Jamaica vs South Africa
Crypto regulation comparison
Jamaica
South Africa
Jamaica has no specific cryptocurrency legislation. The Bank of Jamaica does not regulate or endorse crypto but has not banned it. Jamaica launched its own CBDC, JAM-DEX, in 2022 through the National Commercial Bank. Crypto exists in a legal gray area with no dedicated framework.
South Africa has embraced crypto regulation. In 2022, the FSCA declared crypto assets as financial products under the Financial Advisory and Intermediary Services (FAIS) Act, requiring crypto service providers to obtain FSCA licenses. SARS taxes crypto gains under capital gains tax (up to 18% effective rate for individuals) or income tax depending on trading frequency. South Africa is the largest crypto market in Africa.
Key Points
- No specific cryptocurrency legislation or regulatory framework
- BOJ does not recognize crypto as legal tender but has not banned it
- Jamaica launched the JAM-DEX CBDC in 2022
- FSC Jamaica has not issued specific guidance on crypto asset regulation
- Tax treatment of crypto gains is unclear due to lack of specific guidance
Key Points
- Crypto declared a financial product under FAIS Act (2022); service providers must be FSCA-licensed
- FSCA began licensing crypto asset service providers (CASPs) in 2023
- Capital gains taxed at effective rate up to 18% (45% max marginal rate × 40% inclusion)
- Frequent trading may be classified as income and taxed at marginal rates (up to 45%)
- SARB regulates cross-border crypto transactions under exchange control regulations