores Mobiliarios (CVM) / Central Bank of Brazil (BACEN)Unregulated
4Canada (G20)Canadian Securities Administrators (CSA)Regulated
5China (G20)The National Internet Finance Association (NIFA)Partly Regulated (Several banking restriction. Coin offerings are prohibited)
6 Estonia The Estonian Government Regulated
7France (G20)4Autorité des Marchés Financiers (AMF)Regulated
8Germany (G20) Germany’s Federal Financial Supervisory Authority (BaFin)Regulated
9GibraltarGibraltar Financial Services CommissionRegulated
10Hong KongHong Kong’s Securities and Futures Commission (SFC)Regulated
11India (G20)RBI, Ministry of Finance, Supreme Court of IndiaUnregulated and await regulation
12Indonesia (G20) Financial Services AuthorityPartially Regulated
13Italy (G20)Italian Ministry of EconomicRegulated
14Japan (G20)Payment Services Act (PSA) / Financial Instruments and Exchange Act (FIEA)Regulated
15 MalaysiaSecurities Commission of Malaysia (SC)Regulated (IEOs)
Further regulations awaited in 2021
16Malta Malta Financial Services Authority (MFSA) Malta Digital Innovation Authority (MDIA)Regulated
17Mexico (G20)5CNBV – Comision Nacional Bancaria y de ValoresRegulated
18PhilippinesPhilippines Securities and Exchange Commission (SEC)Partially Regulated
19Russia (G20)Ministry of Finance of the Russian FederationRegulated
20Saudi Arabia (G20)6Saudi Arabian Monetary Authority (SAMA)Partly Regulated
21Singapore The Monetary Authority of Singapore (MAS)Regulated
22South Africa (G20)South African Reserve Bank (SARB)Unregulated, Bill proposed and awaiting regulations 2021
23South Korea (G20)Financial Action Task Force (FATF)Regulated
24SpainSpain’s National Securities Market Commission (CNMV)Regulated
25 SwedenSweden’s Financial Supervisory Authority (FSA)Partly Regulated, Waiting for further guidelines in 2021
26SwitzerlandSwiss Federal Tax Administration (SFTA)Regulated
27ThailandThailand’s Security Exchange Commission (TSEC)Regulated
28Turkey (G20)7Banking Regulation and Supervision Agency (BRSA) / Capital Markets Board of Turkey (CMB) / Financial Crimes Investigation Board of Turkey (MASAK)Unregulated
29United Arab EmiratesSecurities and Commodities AuthorityRegulated
30United Kingdom (G20) Financial Conduct Authority (FCA)Regulated
31United States (G20)Securities & Exchange Commission (SEC)Regulated in majority states


Countries marked as “regulated” in the table above, have major guidelines in place for crypto assets, covering aspects such as taxation, settlement and process of declaration. Countries marked as “partly regulated” do not yet have in place guidelines for a few of these aspects.

Leave a Reply

Your email address will not be published. Required fields are marked *

Close Bitnami banner