Last updated: 12.2017

No Legal Advice or Attorney-Client Relationship: This chart is provided by Perkins Coie LLP’s Blockchain Technology & Digital Currency industry group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. Recipient should not act upon this information without seeking advice from a lawyer licensed in his/her own state or country. 

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Current Summary

Developments Over Time




Abu Dhabi Issuers and intermediaries of virtual currencies and “security” tokens may be subject to regulation—depending upon the nature of the product and service. 10.09.2017 The Financial Services Regulatory Authority (FSRA) of Abu Dhabi issued guidance on the regulation of initial coin/token offerings (ICO) and digital currency as supplemental guidance to the existing 2015 Financial Services and Markets Regulations (FSMR). The guidance was directed at both issuers and intermediaries. FSRA indicated that it will determine if a token issued in an ICO would be regulated as a security on a case-by-case basis. A token deemed a security (Security Token) would be subject to regulation under the FSMR. Additionally, any market intermediaries dealing in Security Tokens and/or their derivatives will need to be licensed and approved by FSRA as Financial Services Permission holders, Recognised [sic] Investment Exchanges, or Recognised [sic] Clearing Houses. The Guidance also makes clear that, while spot trading of virtual currencies is not regulated under FSMR, derivatives are regulated as a type of Specified Investment under the FSMR. Consequently, any market intermediaries or market operators dealing in derivatives of virtual currencies will be subject to regulation under FSMR. Source.

Virtual currencies are not legal tender under the country’s National Constitution, which designates the Central Bank as the only authority that may issue legal tender.

11.02.2017 Argentina’s largest futures trading market, the Mercado de Termino de Rosario (Rofex) has been considering offering services to investors in digital currencies and plans to make an announcement by the end of 2017. Preliminary drafts for the services include offering custody services for Bitcoin and the ability for clients to use Bitcoin as collateral in futures trading. Source.
07.10.2014 The Unidad de Información Financiera (UIF) issued a resolution requiring a wide range of financial institutions as well as profit and non-profit entities to report all transactions with virtual currencies on a monthly basis. Source no longer available.
05.29.2014 The Central Bank of Argentina issued a statement about the risks involved in the use of virtual currency, including volatility and fraud, and confirmed that it is not legal tender. Source no longer available.
*EU Member

Austria regulates financial services involving virtual currencies.



The Financial Markets Authority (FMA) of Austria issued a warning advising the country’s consumers to exercise utmost caution in relation to virtual currencies, particularly when related to business and investment models based on virtual currencies. Further, the FMA explicitly advised consumers that such offerings are not subject to any form of regulation, and in particular are not subject to supervision by the FMA. Source.


The Financial Markets Authority (FMA) of Austria issued guidance on the regulation of alternative currencies and bonus points. When such products represent financial services, a license issued by the Financial Market Authority (FMA) is required. Products providing a means of payment may require a banking license and may be regulated as issuance of E-money. Primary Source. Secondary Source.


Austrian ministers appear to have given conflicting guidance on the tax treatment of Bitcoin during a parliamentary Q&A session. The finance minister reportedly stated that Bitcoin is not a financial instrument, and that capital gains tax would apply to bitcoin holdings sold within a year of purchase, while the minister for science, research and economy reportedly referred to German policy recognizing bitcoin as a unit of account. Source no longer available.


Digital currency exchanges will be subject to registration and regulation in mid-2018, once amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act of 2006 take effect.

Digital currency transactions are no longer subject to goods and services taxes (GST) but remain subject to incomes and capital gains taxes.



On December 7, 2017 the Australian Parliament passed amendments to the Anti-Money Laundering and Counter-Terrorism Financing Act of 2006. Among other rules, the law as amended requires digital currency exchanges to: identify and verify their customers’ identities; monitor and report large or suspicious transactions to the Australian Transaction Reports and Analysis Centre (AUSTRAC); register on the Digital Currency Exchange Register maintained by AUSTRAC; create a management protocol to identify, reduce, and manage money laundering and terrorism-financing risks; and keep certain records for seven years of transactions and customer IDs. The amendments will become effective 6 months following assent by the Governor-General. Source.

12.08.2017 The Australian Taxation Office updated its guidance on GST and digital currency to address tokens and ICOs. In particular, the guidance states that tokens that provide a right or entitlement to goods and services are not digital currency and may be subject to GST. Source.
10.18.2017 Australia approved legislation introduced on September 14 to remove the double taxation on digital currency, which is in-line with the 2017-18 budget released earlier this year. The new legislation will ensure that consumers who use digital currency will no longer pay goods and services tax (GST) on purchases of digital currency. Source.
08.07.2017 Australian senators from both major political parties announced that the Reserve Bank of Australia (RBA) should formally recognize bitcoin and other digital currencies as official forms of currency. This pressure from parliament follows the Tax Office’s decision to stop treating digital currency as intangible property subject to goods and services tax, which effectively double taxes digital currency transactions. This change was revealed in the May 2017 release of the 2017-18 budget and took effect on July 1. This policy change and the recent pressure from parliament represent Australia’s move to embrace digital currencies as “normal” currency. Source.
03.20.2017 Australia’s securities and investments regulator, ASIC, released guidance on the use of distributed ledger technology (including blockchain) in financial services and financial markets. The guidance includes a framework to help the assessment of whether technology and risk management standards required by the regulator will be met. Primary Source. Secondary Source. Tertiary Source.

The Australian Attorney-General’s Department issued a Consultation Document stating that the government wants to begin drafting legislative proposals to regulate digital currencies by the middle of 2017. The goal is to begin finalizing that legislation in 2018. To that end the government solicited public comment on the proposal that looks to include digital money in the laws against money laundering. Source.


The Australian Department of Treasury issued a white paper listing crypto-currencies, such as bitcoin, as a challenge in determining how to appropriately tax companies and could provide a company with the ability to relocate profits to minimize their taxes. Source.


The Australia Taxation Office issued guidance on the tax treatment for Bitcoin. The ATO concluded that Bitcoin is neither money nor a foreign currency, but is an asset for capital gains tax purposes. However, capital gain or loss from using bitcoin to purchase goods or services for personal use or consumption will be disregarded, provided that cost of the bitcoin is $10,000 or less. Source.


Bank of Australia governor Glenn Stevens stated that, while virtual currencies pose regulatory questions, he believes that investors who are prepared to accept the risk in speculating in virtual currency should be allowed to do so. Source.


Australian Taxation Office (ATO) confirms Bitcoin transactions are subject to goods and services (GST) and income tax and says that speculators should keep records for capital gains taxes and that bitcoin is expected to be means of electronic payment or money. Source.


Bangladesh Bank issued a warning against conducting transactions in cryptocurrency, and reportedly stated that such use is punishable by up to 12 years in jail


Bangladesh Bank issued a warning against conducting transactions in cryptocurrency, and reportedly stated that such use is punishable by up to 12 years in jail. Source.

*EU Member

The National Bank of Belgium has warned investors and the public of the dangers of virtual currencies and declared that they are not legal tender, and the Minister of Justice has announced his intention to impose strict regulations on virtual currency activities.


The National Bank of Belgium issued a report on the threat of digital currencies to monetary policy—concluding that “any threats to monetary stability caused by digital currencies issued by private players are rather limited at this point.” Source.

04.15.2017 Koen Geens, the Minister of Justice of Belgium, has announced his intention to subject virtual currency to the same strict regulation as currently applies to the ordinary financial sector. This marks the first such statement by the Belgium government. Source.

Federal Public Service Finance reportedly issued a statement that bitcoin trading transactions are not subject to VAT, however, its position is subject to change pending the position taken by the European Committee. Source no longer available.


National Bank of Belgium (NBB) and Belgian Financial Services and Markets Authority (FSMA) warned investors that virtual currencies are not issued by a central bank; there is no current regulation; risks associated with security, hacking, and fraud; value fluctuates; exchange rate is variable; and they are not legal tender. Source.


NBB does not have plans for financial regulations to regulate Bitcoin (not an official position, but expressed in a meeting between the bank and industry reps). National Bank likely to issue warnings similar to those issued by the EBA and other European nations. Source no longer avaiable.


Minister of Finance Koen Geens commented that Belgian National Bank does not object to Bitcoin, which was being used by only a handful of traders at this time, and that there was no indication that Bitcoin was being used for money laundering. Source no longer available. 

Bermuda Government intends to begin regulating virtual currencies and ICOs in 2018. 11.22.2017

The Government of Bermuda announced it will begin to regulate virtual currency exchanges, coins and securitized tokens, in early 2018. The new regulation would include the activities of firms, operating in or from Bermuda, that use distributed ledger technologies (DLT) to store or transmit value. Source.

Boliviaa Virtual currency has been explicitly banned. 05.06.2014

The Central Bank of Bolivia banned any currency or coins not issued or regulated by the government, including a list of virtual currencies. The Bank’s resolution states that citizens are prohibited from denominating prices in any currency that is not previously approved by its national institutions. Source.


The Central Bank of Brazil has not yet regulated virtual currencies, but has issued the now-standard warnings about their use.


Brazil’s House of Representatives held a public hearing to discuss a bill that would give the country’s central bank oversight of digital currency activity in the country. Primary Source. Secondary Source.


Brazilian tax authority requires reporting of bitcoin holdings and payment of capital gains taxes for holders of bitcoin over certain value thresholds. Source.


Central Bank of Brazil says that virtual currencies are not “electronic currency” under Brazilian law. It warned that virtual currencies are not guaranteed or issued by a central authority, are not guaranteed by real assets, may be subject to volatility and total loss of value, can be used in illegal activities, and may be insecure due to the possibility of hacking. Finally, the Bank said that it was following the evolution of virtual currencies, and would consider adopting measures. Source no longer available. 


Brazil adopted  Law No. 12,865, which specifically referenced regulation of electronic currency.  While the definition of “electronic currency” appeared to cover virtual currency, the Central Bank of Brazil later distinguished electronic currency from virtual currency. Source no longer avaiable.

*EU Member

Personal income from the sale or exchange of bitcoin is taxable, and will be treated as income from sale of financial assets. 


The Bulgarian Revenue Agency determined that income from the sale of bitcoin will be treated as income from sale of financial assets. Source no longer available.


Canadian lawmakers seem to be taking a lighter approach to regulating virtual currencies, with a ‘regulate-and-embrace’ policy, focusing primarily on anti-money laundering concerns. Virtual currencies are not legal tender in Canada. As of 2014, however, the Canadian anti-money laundering legislation has been amended to classify persons “dealing in virtual currencies” as “money services businesses” subjecting those businesses to Canada’s anti-money laundering and counter-terrorist financing regime. The effective date of these amendments has not yet been announced. Regulations from the Department of Finance are currently being drafted that are expected to further specify the types of business subject to the anti-money laundering regime. No federal law exists in Canada for the regulation of certain financial transactions, including securities. Each province passes its own binding laws, although there are some federal entities that serve in research and/or advisory capacities.

