❌

Normal view

There are new articles available, click to refresh the page.
Before yesterdayCoinmonks

Onchain Yield for Non-US Investors: The Map Is Wrong

27 October 2026 at 01:08

The US finalised its stablecoin yield rule on 21 October. The real border is not where you think, and the UK proves it.

Dark navy title card reading “Onchain Yield for Non-US Investors: The Map Is Wrong” with stat chips showing $301B stablecoin market, B3 and B- credit ratings from Moody’s and S&P, and 2017 operating with zero exploits.
The US closed the door on issuer-paid stablecoin yield on 21 October 2026. For everyone outside America, the map just changed.

On 21 October 2026, the US Office of the Comptroller of the Currency finalised its rules under the GENIUS Act.

One line did most of the work: a permitted payment stablecoin issuer cannot pay a holder interest or yield simply for holding, using or storing the coin.

Most outlets filed that under American news.

It is not. It quietly redrew the map for everyone else.

Because “non-US investor” is not a category. It is roughly 190 different answers wearing one label.

If you are planning around a US border, you are planning around a line that has already moved.

Can Non-US Investors Access Onchain Yield? The Short Answer First

Yes. In most jurisdictions, and often through fewer gates than a US retail investor now faces.

Onchain yield is produced by smart contracts on public blockchains. Those contracts do not read your passport. That is the design, not a loophole.

But three things sit between “the contract will accept you” and “you should proceed”:

  • Your local law. Some countries restrict or ban holding cryptoassets. Some require a licence you do not hold.
  • The interface you use. A website is a company. Companies have regulators, lawyers and a registered address.
  • Tax. Access is not permission, and it is never a tax ruling.

Two routes exist in practice.

The first is permissionless DeFi yield, reachable with a wallet and nothing else.

The second is tokenized real-world-asset products built specifically for non-US investors under securities exemptions.

Those are aimed at you and still gated, usually with KYC, wallet allowlisting, minimums and lockups.

So the honest picture is split. One route is open. The other was designed for you and still asks for papers.

Permissionless at the protocol layer does not mean permitted at the personal layer.

Hold that, because the rest of this depends on it.

Why the US Border Stopped Being the Real Line for Stablecoin Yield

Here is what the “escape the US” takes keep missing.

The EU got there first. Under MiCA, interest on e-money tokens and asset-referenced tokens is already prohibited.

The US arrived at the same place with the GENIUS Act in July 2025, and this week’s final rule confirmed it.

Two of the world’s largest regulatory blocs now agree: the issuer of a payment stablecoin does not pay you for holding it.

So the interesting question is no longer whether you sit inside or outside America.

It is this: where does the yield actually come from, and who is paying it?

A rate funded by a protocol’s own surplus and set by token holder vote is a structurally different object from an issuer passing along reserve interest. That distinction now does real work.

Some scale for context. The total stablecoin market sat near $301 billion on 21 October 2026.

Most of those dollars are idle. Not because people chose idleness, but because the route to anything else was unclear.

Two-layer diagram contrasting the permissionless protocol layer with the jurisdiction-gated interface layer, listing prohibited jurisdictions including the United Kingdom, China, Hong Kong, Russia, Iran and Venezuela.
The protocol does not check your passport. The front end does. That is where access actually breaks for non-US investors.

Protocol vs Interface: The Two Layers That Decide Your Access

This part surprises people.

The protocol layer is permissionless. Open-source smart contracts, deployed on Ethereum and other public chains. No gatekeeper. Reachable directly, or through any independent front end.

The interface layer is not. A front end is operated by a legal entity, and that entity geo-restricts.

Take a real example instead of a hypothetical. Sky.money publishes its prohibited jurisdiction list in its Terms of Use, version 2.0, updated 1 September 2026.

Thirty-five countries and regions are named. China, Hong Kong, Russia, Iran, Venezuela.

It also names the United Kingdom.

It does not name the United States.

Read that again. Meanwhile the UK’s Financial Conduct Authority published fresh DeFi consultation papers on 21 October 2026, with its full cryptoasset regime due in force from October 2027.

The border is not America versus the world. It is drawn country by country, by lawyers, and it moves.

