Cryptocurrency Regulation in Ghana: The Past, the Now, and the What-Ifs
1. INTRODUCTION
As of June 2025, approximately 562 million people worldwide (roughly 6.8% of the global population) use or hold cryptocurrency. This decentralized, non-physical medium of exchange, created and stored on blockchain technology, has evolved over the last decade from a niche innovation to a mainstream phenomenon, with Ghana emerging as a significant participant in recent years. From utilisation as a means of payment, remittance, and even as an investment vehicle, cryptocurrencies like Bitcoin have served multiple functions beyond use as a payment method.
Despite regulatory efforts by various countries including Singapore’s Monetary Authority, Kenya’s draft Virtual Asset Service Providers Bill, and the passing of the Genius Act in the US, Ghana has maintained a cautionary stance for years. The cryptocurrency (‘crypto’) market in Ghana operated in a legal gray zone until the recent developments marked a decisive shift toward formal regulation.
This transition began with the Bank of Ghana’s August 2024 Draft Guidelines on Digital Assets through a July 2025 notice from the Bank of Ghana (‘BoG’ or the ‘Bank’) imposing a mandatory registration of Virtual Asset Service Providers (VASPs) operating in Ghana, to an announcement by the BOG’s Governor that the Bank will commence regulation of virtual assets by September 2025. This regulatory evolution represents an environment moving from uncertainty toward structured oversight that will require individuals, businesses, and other stakeholders in the cryptocurrency ecosystem to adapt quickly.
This article examines Ghana’s cryptocurrency regulatory space by tracing the country’s history, adoption pattern, current state, and future implications for market stakeholders.
2. HISTORICAL CONTEXT AND CURRENT LANDSCAPE
2.1 The Global Cryptocurrency Evolution
The evolution of money, from barter trading to cowrie currency to fiat currencies like the USD and GHS, has taken various forms shaped by trust and technology.
The concept of digital money predates Bitcoin by decades with roots in electronic cash systems in the 1980s. Notably, David Chaum’s Digicash pioneered cryptographic approaches to anonymous online payment. Although Digicash filed for bankruptcy just a decade before the emergence of blockchain-based cryptocurrencies like Bitcoin, David Chaum’s Digicash was a crucial early proponent of cryptography, which is the basic principle governing digital currencies today.
Cryptocurrency did not appear out of nowhere. The concept of cryptocurrency stems from the desire to have payment exchanges without an intermediary, unlike what we have in the traditional banking system, solving the Byzantine Generals Problem. As there is no central authority to validate or manage transactions, cryptocurrency relies on consensus algorithms, unlike traditional financial systems where banks and governments ensure that transactions are legitimate. This breakthrough came about in 2008 when a pseudonymous Satoshi Nakamoto released the Bitcoin white paper proposing a peer-to-peer electronic cash system. In 2009, the first Bitcoin block was mined, with cryptographers and programmers proving that a decentralized monetary system could function in practice.
Unlike electronic money, most cryptocurrencies are not fiat-backed. Each coin serves as its unit of account, and the unit is intrinsically valueless except by collective belief in its value rather than government backing, which contributes to its high volatility. However, certain cryptocurrencies such as stablecoins are designed to maintain price stability by being pegged to fiat currencies or other assets. Bitcoin’s price, for example, is a product of supply, demand, regulation, and market sentiment.
Following the early peer-to-peer transfers and exchanges of 2009, centralized exchanges rose from large, centralized exchanges, tokens, and Initial Coin Offers (ICOs) to smart contracts, decentralized finance, and stablecoins. From 2023 to date, we have seen maturing infrastructure and clearer regulations in multiple jurisdictions, driving more compliant business models and a shift to virtual asset payments and tokenized assets.
2.2 Ghana’s Cryptocurrency Landscape
In Ghana, the thriving mobile money industry has paved the way for crypto adoption. The mobile money sector has seen tremendous usage in recent years, with a 2.2 billion GHS transaction volume as of the first quarter of 2025, demonstrating a surge in user comfort with digital payment systems.
