Bahrain vs China
Crypto regulation comparison
Bahrain
China
Legal
Banned
Bahrain is one of the most crypto-friendly jurisdictions in the Middle East. The Central Bank of Bahrain introduced a comprehensive crypto-asset regulatory framework in 2019, and there is no personal income or capital gains tax. Several major exchanges including Binance have obtained licenses.
China has imposed a comprehensive ban on cryptocurrency activities. In September 2021, the PBOC and ten other agencies jointly declared all cryptocurrency transactions illegal, and the State Council banned crypto mining. China is instead promoting the digital yuan (e-CNY) CBDC.
Tax Type
No tax
Tax Type
Unclear
Tax Rate
0%
Tax Rate
N/A
Exchanges
Yes
Exchanges
No
Mining
Yes
Mining
No
Regulator
CBB (Central Bank of Bahrain)
Regulator
PBOC (People's Bank of China), CBIRC, CSRC
Stablecoin Rules
Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules
Not applicable; all crypto activities are banned
Key Points
- CBB Crypto-Asset Module provides a full regulatory framework for exchanges, custodians, and brokers
- No personal income tax or capital gains tax in Bahrain
- Licensed exchanges include Binance (CoinMENA), Rain, and others
- VASPs must meet AML/CFT requirements and obtain CBB licensing
- Bahrain positions itself as a regional fintech and crypto hub
Key Points
- All crypto transactions declared illegal by PBOC and 10 agencies in September 2021
- Crypto mining banned by the State Council in 2021 after a series of provincial crackdowns
- Financial institutions and payment companies prohibited from facilitating crypto services
- China actively developing and piloting the digital yuan (e-CNY) CBDC
- Despite the ban, some Chinese citizens reportedly access crypto via VPNs and OTC desks