IMF (International Monetary Fund)

1. Organisation Overview

The International Monetary Fund (IMF) is an international financial institution with 190 member countries. Its mandate encompasses global monetary cooperation, financial stability, international trade facilitation, and poverty reduction. The IMF's relevance to crypto payment regulation stems from:

• Surveillance (Article IV consultations): The IMF assesses each member country's economic policies, including crypto-asset regulation, in annual Article IV consultations
• Lending conditionality: IMF loans can include conditions related to crypto-asset regulation (as demonstrated with
  El Salvador)
• Policy guidance: Board-level papers and departmental research shape international consensus
• Technical assistance: Direct support to countries developing crypto-asset regulatory frameworks
• Data and monitoring: The IMF Crypto-Assets Monitor tracks cross-border crypto flows

The IMF does not set binding regulatory standards but exercises significant influence through its surveillance function, lending programmes, and coordination with the FSB, FATF, and standard-setting bodies.

Sources

• Digital Payments and Finance — IMF Topic Page

2. Elements of Effective Policies for Crypto Assets (February 2023)

Document: Elements of Effective Policies for Crypto Assets Published: 23 February 2023 (Executive Board discussion 8 February 2023) Reference: Policy Papers Vol. 2023, Issue 004 (PPEA2023004)

This is the IMF's foundational policy paper on crypto-asset regulation. It provides guidance to member countries on key elements of an appropriate policy response.

The Nine Elements

Core principle (Element 1): The IMF explicitly recommends against granting crypto assets legal tender status. This position directly informed the IMF's engagement with

El Salvador on Bitcoin.

Sources

• IMF Executive Board Discusses Elements of Effective Policies for Crypto Assets — IMF Press Release No. 23/51, 23 February 2023
• Elements of Effective Policies for Crypto Assets — Full Paper — IMF Policy Paper 2023/004

3. IMF-FSB Synthesis Paper: Policies for Crypto-Assets (September 2023)

Document: IMF-FSB Synthesis Paper: Policies for Crypto-Assets Published: 7 September 2023 Reference: FSB/IMF (2023), R070923-1

Produced at the request of the Indian G20 Presidency, this joint paper consolidates the IMF's macroeconomic policy guidance and the FSB's financial stability recommendations into a unified framework.

Key Positions on Crypto Payments

Comprehensive regulation as baseline: The synthesis paper finds that comprehensive regulatory and supervisory oversight of crypto-asset activities should be the baseline, rejecting blanket bans as ineffective.

Crypto payments in developing countries: The paper warns that widespread adoption of crypto assets in developing countries could:

• Undermine the effectiveness of monetary policy
• Circumvent capital flow management measures
• Exacerbate fiscal risks
• Divert resources from financing the real economy

Systemic risk from payment adoption: Direct connections between crypto assets and systemically important financial institutions are currently limited, but could emerge as a source of systemic risk in specific jurisdictions if crypto assets gain traction for payments or retail investments.

Stablecoins: Stablecoin arrangements used for payments require regulation proportionate to their potential systemic importance, consistent with FSB GSA recommendations.

Sources

• IMF-FSB Synthesis Paper: Policies for Crypto-Assets — FSB, 7 September 2023
• Synthesis Paper PDF
• Crypto Needs Comprehensive Policies — IMF Blog

4. Global Financial Stability Reports — Crypto Sections

4.1 GFSR October 2021 — Chapter 2: "The Crypto Ecosystem and Financial Stability Challenges"

Reference: GFSR, October 2021, Chapter 2

This was the first dedicated GFSR chapter on crypto-asset financial stability risks.

Key findings:

• Total crypto market value surpassed USD 2 trillion as of September 2021 — a 10-fold increase since early 2020
• Concentration risks: Binance handled over half of trading volumes; Tether issued more than half of stablecoin supply
• Financial stability risks at the global level "appear contained for now"
• However, macro-criticality can be "significantly higher" for some EMDEs where adoption has progressed fast
• Challenges include: operational risks, market integrity gaps, data availability, and cross-border activity oversight

Payment-specific concerns: Stablecoin growth as a payment mechanism creates interconnections with the traditional financial system through reserve asset holdings, bank deposit backing, and commercial paper exposure.

Sources

• GFSR October 2021 — Chapter 2: The Crypto Ecosystem and Financial Stability Challenges
• Chapter PDF
• Crypto Boom Poses New Challenges — IMF Blog

5. IMF Positions on Crypto Payments in Developing Countries

5.1 Macroeconomic Risks for EMDEs

The IMF has consistently warned that crypto payment adoption in emerging market and developing economies (EMDEs) poses heightened risks compared to advanced economies:

Currency substitution (cryptoisation): When people and companies forego their national currency in favour of a foreign-currency-denominated stablecoin, it decreases the central bank's ability to control monetary policy and serve as lender of last resort. Stablecoins, being digital and transnational, can accelerate this process.