So much for “non-US access.”

Horizontal bar chart comparing $16.24 billion of collateral backing the system against $10.02 billion of USDS supply and $4.86 billion of sUSDS supply, with a callout reading $1.62 of collateral per $1 of USDS.
Roughly $1.62 of collateral value behind every $1 of USDS obligation, published live rather than attested once a quarter.

What Actually Crosses Borders? Measurement, Not Tokens

Tokens move freely. Trust does not.

An allocator in Singapore, a founder in Lagos and a saver in Sao Paulo share no vocabulary for “is this safe.” That gap is the real barrier to global onchain yield. Not geography.

Which is why two announcements this year matter more than they look.

On 7 October 2026, Moody’s assigned Sky Protocol a B3 counterparty risk rating with a stable outlook.

It was the first rating Moody’s has issued on any stablecoin protocol. S&P Global had already assigned a B- in August 2025, the first credit rating ever given to a DeFi protocol, and affirmed it this year.

Sky Protocol is currently the only stablecoin protocol formally rated by both.

Neither rating is investment grade. Nobody is pretending otherwise, and both agencies published what would need to improve. That is the point of a scale. A rating is not a compliment.

A credit rating is the one document that reads the same in Singapore, Sao Paulo and Lagos.
Timeline graphic showing S&P Global assigning a B- rating in August 2025 and Moody’s assigning a B3 counterparty risk rating in October 2026, noting Sky Protocol is the only stablecoin protocol rated by both.
Two agencies, two separate processes, one scale that institutional allocators already use in every market.

Then the backing, which anyone can check without asking permission:

  • USDS supply across USDS and DAI: around $10.02 billion
  • Collateral backing the system: around $16.24 billion
  • sUSDS supply: around $4.86 billion
  • Operating since 2017, across every market cycle, with no exploits

That is roughly $1.62 of collateral value behind every $1 of USDS obligation, visible in real time rather than attested once a quarter.

If you want the mechanics, Sky.money has a plain-English explainer on what actually backs a stablecoin.

The protocol underneath is not running on fumes either. Sky Protocol generated $107.35 million in gross revenue in Q2 2026, its second consecutive quarter above $100 million and its fifth straight quarter of surplus.

Trailing twelve-month net protocol revenue stood at $159.63 million, and protocol collateral climbed 45.5% year over year.

Those are numbers a rating agency can audit. Which is exactly why one did.

In September 2026, Galaxy Digital put $100 million of sUSDS on its corporate balance sheet and approved it as collateral across its institutional trading business. Institutions do not do that on vibes.

Four-step flow diagram showing USDC converting 1:1 to USDS through the Peg Stability Module, USDS supplied to receive sUSDS, and sUSDS accruing the governance-set Sky Savings Rate funded from protocol surplus.
Four steps from a stablecoin in your wallet to the Sky Savings Rate. No lockups, no maturity date, no claim button.

How Non-US Investors Reach the Sky Savings Rate Through USDS and sUSDS

The mechanics are deliberately boring.

  1. Convert USDC to USDS at 1:1 through the Peg Stability Module. No fees, no slippage.
  2. Supply USDS and receive sUSDS, the world’s largest yield-bearing stablecoin.
  3. Your sUSDS accrues the Sky Savings Rate continuously. No lockup, no maturity date, no claim button.
  4. Redeem back to USDS whenever you want.

What separates the Sky Savings Rate from most stablecoin yield:

  • It is governance-set, not demand-set. SKY holders vote it up or down onchain, in public, before it takes effect.
  • It is funded from aggregate protocol surplus, not one lending market or one borrower.
  • It is not paid from token emissions.
  • You hold exposure to the rate itself, not to any single Agent, pool, strategy or asset manager.

The rate is variable and can change. Check it live on the sUSDS page rather than trusting a number in an article.

For anyone who wants something other than the baseline, there is Fixed Yield, where the rate is fixed only if you hold to maturity, Vaults curated on Morpho, stUSDS for advanced risk capital, and Sky Ecosystem Rewards. Different risks, different reasons. sUSDS stays the baseline.