 12.08.2017 The Superior Court of Quebec sentenced Dominic Lacroix to two months in prison and levied a fine of $110,000 CD for running virtual currency scam PlexCoin. Source.
11.2017 The Bank of Canada has issued a discussion paper addressing whether a central bank should issue digital currency (CBDC) that could be used by the general public. Noting potential risks and benefits, the bank made several conclusions, including: Increasing contestability in retail payments is the most credible motivation to issue CBDC; Complete anonymity is undesirable because it could foster criminal activity; and Banks considering issuance of a digital currency should proceed cautiously and incrementally. Source.
11.02.2017 The Ontario Securities Commission (OSC) has granted regulatory relief to Toronto-based Funder, Inc. to allow Ontario’s first regulated ICO/ITO. Specifically, Funder has been exempted from registering as a dealer, allowing it to carry out its ICO/ITO under existing exemptions in securities law. Source.
09.06.2017 The British Columbia Securities Commission (BCSC) approved Canada’s first registered cryptocurrency investment fund, and acknowledged in a statement that it views cryptocurrency investments as a new and novel” way to invest. The newly-registered Vancouver firm, First Block Capital Inc. will operate its fund in Ontario and British Columbia. Source.
05.25.2017 The Bank of Canada stated that its experiment with blockchain, or distributed ledger technology, showed it is currently not compatible with operating the country's centralized interbank payment systems. Primary Source. Secondary Source.
02.23.2017 The Canadian Securities Administration (CSA) launched a regulatory sandbox for businesses launching new financial products, services and applications. The objects of this new initiative is to support an encourage innovation, according to the CSA Chair and President and CEO of the Autorité des marchés financiers. Source.
08.18.2016 The central bank of Canada published a new working paper suggesting its researchers believe digital currency exchange rates will become less volatile should adoption increase. Source.

The central Bank of Canada’s Senior Deputy Governor, Carolyn Wilkins, expressed the need for radical change in the approach regarding traditional finance and emerging technology at a speech at Toronto’s Rotman School of Management. Concerning disruptive technologies such as distributed ledgers and bitcoin, Wilkins said “[w]e have to envisage a world in which people mostly use e-money, perhaps even one that’s not denominated in the national currency, like Bitcoin.” Source.


The Canadian Standing Senate Committee on Banking, Trade and Commerce released a report calling for limited regulatory control over digital currencies. Source.


Canadian province of Quebec clarifies provincial legislation to specify that virtual currency ATMs and online virtual currency trading platforms in Quebec must obtain licenses under the provincial Money-Services Business Act to operate in the province. Source.


The Canadian central bank released a working paper examining the effects of competition between different cryptocurrencies and the exchanges.  The authors conclude that there is no clear evidence that Bitcoin will keep its dominant position in the market, and that exchanges will be able to coexist and possibly compete on fees. Source.


The Canadian parliament passed a bill amending its money laundering and terrorist financing act.  The act now applies to persons in Canada engaged in the business of dealing in virtual currencies, as well as persons outside of Canada that provide such services to customers in Canada. Source no longer available.


The Canadian Federal Budget included a reference to intended legislation regarding anti-money laundering and anti-terrorist financing that would apply to virtual currencies. Source.


Financial Transactions and Reports Analysis Centre (FinTRAC) reportedly wrote to several prominent Bitcoin exchanges that they are exempt from Canadian money laundering laws. Source.


Canada Revenue Agency says barter transaction rules apply to use of Bitcoin for goods or services and are subject to tax. Also, Bitcoin bought or sold as a commodity is subject to capital gains taxes. Source.


Financial institutions and third-party payment providers are banned from accepting, using, or selling virtual currencies. Although its use remains legal, the People’ s Bank of China has required exchanges to register with the appropriate regulatory authorities and has suggested it will closely watch the markets. The People’s Bank of China has allegedly warned banks from working with virtual currency-related businesses.


China has banned all companies and individuals from raising funds through ICO activities, reiterating that ICOs are considered illegal activity in the country. Several entities including the People’s Bank of China (PBC), the China Securities Regulatory Commission, and the China Insurance Regulatory Commission, issued a joint statement announcing the ban. Source.


The People’s Bank of China (PBOC) announced its plans to increase supervision and regulation of China’s financial services industry, including large online financial businesses in its risk assessment system, the Macro Prudential Assessment (MPA). These business include P2P lenders, third-party online payment platforms, crowdfunding companies, and other financial services. In July, 45 Chinese financial firms agreed to join a payment-clearing platform called Wanglian, which will allow the PBOC to more closely monitor online payments. An internal PBOC memo indicated that all companies should join the platform by the end of June 2018. Primary Source. Secondary Source.


China’s central bank issued a recruitment ad (in Mandarin) published by the bank on Nov. 9 in connection with hiring blockchain experts to help it develop its own digital currency, Based on the information that has been released by the Central Bank, under this digital currency project the Central Bank would still retain control over the country’s money supply. Primary Source. Secondary Source.


The People’s Bank of China (PBOC) is conducting a digital currency study and is reportedly considering issuing its own digital currency. Source.


Reports from a meeting with the People’s Bank of China (PBOC) indicate that PBOC has warned banks to cease doing business with virtual-currency-related businesses. Source.


In wake of 12.5.13 PBOC statement, BTC China no longer accepts yuan. PBOC extends ban on accepting, using, or selling bitcoin to third party payment providers. Bitcoin remains legal, however, for individuals to use but without providers, is effectively impossible. Source.


PBOC says that bitcoin is not currency, that financial institutions and payment institutions cannot be involved in bitcoin-related transactions, websites.exchanges that deal in bitcoin-related services need to register with appropriate regulatory agencies, PBOC will pay close attention to potential uses of bitcoin for money laundering, and PBOC will educate the public about the risks of using, trading, or dealing in bitcoin (specifically, the lack of a central authority that administers or provides redress). Source.


Colombia’s financial regulatory body (SFC) has prohibited banks from working with virtual currency. The SFC and the Central Bank have also indicated that bitcoin is not a currency.


In a press release, the Colombian Central Bank indicates that bitcoin is not a currency, and cannot be used in connection with Colombia’s exchange rate regime. Source.


Colombia’s financial regulatory body issued a resolution prohibiting financial institutions from holding virtual currency. The release also discussed a number of risks associated with virtual currency. Source.

*EU Member

Informal statements by the Croatian National Bank are favorable regarding the legality of bitcoin.


The Croatian National Bank indicated in an informal discussion that the use and sale of virtual currency would not be unlawful in Croatia. Source.

*EU Member

Virtual currencies are not illegal in Cyprus, but Central Bank has warned about their use.


Central Bank acknowledged that virtual currencies are not illegal, but reiterated earlier warnings about their use and exchange. Source.


Central Bank issues warnings like those of the EBA and Bank of France that virtual currencies have no guarantee of reimbursement, are inherently speculative, pose money laundering and other criminal activity risks, and are risky speculative investment vehicles. Source.

Czech Republic*
*EU Memeber

Czech Ministry of Finance has indicated that virtual currency transactions are subject to anti-money-laundering laws and reporting requirements.


A guidance note from the Ministry of Finance of the Czech Republic’s Financial Analytical Unit indicates that purchase and sale of virtual currencies in excess of 1,000 euros is subject to suspicious activities reporting under the Czech Republic’s anti-money-laundering laws. Source.

*EU Member

Financial Supervisory Authority has issued warnings about the risks of virtual currencies, similar to other European nations, and has suggested there may be amendments to regulations regarding virtual currencies. Currently, it does not appear that virtual currencies are regulated, at least under money laundering or financial institution regulations.


The Danish Assessment Board (Skatterådet) gave its ruling on 25 March 2014 in the case of SKM2014.226.SR (published on 1 April 2014).

The board ruled that bitcoins are not considered an official currency for tax and VAT purposes, as bitcoin is not a currency that:

  • Is regulated by the operators on the global currency markets
  • Is subject to regulation by a central bank
  • Can be withdrawn from circulation
  • Is affiliated to a state or currency area

Furthermore, fluctuation in the value of bitcoins is not taxable as gains or losses on currency covered by the Tax Act on Capital Gains and Losses on Debt and Claims. This conclusion is based on the description of the bitcoin system according to which purchase and ownership of bitcoins does not involve a debtor or creditor and, thus, neither a claim nor debt exists for tax purposes. Source.


On March 18, 2014, the Danish Central Bank issued a statement declaring that Bitcoin is not a currency. The Bank went on to explain, “Bitcoin does not have any real trading value compared to gold and silver, and thus is more similar to glass beads. The Danish Central Bank went on to point out that Bitcoins are not protected by any national laws or guarantees, such as a deposit guarantee. Source no longer available.


Chief Legal Advisor to FSA says that most likely development will be to amend existing financial regulations to cover exchanges and to have money laundering regulations cover cryptocurrency transactions. A member of Parliament suggested, however, that this would be done on a European-wide basis, not just in Denmark. Source.


Financial Supervisory Authority (FSA) releases statement re: risks for cryptocurrencies: (1) losing money to exchanges, (2) theft from virtual wallets, (3) might not be able to exchange it for fiat currency, (4) rapid price fluctuation, (5) links to criminal activity and (6) taxes. FSA also provides that cryptocurrencies are not covered by existing regulatory framework for electronic money, currency exchanges, brokerages, or deposit services. They are unregulated electronic money and there is no permission needed to run an exchange there. Source.


Ecuador has banned issuance, promotion, or circulation of virtual currencies, and plans to issue its own digital currency for use as legal tender.


Ecuador has mandated that all banks and “entities of the public, private, and cooperative financial sectors” must accept the country’s digital currency within the next 360 days. Ecuador’s official fiat currency is the U.S. dollar, and the digital currency under Ecuador’s Electronic Currency System will be “equivalent and convertible to US dollars.” Primary Source. Secondary Source. 


Congress reportedly approved legislation to issue a digital currency for use alongside the U.S. dollar, which is currently the only legal tender in Ecuador. A monetary authority will be established to regulate the digital currency, which will be backed by liquid assets. Source.


Ecuador’s Congress reportedly approved extensive reforms to its financial system providing for, among other things, the creation of a digital currency and financial regulation system controlled by the executive. In connection therewith, it reportedly also banned the issuance, promotion or circulation of all digital currencies. Source no longer available.

