From ban to regulation: a comparative analysis of Ghana’s 2025 Virtual Asset Service Providers Act and US anti-money laundering frameworks

PurposeThis paper aims to compare Ghana’s Virtual Asset Service Providers Act, 2025 (Act 1154), with the USA’s anti-money laundering (AML) framework for virtual assets. It asks whether a unified statute can give an emerging economy advantages over a fragmented, path-dependent regime.Design/methodology/approachThe study uses functional and institutional comparative legal analysis. It reviews statutes, supervisory notices, sandbox materials and enforcement documents through a six-dimensional matrix mapped to Financial Action Task Force Recommendations 10, 12, 15, 16, 20, 26, 27 and 35.FindingsGhana’s Act offers statutory coherence, and early implementation steps show movement beyond a purely prospective regime. However, enforcement capacity for virtual asset service providers (VASPs) is still developing. The US framework is institutionally fragmented yet operationally mature. Ghana’s licensing model more closely resembles a banking charter than a money services business (MSB) registration, increasing demands on supervisory expertise, verification systems and technical infrastructure. Both frameworks also leave gaps around decentralized finance.Research limitations/implicationsImplementing regulations remain incomplete and Ghana does not yet have a mature enforcement record specific to VASPs. The analysis, therefore, combines legal design with early operational evidence rather than a full account of law in action.Practical implicationsEmerging-economy regulators need more than statutory clarity; they need credible supervisory capacity. VASPs in Ghana should expect operational requirements to evolve as implementation matures.Originality/valueThe paper offers an early comparative analysis of Ghana’s Act and contributes to debates on regulatory leapfrogging, implementation gaps and compliance capacity in the Global South.