Six-point checklist card covering local rules, prohibited jurisdictions clauses, VPN restrictions, limited app versions, the source of yield, and tax obligations.
Access is not permission. Six things to confirm before you supply anything, anywhere.

The Jurisdiction Checklist Before You Supply a Single Dollar

Run this first:

  • Check your own country’s rules. Not the protocol’s. Yours.
  • Read the prohibited jurisdictions clause. Two paragraphs, usually decisive, and it changes without a press release.
  • Never use a VPN to pass a geo-block. Sky.money treats misrepresenting your location as a material breach of its terms. Most interfaces do the same.
  • Confirm whether you get the full app or a limited version. Feature-level restrictions are common and rarely advertised.
  • Understand where the yield comes from. Reserve interest, borrowing demand and protocol surplus are three different risks.
  • Assume tax applies. It is your filing, in your country.

So What Is the Honest Answer?

Non-US investors can access onchain yield. Many have more routes open than US retail does right now.

But the useful question was never “am I non-US.”

It is: is my specific jurisdiction served, by this specific interface, for this specific product, today?

The protocol does not care where you live. The front end does. Your tax authority definitely does.

What makes any of this work at global scale is not permissionlessness on its own. It is measurement. Published collateral. Rates voted onchain.

Two independent credit ratings on the same scale a pension fund already uses. A shared language for capital that reads the same whatever the jurisdiction or currency.

That is the part that actually crosses borders.

This is informational only. Not legal, tax or financial advice. Yields are variable and not guaranteed.

Now tell me where you are reading this from. Which jurisdiction are you in, and has an interface ever geo-blocked you out of something you were perfectly entitled to hold? I want to see how wide the gap really is. Comments are open.


Onchain Yield for Non-US Investors: The Map Is Wrong was originally published in Coinmonks on Medium, where people are continuing the conversation by highlighting and responding to this story.

24/7 Markets, 9-to-5 Supervision?

By: Kevin Wei
8 October 2026 at 00:45

24/7 Markets, 9-to-5 Supervision? Supervisory information in an increasingly continuous financial system

Financial markets have always been organized around time. Exchanges have opening and closing hours, settlement takes place according to defined cycles, positions are valued at particular points in the day, and regulatory information is generally prepared for specified reporting periods. These arrangements have shaped not only how financial institutions operate, but also how they are supervised. If risks develop within reasonably familiar market and reporting cycles, periodic snapshots can provide supervisors with a meaningful picture of a firm’s financial condition and activities.

That assumption is becoming less comfortable.

Crypto markets provide the most obvious example of markets operating continuously, but the issue is becoming broader than crypto. Tokenisation, programmable assets, more automated collateral management and increasingly integrated payment and settlement infrastructure could gradually bring more continuous processes into regulated finance. The IMF’s recent work on tokenised finance, for example, discusses atomic settlement, continuous liquidity management and embedded compliance, while also pointing to implications for liquidity and systemic risk.

None of this means that every financial market will become fully 24/7. Nor does it mean that continuous markets necessarily require continuous regulatory intervention. The more interesting question, from a supervisory perspective, is whether the information architecture of supervision needs to evolve as the time structure of markets changes.

Put more simply: a market can increasingly operate in real time while supervision still sees much of it through periodic snapshots.

That gap is worth thinking about.

A snapshot can be correct and still miss the important part

Periodic reporting remains essential. A firm’s capital, liquidity, client assets, exposures and other financial positions need common reference dates so that they can be reviewed over time and compared across institutions. There is nothing inherently outdated about a snapshot.

But snapshots have an important limitation: they are much better at describing a state than explaining the events that produced that state.

Consider a simple example. A firm’s liquidity position may be normal at the beginning of the day and normal again at the end. Between those two points, however, the firm could have experienced significant outflows, liquidated assets, moved collateral, obtained additional funding and eventually restored its position. An end-of-day snapshot might be entirely accurate, while saying very little about the period during which the firm’s risk was greatest.

The same problem can arise with leverage, counterparty exposures, concentration and transaction activity. As financial processes become faster, a material risk may emerge, intensify and be resolved within the interval between two reporting points.

