
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.

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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Region Index
Africa
Latin America
ASEAN & South Asia
GCC & Middle East
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 transactionA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger 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 exchangeA platform where users can buy, sell, or trade cryptocurrencies, 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 infrastructureInfrastructure and networks that enable money transfer between parties 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 assetFATF term for digital value representation tradable or transferable electronically trading and established the SECU.S. federal agency regulating securities markets and protecting investors as licensing authority. Only two provisional VASPEntity providing services related to virtual assets, subject to AML regulations 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 assetsFATF term for digital value representation tradable or transferable electronically regulatory framework and eCedi (retail CBDCDigital form of a nation's fiat currency issued and guaranteed by the central bank) launch. Ghana has 3M active crypto users with transactionA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger 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 (CBDCDigital form of a nation's fiat currency issued and guaranteed by the central bank + licensed VASPEntity providing services related to virtual assets, subject to AML regulations oversight) positions it as a regulatory reference for regional harmonisation, particularly for stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold 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 VASPEntity providing services related to virtual assets, subject to AML regulations framework effective February 2, 2026. Capital requirements scale by VASP type: R$10.8M-R$37.2M (USD 2-6.9M). Travel RuleRequirement to share sender and recipient information for crypto transactions above a threshold implementation phased: domestic transactionsA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger 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 WalletA tool for storing, sending, and receiving cryptocurrencies 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 VASPEntity providing services related to virtual assets, subject to AML regulations 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 FATFGlobal standard-setter for combating money laundering and terrorist financing 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 baseCoinbase's Ethereum Layer 2 network using Optimism's OP Stack, designed for low-cost, high-speed transactions with Coinbase ecosystem integration.
8. El Salvador: Bitcoin Banks Framework Year-End 2025
What Changed: National Assembly passed Investment Banking Law (August 2025) allowing BitcoinThe first decentralized cryptocurrency, created in 2009 by Satoshi Nakamoto 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 BitcoinThe first decentralized cryptocurrency, created in 2009 by Satoshi Nakamoto banking framework creates institutional-grade on-rampA service that converts fiat money into cryptocurrency 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 SingaporeSingapore's central bank and integrated financial regulator overseeing banking, insurance, and securities (MAS) and Otoritas Jasa Keuangan (OJK) renewed MoU on Cooperation in Financial Technology (November 2025). Scope expands to digital financial assets, AIAI systems that learn patterns from data without explicit programming 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 transactionsA transfer of value or data recorded on a blockchain, verified by network participants, and permanently added to the distributed ledger H1 2025); UPI dominates volume (85%). RTGSA funds transfer system where money or securities are settled individually and immediately across central bank accounts 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 interoperabilityThe ability of different blockchain networks to communicate and work together seamlessly. RTGSA funds transfer system where money or securities are settled individually and immediately across central bank accounts 24x7 availability and ISO 20022 compliance position India for wholesale CBDCDigital currency issued by central banks for institutional settlements between financial institutions 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 exchangeA platform where users can buy, sell, or trade cryptocurrencies 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 FATFGlobal standard-setter for combating money laundering and terrorist financing 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-chainThe ability of different blockchain networks to communicate and work together seamlessly bridges, stablecoins, and Web3Next generation internet powered by blockchain enabling user ownership of data and digital assets 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 DeFiFinancial systems built on blockchain that operate without intermediaries like banks protocols into prudential regulation scope, requiring institutional-grade governance, KYCA process where exchanges and financial institutions verify user identity, AMLRegulatory framework requiring financial institutions to detect and prevent money laundering, terrorist financing, and other illicit financial activities/CFT, cyber-risk management.
13. DIFC: DFSA Crypto Token Regime Amendments
What Changed: DFSA Consultation Paper 168 (October 2025) proposes amended crypto tokenA digital asset built on an existing blockchain, often representing utility or value regime shifting from centralised 'Recognised Crypto Tokens' list to firm-level suitability assessments. USDCA fully-reserved stablecoin pegged 1:1 to the US Dollar, issued by Circle and backed by regulated financial institutions and EURC approved as recognised tokens; Ripple granted in-principal license; RLUSD stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold 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 stablecoinA cryptocurrency pegged to a stable asset, such as USD or gold 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 VASPEntity providing services related to virtual assets, subject to AML regulations regulatory framework. Crypto currently illegal under 2018 declaration; no licensed VASP framework exists. SAMA conducting CBDCDigital form of a nation's fiat currency issued and guaranteed by the central bank 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 VASPEntity providing services related to virtual assets, subject to AML regulations 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; DeFiFinancial systems built on blockchain that operate without intermediaries like banks 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: VASPEntity providing services related to virtual assets, subject to AML regulations licensing creating winner-take-most outcomes; regulatory cycle shifting from whether-to-regulate to how-to-regulate.
Weekly infrastructure intelligence covering payment system modernisation, VASPEntity providing services related to virtual assets, subject to AML regulations licensing frameworks, CBDCDigital form of a nation's fiat currency issued and guaranteed by the central bank rollouts, cross-border settlement corridors, and regulatory consolidation patterns across emerging markets.
Sources
- Access Bank - PAPSS Settlement Infrastructure
- ThisDay Live - PAPSS COWRY Forum (December 14, 2025)
- Vellum - Kenya Supreme Court Digital Payments Ruling
- CoinGeek - Nigeria VASPEntity providing services related to virtual assets, subject to AML regulations Licensing
- Breaking Crypto - Ghana CBDCDigital form of a nation's fiat currency issued and guaranteed by the central bank/Virtual AssetsFATF term for digital value representation tradable or transferable electronically
- TRM Labs - Global Crypto Policy Review 2025-26
- Chambers - Brazil VASPEntity providing services related to virtual assets, subject to AML regulations Regulation
- Thunes - LATAM Payments Trends
- Chambers - Argentina VASPEntity providing services related to virtual assets, subject to AML regulations Regulation
- Live BitcoinThe first decentralized cryptocurrency, created in 2009 by Satoshi Nakamoto News - El Salvador Bitcoin Banks
- FinTech News Singapore - Indonesia Fintech Collaboration
- PIB India - UPI Recognition
- Vietnam Briefing - Vietnam Crypto Licensing
- DataBird Journal - UAE Federal Decree Law No. 6
- KS Law - DFSA Crypto Amendments
- 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