Julien Ayyipey
By the time the Virtual Asset Service Providers Act was passed in December 2025, Ghana’s virtual asset market was already up and running.
Substantial financial activity is already taking place through virtual asset platforms, much of it beyond the traditional banking and payments system.
The Bank of Ghana describes Act 1154 as establishing the legal foundation for the registration, licensing and supervision of virtual asset service providers, but the important point is that the law has simply introduced a regulatory framework around an existing market.
The scale of that market is becoming increasingly difficult to ignore. Chainalysis estimates that Sub-Saharan Africa received more than US$205 billion in on-chain value between July 2024 and June 2025, about 52% more than in the preceding year, with Ghana among the five largest markets in the region.
More than 8% of value transferred was in transactions below US$10,000, compared with about 6% elsewhere, suggesting that the story goes beyond speculative trading. The Head of Data Analytics, Research and Strategy at First National Bank, Julien Ayyipey asserts that across the region, virtual assets are increasingly intersecting with smaller transactions, cross-border payments and ordinary financial activity, while stablecoins are becoming an important part of how value moves across borders.
He highlights some of the key areas of assessment;
The Issue Is Bigger Than Crypto
Public discussion often treats virtual assets as another name for cryptocurrency speculation, but that is too narrow. “There are at least two distinct economic issues to consider. The first is settlement, where stablecoins and other digital assets can provide alternative ways of moving value, particularly across borders. The second is ownership and record-keeping, where tokenisation allows an existing asset, such as an invoice, security or commodity, to be represented digitally, with ownership and transfers recorded differently” Julien affirmed.
The distinction should be clear because putting an asset into digital form does not make the underlying asset more valuable. A weak asset does not become a strong one simply because it has been tokenised.
Technology can improve the plumbing of a financial system, make records clearer and reduce friction in some processes, but it does not remove credit risk, legal uncertainty, fraud, weak enforcement or poor governance. That should be Ghana’s starting point.
Start With The Cost Of Moving Money
One of the clearest applications is cross-border payments. The World Bank reported that sending US$200 to Sub-Saharan Africa cost an average of 8.78% in the first quarter of 2025, moderating to 8.46% by the third quarter, yet the region remained the most expensive in the world for receiving remittances. There is, therefore, a clear economic incentive to reduce the cost and complexity of moving money across borders.
However, a stablecoin does not automatically make a remittance cheap.
The digital transfer itself may cost relatively little, but much of the difficulty sits at the two ends of the transaction: converting conventional currency into a digital instrument and converting it back into cedis that the recipient can actually spend.
That requires reliable on-ramps and off-ramps, regulatory compliance, liquidity and links into the domestic financial system.
This is where the new regulatory framework could make a meaningful difference. A licensed provider operating within Ghana’s financial system can potentially offer something an offshore platform cannot provide as easily i.e. a regulated route between digital value and the domestic economy.
For consumers, that could mean more competition and, over time, lower transaction costs. It also brings a less fashionable but equally important benefit, ACCOUNTABILITY. A regulated provider can be supervised, customers can be identified, transactions can be subjected to financial-crime controls, and complaints can be addressed within a recognised framework.
There is, of course, a trade-off. Greater participation in the formal financial system also means greater transparency, so for users attracted to virtual assets precisely because they sit outside traditional financial channels, regulation changes the proposition.
For Businesses, The Opportunity Is Efficiency
The business case may ultimately prove more important than consumer speculation. Consider a Ghanaian importer paying an overseas supplier.
The transaction may involve sourcing foreign currency, several intermediaries and an international settlement process, all of which add time and cost. Digital settlement infrastructure could reduce some of that friction, although the extent of the benefit will depend on how well it connects to the existing financial system.
Tokenisation raises a different possibility. A business may have a legitimate invoice from a credible customer but still struggle to raise working capital because it lacks the traditional collateral lenders normally require. Representing that invoice digitally, with a clear record of ownership and transfer, could make verification, transfer and financing more efficient.
But the qualification is important. A tokenised invoice does not turn a bad debtor into a good one, eliminate fraud, strengthen a weak contract or guarantee that a lender will ultimately be repaid. What it can improve is the record, and the same principle applies to land, commodities and other assets. Better records can help markets work more efficiently, but technology cannot substitute for strong institutions. This is why some of the more ambitious claims around tokenisation deserve caution.
For Banks, This Is A Deja Vu
For Ghanaian banks, the most important question is far from whether a virtual asset company will replace a bank, because that is unlikely to be how disruption appears. There was no dramatic moment when a cryptocurrency exchange walked into a banking hall and took away a customer; the customer simply found another route.
But Ghana has already lived through a very similar disruption: mobile money.
When mobile money first scaled, it did not politely integrate into banking systems. It moved faster than them. It reached people banks had not fully served, it changed how everyday payments were made, and it quietly shifted large volumes of small-value transactions away from bank branches and traditional payment rails. For many Ghanaians, the first real “bank account” they actively used was a mobile money wallet.