This creates what I see as an increasingly important distinction for supervisory data:

A snapshot tells us where the firm was. Event data can help explain how it got there.

The distinction sounds simple, but it has quite significant implications. If the supervisory question is only “what was the position?”, a periodic balance may be sufficient. If the question becomes “what happened, how quickly, in what sequence, and what else changed at the same time?”, the data model needs to look quite different.

Real-time markets do not necessarily justify real-time reporting

There is an obvious response to this problem: if markets become more real-time, perhaps regulatory reporting should become more real-time as well.

I do not think that conclusion necessarily follows.

The technical ability to collect more granular and frequent information does not automatically make supervision better. A supervisor receiving every transaction, collateral movement, wallet transfer, position change and system event from every regulated institution would undoubtedly possess more data. Whether that supervisor would possess more understanding is another matter.

In fact, the problem could simply move from information scarcity to information overload.

Supervisory attention is limited, and not every market event has regulatory significance. A large transaction may be entirely ordinary in context. A rapid change in an exposure may reflect a legitimate business activity. An unusual statistical pattern does not necessarily represent misconduct or even elevated risk. Streaming all available information to a regulator therefore risks creating a very sophisticated mechanism for producing noise.

For this reason, I think the more useful objective is not real-time reporting, but continuous supervisory awareness.

The difference is important.

Continuous supervisory awareness does not require a regulator to observe every event as it happens. Instead, it means having sufficient information and analytical capability to recognize when something material has changed and to bring that change to supervisory attention at the appropriate time.

Conceptually, the chain might look something like:

Data → Signal → Alert → Context → Judgement

Technology can support the earlier parts of this chain. Data can be processed continuously, indicators can detect specified changes and alerts can direct attention towards potentially significant developments. But an alert is not itself a supervisory conclusion. Context is needed to understand the business circumstances, and judgement is needed to decide whether the event requires further enquiry or action.

That distinction matters because it places technology in a supporting role rather than treating automation as a substitute for supervision.

The emerging challenge is deciding what matters

Once the objective changes from collecting everything to identifying what matters, the problem becomes more interesting.

What should generate a supervisory signal?

There is unlikely to be a universal answer. Relevant indicators would depend on the institution, its activities and the risks being supervised. Depending on the context, material changes in liquidity, leverage, concentration, large exposures, collateral positions, settlement failures, transaction patterns or operational conditions might warrant attention.

But individual thresholds may be only part of the answer.

One event in isolation can be difficult to interpret. A large transaction may not be particularly meaningful. A liquidity movement may reflect normal activity. An operational incident may have no financial consequence.

A large transaction occurring together with a sharp liquidity movement, growing concentration and an operational incident may tell a different story.

This points towards a more useful role for supervisory analytics: not simply identifying whether individual numbers cross predetermined limits, but identifying relationships among events and changes that together may justify attention.

Seen this way, the regulatory challenge is less about monitoring everything continuously and more about finding the right level of abstraction. Raw transactions sit at one end. Period-end regulatory returns sit at the other. Between them may be a useful layer of events, indicators and relationships that can help supervisors understand material changes without requiring them to consume the entire underlying data stream.

Faster finance is not automatically safer finance

There is another reason why the time dimension matters.

Much of the discussion around technological change in financial markets treats speed as an obvious improvement. Faster settlement reduces certain exposures. More rapid collateral movement can improve efficiency. Automation can remove manual processing and reduce delays.

These benefits are real, but speed can also change how risks behave.

The IMF’s 2026 work on tokenised finance makes a particularly interesting observation in this regard. It notes that traditional financial arrangements contain temporal frictions, including settlement and processing delays, which can allow exposures to be netted and liquidity to be mobilized. Tokenised arrangements can reduce some of these frictions, but liquidity demands can correspondingly materialize more immediately.

This suggests that we should distinguish between delays that are merely inefficient and timing arrangements that also perform an implicit risk-management function.

A delay may provide time to reconcile inconsistent records, obtain liquidity, investigate an exception or intervene before an action becomes irreversible. Removing unnecessary delays may clearly improve a market, but removing a temporal buffer without recognizing the function it performed can change the nature of the risk rather than simply eliminate it.

