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Bahrain vs United Kingdom

Crypto regulation comparison

Bahrain

Bahrain

United Kingdom

United Kingdom

Legal
Legal

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.

The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').

Tax Type No tax
Tax Type Capital gains
Tax Rate 0%
Tax Rate 18-24%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator CBB (Central Bank of Bahrain)
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Stablecoin Rules Regulated under CBB crypto-asset module; stablecoin issuance requires CBB licensing
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
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
  • FCA AML registration required for all crypto firms operating in the UK
  • Capital Gains Tax: 10% (basic rate) or 20% (higher rate); £3,000 annual exempt amount (2024/25)
  • Financial promotions regime (2023): strict rules on crypto advertising, risk warnings mandatory
  • Financial Services and Markets Act 2023 brings crypto into regulatory perimeter
  • HM Treasury developing comprehensive crypto regulatory regime (exchange licensing, conduct rules)