Banks lost transactions in fragments: school fees paid via mobile money, remittances received on phones, small business payments settled without ever touching a bank branch. The impact showed up as a gradual re-routing of financial life.
Virtual assets raise a familiar question: is this another mobile money moment, but at a different layer of the financial system?
The loss therefore appears as an absence: a payment that never passed through the bank, an FX transaction booked somewhere else, or value stored outside the traditional banking system. That is much harder to see in a management report than a conventional competitor taking market share.
Cross-border payments are the most immediate pressure point because banks form part of the existing chain through which international payments, foreign-exchange conversion and settlement generate revenue. If alternative infrastructure reduces the total cost of that chain, some traditional revenue pools will come under pressure, and pretending otherwise would not be a strategy.
Deposits require more nuance. To the extent that stablecoins substitute for balances that would otherwise remain within banks, sustained adoption could gradually affect bank funding. However, that relationship should not be overstated because some users may otherwise have held foreign currency in cash or through other channels. The eventual impact therefore depends on what stablecoins are actually replacing.
Banks also have advantages that virtual asset providers cannot recreate overnight. They have access to domestic payment infrastructure, established customer-identification systems, balance sheets, treasury capabilities, compliance frameworks and long-standing supervisory relationships.
That creates room for collaboration as well as competition because licensed virtual asset providers may still require banking relationships for settlement, cash conversion, treasury services and other financial functions.
The commercial opportunity for banks is therefore to find ways of earning from legitimate financial activity as it moves inside the regulated perimeter.
There is also a wider policy issue: if the banking industry collectively makes it practically impossible for properly regulated providers to access domestic financial infrastructure, the underlying economic activity does not necessarily disappear. It may simply remain offshore, leaving banks outside potentially valuable financial flows and regulators with less visibility over them, collaboration is key.
The State’s Side Of The Ledger
This may ultimately be the most important part of the story. For policymakers, the value of regulation is not that every transaction suddenly becomes visible, because it will not. People can still transact through offshore platforms and private wallets beyond the immediate reach of domestic institutions. What regulation can do, however, is bring more activity through licensed domestic channels and thereby improve the state’s line of sight.
That distinction matters because monetary and financial authorities make decisions using information about liquidity, capital flows, foreign-exchange demand and financial-system behaviour.
When significant financial activity takes place outside regulated institutions, measurement becomes more difficult. Although a licensing regime cannot solve that problem entirely it can reduce it.
Julien disclosed that there may also be opportunities around government securities. “Tokenisation could provide infrastructure through which securities are divided into smaller economic units or settled more efficiently, where regulation and product design permit. But again, technology should not be confused with policy”, he added.
Putting a treasury bill onto different infrastructure does not automatically remove minimum investment requirements, distribution costs or investor-protection rules; those remain policy choices.
Gold may offer another interesting opportunity for Ghana. A digital ownership and transaction record connected to a properly regulated gold market could potentially improve traceability between production, payment and subsequent transfer.
Ghana’s advantage, however, would not come from tokenisation alone. It would come from combining the technology with something the country already possesses: a significant gold industry and an established domestic market infrastructure.
The same discipline should apply to public procurement and other government applications. Better transaction records can improve transparency and make transactions easier to trace, but they cannot turn a weak control environment into a strong one or solve deeper political and institutional weaknesses on their own.
Regulation Is Now An Execution Question
The passage of Act 1154 matters because it moves Ghana from debating whether virtual assets should be recognised to deciding how they will operate within the financial system.
The Bank of Ghana, together with the Securities and Exchange Commission (SEC) and the Financial Intelligence Centre, have begun engaging virtual asset service providers as Ghana develops its supervisory approach, including requirements around financial crime, while the SEC has also introduced a regulatory sandbox through which virtual asset businesses can be tested under supervision.
That is progress, but legislation is only the first layer. The more consequential questions concern how the framework works in practice: whether licensed providers can obtain appropriate banking and settlement relationships, how they will connect to Ghana’s domestic financial infrastructure, how customer protection, liquidity, custody and financial-crime controls will work, and how different virtual asset transactions will be treated for tax purposes.
These questions will determine whether regulation actually changes financial behaviour or simply places a legal framework around activity that continues largely outside the domestic financial system.
The Money Will Not Wait
The debate “about whether Ghana is for or against cryptocurrency”, is a statement becoming increasingly irrelevant. The economic activity already exists, and the more useful question is whether Ghana can bring legitimate parts of that activity into a financial system that is safer for consumers, commercially relevant for financial institutions and more visible to policymakers.
The test of Act 1154 will simply be whether legitimate financial activity that currently sits outside Ghana’s line of sight begins moving inside it, not who or how licenses are issued.
If regulation succeeds, Ghana gains more than a virtual asset industry; it gains a better view of how money moves through its economy and a better opportunity to participate in the value created along the way. If it does not, the market will not disappear. It will simply continue elsewhere.
Ghana has passed the law. Now comes the harder part: building a financial system that gives people a reason to operate within it, he concludes.
Source: FNB Bank