Capital flow management: Crypto payment channels can circumvent capital flow management measures, undermining countries' ability to manage balance-of-payments pressures. The IMF's analysis found that stablecoin flows relative to GDP are most significant in Latin America and the Caribbean (7.7%) and Africa and the Middle East (6.7%).

Dollar demand channel: IMF Working Paper No. 2025/141 (Decrypting Crypto) found that North America exhibits net outflows of stablecoins, with evidence suggesting these flows meet global dollar demand — increasing during periods of dollar appreciation.

5.2 Regional Stablecoin Adoption Data

The IMF's Understanding Stablecoins departmental paper (December 2025) documents stablecoin adoption across regions:

Total 2024 stablecoin transactions analysed: approximately USD 2 trillion.

Sources

• Decrypting Crypto: How to Estimate International Stablecoin Flows — IMF Working Paper No. 2025/141
• How Stablecoins Can Improve Payments and Global Finance — IMF Blog
• How Stablecoins and Other Financial Innovations May Reshape the Global Economy — IMF Blog

6. Understanding Stablecoins — IMF Departmental Paper (December 2025)

Document: Understanding Stablecoins Published: 2 December 2025 Reference: Departmental Papers Vol. 2025, Issue 009 DOI: 10.5089/9798229024075.087 Authors: Tobias Adrian and 15 co-authors (Monetary and Capital Markets Department)

This is the IMF's most comprehensive publication on stablecoins to date.

Key Findings

Market scale: Over 250 stablecoins in circulation; market capitalisation exceeding USD 308 billion.

Benefits acknowledged:

• Stablecoins could enable faster and cheaper payments, particularly across borders and for remittances
• Blockchains can simplify cross-border payment processes and reduce costs
• Could increase competition with established payment service providers
• Could make retail digital payments more accessible to underserved customers

Risks identified:

• Currency substitution when stablecoins denominated in foreign currencies gain adoption
• Reduced central bank ability to control monetary policy
• Financial stability risks from reserve asset management
• Consumer protection gaps
• AML/CFT compliance challenges

Regional adoption: Stablecoin holdings relative to total deposits in Africa rose from virtually zero in 2020 to 1.5% by 2024.

Sources

• Understanding Stablecoins — IMF Departmental Paper 2025/009
• Understanding Stablecoins PDF
• IMF Warns Dollar Stablecoins Threaten Monetary Policy — Yahoo Finance

7. El Salvador: IMF Conditions on Crypto Legal Tender

The IMF's engagement with

El Salvador on Bitcoin represents the most direct application of IMF crypto payment policy through lending conditionality.

Timeline

IMF Programme Conditions on Bitcoin

As part of the EFF agreement,

El Salvador agreed to:

• Amend the Bitcoin Law to make Bitcoin use optional and remove legal tender status
• Remove mandatory acceptance requirement on merchants
• Stop accepting tax payments in Bitcoin
• Wind down government involvement in the Chivo wallet
• Not increase overall Bitcoin holdings by the public sector
• Reduce Bitcoin purchases by the government

IMF Assessment of Bitcoin Adoption

The IMF found that Bitcoin adoption as official currency with legal tender status:

• Had not led to visible improvements in financial inclusion
• Despite large use of public funds for subsidising Bitcoin transaction costs, acceptance and use by individuals and firms remained minimal
• Created fiscal risks and governance concerns

Sources

• IMF Country Report No. 25/58 — El Salvador — IMF, 2025
• IMF Country Report No. 25/68 — El Salvador — IMF, 2025
• IMF Executive Board Concludes 2025 Article IV consultation and First Review Under the EFF for El Salvador
• El Salvador agrees with IMF to 'confine' Bitcoin use — Global Government Finance

8. Capital Flow Management Measures and Crypto Payment Restrictions

The IMF's Institutional View on Capital Flows (IV), adopted in 2012 and updated in 2022, provides the framework for when capital flow management measures (CFMs) are appropriate. Crypto payment channels create challenges for CFM effectiveness:

Key IMF position: Jurisdictions should guard against excessive capital flow volatility and maintain the effectiveness of capital flow management measures (Element 2 of the Nine Elements framework).

Crypto-specific challenges:

• Stablecoin-denominated cross-border transfers can bypass traditional banking channels subject to CFMs
• Pseudonymous transactions complicate monitoring and enforcement
• Jurisdictions with weak CFM frameworks are more vulnerable to crypto-enabled capital flight

IMF Working Paper No. 2025/141 findings: Net stablecoin flows mainly move from North America to other regions, likely meeting dollar demand abroad. This pattern intensifies during periods of dollar appreciation — suggesting stablecoins serve as a capital flow channel responsive to macroeconomic conditions.