*EU Member

Informal cautions regarding use of bitcoin in response to email inquiries; bitcoin income is treated as capital gains. 11.06.2017

Estonia agreed to coordinate with fellow Baltic and EU-Member countries Latvia and Lithuania to develop capital markets in the Baltic region, which was memorialized between the ministries of the three countries in a Memorandum of Understanding. The agreement set forth the goals of stimulating investment, creating jobs, supporting economic and social convergence to help absorb economic shocks, all of which will be achieved in part by facilitating cross-border investments and dismantling burdensome investment barriers. Source.


Estonia proposed the launch of its own state-managed cryptocurrency, “estcoin,” which would be launched using an ICO. Estonia has been quick to embrace digital innovation, and was the first country to offer a digital ID to non-Estonians that offers access to banking and other services. However, the European Central Bank (ECB) has been highly critical of Estonia’s plan and indicated that it would not allow any member state to launch its own digital currency. Source.


Estonian Supreme Court Rules Against Bitcoin Trader. The Supreme Court decided to apply extra regulation to Bitcoin trading, including the requirement to meet customers in person as well as the requirement keep IDs of all customers and report those who trade more than 1,000 Euros more per month.. This ruling not only applies to Bitcoin, it applies to all blockchain tokens and assets. Source.


The Estonian Supreme Court asked various government agencies and officials, including the Ministry of Finance, the Interior Ministry, the Estonian Central Bank and the Estonian Financial Supervision Authority, to answer questions regarding the government’s stance on the legality of bitcoin as it considers arguments in a 2014 case filed by the operator of a bitcoin trading company, Although the response was due by January 11, 2016, as of March 21, 2016 the Court has yet to publish its findings. Source.


The Estonian Tax Authority stated that income derived from Bitcoin transactions constitutes capital gain subject to taxation. Source no longer available.


Head of the Estonian central bank payment and settlement system expresses concerns in an email about risks associated with bitcoin, including the nature of the decentralized system and the potential for a Ponzi scheme. Source.


European Banking Authority issued warnings to the public about the risks associated with virtual currencies, and recently indicated it will apply anti-money laundering and anti-terrorist financing rules to virtual currencies.

Member States:

  • Austria
  • Belgium
  • Bulgaria
  • Croatia
  • Cyprus
  • Czech Republic
  • Denmark
  • Estonia
  • Finland
  • France
  • Germany
  • Greece
  • Hungary
  • Ireland
  • Italy
  • Latvia
  • Lithuania
  • Luxembourg
  • Malta
  • Netherlands
  • Poland
  • Portugal
  • Spain
  • Sweden
  • United Kingdom
09.07.2017 The European Central Bank (ECB) President Draghi has rejected Estonia’s plans to launch its own state-run digital currency, “estcoin,” and indicated that the ECB would not allow Estonia or any other EU member state to introduce its own currency. The basis for the criticism is the ECB’s position that cryptocurrencies in general could erode the bank’s control of the supply of money. Source.

EU ministers met in December following the terrorist attacks on Paris and agreed to tighten checks on payment methods used by terrorist organizations. The European Commission is currently conducting a risk assessment on terrorist financing and money laundering, paying particular attention to virtual currencies. Documents recently released indicate the Commission will propose stricter rules involving virtual currencies and prepaid cards by June 2016. Primary Source. Secondary Source.


European Court of Justice ruled that the value-added tax (VAT) will not apply to purchases of bitcoin through exchanges. This ruling flows from a VAT provision for excepts related to currency, bank notes and legal tender. Source.


Europol issued an internet organized crime threat assessment, which examines the various technologies and services used by cybercrime organizations. The assessment includes a discussion of the use of virtual currencies, including Bitcoin, in laundering the proceeds of cybercrimes. Source.


The European Commission indicated that it will impose anti-money laundering and anti-terrorist financing rules on virtual currencies. Source no longer available.


Sweden reportedly asked the European Union to provide definitive rules on the VAT treatment of cryptocurrencies, expressing concern over the inconsistencies in approach among member states. Source.


European Banking Authority (EBA) warns consumers on virtual currencies because (1) consumers can lose value, (2) can be stolen from virtual wallets, (3) EU refund rights do not protect, (4) value can change quickly, (5) can be used for criminal activity, including money laundering, and (6) consumers may be subject to tax liability. Source.


The European Central Bank releases a detailed report regarding virtual currency and its potential for regulation under EU regimes. Source.

Financial Action Task Force


06.2014 FATF issued a report defining key terms associated with virtual currencies and describing the AML and terrorist financing risks associated with them.  The report also provides examples of key law enforcement actions involving virtual currency. Source.

*EU Member

Based on informal interviews, the best indication is that virtual currencies are treated as commodities in Finland. 11.22.2017

Finland’s Financial Supervisory Authority (FSA) issued a warning that initial coin/token offerings (ICOs/ITOs) and cryptocurrencies are risky and highly speculative investments. The FSA warned consumers of the volatile price of bitcoin and other digital currencies citing the European Banking Authority (EBA)’s 2013 publication on the risks of cryptocurrencies. Noting growing interest in ICO/ITOs, the FSA listed several risks associated with token sales, including fraud, loss of capital, price volatility, inadequate information, and technology risks. The FSA also cautioned potential ICO/ITO issuers to be aware of existing regulatory requirements. Source.


The Finnish Central Board of Taxes judged Bitcoin to be a financial service in ruling 034/2014, making Bitcoin exempt under the EU VAT directive. Source.


Bank of Finland says, through interview with head of oversight Paeivi Heikkinene, that Bitcoin is not “currency” or a “payment instrument,” but is “more comparable to a commodity.” Source.


The Finnish Tax Authority released tax interpretations regarding bitcoin, indicating that capital gains treatment would be given to an exchange of bitcoin for another currency, but that losses would not be deductible. Source.


In television interview, Finnish Central Bank says that bitcoins are legal and can be invested in and used however people would like. There are no guarantees, however, that unregulated virtual currencies can be exchanged back into traditional money. Source.

*EU Member

Bank of France has issued warnings similar to other European nations. There were informal indications that France might have been willing to allow virtual currency companies to operate as payment service providers under French law, and France has now indicated it will implement customer identity verification rules for virtual currency platforms.


France has passed new laws to allow banks and fintech companies to create platforms where unlisted securities can be traded instantly. France’s Finance Minister released a statement saying that this will allow for the development of new trading platforms and transactions that are faster, cheaper, more transparent, and safe. Securities listed on exchanges will still need to pass through custodians and clearing houses. Source.


France’s Central Bank (The Banque de France) issued a press release indicating that it has tested the blockchain technology for hypothetical use in the management of SEPA Credit Identifiers, or identification markers used to establish the identity of creditors within the Single Euro payments Area. Source.


The French Senate released a report focusing on the type of regulation the government should apply on bitcoin transactions. and refers to Bitcoin as a type of virtual bartering tool, and calls cryptocurrencies a “long-term trend raising important legal and economic matters, that can no longer be disregarded by public authorities”. Source.


The finance ministry reportedly announced that it plans to implement customer identity verification rules for bitcoin distributors and other platforms by the end of the year. It also reportedly implemented tax rules classifying bitcoins as property subject to capital gains and asset taxes. Source.


Police reportedly shut down a bitcoin exchange operating illegally in France, seizing 388 bitcoins in the process. The site’s operators are reportedly being examined on potential charges of illegal banking, money laundering and operating an illegal gambling website. Source.


The senate committee on finance heard testimony on the issues raised by the development of Bitcoin and other virtual currencies.  The committee concluded that the rise of virtual currencies is a long-term trend that can no longer be disregarded by public authorities.  It further noted that despite its risks, bitcoin offers multiple opportunities for the future and that public authorities should work on a balanced regulatory framework. Source.


The French Ministry of Economy stated that revenue from sales of virtual currency is taxable income. The French Banking Federation indicates that wiring revenue from the sale of virtual currency to a personal bank account may require the bank to file a declaration with the French anti-money-laundering agency. Source.


Bank of France warns about risks associated with virtual currencies: (1) security risks, (2) absence of central regulatory authority, (3) speculation and huge volatility, (4) legal risk, and (5) use of currencies for illegal and illicit activities. Source.

*EU Member

Virtual currencies are financial instruments under German law and, more specifically, are a form of “private money” that can be taxed as capital. Certain uses may also require a license or permit. Earlier guidance from the German financial supervisory authority also suggested virtual currencies are commodities, and are subject to taxation both upon sale of bitcoin and sale of goods in exchange for bitcoin. Germany has not adopted laws specific to ICOs, but ICOs are subject to certain existing regulation.


Germany’s Federal Financial Authority (BaFin) released a statement warning consumers of the risks of initial coin offerings (ICOs). The authority considered ICO/ITOs a highly speculative form on investment not subject to currency market regulations. Source.


The Austrian and German governments are funding a research effort focused on the use of digital currencies in organized crime.: “BitCrime”. The initiative, is split into two sub-projects: (1) the German sub-project, primarily supported by the German Federal Ministry of Education and Research, and (2). the Austrian sub-project, backed primarily by the Austrian Federal Ministry for Transport, Innovation and Technology, the Austrian Institute of Technology, and the Federal Ministries of Finance and the Interior. Source.


The Deutchebank Bundesbank expressed its skepticism about bitcoin and other digital currencies as “trustless” currencies, saying they are not ultimately feasible. Delivering a keynote speech at the Official Monetary and Financial Institutions Forum (OMFIF), a member of the executive board of the Bundesbank indicated that that virtual currencies are a fabrication, by virtue of how they are transferred peer-to-peer, and based on the bank’s opinion that they have no intrinsic value. Source.


The German Ministry of Finance has reportedly published a letter ruling that the commercial sale of bitcoin is a “miscellaneous service.” Retailers accepting bitcoin would be taxed on the sale of goods and upon selling any bitcoins they accept in purchases. Source.


BaFin releases an overview of risks related to virtual currency, and indicates that commercial use of BTC may require licensure and permitting in certain circumstances. Source.


German Finance Ministry says that virtual currency is not e-money or foreign currency but is still a financial instrument under German banking rules. Virtual currency is therefore more akin to “private money” that can be used in “multilateral clearing circles” (suggesting that virtual currency would be taxed as capital). Source.


BaFin (German financial supervisory authority) says that Bitcoins are exempt from definition of e-money because they are not tied to legal tender currency. Instead, it is a commodity subject to taxation. Source.



N/A 10.12.2017

Gibraltar’s legislature published draft legislation, which incorporates distributed ledger technology (DLT) into its existing Financial Services Regulations. The new rules, which are planned to take effect in January 2018, are directed at firms offering blockchain services including cryptocurrency exchanges, but will cover any commercial use of DLT for storing or transmitting value. Under the new framework, a firm offering DLT services would need to apply for a working license, which would be granted provided it conforms to several regulatory standards, including protection of consumer assets, robust cybersecurity, and transparency. Source.


