United Kingdom vs Myanmar
Crypto regulation comparison
United Kingdom
Myanmar
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').
Myanmar's Central Bank issued Notification No. 9/2020 prohibiting the sale, purchase, and exchange of unregulated digital currencies. Violations are prosecuted under the Anti-Money Laundering Law and Financial Institutions Law with penalties including imprisonment and fines. Despite the ban, underground stablecoin usage persists, particularly USDT.
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
- CBM Notification No. 9/2020 prohibits sale, purchase, and exchange of digital currencies
- Violations prosecuted under Anti-Money Laundering Law and Financial Institutions Law
- Financial institutions banned from dealing in digital currencies
- CBM is exploring a central bank digital currency (digital kyat)
- Underground stablecoin (USDT) usage persists despite ban
Sources
- HMRC - Cryptoassets Manual
- FCA - Cryptoassets Information
- HMRC - Capital Gains Tax Rates
- HMRC - Cryptoassets Manual: Mining
- FCA - Regulation of Digital Assets Speech
- FCA - Cryptoasset Registration Application
- FCA - Regulating Cryptoasset Activities (DP25/1)
- FCA - Financial Promotion Rules for Cryptoassets (PS23/6)