This is not an argument for preserving slow infrastructure. It is an argument for understanding what is being removed when infrastructure becomes faster.

And there is a supervisory consequence. If financial risk can emerge and propagate more quickly, supervisory information may also need to become more responsive. The objective is not necessarily for supervision to operate at the same speed as the market. It is to understand which risks require a faster supervisory response and which do not.

Perhaps the reporting model matters more than reporting frequency

For me, this leads to a more fundamental question about regulatory data.

When existing regulatory information is considered insufficiently timely, the intuitive response is often to increase reporting frequency. Quarterly reporting becomes monthly, monthly becomes weekly, and weekly can eventually become daily.

That may sometimes be appropriate. But it assumes that the existing information model is basically correct and that only the reporting interval needs changing.

In an increasingly continuous financial environment, that assumption deserves examination.

Rather than asking only,” How can the same return be submitted more frequently?”, it may be more useful to ask,” What do supervisors actually need to know between reporting dates?”

The second question produces a different set of information requirements. A supervisor may need to understand what changed, when it changed, how quickly the change occurred, which entities or instruments were involved, whether several exposures moved together, whether the movement was temporary or persistent, and whether an operational event was associated with the change.

These are not simply more frequent snapshots. They are information about events and relationships.

A future supervisory data architecture may therefore need several complementary layers. Periodic position data can continue to provide structured information about financial condition. Event data can describe material changes between those positions. Reference data can establish the identities and relationships between firms, instruments, accounts, wallets and other objects. Analytical indicators can identify significant movements, while alerts can direct attention towards situations requiring supervisory consideration.

This would be quite different from attempting to transform every regulatory return into a real-time feed.

The aim would instead be to use the appropriate information model for the supervisory question being asked.

From observing firms to observing processes

There is an additional implication that may become more important as finance becomes programmable.

Traditional supervision is understandably organized largely around regulated entities. Firms hold licenses, carry financial resources, maintain controls and submit returns. The institution is therefore a natural unit of supervision.

But increasingly automated financial infrastructure may require supervisors to understand processes that cross institutional boundaries as well.

A tokenised transaction, for example, may involve an issuer, an intermediary, a custodian, a settlement asset, a ledger and other technology or service providers. The relevant risk may not sit entirely inside any single participant. It can emerge at the interface between them.

The Bank of England’s current work on wholesale-market innovation similarly describes an increasingly interconnected payment and settlement ecosystem and a vision in which different forms of money, assets and technologies can interact.

In such an environment, supervisory awareness may increasingly depend not only on the state of individual firms, but also on the relationships and flows between firms, infrastructures and technologies.

This is closely related to the issue I explored in my earlier article, Transactions Without Infrastructure. A transaction can be technically visible while important institutional relationships around it remain difficult to observe. Continuous markets add another dimension to the same problem: even when the necessary information exists, its usefulness can depend on whether it reaches the supervisory process while it is still relevant.

AI adds another clock

AI makes this time problem even more interesting.

In May 2026, IOSCO published its Supervisory Toolkit for AI Use in Capital Markets, covering areas including governance and risk management, third-party dependencies, disclosure, recordkeeping and reporting, and indicators for monitoring AI adoption. The toolkit encompasses traditional machine learning, generative AI and emerging agentic AI techniques.

As financial institutions automate more decisions and operational processes, supervisors may increasingly face systems in which actions occur continuously and at machine speed.

This does not mean supervision itself should attempt to operate at machine speed. In fact, trying to do so may miss the point.

A more realistic model may involve machines helping humans determine where judgement is required.

This is a subtle but important distinction. The objective of supervisory technology should not simply be to make regulators faster. It should make regulatory attention more selective, better informed and more timely.

In that sense, the purpose of automation is not to remove the human supervisor from the loop. It is to make sure that the human enters the loop at the right point.

What this could mean for SupTech

SupTech is often associated with better dashboards, automated data collection, machine learning and more sophisticated analytics. All of these can be valuable.

But I think there is a larger opportunity.

The real value of SupTech may eventually lie in redesigning the information architecture of supervision, not simply applying new technology to the existing reporting architecture.

That would require difficult choices.