The Gibraltar Stock Exchange (GSE) announced its plan to “fully integrate” the use of blockchain into its operational processes. Details of the plan haven’t been unveiled yet, but the GSE indicated that it has partnered with fintech firm Cyberhub Fintech. Source.


The Bank of Greece has adopted the EBA warnings regarding virtual currencies.


Bank of Greece adopted the EBA’s warnings to consumers regarding virtual currencies. Source.


See Denmark, above; autonomous country but under Kingdom of Denmark

Hong Kong

Informal guidance suggests that regulatory authorities are monitoring virtual currencies, particularly with regard to money laundering. Virtual currency considered a virtual commodity and not legal tender.


The Hong Kong Monetary Authority (HKMA), ,in partnership with the Hong Kong Applied Science and Technology Research Institute (ASTRI). published a white paper on distributed ledger tech. The paper presents blockchain as a tool that “carries enormous potential” depending on the kind of application but highlights that from the regulatory perspective, risks remain. Source.


A senior Hong Kong official indicated, in response to a question submitted during a meeting of the Legislative Council of Hong Kong, that the government does not see a need for legislation that would regulate or ban bitcoin activities. The statement indicated that bitcoins are not a legal tender, and their value is not backed by any physical items, issuers or the real economy. Source.


The Hong Kong Monetary Authority issued a statement warning the public about the risks involved in virtual currency trading after a a bitcoin exchange allegedly stole its clients’ funds. The statement also stated that Bitcoin is a virtual “commodity” and not legal tender. Source.


Secretary for Financial Services and the Treasury says that there are high risks in exchanging, trading, and holding bitcoin; there are no physical currency guarantees; and its value is highly speculative. Also suggested that Hong Kong was monitoring the virtual currency market and was particularly concerned about money laundering. Source.

*EU Member


The National Bank of Hungary has issued warnings similar to those of other countries.



The National Bank of Hungary (MNB) issued a public statement warning citizens who use or invest in cryptocurrencies such as bitcoin, citing their unregulated nature amid increasing instances of high-return investment schemes abusing the cryptocurrency. The warning also reminded users that there is no institution guaranteeing the execution of a transaction or the reimbursement of payment. Source.


National Bank of Hungary warns about the use of virtual currencies, including that they are not issued or guaranteed by a central authority, the possibility of loss of value or theft, their volatility, and the inability to seek recourse or refund. Source no longer available.


Regulates virtual currencies as electronic currency through the Icelandic Exchange Act, which effectively prohibits entities from engaging in the exchange of virtual currency.


Icelandic Exchange Act applies to bitcoin exchanges, and bitcoin is not exempt as a good or service. Therefore, one cannot engage in foreign exchange that involves the electronic currency, bitcoin. Source.



The Indian government does not (yet) regulate cryptocurrency exchanges. Reserve Bank of India has issued warnings to the public about the risks associated with virtual currencies and has suggested it is examining virtual currencies under India’s existing legal framework.



The Indian Supreme Court issued a notice to the central bank and several other agencies asking them to respond to a petition made to the court to regulate bitcoin. The petition called on the Court to make cryptocurrencies accountable to the exchequer, expressing concerns about the untraceablility of digital currency transactions. Source.


The Securities and Exchange Board of India (SEBI) has established a 10-member advisory panel to examine on recent global fintech developments and report on opportunities for the Indian securities market. The goal of the new Committee on Financial and Regulatory Technologies is to help prepare India to adopt fintech solutions and foster innovations within the country. Source.


The Reserve Bank of India's governor and two deputy governors made statements about bitcoin. He indicated that while the technologies have the potential to be disruptive they could also have undesirable consequences if left unchecked. He also acknowledged that the technology can assist financial inclusion, that Cryptocurrency can help alleviate transaction settlement concerns. Source.


Reserve Bank of India issues warnings to customers who buy, sell or trade in virtual currencies about security risks, absence of regulatory authority, speculation and volatility, legal risk, and use of currencies for illegal activities. Also says it is “presently examining” issues associated with using, holding, and trading VCs, including regulations for foreign exchanges and payments systems laws. Source no longer available.


India’s Enforcement Directorate raided the offices a virtual currency exchange, reportedly in response to violations of India’s Foreign Exchange Management Act. Source.


Virtual currencies are not legal tender, and using virtual currencies violates the country’s information and electronic transaction laws and currency laws.


Bank Indonesia issued a statement on virtual currencies stating that these are not considered to be currency or legal payment instruments in Indonesia, and warned the public that the user/owner of bitcoins bears all risks related to their ownership/use. Source no longer available.


Deputy Governor of Indonesian Central Bank says that using bitcoin violates information and electronic transaction laws and currency laws. DG also strongly urged Indonesians not to use bitcoin as a means of payment, and highlighted security risks of bitcoin too. Source.

International Monetary Fund N/A 09.29.2017 At a conference held by the Bank of England, the IMF Managing Director Christine Lagarde spoke about how fintech will change central banking over the next generation, specifically virtual currencies, new models of financial intermediation, and artificial intelligence. Lagarde indicated that the IMF believes virtual currencies like bitcoin pose very little or no challenge to the existing order of central banks and fiat currency based on the position that the underlying technologies are not yet scalable, the currencies are unregulated, and several platforms trading or storing virtual currencies are subject to cybersecurity breaches. Regardless, Largarde cautioned not to dismiss virtual currencies and noted that many, especially developing, countries might see an increase in the use of virtual currencies, rather than adopting the fiat currency of another country, e.g. the U.S. dollar. Source.
Iran Iran intends to implement strict regulations for digital currencies. 12.02.2017 Bucking international sanctions, the High Council of Syberspace in Iran (HCC) announced that it will accept the use of bitcoin but the digital currency will be subject to strict regulation. Source.

*EU Member

The Central Bank of Ireland does not regulate bitcoin.  Ireland’s Revenue Commissioners are monitoring bitcoin for tax-related developments.


Ireland’s Central Bank Chief, Philip Lane, has maintained that blockchain is a large policy challenge. In a speech given in May, he indicated that the central bank is working to establish an internal working group that would focus on researching and advising on fintech developments and how the bank can use technologies like blockchain. Source.


The Central Bank of Ireland was cited by the Minster for Finance as stating that it does not regulate bitcoin or consider it to be legal tender.  The Minister for Finance also referenced a statement by the Revenue Commissioners that they are monitoring development of virtual currency and its tax implications, although they do not believe virtual currency represents a significant risk for tax evasion.  Currently, implications for taxation are varied, as bitcoin has elements both of a commodity and a currency. Source.

Isle of Man

The government intends to put economic infrastructure in place promoting virtual currency businesses, subject to anti-money-laundering requirements.




The Isle of Man has been committed to fostering innovation in its fintech and digital payments sector over the last few years. Regulations remain fairly loose, and the Department of Economic Development has been active in directly investing in local businesses (£4.5 million in 2016). In 2016, the Gambling Supervision Commission (GSC) and Treasury approved regulation to allow digital currencies including bitcoin to be accepted as cash. Primary Source. Secondary Source. Tertiary Source.

The Gambling Supervision Commission Officials weighing regulatory changes that would allow gambling services to accept digital currencies “as if they were cash”. They issued a “public consultation” that was open from 4/26/16 until 05/20/16. Source.


The Isle of Man Department of Economic Development announced plans to run a trial of the first government-owned blockchain project. Source.


Effective April 1, 2015, virtual currency businesses, including those that exchange, sell, buy, or store virtual currency, must comply with the Isle of Man's anti-money laundering laws. Source.


The Isle of Man Department of Economic Development announced that it intends to take action in the coming months to implement a regime that promotes business opportunities in digital currency but also applies appropriate anti-money laundering requirements. Source no longer available.


The Israeli central bank and Finance Ministry has issued warnings to the public about the risks associated with virtual currencies.


Israel's government is set to apply capital gains tax to bitcoin sales, categorizing digital currencies as a type of property. According to a statement published on 12th January, the Israel Tax Authority (ITA) said that it would consider bitcoin and other digital currencies as a kind of intangible asset rather than a foreign currency. Individuals involved in the sale or mining of digital currencies would be subject to business tax rates. Further, any commercial sales of bitcoin or transactions involved with trading are subject to value-added tax (VAT), the agency said. Source.


Central Bank and Finance Ministry warns against the use of virtual currencies, similar to those of the European Banking Authority. It warned that virtual currencies are not legal tender, may be subject to volatility, can be used for money laundering or terrorist financing, and are subject to loss via a technical attacks by hacking. Source no longer available.


Reportedly, the Bank of Israel and the Israel Securities Authorities, and justice and finance ministries are waiting to see how other countries address virtual currencies before taking action. Source.

*EU Member

A law requiring identification of parties in bitcoin transactions has been proposed in the Italian Parliament, but no regulation yet. Virtual currency is not legal tender


The European Parliament is yet to approve the proposed modification of current anti-money laundering laws (AML) that were published in Italy late last month. The modified law, AML4, was introduced in Italy with its publication in the Italian Official Journal of the Legislative Decree 25th May 2017. . The proposed legislation contains numerous articles that directly address cryptocurrencies, in addition to introducing a specific registry for Virtual Currency Exchanges. Primary Source. Secondary Source.


Agenzia delle Entrate, Italy's top tax authority, released new information about its treatment of digital currencies, stating that purchases and sales made with bitcoin remain exempt from VAT. Source.


The Central Bank of Italy issues a directive warning that virtual currency could be used for money laundering and terrorist financing, but that businesses that store and exchange virtual currency for fiat currency, among other virtual currency-related businesses, are not required to comply with AML/KYC requirements. Source.


The Central Bank of Italy issues two directives warning about the use of virtual currency and agreeing with the EBA’s stance that financial institutions should not buy or invest in virtual currency until a formal legal framework is established. Primary Source. Secondary Source.


The attorney general of Rome and an officer of the Italian financial police reportedly warned in separate interviews that Bitcoin could be abused by criminals, and called for regulations to combat criminal activity involving virtual currency. Source.


A law is proposed in the Italian Parliament to require identification of a sender in a transaction involving more than 1,000 euros. Source. 


Japan approved a law regulating Virtual Currencies on May 25, 2016 which was promulgated on June 3, 2016. The law was enacted and came into effect on April 1, 2017.

