For most of the past decade, the story of crypto regulation has been told from the perspective of Washington, Brussels, and London. The SEC, the FCA, MiCA. The frameworks that have dominated headlines and shaped industry behaviour have been built by and for developed economies with established banking systems, deep capital markets, and relatively small unbanked populations.
That story is shifting, and emerging markets are the ones driving the change.
Across Africa, South Asia, and Southeast Asia, a different regulatory conversation is happening. It is messier and more urgent, shaped by pressures that Western regulators have never had to confront in the same way. The question these markets are asking is not how to regulate crypto to protect an existing financial system. It is how to build a financial system that actually works for the majority of their populations, and whether crypto can be part of that answer.
Pakistan’s decision last week to permit banks to service licensed crypto firms is the latest and most significant example of that conversation producing results. But it is one moment in a much longer and wider story.
Why Western frameworks do not travel well
The regulatory models developed in the United States and Europe were built around specific assumptions. That most of the population has access to banking. That established financial institutions are the primary channel for savings, investment, and transfer of value, and that the primary risk to be managed is speculation and fraud within an otherwise functioning system.
None of those assumptions hold in most of the Global South. According to the World Bank’s Global Findex 2025 report, around 42% of adults in Sub-Saharan Africa remain without a bank account, despite significant progress driven by mobile money adoption over the past decade. In parts of South Asia, hundreds of millions of people continue to operate outside the formal financial system despite rapid economic growth. In Southeast Asia, mobile money has done more to extend financial access in the past decade than traditional banking managed in the previous fifty years.
When regulators in these markets look at crypto, they are not looking at it through the same lens as the SEC or the FCA. They are looking at it as potential infrastructure for populations that existing infrastructure has failed. The regulatory response, when it comes, needs to reflect those differences rather than simply importing frameworks designed for different conditions.
Where the Global South currently stands
The regulatory picture across emerging markets is uneven and fast-moving, and in some cases further advanced than many observers realise.
Nigeria is the largest crypto market in Africa by volume and has had one of the most turbulent regulatory histories. After an outright ban on crypto transactions through the banking system in 2021, Nigeria has moved decisively toward a structured framework. In March 2025, President Bola Tinubu signed the Investments and Securities Act 2025, formally classifying digital assets as securities and placing them under the authority of the Securities and Exchange Commission. Banks can now open accounts for SEC-licensed crypto firms, with strict AML and KYC requirements attached. The framework is not without complications. Enforcement is uneven and institutional practices take time to catch up with new legislation. But the direction is clear and the legal foundation is now in place.
Kenya presents a different picture. A country that pioneered mobile money through M-Pesa and demonstrated that financial infrastructure could be built specifically for emerging market conditions rather than imported from developed economies, Kenya is at an earlier stage of crypto regulation but has the institutional knowledge and regulatory experience to move thoughtfully. The Capital Markets Authority has been consulting on a framework for digital assets and the trajectory is toward structured engagement rather than restriction.
In Southeast Asia, the Philippines has been one of the more proactive regulators. Bangko Sentral ng Pilipinas established a virtual asset service provider framework that has allowed a functioning licensed crypto sector to develop since 2017, with exchanges including PDAX, Maya, and Coins.ph operating under formal regulatory approval. The picture is not without complexity. In 2025 the central bank extended a moratorium on new VASP licenses citing consumer protection concerns, signalling that even progressive regulators are wrestling with how fast to move. That tension between openness and caution is arguably more honest than a framework that pretends the risks do not exist.
El Salvador sits apart from the others. Its decision to adopt Bitcoin as legal tender in 2021 was controversial and its economic impact has been debated extensively. But its subsequent development of a broader digital asset licensing framework has attracted international crypto businesses seeking a compliant operating base in a jurisdiction that takes the sector seriously. Several companies have chosen El Salvador not because of the Bitcoin law but because of the regulatory infrastructure that followed it.
What Pakistan’s approach adds to this picture
Pakistan’s move is notable not just because of the scale of the market, around 27 million active crypto users, but because of the deliberateness of the approach. As Oliver Cook KC wrote in Profit by Pakistan Today this week, this is less a crypto story than a governance story. The framework being built through PVARA is demanding. Strict AML and KYC requirements, segregated client accounts, formal licensing processes. It is a structured entry point with real compliance requirements attached, not an open invitation.
Worth being precise about what actually happened. Pakistan has not completed a regulatory framework. It has taken a significant and deliberate step toward one. The licensing process is still underway. Major exchanges received No Objection Certificates late last year, initiating the formal process, but full operational approval has not yet been granted. What gets built inside the framework matters as much as the framework itself.
But that framing is part of what makes this significant to the markets watching. The countries that have tried to simply open their doors without a compliance architecture have found that the populations they were trying to serve end up more vulnerable, not less, when the infrastructure they are using has no regulatory accountability attached to it.
The Global South is not waiting for Western regulators to arrive at a model it can borrow. Each of these markets, Nigeria, Kenya, the Philippines, Pakistan, is working through the same fundamental questions in its own way, at its own pace, shaped by its own economic conditions. The answers are going to look different in Lagos than they do in Karachi. And that is not a problem. It is the point.
Pakistan has signalled clearly which direction it is heading. Whether the framework it builds lives up to that signal is the question the rest of the Global South will be watching closely.
Oliver Cook KC
Oliver Cook KC is a King’s Counsel specialising in financial crime, emerging technology law, and international regulatory frameworks. Recognised by Chambers and Partners and Legal 500 as a leading expert in cases involving encrypted communications and digital evidence, he has presented to delegates of The European Parliament on the intersection of law and technology. He is co-founder of Fuutura, a compliance-first digital infrastructure company building for the Global South.
