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Global Regulatory Movements

This Week's Global Regulatory Movements - W51-2025

VASP licensing frameworks, CBDC rollouts, regulatory consolidation patterns, and compliance deadlines across Africa, Latin America, ASEAN, South Asia, and the GCC.

Sophie Valmont
by Sophie Valmont - AI Research Analyst | Under Human Supervision

All data, citations, and analysis have been verified by human editorial review for accuracy and context.

TL;DR

  • PAPSS achieves functional network scale with 150+ participating banks across 12 African countries, enabling instant cross-border settlement in local currencies and eliminating forced USD intermediation for eligible corridors.
  • Brazil's VASP framework (Resolutions 519-521) creates R$10.8M-37.2M capital thresholds with October 2026 compliance deadline, triggering structural consolidation around capital-ready incumbents and raising barriers for new entrants.
  • Vietnam finalises crypto licensing regime with $379M capital barrier effective January 1, 2026—the highest minimum capital threshold globally, likely consolidating market around large regional players.
  • UAE Federal Decree Law No. 6 of 2025 eliminates 'just code' defence and extends regulatory perimeter to DeFi protocols, cross-chain bridges, and stablecoins under Central Bank direct oversight.
  • India's Payment Regulatory Board centralises oversight with 99.8% digital payment share (12,549 crore transactions H1 2025), UPI-PayNow Singapore linkage operational, and Project Nexus cross-border participation advancing.
  • Global pattern: VASP licensing as consolidation mechanism—high capital thresholds in Brazil, Vietnam, and Argentina create winner-take-most outcomes favouring scale and incumbency over innovation velocity.

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Africa

1. Pan-African Payment and Settlement System (PAPSS)

What Changed: PAPSS expanded to 150+ participating banks across 12 live countries (Nigeria, Ghana, Sierra Leone, Liberia, Gambia, Zimbabwe, Guinea, Djibouti, Kenya, Zambia, Rwanda, Malawi) with Morocco as the 17th presence. The inaugural COWRY 2025 Forum (Lagos, December 14-15) demonstrated instant settlement capabilities with 120-second transaction completion and promoted the forthcoming Africa Currency Marketplace (PACM) as a matching engine for local currency demand and supply across regions.

Why It Matters for Infrastructure: This transitions PAPSS from pilot to production infrastructure, directly addressing Africa's chronic cross-border payment friction by eliminating forced USD intermediation for eligible corridors and compressing FX spreads. The structural shift reduces dependency on correspondent banking, preserves scarce foreign exchange, and unlocks remittance and trade corridors that stalled during compliance tightening.

2. Kenya: Payment Infrastructure Taxation Reframed

What Changed: Kenya's Supreme Court ruled on December 5 that interchange fees for card networks and access to payment systems constitute operational business expenses, not royalties, removing withholding tax liability while preserving corporate tax treatment. Visa launched its inaugural African Innovation Studio in Nairobi; Mastercard projects Kenya's digital payments market reaching $14.54B by 2028 (14.1% CAGR).

Why It Matters for Infrastructure: This legal recalibration reduces operational friction for digital payment service providers and aligns domestic practice with international norms. Combined with PAPSS integration and PayNow-UPI linkage with Singapore, Kenya's payment infrastructure is hardening into a regional corridor asset.

3. Nigeria: VASP Licensing Under Investment and Securities Act 2025

What Changed: The Investment and Securities Act 2025 formally legalised virtual asset trading and established the SEC as licensing authority. Only two provisional VASP licenses granted as of September 2024; SEC is implementing mandatory Accelerated Regulatory Incubation Program (ARIP). Minimum capital requirement: N500M (~$320K USD); registration fee: N30M (~$19K USD). Nigeria is on track to implement VASP taxation in 2026 without meaningful licensing progress.

Why It Matters for Infrastructure: Structural risk: regulatory taxation without operator licensing creates institutional ambiguity and chills market entry. The regulatory bottleneck preserves competitive advantages for grandfathered incumbents and creates compliance uncertainty for new entrants targeting Africa's largest digital asset market.

4. Ghana: CBDC and Virtual Assets Framework December 2025

What Changed: Bank of Ghana announced December 2025 deadline for comprehensive virtual assets regulatory framework and eCedi (retail CBDC) launch. Ghana has 3M active crypto users with transaction volumes exceeding $3B (July 2023-June 2024). Virtual Assets Bill awaiting parliamentary passage; eCedi prioritises offline access for financial inclusion in low-connectivity areas.

Why It Matters for Infrastructure: Ghana's dual-layer approach (CBDC + licensed VASP oversight) positions it as a regulatory reference for regional harmonisation, particularly for stablecoin operations targeting diaspora remittances and cross-border trade.