09.30.2017 The Financial Services Agency (FSA) of Japan granted its first licenses for digital currency exchanges to 11 companies. To obtain a license, companies must meet several strict requirements, including segregating individual customer accounts and strengthening its computer systems. Source.
04.01.2017 On April 1, Japan’s Financial Services Agency enacted a new law authorizing the use of digital currency as a method of payment, essentially granting it the same legal status as any other currency. The law follows months of debate which ultimately brought Bitcoin exchanges under anti-money laundering/know-your-customer rules, and resulted in the categorization of Bitcoin as a kind of prepaid payment instrument. The law will put in place capital requirements for exchanges as well as cybersecurity and operational stipulations. In addition, those exchanges will also be required to conduct employee training programs and submit to annual audits. Source.
02.01.2017 Overview of Japan financial regulations regarding virtual currencies, and payments generally. (Licensing specific issues are summarized in Section 6). Source.

Japan passed a bill that includes amendments to the Payment Services Act (the PSA) and the Act on the Prevention of Transfer of Criminal Proceeds (the "Criminal Proceed Transfer Act"), both of which provide for virtual currency exchange transactions to be regulated by the relevant authorities.

The following persons or entities will fall under the category of a virtual currency exchange operator (VCEO): a person or entity that, in the course of trade, engages in (i) purchases and sales of the virtual currency or exchanges the virtual currency for another virtual currency; (ii) an intermediator or agent of the above transactions; or (iii) custody or safekeeping services in relation to a dealing or broking transaction set forth in (i) or (ii) above. Such person or entity is required to register with the Prime Minister as a VCEO.

A foreign entity that engages in the virtual currency exchange business outside of Japan and does not obtain such registration with the relevant regulator shall be prohibited from making solicitations of the businesses indicated in (i) through (iii) above to a resident in Japan. Further, a VCEO is now categorized as a "Specified Business Operator" under the Criminal Proceed transfer Act. Accordingly, a VCEO is required to confirm the identities of its customers at the time of any transaction and to report any suspicious trading to the relevant authorities. Finally, the amendments left unclear whether the simple purchase of virtual currencies would be subject to Japanese tax. 

The legislation was promulgated on June 3, 2016 and it is expected to be enforced within one year from the promulgation date.

Source no longer available.


On March 3, 2016 Japan first bill regarding cryptocurrencies was submitted to the Diet. The bill (i) provides definitions of Virtual Currency and Virtual Currency Exchange Services, (ii) requires registration of Virtual Currency Exchange Services (iii) sets forth the regulations regarding the business of Virtual Currency Exchange Service Providers, and (iv) imposes certain obligations (including customer identification obligations) by designating Virtual Currency Exchange Service Providers as “specified business operator” within the meaning of the Act on Prevention of Transfer of Criminal Proceeds. Primary Source. Secondary Source.


The Financial Services Agency (FSA) has proposed legislation that would recognize virtual currencies as equal to conventional currencies. If passed, virtual currency companies would be required to register with the FSA. Regulators hope to have the legislation passed before the end of the current Diet session. Source.


Japan’s Liberal Democratic Party reportedly stated that Japan has decided against regulating bitcoin for now, but will continue to assess the possibility of regulation. Source.


Virtual Currencies under threshold amount are subject to “light touch” regulatory scheme.


Authorities in the State Assembly, the legislature of the British Crown dependency of Jersey, published an order on 23rd September, stating that anyone operating as a digital currency exchanger is exempt from registration requirements if their annual turnover is less than £150,000. The order came into force on 26th September. The Jersey legislature also approved a change to the dependency's money laundering statutes, which would apply to digital currency exchangers. The orders reflect the outcome of a consultation process begun last year by Jersey's government. Source.


The States of Jersey government released a regulatory scheme for virtual currency exchangers. As companies grow, regulatory requirements increase, with those companies exceeding 150,000 GBP facing higher reporting and registration requirements. Source.


Virtual currencies are not legal tender in Jordan and the Central Bank has warned against their use. Banks, currency exchanges, financial companies, and payment service providers operating in Jordan are prohibited from dealing in virtual currencies.


Reportedly, the Central Bank of Jordan warned against the use of virtual currencies and said they are not legal tender. The warnings were similar to those issued by other countries: that there is a high risk of devaluation, that their value is highly volatile, that virtual currencies can be used for criminal activities, and that there is a risk of total loss because it is not backed by a central authority. Further, the Central Bank reportedly told all banks, currency exchange companies, financial companies, and payment service providers, that they are prohibited from dealing in virtual currencies. Source.






The Republic of Kazakhstan has agreed to a deal with Astana International Finance Center (AIFC) and Malta-based company EXANTE to develop and promote the cryptocurrency market in Kasakhstan. Source.


Kazakhstan has shown a strong commitment to embrace blockchain technology over the last few years. In 2015, The government has made moves towards regulating cryptocurrencies, in an effort to attract cryptocurrency startups, blockchain businesses, and ICOs. In June 2017, Kazakhstan announced its plans to start selling blockchain-based bonds, seeking to provide investors with a quick and inexpensive way to buy bonds. Source no longer available.

Kyrgyzstan Krygyzstan’s central bank has stated that the use of virtual currency is illegal. 08.26.2014 The central bank issued a press release stating that the only legal tender in Kyrgyzstan is its national currency, the som, and that the use of virtual currency as a means of payment is illegal.  The press release further warns of the risks of holding or transacting in virtual currency. Source no longer available.
*EU Member
N/A 11.06.2017 Latvia agreed to coordinate with fellow Baltic and EU-Member countries Estonia and Lithuania to develop capital markets in the Baltic region, which was memorialized between the ministries of the three countries in a Memorandum of Understanding. The agreement set forth the goals of stimulating investment, creating jobs, supporting economic and social convergence to help absorb economic shocks, all of which will be achieved in part by facilitating cross-border investments and dismantling burdensome investment barriers. Source.


Bank of Lebanon has issued warnings to the public about the risks associated with virtual currencies, and has said that financial institutions and exchanges cannot, be decree, deal in virtual currencies as “e-money.”


Bank of Lebanon has warned about risks of digital currencies, including that transactions made through unregulated networks cannot be guaranteed and losses not recoded; transactions may be irreversible; the currencies are highly speculative and volatile; and can be used for criminal activities. It also reminded financial institutions and exchanges that “e-money” is prohibited by decree. Source.

*EU Member

Central Bank of Lithuania has issued the standard EBA warnings but is holding off on further regulations for now.


Lithuania agreed to coordinate with fellow Baltic and EU-Member countries Estonia and Latvia to develop capital markets in the Baltic region, which was memorialized between the ministries of the three countries in a Memorandum of Understanding. The agreement set forth the goals of stimulating investment, creating jobs, supporting economic and social convergence to help absorb economic shocks, all of which will be achieved in part by facilitating cross-border investments and dismantling burdensome investment barriers. Source.


The Bank of Lithuania published a position paper on virtual currencies and initial coin offerings (ICOs) with guidance for potential organizers of ICOs. The bank reaffirmed its 2014 position, prohibiting banks and financial institutions from transacting with or handling cryptocurrencies. Regarding ICOs, the bank noted that although they are not currently regulated, ICOs involving the sale of coins with features of securities should be subject to Lithuania’s existing securities law. Primary Source. Secondary Source.


Central Bank of Lithuania clarifies that regulation of virtual currencies is under discussion but that it is likely to wait until further action from EU countries before pursuing regulation. Source.


Additional warnings issued regarding virtual currency and fluctuations in value of virtual currency. Source no longer available.


Central Bank of Lithuania adopts the EBA warnings to consumers. Source no longer available.

*EU Member

The issuance of virtual currency is not regulated “from a monetary point of view.” Financial services providers, which could include virtual currency businesses, must receive authorization from the Minister of Finance.



The Luxembourg financial regulatory commission (CSSF) has issued a statement concludes that virtual currencies are not legal tender. It warns that virtual currencies entail risks for their holders, and reminds financial services providers that carrying out activities of the financial sector requires an authorization by the Minister of Finance and subjecting themselves to CSSF supervision. Source.



Virtual currencies were previously not legal tender in Malaysia, but the government will enforce new cryptocurrency regulation soon.



The chairman of Securities Commission Malaysia (SC) said at a finance conference that the SC is working on regulations and guidelines for the use of digital assets and cryptocurrency. The SC is working closely with Bank Negara Malaysia (BNM), the country’s central bank, to draft the potential regulations. The chairman also indicated that the SC is working on a pilot program to research distributed ledger technology. Source.


Central Bank of Malaysia has said that “The bitcoin” is not legal tender in Malaysia, that is does not regulate the operations of bitcoin, and that the public is advised to be cautious of the risks associated with the use of digital currencies. Source no longer available.

*EU Member

Malta’s government is reportedly developing a broad national strategy that will see the government embrace bitcoin and blockchain innovation to promote and adopt the technology.


The Malta Financial Services Authority (MFSA) published draft regulation for collective investment schemes investing in virtual currencies, which would be narrowly applicable to Professional Investor Funds (PIFs) that have investing in virtual currencies as their objective. With the aim of protecting investors and mitigating risk, the MFSA has decided that investing in virtual currencies should be limited to PIFs organized as SICAVs or INVCOs, types of legal entities that are required to have a board of directors responsible for the conduct of the business and collective investment scheme. Source.


Malta’s government is reportedly developing a broad national strategy that will see the government embrace bitcoin and blockchain innovation to promote and adopt the technology. The island nation’s Cabinet has approved the first draft of a national strategy to promote blockchain. The revelation was made by Malta’s Prime Minister Joseph Muscat, speaking at an official financial conference. Source.


Virtual currencies are not legal tender currency, and the Bank of Mexico has warned of risks of using virtual currencies.


Mexico’s Secretariat of Finance and Public Credit clarified its stance on bitcoin, stating that virtual currencies will be included in the prohibitions of article 32 of Mexico’s LFPIORPI, its federal law that is meant to prevent and identify operations transacted with illicit goods. Source no longer available.


The Bank of Mexico has issued a press release warning of the risks of using virtual currencies, which also indicates that virtual currency is not legal tender. The release notes that currently virtual currencies do not currently have significant penetration in Mexico, however, the Bank in coordination with other authorities is monitoring their development and will issue regulations if necessary. Source no longer available.

Morocco The use of cryptocurrencies is outlawed in Morocco. 11.21.2017

Morocco’s foreign exchange authority, the Office des Changes, stated in a press release that transacting with cryptocurrencies within Morocco violates existing regulations. Source.

*EU Member

The Netherlands do not regulate bitcoin under its Act on Financial Supervision, but its national bank has released consumer warnings regarding the use of virtual currency. One court has ruled that it is a “medium of exchange” but not electronic money and another court has classified virtual currency as an “object” subject to seizure.


The Dutch central bank has committed to developing an internal blockchain prototype dubbed "DNBCoin", according to a recent publication. The development signals a desire on the part of the Dutch central bank to explore blockchain tech as an avenue for swapping physical cash with digital replacements. Source.


