The 2024 Bill provided for a Kes 150,000 & an additional Kes 15,000 penalty for each day or part of each day for which the contravention continues in the case where a licensee failed to provide the relevant regulatory authority with online or automated real time read-only access to both its client’s and its own virtual asset transaction records. It seems to have been dropped in the 2025 Bill

Key changes in the Bill unlike in 2024, it has rejigged to attain clarity of functions, assigning the oversight of the wallets to the Central Bank while transferring the oversight of the investments/exchange aspects to Capital Markets Authority. This is a clean up of roles given that the 2024 Bill had captured transfer & exchange of virtual assets as something regulated by both Central Bank of Kenya & Capital Markets Authority

Also, it adds a provision for Token issuance Platforms for issuance and secondary trading once real assets are tokenized. This shows there is an attempt to democratize access to the tokens generated, especially with the retail market.

Finally, the 2025 Bill introduces Stable coins and Initial coin offerings. Stable coins issuances will be regulated by the Central Bank of Kenya and Initial coin offerings will be regulated by the Capital Markets Authority.

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