Sources

• Elements of Effective Policies for Crypto Assets — IMF Policy Paper 2023/004, Element 2
• Decrypting Crypto — IMF WP 2025/141

9. IMF Technical Assistance on Crypto Payment Regulation

The IMF provides technical assistance (TA) to member countries developing crypto-asset regulatory frameworks. Recent examples:

9.1 Kenya (January 2025)

Document: Technical Assistance Report — Kenya: Crypto Regulation and Legislation Reference: Country Report (TAR) 2025/001

The IMF recommended:

• Classification of crypto assets aligned with international standards
• Inter-agency coordination between the Capital Markets Authority, Central Bank, and communications regulator
• Strengthened AML/CFT oversight
• FATF Recommendation 15 implementation targeted for April 2025

Sources

• Kenya: Crypto Regulation and Legislation — Technical Assistance Report — IMF, January 2025

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9.2 Nigeria (2025)

The IMF published a selected issues paper on regulating the crypto market in Nigeria as part of the 2025 Article IV consultation. The paper addresses:

• Regulatory framework development for crypto exchanges
• Consumer protection in the context of high retail crypto adoption
• AML/CFT considerations following Nigeria's addition to the FATF grey list
• The launch of cNGN, Nigeria's first locally issued stablecoin, via two licensed crypto exchanges

Sources

• Regulating the Crypto Market in Nigeria — IMF Selected Issues Paper, July 2025
• Nigeria: 2025 Article IV Consultation

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9.3 Regional Training Programmes

The IMF has conducted regional training and capacity building on crypto-asset regulation covering:

• Asia-Pacific, Central Asia, Middle East, North Africa, Sub-Saharan Africa, and Caribbean regions
• Bilateral training provided in Albania, Ukraine, Vietnam, and Zimbabwe
• Over 250 individual supervisors from approximately 60 regulatory authorities trained over a 12-month period

Sources

• The Changing Landscape of Crypto Assets — IMF Speech — February 2024

10. Article IV Consultations Mentioning Crypto Payment Regulation

IMF Article IV consultations increasingly address crypto-asset and payment regulation. Notable recent examples:

The IMF has noted that robust supervision of crypto payment activities requires coordination across multiple regulatory agencies — securities regulators, payment system overseers, central banks, and AML/CFT supervisors.

Sources

• IMF Staff Completes 2025 Article IV Mission with Nigeria
• El Salvador: 2025 Article IV Consultation

11. G20 Crypto-Asset Policy Implementation Roadmap

The IMF co-leads the G20 Crypto-Asset Policy Implementation Roadmap with the FSB.

October 2024 Status Report findings:

• Nearly all FSB member jurisdictions have plans to develop or revise crypto-asset regulatory frameworks
• About half of non-FSB RCG member countries expect alignment with the FSB Framework by 2025
• IMF, FSB, and standard-setting bodies have organised workshops, outreach sessions, knowledge sharing events, and capacity building programmes beyond the G20

Roadmap structure:

1. Promote implementation of policy frameworks
2. Build institutional capacity beyond G20 jurisdictions
3. Enhance global coordination, cooperation, and information sharing
4. Address data gaps

Sources

• G20 Crypto-asset Policy Implementation Roadmap: Status report — FSB/IMF, 22 October 2024
• Status Report PDF

12. Key Document Reference Table

13. Verification Notes

• The "Nine Elements" framework was verified via IMF Press Release No. 23/51 and the full Policy Paper 2023/004 PDF
• El Salvador EFF loan amount (USD 1.4 billion) and programme conditions verified via IMF Country Reports 25/58 and 25/68 and the June 2025 Article IV press release
• El Salvador Bitcoin adoption assessment ("not led to visible improvements in financial inclusion") verified from IMF Country Report language
• IMF Working Paper 2025/141 (Decrypting Crypto) statistics on stablecoin flows verified via IMF publications page and the paper's abstract
• Stablecoin regional flow data (North America USD 633bn, Asia-Pacific USD 519bn, LatAm 7.7% of GDP) from WP 2025/141
• Understanding Stablecoins departmental paper reference (2025/009) and DOI verified via IMF eLibrary
• Kenya TA report (2025/001) verified via IMF TAR publications page
• Nigeria crypto regulation paper verified via IMF selected issues papers page
• Regional training statistics (250+ supervisors, 60 regulatory authorities) verified from the February 2024 IMF speech
• The IMF-FSB Synthesis Paper date (7 September 2023) confirmed via both FSB and IMF websites
• Africa stablecoin deposits figure (0% in 2020 to 1.5% by 2024) sourced from the Understanding Stablecoins paper as cited by BitcoinKE
• All URLs were fetched or confirmed accessible as of March 2026

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Related coverage

IMF (International Monetary Fund) in other research domains:

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