Hong Kong vs Kenya
Crypto regulation comparison
Hong Kong
Kenya
Legal
No Regulation
Hong Kong has positioned itself as a major crypto hub in Asia with a comprehensive licensing regime. The SFC implemented a mandatory licensing framework for virtual asset trading platforms (VATPs) effective June 2023. Hong Kong has no capital gains tax, making it attractive for crypto investors and businesses.
Kenya has no comprehensive cryptocurrency legislation, though it is one of Africa's leading crypto markets by adoption. The Central Bank has issued warnings but no formal ban. Kenya's 2023 Finance Act introduced a 3% Digital Asset Tax on income from digital asset transfers, signaling growing regulatory attention.
Tax Type
No tax
Tax Type
Varies
Tax Rate
0%
Tax Rate
1.5-3% (proposed digital asset tax)
Exchanges
Yes
Exchanges
Yes
Mining
Yes
Mining
Yes
Regulator
SFC (Securities and Futures Commission), HKMA
Regulator
CBK (Central Bank of Kenya), CMA (Capital Markets Authority)
Stablecoin Rules
HKMA developing a licensing regime for stablecoin issuers under a 2024 bill
Stablecoin Rules
No specific stablecoin regulation
Key Points
- Mandatory VATP licensing regime under the AMLO effective June 1, 2023
- No capital gains tax in Hong Kong; profits tax applies only to business profits
- SFC approved spot Bitcoin and Ether ETFs for retail investors in April 2024
- HKMA consulting on stablecoin issuer licensing under a dedicated bill
- Hong Kong actively competes with Singapore as Asia's leading crypto hub
Key Points
- No specific cryptocurrency legislation, but the 2023 Finance Act introduced a 3% Digital Asset Tax
- CBK has issued multiple warnings about crypto but has not imposed a ban
- CMA considering a framework for digital asset regulation
- Kenya consistently ranks among the top countries globally for crypto adoption (P2P volume)
- M-Pesa mobile money dominance shapes how Kenyans access crypto via P2P exchanges