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

Daniel Commey, Edem Kojo Amenyo and Vida Commey

Journal of Money Laundering Control, 2026, vol. 29, issue 6, 225-243

Abstract: PurposeThis 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/approachThe 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.FindingsGhana’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/implicationsImplementing 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 implicationsEmerging-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/valueThe 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.

Keywords: Ghana; Implementation gap; Anti-money laundering; Regulatory leapfrogging; Virtual asset regulation; Virtual asset service providers (search for similar items in EconPapers)
Date: 2026
References: Add references at CitEc
Citations:

Downloads: (external link)
https://www.emerald.com/jmlc/article/29/6/225/1384 ... parative-analysis-of (text/html)
https://www.emerald.com/jmlc/article-pdf/29/6/225/ ... c-12-2025-0247en.pdf (application/pdf)

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:eme:jmlcpp:jmlc-12-2025-0247

DOI: 10.1108/JMLC-12-2025-0247

Access Statistics for this article

Journal of Money Laundering Control is currently edited by Dr Paul Gilmour

More articles in Journal of Money Laundering Control from Emerald Group Publishing Limited
Bibliographic data for series maintained by Emerald Support ().