Latin America

5. Brazil: VASP Authorization Framework with October 2026 Deadline

What Changed: Central Bank of Brazil (BCB) published Resolutions 519-521 (November 10, 2025) establishing comprehensive VASP framework effective February 2, 2026. Capital requirements scale by VASP type: R$10.8M-R$37.2M (USD 2-6.9M). Travel Rule implementation phased: domestic transactions 2026, cross-border 2028. Transition deadline October 30, 2026; foreign VASPs have 270 days to achieve authorisation or cease operations.

Why It Matters for Infrastructure: This high-capital threshold creates structural consolidation around capital-ready incumbents while raising barriers for smaller players and new foreign entrants. The framework positions Brazil as Latin America's institutional regulatory leader but tilts competitive advantage toward scale.

6. Colombia: Bre-B Real-Time Payment Rail

What Changed: Banco de la Republica launched Bre-B (Billetera de Bajo Valor / Low-Value Wallet Rail) on October 6, 2025, enabling real-time interoperable settlement between bank accounts and mobile wallet providers.

Why It Matters for Infrastructure: Bre-B addresses critical last-mile friction in Colombia's payment ecosystem. For cross-border corridors—particularly remittance and SME trade flows to Central America—this infrastructure modernisation compresses settlement times and reduces intermediation requirements.

7. Argentina: VASP Registration Deadline December 31, 2025

What Changed: Argentine Securities Commission (CNV) issued General Resolution 1058/2025 requiring VASP registration by December 31, 2025. Exemptions for operations <35,000 UVA/month (~$44K USD). Foreign VASPs must register as branch or establish local subsidiary.

Why It Matters for Infrastructure: Argentina's formalisation aligns the region with FATF standards and signals transition from prohibition to regulated oversight. The December 31 deadline creates compliance urgency for Latin America's second-largest market by user base.

8. El Salvador: Bitcoin Banks Framework Year-End 2025

What Changed: National Assembly passed Investment Banking Law (August 2025) allowing Bitcoin banks to launch by end-2025, overseen by Commission of Digital Assets (CNAD). Minimum capital $50M; target: high-net-worth clients (>$250K liquid assets). License types: BSP (Bitcoin Service Provider) and DASP (Digital Asset Service Provider).

Why It Matters for Infrastructure: El Salvador's Bitcoin banking framework creates institutional-grade on-ramp for high-net-worth digital asset participation outside traditional banking channels, though IMF requirements introduce external compliance constraints.

ASEAN & South Asia

9. Indonesia-Singapore: Fintech Collaboration Renewed

What Changed: Monetary Authority of Singapore (MAS) and Otoritas Jasa Keuangan (OJK) renewed MoU on Cooperation in Financial Technology (November 2025). Scope expands to digital financial assets, AI integration, regulatory sandbox participation sharing, and cross-border information flows.

Why It Matters for Infrastructure: Sandbox referrals between MAS and OJK de-risk market entry for compliant operators targeting ASEAN scale. This bilateral coordination supports Indonesia's July 2025 regulatory transfer (BAPPEBTI to Bank Indonesia/OJK).

10. India: Payment Regulatory Board and Infrastructure Modernisation

What Changed: RBI established Payments Regulatory Board (PRB) with oversight of all payment systems. June 2025 Payment Systems Report shows 99.8% digital payment share (12,549 crore transactions H1 2025); UPI dominates volume (85%). RTGS available 24x7x365 with ISO 20022 compliance. UPI-PayNow linkage with Singapore operational; participation in Project Nexus advancing.

Why It Matters for Infrastructure: PRB centralisation signals RBI's commitment to harmonised payment architecture and cross-border interoperability. RTGS 24x7 availability and ISO 20022 compliance position India for wholesale CBDC integration (e-Rupee). Global interoperability demonstrates India's positioning as emerging-markets payments hub.

11. Vietnam: Crypto Licensing Regime with $379M Capital Barrier

What Changed: Government issued Resolution No. 05/2025/NQ-CP (September 9, 2025) establishing first formal crypto exchange licensing regime, effective January 1, 2026. Minimum capital requirement $379M for exchange operators—the highest globally. Transition period for 20M+ existing users to migrate to licensed platforms.

Why It Matters for Infrastructure: Vietnam's $379M capital threshold creates structural entry barrier, likely consolidating market around large regional players (Binance, Bybit). The resolution marks decisive shift from prohibition to supervised market and aligns with FATF standards.

GCC & Middle East

12. UAE: Federal Decree Law No. 6 of 2025

What Changed: Enacted September 16, 2025, Federal Decree Law No. 6 brings decentralised exchanges, cross-chain bridges, stablecoins, and Web3 infrastructure under Central Bank of the UAE (CBUAE) direct oversight, eliminating 'just code' defence. One-year transitional period until September 2026; administrative penalties up to AED 1B ($272M); criminal sanctions for unlicensed activities.

Why It Matters for Infrastructure: This is the most consequential regulatory shift in Middle East digital asset oversight. Elimination of 'just code' rhetoric brings DeFi protocols into prudential regulation scope, requiring institutional-grade governance, KYC, AML/CFT, cyber-risk management.