Early crypto users and adopters primarily turned to Bitcoin for online trading, remittances and investment through peer-to-peer (P2P) informal platforms. Despite regulatory uncertainty, young Ghanaians have actively traded on platforms such as Binance, and international crypto businesses and exchanges increasingly view Ghana as a growth market.
This organic adoption occurred even without a clear regulatory framework.
3. GHANA’S REGULATORY JOURNEY
Ghana’s posture on cryptocurrency and virtual assets has moved from caution toward a structured oversight, reflecting a broader understanding of the potential benefits and risks of virtual assets.
Public notices reiterated the BOG’s previous non-regulatory position, warning about the risks of cryptocurrency and maintaining a stance that cryptocurrency is neither regulated nor legal tender. In 2018, the BOG issued a notice highlighting that activities in digital currencies were not licensed or regulated. In 2022, it issued another notice targeting a specific virtual currency, “Freedom Coin”, cautioning Ghanaians against cryptocurrency transactions while maintaining that such activities fell outside regulatory purview.
Paradoxically, the Bank of Ghana was one of Africa’s pioneers on central bank digital currency (CBDC): the eCedi. The eCedi initiative outlined in the Bank’s Design Paper stated one of the reasons for considering e-cedi to be part of efforts to digitalize the economy in Ghana.
In June 2024, the BOG also announced its successful use of digital credentials for international trade and cross-border payment (Project DESFT) in collaboration with the Monetary Authority of Singapore. The project involved live trade transactions, which “demonstrated the feasibility of utilizing the proposed Ghanaian domestic retail CBDC platform, the eCedi, in cross-border transactions”.
The regulatory landscape shifted dramatically in August 2024, when the BOG issued Draft Guidelines on Digital Assets, highlighting the surge in use of cryptocurrencies such as Bitcoin and Tether (USDT) in Ghana, and soliciting industry feedback on its proposed regulatory approach.
The draft outlined guidelines, including:
- Definition of services for virtual asset service providers
- Risk assessment requirements for market participants
- Expanded scope for Enhanced Payment Service Providers (EPSPs)
- Consumer protection measures
Two pivotal developments occurred in 2025: a public indication that a regulatory framework will begin by September 2025, and a mandatory registration requirement for virtual asset service providers in Ghana. These signal licensing, consumer protection, and compliance regulations for market participants.
4. FUTURE IMPLICATIONS AND EXPECTATIONS – ADOPTION, COMMERCE, BUSINESS, AND REGULATION
With the upcoming regulatory framework, stakeholders can only wait patiently. However, we can expect a surge in activities relating to cryptocurrency, including adoption, commerce, fiat consideration, business, and regulation.
4.1 Adoption and Licensing
According to Business Insider Africa, Africa’s crypto adoption has grown at a steady rate from 40.1 million to 43.5 million users in 2025. In 2024, Ghana ranked 9th in Africa and 46th globally, behind Nigeria and Kenya, but ahead of many peer states in the crypto adoption index.
This continuous adoption, ownership, and use continue to see an upward trend globally, which is helpful for Ghana’s market planning. As we advance, we can expect, with the upcoming regulation, an increase in payments by crypto and stablecoins in sectors with cross–border needs such as remittances, digital services, and e-commerce.
With the BOG finalizing a virtual asset service provider regime, Ghana’s remittance corridors may see stablecoin and crypto solutions offered by licensed entities, and crypto-based business transactions will transition from speculation to integration.
Banks and licensed payment providers and aggregators such as Enhanced Payment Service Providers (EPSPs) and Dedicated Electronic Money Issuers (DEMIs) may integrate decentralized digital payment systems, without necessarily declaring cryptocurrency legal tender. Merchants may increasingly accept crypto through these licensed payment intermediaries. This may mirror the regulatory shift in Nigeria in 2023, where banks were allowed to open and operate accounts for VASPs, including crypto exchanges.