Which information genuinely needs to be reported periodically? Which events are sufficiently important to be captured earlier? Which indicators are reliable enough to trigger attention? How should events across different systems or entities be connected? At what point does an automated signal require human review? And perhaps most importantly, how do we prevent a system designed to reduce information overload from simply creating a new form of it?

These questions are more difficult than building another dashboard.

They are also, in my view, more important.

A perspective from regulators

Working in financial regulation makes these questions particularly relevant to me. Hong Kong operates as an international financial center connected across jurisdictions and time zones. Digital assets already demonstrate what continuously operating markets can look like, while tokenisation and increasingly automated financial infrastructure may gradually introduce similar characteristics into more traditional markets.

The appropriate response is unlikely to be simply to request more data, more frequently.

A more useful objective may be straightforward to state, even if it is difficult to achieve:

the right information, at the right level of detail, at the point when the risk matters.

This also places discipline on supervisors. Real-time data should not become an objective in itself. More granular regulatory information imposes costs on both industry and regulators. Each additional data requirement should therefore have a clear supervisory purpose.

Continuous supervisory awareness should ultimately mean more selective use of information, not indiscriminate collection of information.

That distinction will matter if the idea is to scale.

The supervisory clock does not need to match the market clock

The phrase “9-to-5 supervision” is deliberately provocative. Financial supervision, particularly in an international market, has never fitted neatly into office hours. Critical incidents already require escalation outside normal reporting and working cycles.

The real issue is therefore not whether supervisors work at night.

It is whether the information architecture of supervision remains too dependent on the reporting calendar when the activities being supervised are becoming more continuous.

That is a different problem.

And it suggests a different direction for supervisory technology.

The transition may not be: 9-to-5 supervision → 24/7 supervision

It may instead be: Periodic supervision → continuous supervisory awareness

The distinction leaves an important role for both technology and people. Technology can monitor information, recognize material changes and help direct attention. Supervisors can provide context, challenge explanations, connect events to broader risks and exercise judgement.

This is, to me, a more useful way to think about the next stage of SupTech.

The goal should not be a regulator that watches everything.

It should be a supervisory system that is able to recognize when something is worth watching.

A 24/7 market does not necessarily need a supervisor watching 24/7. It needs a supervisory system that knows when the supervisor should look.

The views expressed in this article are personal and do not necessarily represent those of any institution with which I am affiliated.


24/7 Markets, 9-to-5 Supervision? was originally published in Coinmonks on Medium, where people are continuing the conversation by highlighting and responding to this story.

IMF Flags Gaps in Ghana’s Crypto Framework Ahead of December 2026 Licensing Go-Live — Crypto Africa

28 September 2026 at 09:37
  • The Central Bank of Ghana asked the IMF to conduct a technical assistance mission regarding its digital asset regulatory framework.
  • In its report, the IMF identified several structural gaps in market abuse protections, stablecoin redemption rights, and offsite reporting, and proposed solutions for Ghanaian regulators to implement.
  • The IMF also noted that Ghana’s cryptocurrency volume was driven mostly by stablecoin use, for trading, cross-border commerce, and inflation hedging.
  • The Bank of Ghana and SEC Ghana have till December 2026 to implement the IMF’s proposed regulations.

The International Monetary Fund (IMF) released a technical assistance report on September 25. In the report, the IMF informed the Bank of Ghana (BoG) and Ghana’s Securities and Exchange Commission (SEC Ghana) that its current guidelines and regulations “fall short of comprehensive oversight.”

The IMF noted that while current regulation was “directionally aligned with global standards,” Ghana’s central bank and the SEC must close key gaps before the digital asset licensing regime goes live later in December 2026.

Ghana’s Current Crypto Framework

In December 2025, Ghana passed the Virtual Asset Service Providers (VASP) Act (Act 1154). The Act gives the Bank of Ghana and SEC Ghana regulatory and supervisory authority over virtual assets.

In line with the VASP Act, the Bank of Ghana regulates and supervises:

The Securities and Exchange Commission Ghana regulates and supervises:

The current framework also requires stablecoin issuers (cedi-backed or backed by foreign currency) to obtain a licence to continue marketing to the Ghanaian market. Stablecoin issuers may keep reserves abroad, provided they are held in banks in “non-high-risk” jurisdictions.