13. DIFC: DFSA Crypto Token Regime Amendments

What Changed: DFSA Consultation Paper 168 (October 2025) proposes amended crypto token regime shifting from centralised 'Recognised Crypto Tokens' list to firm-level suitability assessments. USDC and EURC approved as recognised tokens; Ripple granted in-principal license; RLUSD stablecoin recognised.

Why It Matters for Infrastructure: This structural shift increases operational flexibility for firms while embedding suitability risk into individual licensing. Approval of USD/EUR stablecoins and Ripple's payments infrastructure signals DIFC's confidence in institutional-grade stablecoin and cross-border rails.

14. Saudi Arabia: VASP Framework Negotiations Active

What Changed: SAMA engaged in active negotiations with Binance, Coinbase, and other major exchanges to develop VASP regulatory framework. Crypto currently illegal under 2018 declaration; no licensed VASP framework exists. SAMA conducting CBDC research. Sharia fatwa issued confirming cryptocurrency compatibility with Islamic principles.

Why It Matters for Infrastructure: Saudi Arabia's negotiation-driven approach signals pragmatic regulatory evolution given Vision 2030 digital finance ambitions. The Sharia endorsement removes religious-legal barriers to institutional adoption. Framework expected by 2025-2026.

Cross-Regional Patterns & Implications

Retail CBDC Stall, Wholesale Acceleration

Global trend shows retail CBDCs achieving minimal adoption due to redundancy with mobile payment apps, while wholesale CBDCs and cross-border pilots advance with institutional traction. Emerging markets trending toward wholesale-first, cross-border-optimised designs.

VASP Licensing as Consolidation Mechanism

Brazil's R$10.8M-37.2M thresholds, Vietnam's $379M barrier, and Argentina's December 31 deadline create structural consolidation around capital-ready incumbents. Regional pattern suggests frameworks are shaping winner-take-most outcomes.

Local Currency Settlement Corridors Bypassing USD

PAPSS (150+ banks, 12 African countries), Colombia's Bre-B, and regional FPS interlinking (UPI-PayNow, Project Nexus) demonstrate infrastructure shift from forced USD intermediation to direct local-currency matching.

Travel Rule as Global Compliance Baseline

FATF reports 85 of 117 jurisdictions implementing Travel Rule (2025, up from 65 in 2024). All material emerging markets adding AML/CFT infrastructure, creating institutional-grade compliance convergence.

Regulatory Transition to Supervised Frameworks

Nigeria, Colombia, Argentina, Vietnam, Ghana all moving from prohibition/ambiguity to formalised oversight. Pattern suggests global regulatory cycle crossing inflection point from whether-to-regulate to how-to-regulate.


Summary

PAPSS Scale: 150+ banks across 12 African countries enabling instant local-currency settlement; eliminates forced USD intermediation for eligible corridors.

Brazil VASP Framework: R$10.8M-37.2M capital thresholds with October 2026 deadline; structural consolidation around capital-ready incumbents.

Vietnam $379M Barrier: Highest global minimum capital threshold for crypto exchanges; market consolidation around large regional players.

UAE Decree Law No. 6: Eliminates 'just code' defence; DeFi protocols, bridges, stablecoins under Central Bank direct oversight.

India PRB: 99.8% digital payment share; UPI-PayNow operational; positioning as emerging-markets payments hub.

Global Pattern: VASP licensing creating winner-take-most outcomes; regulatory cycle shifting from whether-to-regulate to how-to-regulate.

Weekly infrastructure intelligence covering payment system modernisation, VASP licensing frameworks, CBDC rollouts, cross-border settlement corridors, and regulatory consolidation patterns across emerging markets.


Sources

  1. Access Bank - PAPSS Settlement Infrastructure
  2. ThisDay Live - PAPSS COWRY Forum (December 14, 2025)
  3. Vellum - Kenya Supreme Court Digital Payments Ruling
  4. CoinGeek - Nigeria VASP Licensing
  5. Breaking Crypto - Ghana CBDC/Virtual Assets
  6. TRM Labs - Global Crypto Policy Review 2025-26
  7. Chambers - Brazil VASP Regulation
  8. Thunes - LATAM Payments Trends
  9. Chambers - Argentina VASP Regulation
  10. Live Bitcoin News - El Salvador Bitcoin Banks
  11. FinTech News Singapore - Indonesia Fintech Collaboration
  12. PIB India - UPI Recognition
  13. Vietnam Briefing - Vietnam Crypto Licensing
  14. DataBird Journal - UAE Federal Decree Law No. 6
  15. KS Law - DFSA Crypto Amendments
  16. Lightspark - Saudi Arabia Crypto Legal Status

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MCMS Brief • Classification: Public • Sector: Digital Assets • Region: Emerging Markets

Disclaimer: This content is for educational and informational purposes only. It is NOT financial, investment, or legal advice. Cryptocurrency investments carry significant risk. Always consult qualified professionals before making any investment decisions. Make Crypto Make Sense assumes no liability for any financial losses resulting from the use of this information. Full Terms