Based on unofficial statements, the Ministry of Finance is reportedly considering exempting bitcoin transactions from VAT, treating bitcoins similarly to payment instruments. Source.


Dutch prosecutors released a document describing their response to Project ITOM, which involves collaboration between EU and U.S. law enforcement, financial intelligence and monetary agencies to tackle illegal trade on the dark web. The Dutch prosecutors identified cryptocurrencies as one of their priorities for deterrent action, and emphasized the need for law enforcement to be able to obtain more information on Bitcoin transactions. Source.


Courts reportedly ruled that bitcoins are objects, and the public prosecution department can therefore legally seize virtual currency from criminals and place them in its own digital purse. Source.


A district court in a civil suit involving an uncompleted bitcoin transaction between two parties ruled that bitcoin is a medium of exchange that is an acceptable form of payment in the country but that cannot be defined as legal tender, common money, or electronic money. Source no longer available.


The Dutch Central Bank issues additional warnings relating to use of virtual currency, including statements that virtual currencies are not a viable alternative for legal tender. Source.


Virtual currencies such as bitcoins currently do not fall within the scope of the Act on Financial Supervision of the Netherlands, as the Dutch Minister of Finance recently emphasized. Source no longer available.


The Dutch Central Bank released a warning listing risks of usage of virtual currency and stated that it does not supervise virtual currencies. Source.


A transcript of a question and answer section with the Dutch Minister of Finance regarding risks of using bitcoin. The Q&A indicates that bitcoin is not a financial product for the purposes of the Act on Financial Supervision and that bitcoin transactions are taxable on an as-converted to legal tender basis. Source.

New Zealand

Informal warnings about the risks associated with virtual currencies; suggestion from Commerce Commission that virtual currency may be regulated.


New Zealand’s Financial Markets Authority (FMA) published commentary on initial coin offerings (ICOs) and cryptocurrency services to supplement its online resources for investors. The FMA indicated that the specific characteristics and economic substance of an ICO determine whether the coins/tokens offered are a financial product and how (or if) it should be regulated. With respect to cryptocurrency services generally, the FMA set forth the legal obligations business offering services including crypto exchanges, wallets, and brokering: (1) Must be a member of a dispute resolution plan; (2) Must be on the Financial Services Providers Register; (3) Must comply with fair dealing provisions in the Financial Markets Conduct Act. Source.


The Deputy Governor of New Zealand's Reserve Bank (RBNZ) reportedly likened Bitcoin to a commodity rather than a realistic cash substitute, and stated that a change in regulatory approach was needed to manage the increased operational risk caused by the rise of online and mobile payments. Source.


Reserve Bank of New Zealand Gov. John McDermott warned people to “tread carefully” because of supply, controls, and monitoring. Also warned of risks from volatility in pricing and speculation. Source.


New Zealand’s Commerce Commission reported as stating that bitcoin is covered by New Zealand’s Fair Trading Act and Commerce Act. Source.



Indications are that virtual currencies are not “money” or “currency” but are assets subject to capital gains taxes.



Following a recent European Court of Justice ruling, the Directorate of the Norwegian Ministry of Finance reviewed its position on the applicability of VAT exemptions to Bitcoin, and recently concluded that services relating to the exchange of Bitcoin are covered by the VAT Act’s exemption for financial services. Source.


Norwegian Director of General Taxation says that virtual currencies are not “money” or “currency” (a widely accepted and agreed upon method of exchange for goods and services). Virtual currencies are, however, assets subject to capital gains taxes. Source.


Exchanges are not regulated by the Philippines Central Bank or other regulatory authorities in the country.


The Philippines Government has been moving towards legalizing and regulating digital currencies, which would be deemed securities and placed under the supervision of the Philippines Securities and Exchange Commission (PhSEC). The PhSEC and the Bangko Sentral ng Pilipinas (BSP) have been in discussions about the potential legalization and scope of the regulation. This follows the BSP’s granting an Electronic Money Issuer license in November 2017 to a major bitcoin exchange based in the Philippines. Source.


Establishing itself as one of the first governments in Southeast Asia to formally regulate digital currency, the Bangko Sentral ng Pilipinas (BSP) issued Circular No. 944, regulating digital currency exchanges as remittance and transfer companies. Digital currency exchanges must obtain a Certificate of Registration (COR) and comply with annual filing and reporting obligations. The regulatory framework requires digital currency companies to implement appropriate risk management and security controls, and restricts “pay-outs” greater than $10,000 to checks and direct deposit. Source.


The Central Bank of the Philippines has issued a press release describing virtual currencies and the risks of buying, holding or trading virtual currencies. The release indicates that the Central Bank is monitoring developments and may adopt appropriate regulatory measures as needed. Source.


Virtual currencies are not illegal, but are also not legal tender. They are subject to capital gains taxes and value-added tax.


Poland’s Financial Ombudsman has called on the country’s Ministry of Finance to regulate the local cryptocurrency industry, claiming that as Poland’s cryptocurrency market is experiencing rapid growth, it should be subject to regulations that would protect customers of cryptocurrency exchanges. The appeal urged the Finance Ministry to evaluate and compare the best practices from those countries that have regulated cryptocurrencies, and implement the best instruments. Source.


Poland’s Central Statistical Office (GUS) has recognized the trading and mining of virtual currencies as an official economic activity. As a result, companies active in the industry will now be able to register with the agency. The development marks a significant advance for industry players in Poland where, to date, the state has not issued any specific legislation that regulates bitcoin and other virtual currencies. Source.


A draft bill introduced in Poland aims to create a create a Central Database of Accounts to be maintained by the Ministry of Finance, which would provide authorities rapid and easy access to information on the locations of certain funds and other liquid assets. The draft bill would apply to banks, credit unions, payment services providers, and “entities that offer products or services that enable storage of authentication data required to access virtual currencies,” Covered entities would be required to notify authorities within 24 hours of the opening or closing of an account, or a change to account information, with penalties of up to PLN 1.5 million or up to three years in prison. The bill marks Poland’s first attempt at regulating the digital currencies market.  Source no longer available.


The Polish Ministry of Finance concluded that, while virtual currencies are not subject to any separate regulation under Polish legislation, and while their use in Poland is fully legal, they are subject to income tax. Source.


Poland's Ministry of Digital Affairs announced an expansive digitization plan which seeks to promote digital public services, the development of cashless solutions and the implementation of electronic identification (eID). Source.


The deputy finance minister reportedly released a statement that options and futures contracts based on bitcoin can be considered as financial instruments.  The statement also concluded that Bitcoin is not legal tender in Poland or elsewhere. Source.


The Lodz provincial office of the Polish Tax Administration issued an opinion stating that the sale of mined bitcoins is subject to Polish value-added tax of 23%, based on the rationale that bitcoin mining is a service with a set service fee, and mined bitcoins will be subject to VAT as a result. Source.


Ministry of Finance announces that it does not consider bitcoin illegal, although it is not a legal currency either. Also clarified that profits from virtual currencies are subject to taxation as gains. Source.

*EU Member

Warnings from the Bank of Portugal about the risks of virtual currency, while clarifying that the Bank does not regulate bitcoin.


The Ministry of Finance has proposed amendments to the criminal code that would result in prison terms for those found guilty of converting virtual currencies into rubles. Primary Source. Secondary Source. Tertiary Source.


The Bank of Portugal issued a consumer alert warning of the risks of use of virtual currencies such as Bitcoin. The warning states that virtual currencies are not safe, and cautions that users bear the risks of using virtual currencies due to their lack of legal tender status and consumer protection regulation. Source no longer available.


The Bank of Portugal issued a press release highlighting the risks of using bitcoin and stating that the Bank of Portugal does not oversee or supervise the issuance or use of bitcoin.  The Bank concluded the release by indicating that banks are aware of the need to monitor and may eventually recognize and act on bitcoin. Source no longer available.


Digital currencies were previously banned as money surrogates under federal law, however, 2017 has seen a softening of Russia’s regulation of cryptocurrency. Plans to regulate cryptocurrency have made headway, and procedures for buying cryptocurrency are scheduled to be announced by the end of 2017.


Deputy Finance Minister of Russia Aleksey Moiseev indicated that the Russian government is working on laws to regulate digital currencies, but proposed that mining of digital currencies will become illegal. Criminal penalties could be applied in cases of financial pyramid schemes or tax evasion, but Moiseev clarified that most penalties would be administrative. Source.


Russian President Vladimir Putin directed his government and the Central Bank to issue an official cryptocurrency, the “cryptoruble.” The cryptocurrency would be legal tender within Russian and subject to taxation. A minister speaking about the directive noted that the digital ruble cannot be mined, and the issuance of the cryptoruble does not signal an endorsement or legalization of other decentralized cryptocurrencies like bitcoin. Source.

09.08.2017 Russia’s finance ministry announced that it wants to regulate cryptocurrency transactions that involve Russian citizens and companies. Acknowledging the global market of cryptocurrencies, Finance Minister Anton Siluanov indicated that the ministry does not intend to ban cryptocurrency outright. By the end of 2017, the finance ministry is due to finish a law that would set forth a procedure for buying cryptocurrency, which includes registration of potential buyers. The ministry indicated that it plans to regulate sales of cryptocurrency in a similar fashion to securities, but it did not explain what criteria would be used to establish which cryptocurrency transactions would fall under the purview of securities law. Source.

Russia's government is said to be moving ahead with plans to introduce rules for blockchain use by 2019. According to state-owned news service TASS, the disclosure came from a report from the Ministry of Communications, which was not publicly accessible. TASS reports that the documents touch on "the adoption of legal acts" related to blockchain, positing 2019 as the time frame for the update. Source.

04.13.2017 A Russian central bank official indicated that it was “too early” to discuss legally recognizing bitcoin. According to the state-run news agency TASS, 2018 would see some kind of regulatory position emerge from Russia's government, though discussions remain ongoing as to what that position might be. Source.

Russian bitcoin ban faces an uncertain future after a draft of the bill was withdrawn. The bill – popularly known as the "Russian bitcoin ban" – received some negative feedback after the Justice Ministry is said to have objected to the bill on the grounds that its comments were not incorporated. The national legislature, the Duma, has been deliberating the bill since earlier this year. Source.


The Finance Ministry in Moscow is planning to submit legislation next month which would punish those using digital currencies. The proposed legislation would prohibit the issuance of digital currencies, as well as their use in exchange for goods and services in Russia. The range of penalties is commensurate with the level of usage. Russia joins Bolivia, Iceland, and Vietnam in taking steps to criminalize digital currency use. Source.


