From ban to regulation: a comparative analysis of Ghana’s 2025 Virtual Asset Service Providers Act and US anti-money laundering frameworks

Abstract

Purpose This paper aims to compare Ghana’s Virtual Asset Service Providers Act, 2025 (Act 1154), with the USA’s anti-money laundering (AML) framework for virtual assets. It asks whether a unified statute can give an emerging economy advantages over a fragmented, path-dependent regime. Design/methodology/approach The study uses functional and institutional comparative legal analysis. It reviews statutes, supervisory notices, sandbox materials and enforcement documents through a six-dimensional matrix mapped to Financial Action Task Force Recommendations 10, 12, 15, 16, 20, 26, 27 and 35. Findings Ghana’s Act offers statutory coherence, and early implementation steps show movement beyond a purely prospective regime. However, enforcement capacity for virtual asset service providers (VASPs) is still developing. The US framework is institutionally fragmented yet operationally mature. Ghana’s licensing model more closely resembles a banking charter than a money services business (MSB) registration, increasing demands on supervisory expertise, verification systems and technical infrastructure. Both frameworks also leave gaps around decentralized finance. Research limitations/implications Implementing regulations remain incomplete and Ghana does not yet have a mature enforcement record specific to VASPs. The analysis, therefore, combines legal design with early operational evidence rather than a full account of law in action. Practical implications Emerging-economy regulators need more than statutory clarity; they need credible supervisory capacity. VASPs in Ghana should expect operational requirements to evolve as implementation matures. Originality/value The paper offers an early comparative analysis of Ghana’s Act and contributes to debates on regulatory leapfrogging, implementation gaps and compliance capacity in the Global South.