Self-custodial wallet / non-custodial software in Ghana

Bank of Ghana (BoG): The central bank is the most active and vocal regulator regarding cryptocurrencies. It is responsible for monetary policy, currency issuance, and the regulation of payment systems and financial institutions.

Financial Intelligence Centre (FIC): Responsible for combating money laundering and terrorist financing, the FIC would have oversight over Virtual Asset Service Providers (VASPs) if a regulatory framework were established, or even under existing AML/CFT laws if they are deemed "financial institutions."

Not Legal Tender: The Bank of Ghana has repeatedly stated that cryptocurrencies are not legal tender in Ghana. The only legal tender is the Ghana Cedi.

Unlicensed and Unregulated Trading: The BoG has issued strong warnings against individuals and institutions participating in or facilitating cryptocurrency trading. These warnings emphasize that such activities are largely unlicensed and unregulated, carrying significant risks.

Example BoG Warning: In March 2018, the BoG issued a public notice titled "Notice to Banks, Other Financial Institutions and the General Public on Virtual Currencies." It explicitly stated: "The Bank of Ghana wishes to notify the general public that cryptocurrencies such as Bitcoin are not licensed in Ghana. The public is therefore strongly cautioned to desist from engaging in any form of cryptocurrency transactions."

Evidence fact gh.licensing.exchanges-operating-in-a-grey-area not found (may have been renamed).

No Official Support for Virtual Asset Service Providers (VASPs): There is no clear framework for the registration or licensing of VASPs, making it difficult for legitimate crypto businesses to operate formally.

However, the Bank of Ghana (BoG), the primary financial regulator, has maintained a cautious and largely prohibitive stance on cryptocurrencies and virtual assets.

Anti-Money Laundering Act, 2020 (Act 1044): This is the most crucial piece of legislation. It provides the legal framework for combating money laundering and terrorist financing in Ghana, incorporating international standards, including those related to targeted financial sanctions. VASPs, by their nature, would fall under the broader definition of financial institutions or designated non-financial businesses and professions (DNFBPs) if they are involved in activities like exchange, transfer, or safekeeping of virtual assets.

VASP Requirements: VASPs operating in Ghana must:

Screen: Conduct ongoing screening of all customers (individuals and entities) and beneficial owners against the UNSC Consolidated Sanctions List.

Freeze Assets: Immediately freeze any virtual assets or funds belonging to, or controlled by, designated individuals or entities.

Prohibit Transactions: Cease all transactions with designated individuals or entities.

Report: Report any hit or frozen assets to the FIC without delay.

Extra-territorial Reach: OFAC sanctions have a broad extra-territorial reach. While not directly binding Ghana as a sovereign nation, they apply to:

Screen: Screen customers and transactions against OFAC's Specially Designated Nationals (SDN) List and other relevant sanctions lists (e.g., SSI List, CAATSA-related lists).

Block/Reject: Block property and interests in property of SDNs and reject prohibited transactions.

Consumer Protection: Volatility, lack of recourse, and potential for fraud.

Anti-Money Laundering (AML) / Counter-Financing of Terrorism (CFT): Anonymity and potential for illicit financing.