Finally, the new regulations may mark a licensing regime for crypto exchange, wallet providers, and brokers requiring registration or licensing under the Bank of Ghana or a designated regulatory authority. We can also expect tax, consumer protection, and AML/CFT considerations. A taxation framework may be developed by the Ghana Revenue Authority (GRA) covering capital gains, income, or Value Added Tax (VAT) on crypto-related transactions. The authors also believe that entities such as the SEC may need to oversee security regulations relating to investment in cryptocurrencies.
4.2 Monetary Policy (Fiat Considerations)
The authors are of the opinion that Ghana is unlikely to grant a legal tender or property status for cryptocurrency, just yet. The Ghana Cedi will remain the sole legal tender in Ghana, although crypto is likely to co-exist with the e-cedi for retail payments and financial inclusion.
The probable path is a regulated recognition of digital assets as financial instruments and not a replacement of the cedi.
4.3 Business and industry implications
The authors also anticipate a risk-based licensing regime for VASPS with requirements for governance, audits, capital adequacy, consumer protection, data protection, cybersecurity, and AML/CFT compliance. We can expect laws on transparency, disclosure, and redress mechanisms.
Cross-border remittance providers may be required to have additional licences or to partner with regulated banks and specialized deposit-taking institutions. This regulatory clarity will open doors to banking services, merchant partnerships, and cross-border transactions. For startups and DeFi projects, regulatory clarity may influence decisions. However, startups that already use strict international standards and follow global best practices like AML/CFT checks and safe custody of customer funds will be in a stronger position when the regulations are finalised.
5. UNIQUE LEGAL IMPLICATIONS ON THE CRYPTO ECOSYSTEM
Beyond regulation, crypto introduces unique legal issues that traditional financial frameworks were not designed to address:
5.1 Consumer Protection
Even under a new regulated regime, cryptocurrency will not be risk-free. Unlike most bank transfer transactions, blockchain transactions cannot be reversed. A single-character error in a wallet address can send funds to the wrong party. This blurs the line between user error and system design, raising difficult questions about liability and contractual remedies. Perhaps the upcoming regulations will address this gap, but until then, regulations must adapt legal concepts of property, contract, and inheritance to current and emerging technologies.
5.2 Digital Asset Inheritance
In conventional banking and finance, beneficiaries of an estate present probate or letters of administration and vesting assent documents to access accounts and funds of a deceased person. With cryptocurrency ownership, however, access and control lie entirely with the private key. If an owner dies without securely sharing credentials, the assets may be permanently lost, something no court order can override on the blockchain.
This raises new questions about estate planning, succession, and fiduciary responsibilities. Likely legal developments would be specialized courts that can resolve disputes and enforce rights, relating to smart contracts and crypto-based transactions.
6. LEGAL SERVICES IN REGULATORY TRANSITION
As Ghana transitions into formal regulation, legal support is critical. Law firms like OAKS Legal can assist clients with regulatory and licensing requirements, registration procedures and ongoing compliance obligations including Anti-Money Laundering/Combating Finance Terrorism (AML/CFT) under the new framework, as well as preparation of compliant internal consumer protection frameworks, and succession planning.
Conclusion
Ghana is at a turning point, and the wheels are moving. From warnings to a structured regulatory framework, adoption is already significant, and the impending regulation will shape how businesses, consumers, and financial institutions participate in this new ecosystem. Ghana may experience challenges relating to volatility and fraud concerns, which could slow adoption; however, we can expect, in the next 5 to 10 years, an enhanced integration of cryptocurrency into Ghana’s financial system.
Nonetheless, the consumer protection and legal implications cannot be overstated. From estate and trust, volatility to irreversible mistakes, crypto presents challenges that demand intricate legal solutions and an efficient framework.
With regulation imminent, stakeholders must prepare now to capitalize on opportunities of a digitalized Ghanaian economy.
By Selasie Atuwo and Lily Oblie:
Selasie Atuwo is Managing Partner at OAKS Legal and specialises in Technology Law. Lily Oblie is an Associate at OAKS Legal with keen interest in Technology and Intellectual Property Law. At OAKS Legal, we stand ready to guide clients through this transition – ensuring compliance, protecting consumers, and helping stakeholders seize the opportunities of a digitalized Ghana.