Lawmakers submitted a new draft bill to Russia’s legislative assembly, the Duma, proposing a ban on virtual currencies. The law would impose imprisonment and civil penalties ranging from $265 to $66,000 for those who violate the law. The bill prohibits “malevolent issuance of money surrogates,” which may include miners as well as exchangers, “assistance in money surrogates circulation,” which captures virtual currency wallets, and “circulation of money surrogates” which includes those who purchase goods and services using virtual currency. The bill goes so far as to prohibit advertising virtual currencies in mainstream media and online, by prohibiting “intended distribution of information sufficient and necessary for issuance of money surrogates in media and information and communications networks.” Source.


Deputy Finance Minister Alexey Moiseev expressed support and appreciation for blockchain technology, while maintaining the Ministry’s stance on bitcoin as a danger to the banking system. The Ministry of Finance seeks to criminalize bitcoin conversions through a proposed draft law that would subject those who convert the virtual currency to up to four years in prison. Source.


The Ministry of Finance revised its proposed legislation banning virtual currency activity, reducing the applicable fines by approximately 20-50%. Source.


Deputy Finance Minister reportedly announced that a law will be passed by next spring banning transactions in virtual currencies. The law will reportedly provide for criminal penalties against miners of virtual currency, and ban access to exchanges and online stores accepting bitcoin. Source.


The finance ministry is reportedly preparing a bill prohibiting transactions with “money substitutes,” including cryptocurrency. The ministry reportedly believes that virtual currencies are attractive to the shadow economy due to their lack of regulation. Source.


Central Bank of Russia says that, under existing regulations, virtual currencies are a money surrogate, not an official currency, and are prohibited. Entities that use or exchanges that trade in virtual currencies will be subject to suspicion based on the potential use of virtual currencies for money laundering or other criminal activities. Source.


Former economy minister and current chief of state-run OAO Sberbank Herman Gref says that banning virtual currencies in Russia would be a “colossal step backward” and had sent letter to the Kremlin, central bank, and Finance Ministry regarding the same. Source.


The Security Committee in the lower house of parliament, the State Duma, approved a draft counterterrorism bill that included restrictions on anonymous transactions, including virtual currencies. Source.

Saudi Arabia N/A 10.08.2017

The governor of the Saudi Arabian Monetary Authority (SAMA) said in a press conference that the authority plans to launch a digital currency through a pilot project. The digital currency would only be available to be traded among banks; the governor ruled out plans to issue a digital currency for use by individuals and companies. Source.

Senegal Senegal is a member if the West African Economic Monetary Union (WAEMU). The Banque Centrale des Etats de l’Afrique de l’Ouest (BCEAO), is the Central Bank of the WAEMU. The countries that are members of this union are Benin, Burkina, Fasco, Cote d’lvoire, Guinea-Bissau, Mali, Niger, Senegal and Togo. 11.06.2016

Banque Régionale de Marchés (BRM) announced that it partnered with eCurrency Mint Limited (eCurrency) to provide a digital currency in the WAEMU. BRM will issue the digital tender, eCFA, in compliance with e-money regulations of BCEAO. The eCFAs will be transacted across all existing payment platforms and will be equivalent to physical legal tender. The eCFA distribution will begin in Senegal and will be extended in a second phase to Cote d’Ivoire, Benin, Burkina Faso, Mali, Niger, Togo and Guinea- Bissau. Source.

Serbia Warning from the National Bank of Serbia that Bitcoin is not legal tender and cannot be subject to sale and purchase by banks and licensed exchange dealers. Warning that lack of legal protections over Bitcoin constitutes a risk and may result in financial losses. 10.02.2014

The National Bank of Serbia issued a statement that Bitcoin is not legal tender in Serbia or any other country, and cannot be subject to sale and purchase by banks and licensed exchange dealers. The statement further warns that due to the lack of legal protections, investing in bitcoin and other similar virtual currencies not issued or backed by a central bank constitutes a risk and may result in financial losses. Source.


Virtual currencies are not “money” or “currency.” However, virtual currency businesses may be subject to anti-money-laundering regulations. Informal reporting suggests that virtual currency sales are taxed as income, investments are taxed as capital gains, and may be subject to goods and services tax.


The Monetary Authority of Singapore (MAS) published a consultation paper proposing legislation for payment services. The proposed bill would expand the scope of regulation to include the purchase and sale of virtual currencies and other innovations used in domestic money transfers and merchant transactions via point-of-sale or online payment gateways. Specifically, payment firms will only need to hold one license under a single regulatory framework to conduct payment activities, and only certain payment activities will require licensing. The MAS indicated its commitment to ensuring that new legislation is not overly burdensome, noting that the bill will not apply a one-size-fits-all to all payment service providers, but will differentiate in how regulatory requirements apply based on the potential risks of specific payment activities.

The new legislation would be incorporated into Singapore’s existing laws on payment services, the 2006 Money-Changing and Remittance Businesses Act. The draft is the second of its kind, and was amended following feedback received from the first consultation paper. The current paper is available for comment until January 8, 2018. Source.


Deputy Prime Minster Shanmugaratnam of the Monetary Authority of Singapore (MAS) responded to questions from Parliament on the topic of regulating cryptocurrencies and initial coin offerings (ICOs). Noting that virtual currencies themselves are not regulated, the DPM clarified that the MAS regulates activities involving the use of cryptocurrencies and updated legislation will be introduced expanding and streamlining the scope of existing laws. With respect to ICOs, he indicated that the MAS has not issued new specific legislation but continues to monitor the development of coin/token offerings in the event that additional targeted legislation becomes necessary. Source.


The Monetary Authority of Singapore announced that it plans to regulate initial coin offerings (ICOs) that it deems to be securities, based on an analysis of facts and circumstances. This is a departure from Singapore’s ICO-friendly position, where regulators previously stated that they do not consider token sales to be securities. Source.


The Monetary Authority of Singapore announced the development of a blockchain proof-of-concept pilot project that will facilitate inter-bank payments, globally. The project aims to develop a payment system that will enable banks to transact between global markets at any hour, with instant transfer of funds between participants. Source.


The central bank of Singapore has proposed a new regulatory framework for payments providers in the city-state, a move that would bring digital currency exchanges under its oversight. The proposed framework would require applicable companies to obtain a license from the Monetary Authority of Singapore (MAS), and divides payment activities into several categories. Digital currency exchanges would be covered by a provision overseeing startups that provide "money transmissions and conversion services." Source.


Monetary Authority of Singapore states that it will regulate virtual currency intermediaries to address money laundering and terrorist financing risks. Planned regulations include requirements to verify customer identities and reporting suspicious transactions. Source no longer available.


Inland Revenue Authority of Singapore (IRAS) reportedly  responds to request about taxation. Companies will be taxed on income based on virtual currency sales. When used as an investment, taxed as capital gains. Further, GST could vary depending on the level of services. Reminded that virtual currencies are not “money” or “currency” so they are a good or service for taxation. Source.


Monetary Authority of Singapore cautions consumers regarding risks of trading in bitcoin. Source no longer available.


Bank of Slovenia has issued warnings to the public about the risks associated with virtual currencies.  Slovenia has also indicated that certain activities, including mining, would be subject to taxation.


The Slovenian Ministry of Finance indicated that individuals selling bitcoin for capital gains would not pay income tax, but bitcoin miners would pay income tax.  Overall, Slovenia intends to review bitcoin taxation on a case-by-case basis. Source.


Bank of Slovenia reiterated EBA warnings about virtual currencies: (1) can lose money, (2) money may be stolen from virtual wallet, (3) EU refund rights do not protect when VC for payment, (4) value can change quickly, (5) can be used for criminal activity, including money laundering, and (6) consumers may be subject to tax liability. Source no longer available.

South Africa

South African Reserve Bank has warned that virtual currencies have no legal status and are subject to lack of security, may lose value, and may not be convertible to legal tender.


South African Town of Orania plans to create a digital version of its existing currency, which will be in circulation within a year, as early as mid-August 2017. The “e-ora” would be a crypto version of the current ora, which is not a true currency in itself, but functions as a voucher pegged to the South African rand. Users will be able to buy e-ora from the central bank via an app and can spend e-ora locally using smartphones. Source.


South Africa’s central bank is “open” to cryptocurrencies and blockchain, according to new statements from its governor. Governor Lesetja Kganyago indicated that the South African Reserve Bank is exploring the technology and interested in innovations that may stem from its development. The remarks suggest a greater degree of interest on the part of the central bank in the technology, coming less than two years after it released a position paper on digital currencies. Source no longer available.


South African Reserve Bank issues warning similar to those of other countries that virtual currencies have no legal statute and cannot guarantee “security, convertibility, or value.” Source.

South Korea

Virtual currencies are not legal currency, are volatile and risky, and have no intrinsic value.


Korea’s Financial Services Commission has issued a ban on the trading of bitcoin futures, prompting several securities firms to cancel seminars scheduled in December for bitcoin futures investors. The Korean government has indicated that it will not ban bitcoin exchanges outright, but that ICOs and futures trading will remain subject to the ban. Source.


A lawmaker in South Korea is pushing for more regulation for digital currency. The representative proposed an amendment to the existing Electronic Financial Transaction Act, which would classify digital currency businesses as digital currency traders, brokers, issuers, and managers. Source.


Financial regulators in South Korea launched a new digital currency task force, with the goal to introduce new regulations for exchange. Source no longer available.


Ministry of Strategy and Finance, Bank of Korea, Financial Services Commission, and Financial Supervisory Service said that “cyber currency” is not a “real legal currency” and does not meet the standard regulations governing currency transactions, either via the Internet or commercial institutions. Also warned about the high volatility in the value of bitcoin, and about its lack of intrinsic value. Source.

*EU Member

Virtual currencies are reportedly taxable as an electronic payment system under gambling law, but its treatment under other areas of law is unclear.


Following its independence referendum, Catalonia is working with fintech experts based in Estonia to create an e-residency program and develop a new digital currency exclusively for the region. Despite Spain’s continued efforts to maintain legal control over Catalonia, the Catalan government intends for the new digital currency to be free of regulatory control from Spain and the European Central Bank. Source.


The Ministry of Treasury confirmed that cryptocurrency is exempt from VAT in Spain. Source.


Ministry of Treasury and General Government reportedly issued a ruling that it will treat Bitcoin as an electronic payment system for purposes of gambling law. It is unclear whether the Ministry’s interpretation is applicable to other areas of laws. Source.

*EU Member

Informal statement from a tax official suggests that virtual currencies are not currencies in Sweden but instead will be treated as assets.


Sweden's central bank is considering the possibility of issuing its own digital currency, though the exact technology it will use is yet to be determined. The Riksbank said it is facing pressure to make the switch following a decline in domestic cash use. With the news, Sweden becomes the latest nation to see its central bank consider a digital currency, a process that for most has included at least some exploration of blockchain-based digital currencies. Source no longer available.