The Bank of Ghana and the SEC each have their own sandbox. On August 19, 2026, SEC Ghana added 9 new firms to its crypto sandbox, growing the number from 11 to 20 participants. The sandbox, which initially launched in March 2026, is expected to run for a 12-month pilot period.

Later that month, on August 25, the BoG inaugurated a five-agency Virtual Assets Coordinating Committee (VACC). The committee includes representatives from the BoG, SEC Ghana, the Ministry of Finance, the Financial Intelligence Centre (FIC), and the Cyber Security Authority (CSA).

The BoG governor described the committee as necessary for coordinating regulatory and supervisory activity.

Less than a week later, UMB Bank gained approval from both the SEC and the Bank of Ghana to provide virtual accounts to eligible VASPs.

The Gaps the IMF Flagged and its Recommendations

Despite all this and the IMF’s acknowledgement that “legislation is in place” and that Ghanaian “authorities are ready to regulate,” the IMF still found gaps in the current framework. The IMF outlined those gaps and its recommendations, urging the BoG and SEC Ghana to implement them before December 2026. They include, but aren’t limited to:

  1. Broad Regulatory Scope: The IMF noted that there were no tailored, activity-specific guidelines for trading platforms, brokers and lending services in Ghana’s VASP Act. It also noted that the Act extends unnecessary financial oversight to network mining, validation and self-hosted wallets.

To combat this, the IMF urged the SEC and the BoG to provide regulations that allow for “comprehensive regulation and supervision of the crypto market’s activities.”

2. Market Conduct, Abuse, Custody and Trading: The existing market abuse provisions apply almost exclusively to proprietary trading. The IMF called for expanding these rules to cover order books, front-running, wash trading, spoofing, and other order misuse by brokers.

The IMF also noted that the current rules do not explicitly prohibit asset rehypothecation. It called for clear rules prohibiting the rehypothecation of clients’ assets without consent. The IMF asked the SEC to develop dedicated trading guidelines covering pre- and post-trade transparency, disclosure, whitepaper requirements, and listing/delisting criteria.

3. Stablecoin Arrangements: The current stablecoin framework does not clearly state end-user redemption rights or minimum rules for liquid reserves. The IMF also noted that the current framework does not clearly distinguish between cedi-backed stablecoins and foreign stablecoins.

The IMF asked regulators to prioritise binding rules for par-value redemption rights. It also asked regulators to enforce liquid reserve allocations and establish clear currency-matching requirements.

4. Reporting, Disclosures and Data Collection: The IMF warned that supervisory offsite reporting requirements are sparse, static, and non-standardised. It relies on annual financial statements rather than dynamic market data.

It asked regulators to consider implementing standardised, activity-specific, periodic reporting templates that cover risk metrics, volume, and reserve details.

Why This Matters

The IMF report estimates that somewhere between 8% and 17% of Ghana’s population participate in the crypto market. With an estimated $21 billion in annual virtual asset transactions, Ghana is the fifth-largest cryptocurrency market in sub-Saharan Africa.

The scale of the market means that Ghana’s regulators need to be careful and thorough as they draft regulations.

The IMF also noted that most of Ghana’s crypto transaction volume is dominated by USDT stablecoin. It also highlighted that current volumes show Ghanaians use USDT for crypto trading and to protect their funds against inflation. Unlike remittance-dependent economies, Ghana showed balanced gross inflows and outflows, driven by increased stablecoin use in B2B cross-border commerce.

With just two months before December, the Bank of Ghana and SEC Ghana face a narrow window to review and refine their regulations.

However, considering that the IMF conducted the technical assessment mission at the request of the Ghanaian central bank, the regulators seem intent on providing clear digital asset governance and regulations for its market.

Originally published at https://cryptoafrica.news on September 28, 2026.


IMF Flags Gaps in Ghana’s Crypto Framework Ahead of December 2026 Licensing Go-Live — Crypto Africa was originally published in Coinmonks on Medium, where people are continuing the conversation by highlighting and responding to this story.

❌
❌