Estonia vs Morocco
Crypto regulation comparison
Estonia
Morocco
Estonia was an early mover in crypto regulation, offering licenses since 2017. However, a 2022 overhaul significantly tightened requirements, revoking hundreds of licenses and imposing stricter capital and compliance standards. Crypto gains are taxed at 20% (rising to 22% from 2025).
Morocco's central bank (Bank Al-Maghrib) banned cryptocurrency transactions in 2017, making it illegal for financial institutions to process crypto payments. Despite the ban, Morocco has one of the highest crypto adoption rates in Africa. The government has been exploring a potential regulatory framework, with Bank Al-Maghrib reportedly studying a CBDC and reconsidering its crypto stance.
Key Points
- Estonia issued crypto licenses since 2017 but drastically tightened rules in 2022
- Hundreds of crypto licenses were revoked in 2020-2022 due to AML concerns
- New requirements include higher share capital (€100,000-€250,000) and local management
- Crypto gains taxed at 20% personal income tax (22% from 2025)
- MiCA framework applicable from December 2024
Key Points
- Bank Al-Maghrib banned crypto transactions for financial institutions in 2017
- Crypto ownership is technically in a legal gray area; trading happens via P2P
- Morocco ranks among the top crypto adopters in Africa despite the ban
- Government exploring regulatory framework and potential CBDC
- No crypto taxation framework exists due to the ban