Sweden announced that it will treat income generated from certain bitcoin mining activity as income from employment. Source.


The Swedish central bank published an article in its biannual economic review journal describing Bitcoin and other virtual currencies, their benefits and risks, use in Sweden and future outlook. Source.


The Swedish Central Bank issued a commentary analyzing whether virtual currencies have affected the retail payments market, which noted that there are significant risks associated with virtual currency, as it is not subject to regulation. Source.


Swedish Tax Agency official says that Sweden is likely to view virtual currencies as an asset, like art or antiques, and not a currency. Source.


Swiss financial regulator has defined licensing requirements for bitcoin kiosk operators and said that virtual currency platforms are subject to anti-money laundering act, but other regulation unlikely because virtual currencies are perceived as a marginal phenomenon.


Switzerland’s Financial Market Supervisory Authority (FINMA) issued guidance on the increase in initial coin offerings (ICOs) within the country. Additionally, FINMA is investigating several ICOs to determine whether the issuers of those ICOs violated current regulations. Source.


The Swiss Federal Department of Finance (FDF) outlined its plan to regulate fintech with the aim of introducing draft legislation to parliament by mid-2017 after a public consultation. The plan’s stated aim was to help the country draw in more fintech companies by virtue of an accommodative stance aimed to reduce barriers to market entry for fintech firms. Source.


The Swiss Federal Tax Administration confirmed that bitcoin is exempt from Value Added Tax (VAT) in Switzerland. Source.


The Swiss federal council issued a report on virtual currencies examining the economic significance, legal treatment and risks of virtual currencies. The report concludes that there is no present need for legislative measures to be taken given that virtual currencies are a marginal phenomenon and many of their applications are covered by existing financial, criminal and contract laws. Source.


The Swiss Financial Market Supervisory Authority issued a fact sheet clarifying that the purchase and sale of bitcoins on a commercial basis, and the operation of trading platforms used to transfer money or bitcoins from a platform’s users to other users, are subject to Switzerland’s anti-money laundering act.  Notably however, a banking license is required by providers who accept bitcoins from clients and administer bitcoin holdings for clients. Source no longer available.


The Swiss financial market regulator gave its approval for a bitcoin kiosk operator to operate a kiosk network, two weeks after delaying the launch of a different bitcoin kiosk. The regulator’s response also set forth the money transmitter licensing and self-regulatory organization membership requirements for operating a Bitcoin kiosk network in Switzerland. Source.


Central Bank and Financial Supervisory Commission warned that virtual currencies are not currencies, but commodities and have no legal protection. Both plan to regulate virtual currencies.


The executive branch of the Government of Taiwan has approved a draft of the Financial Technology Innovative Experimentation Act. The Act would establish a regulatory sandbox for fintech firms to test new financial products in the pilot stage. Source.


The Financial Supervisory Commission (FSC) released a statement to CoinDesk reiterating an earlier statement defining bitcoin as a “virtual commodity” and refusing to acknowledge it as a currency. The FSC stated “At the end of 2013, the Central Bank of the Republic of China and the FSC has [sic] released a joint statement that defines Bitcoin as a 'virtual commodity'. Considering the non-currency nature and risk of Bitcoin, the FSC has required banks in Taiwan not to receive or exchange Bitcoin. At present, the FSC’s position on this issue remains the same as before." Source.


Taiwan’s Financial Supervisory Commission Chairman recently stated at a legislative hearing the opinion that virtual currencies were illegal. Commission plans to work with the Central Bank to regulate virtual currencies. Source.


Central Bank and Financial Supervisory Commission warned against use because virtual currencies do not have legal protection. Suggested they may regulate virtual currencies if country financial institutions begin to engage with virtual currencies. Source.


Thai law probably does not regulate virtual currencies, but that does not mean that exchanges are free to operate in Thailand.


A senior director of the Bank of Thailand reportedly stated that a company providing bitcoin exchange against the baht does not require approval or a license from the central bank. However, exchanging bitcoin for foreign currency would require an operating license granted by the central bank. The official also stated that exchanges also have to comply with related commercial, consumer and anti-money laundering laws. Source.


Reportedly, the Bank of Thailand concluded that Thai law does not regulate virtual currencies, but that exchanges still cannot operate to the extent that they cannot prevent virtual currencies from being exchanged for currencies other than the baht. Source.


Bank of Thailand reportedly said, in a meeting with a Bitcoin company, that there is an absence of applicable laws and capital controls and that, buying or selling bitcoin, buying or selling goods or service for bitcoin, or receiving bitcoin from outside Thailand is illegal. Source.


The Central Bank of Tunisia exerts, on the State's behalf, the exclusive privilege of issuing on the territory of the Republic bearer banknotes and metal coins which are the only legal tender in the country.

It is illegal to import or export Tunisian dinars. As a result, many converting ATMs exist throughout the country for tourists.

The currency for Tunisia is the Dinar. The Dinar is the official currency of several countries including Libya, Algeria, Iraq, Jordan, and Tunisia. The common currency symbol for the Tunisian Dinar is TD.


Tunisia has been reported to be replacing its self-created eDinar digital currency with a blockchain-based version, making it the world’s first country to issue national currency using advanced blockchain technology. Source.


Tunisia agreed to become the first nation to offer its national currency for transmittance through cryptographic technology. Primary Source. Secondary Source.


Turkey’s recently enacted law on payment services and electronic money does not apply to bitcoin.


Turkey’s Banking Regulation and Supervision Agency announced in a press release that bitcoin is not covered by Turkey’s “Law on Payment and Securities Reconciliation Systems, Payment Services and Electronic Money Institutions” and is therefore not subject to regulation under the Law. The Agency cautioned bitcoin users about risks associated with volatility and anonymity within the bitcoin system. No apparent changes in this position as of April 2015. Source.

United Arab Emirates

The UAE’s recently enacted regulatory framework on Stored Values and Electronic Payment Systems does not apply to bitcoin.


On January 1, 2017, the Central Bank of the UAE issued a Regulatory Framework for Stored Values and Electronic Payment Systems, prohibiting “all Virtual Currencies (and any transactions thereof). The Central Bank of the United Arab Emirates (UAE) has clarified its past statements about a prohibition on “virtual currencies”, confirming that rules released last month do not apply to bitcoin. Caution is advised until a formal statement is released by the Central Bank. Source.

United Kingdom*
*EU Member

Reportedly, exchanges do not have to register under money laundering regulations. Virtual currencies are taxed under goods and services taxes based on profits from a sale. The UK is planning stricter regulations on Bitcoin.


The Financial Conduct Authority in the UK published a warning to consumers about the risks of investing in cryptocurrency contracts-for-differences. The risks include (1) price volatility; (2) leverage, potential multiplying the losses of the investor; (3) fees); and (4) lack of price transparency. Investors are protected by FCA regulation, which required that firms offering CFDs be authorized and supervised by the FCA; individual complaints can be referred to the FCA’s ombudsman; and eligible consumers have access to the Financial Services Compensation Scheme. Source.

10.27.2017 The UK Parliament is discussing amendments to the European Union’s current Anti-Money Laundering Directive, which would include cryptocurrency. The proposed amendments would bring digital currency exchange platforms and custodian wallet providers under the purview of existing legislation. Discussions for amendments are expected to run through the end of 2017/early 2018. Source.
07.25.2017 The London Stock Exchange announced its partnership with IBM to adopt a blockchain model to digitize securities certificate data. Small private European companies will be able to interact with shareholders and vice versa. Source.

The Governor of the Bank of England stated that the fintech sector did not need the same level of regulations as banks. Britain has seen a large boom of business from fintech firms, which employ more than 60,000 people there and is a business worth nearly 7 billion pounds (for companies providing services like contactless payments, banking apps and online crowd sourcing). Source.


The UK’s government-owned Royal Mint plans to use blockchain technology to operate a new gold-trading system. The Royal Mint is working to put $1 billion worth of gold on a blockchain sometime next year to allow customers to own and trade fractions of gold, stored in the Royal Mint’s vaults, using a digital token called Royal Mint Gold (RMG). Each RMG holds the value of one gram of gold. Source.


Light touch regulation of virtual currency exchanges have come into effect on the autonomous island of Jersey in the UK. The new laws make virtual currency exchange a supervised business and require exchange businesses with an annual turnover threshold of £150,000 or more to register with the Jersey Financial Services Commission (JFSC). Digital currency service providers will be sanctioned if they fail to register within three months of crossing that threshold. Source.


The UK Treasury published a report last week describing the government’s plans to stop money laundering and terrorist financing risks. As part of the plans, the government will implement AML regulation. However, it will not seek to impose these AML regulations on virtual currency wallet providers. Source.


The UK Treasury published a risk assessment in October 2015 of money laundering and terrorist financing. According to the report, the majority of the illicit transactions involving virtual currencies involve online markets and the sale and purchase of controlled substances and firearms, rather than terrorism and money laundering. The report noted that “[t]here is little evidence to indicate that the use of digital currencies has been incorporated into established money laundering techniques […] [and] little evidence to indicate that the use of digital currencies has been adopted by criminals involved in terrorist financing.” Source.


In a Treasury report released in late March, the UK Government announced plans to regulate bitcoin exchanges with anti-money laundering regulations, while at the same time committing significant funds to research and study of Bitcoin technology. Source.


Bank of England issued a report assessing the macroeconomic effects of digital currencies. The report concludes that digital currencies do not currently pose a material risk to monetary or financial stability in the U.K. Source no longer available.


HMRC reportedly considering categorizing virtual currencies as a “private currency,” which would eliminate profits taxes. Source.


HMRC reportedly wrote to FYB-UK that there is no requirement for an exchange to register under UK money laundering regulations. Source.


Her Majesty’s Revenue & Customs (HMRC) says that digital currencies are covered by the UK tax system and, when used to pay someone for goods and services, the profits are taxable. Source.

United States

Please refer to the Perkins Coie Virtual Currency Report for analysis of U.S. law.





Virtual currencies are not money nor legal tender in Vietnam and the State Bank of Vietnam warns against investing in, holding, or transacting in virtual currencies.



Venezuela has launched its own digital currency, the “petro”, backed by oil, gas, gold and diamond reserves. President Nicolas Maduro announced the launch, which he said would Help Venezuela advance its sovereignty and overcome the burdens of global economic sanctions. Source.


State Bank of Vietnam recommends not investing in, holding, or transacting in virtual currencies because of harm and risks of use for criminal purposes, lack of technical security and vulnerability to hacking, price volatility, and lack of a central government authority. It also determined that virtual currencies are not money nor are they a form of legal payment in Vietnam. Source.