Myanmar vs South Africa
Crypto regulation comparison
Myanmar
South Africa
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.
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
- 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
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