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United Kingdom vs Kazakhstan

Crypto regulation comparison

United Kingdom

United Kingdom

Kazakhstan

Kazakhstan

Legal
Legal

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').

Kazakhstan has a dual approach to crypto regulation. The Astana International Financial Centre (AIFC) operates as a regulated sandbox where licensed crypto exchanges can operate under AFSA supervision. Outside the AIFC, crypto regulation is more restrictive. Kazakhstan became a major mining hub after China's ban but has since tightened mining regulations.

Tax Type Capital gains
Tax Type Capital gains
Tax Rate 18-24%
Tax Rate 10%
Exchanges Yes Yes
Exchanges Yes Yes
Mining Yes Yes
Mining Yes Yes
Regulator FCA (Financial Conduct Authority), HMRC, Bank of England
Regulator AFSA (Astana Financial Services Authority), NBK (National Bank of Kazakhstan)
Stablecoin Rules Stablecoin regulation under Financial Services and Markets Act 2023; fiat-backed stablecoins to be regulated by FCA
Stablecoin Rules AIFC (Astana International Financial Centre) has its own framework for digital assets including stablecoins
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)
Key Points
  • AIFC provides a regulatory sandbox for licensed crypto exchanges and businesses
  • Mining is legal and licensed, with a specific tax on electricity consumption for miners
  • Kazakhstan became the world's second-largest Bitcoin mining country after China's 2021 ban
  • 2022 mining crackdown introduced stricter licensing and energy consumption taxes
  • Outside AIFC, domestic crypto payments and exchanges face greater restrictions