I. Introduction

Yes, as a general rule, a non-government organization, non-stock non-profit corporation, foundation, charitable institution, or civil society organization in the Philippines may accept cryptocurrency donations. There is no general Philippine law that categorically prohibits an NGO from receiving donations in Bitcoin, Ether, stablecoins, or other digital assets.

However, the legal answer is not simply “yes.” Crypto donations raise important issues involving corporate authority, tax treatment, accounting, anti-money laundering compliance, donor due diligence, foreign donations, securities regulation, data privacy, internal governance, and reputational risk. An NGO that accepts crypto should treat it not merely as a fundraising method, but as a regulated-risk transaction requiring board approval, proper documentation, valuation, reporting, controls, and conversion policies.

In Philippine practice, the safest position is this: an NGO may accept crypto donations if doing so is consistent with its corporate purposes, allowed by its internal rules, properly documented, not connected to illegal activity, accurately valued and reported, and handled through controls that reduce money-laundering, fraud, tax, and governance risks.

II. What Is a Crypto Donation?

A crypto donation is a voluntary transfer of a digital asset to an NGO without expectation of repayment, ownership interest, commercial return, or equivalent consideration. It may involve:

cryptocurrency such as Bitcoin or Ether;
stablecoins such as USDT or USDC;
tokens issued on a blockchain;
NFTs or other blockchain-based assets;
proceeds from a crypto exchange converted into Philippine pesos and donated to the NGO; or
crypto transferred to a wallet controlled by the NGO or by a third-party donation processor.

A distinction matters between receiving crypto itself and receiving pesos generated from crypto. If the donor sells crypto through an exchange and donates pesos to the NGO, the NGO receives a peso donation. If the NGO receives the token directly into its own wallet or through a custodian, then the NGO accepts a digital asset and must address custody, valuation, conversion, and reporting issues.

III. Is There a Philippine Law Prohibiting NGOs from Receiving Crypto?

There is no general Philippine prohibition against an NGO accepting crypto as a donation. Philippine law generally allows juridical persons, including non-stock corporations, to receive property by donation, subject to their legal capacity, corporate purpose, and applicable restrictions.

The Revised Corporation Code recognizes non-stock corporations, which may be organized for charitable, religious, educational, professional, cultural, scientific, civic, service, or similar purposes. A non-stock corporation does not distribute income to members, trustees, or officers as profit. Its income or assets must be used to further its stated purposes.

Crypto, while not legal tender in the Philippines, may be treated as a form of property or digital asset capable of being transferred, held, sold, or converted. The fact that cryptocurrency is not legal tender does not automatically prevent a private party from accepting it. Legal tender rules generally concern the compulsory acceptance of Philippine currency for payment of debts. Donations are voluntary transfers; the NGO is not required to accept crypto, but it may choose to do so if lawful and properly managed.

IV. Corporate Authority: Does the NGO Have Power to Accept Crypto?

The first legal question is internal authority. The NGO should examine its:

Articles of Incorporation;
By-Laws;
stated purposes;
board resolutions;
fundraising policies;
investment or treasury policies; and
donor acceptance policies.

Most NGOs have broad authority to receive donations, grants, gifts, contributions, and property in furtherance of their purposes. If the governing documents allow the receipt of donations generally, crypto may fall within that authority as a form of donated property.

However, crypto acceptance should ideally be expressly approved by the board of trustees. This is especially important because crypto involves volatility, cybersecurity, valuation issues, and possible exposure to illicit funds. The board should adopt a resolution authorizing the NGO to accept crypto donations and should approve a written crypto donation policy.

The board resolution should address:

which cryptocurrencies or tokens may be accepted;
whether the NGO will hold or immediately convert crypto;
who controls wallets or exchange accounts;
who approves acceptance or rejection of donations;
donor identification thresholds;
recordkeeping requirements;
valuation methodology;
accounting treatment;
AML and sanctions screening;
reporting to regulators, donors, auditors, and tax authorities; and
procedures for suspicious, anonymous, restricted, or high-risk donations.

V. The Non-Distribution Constraint

For non-stock non-profit corporations, the central rule is that no part of the organization’s income may be distributed as dividends or profits to members, trustees, or officers. Crypto donations, once accepted, become assets of the NGO and must be used for the NGO’s stated non-profit purposes.

This means the NGO should not use crypto donations for private benefit, insider trading, speculative enrichment, or personal wallet transfers. Any conversion, sale, or use of crypto must be for legitimate organizational purposes. Officers and trustees should not personally custody NGO crypto unless there are strict safeguards, written authorization, and segregation from personal assets.

VI. Is Crypto Legal Tender in the Philippines?

Cryptocurrency is not Philippine legal tender. The Philippine peso is the country’s legal tender. This matters because an NGO cannot insist that a debtor pay in crypto to discharge a peso obligation, nor can crypto be treated as official Philippine currency.

But non-legal-tender status does not mean crypto is illegal. Private parties may voluntarily agree to transfer or receive crypto, subject to applicable laws. For donations, the relevant question is not whether crypto is legal tender, but whether the NGO may receive property in that form and whether it complies with relevant regulatory, tax, accounting, and anti-money-laundering rules.

VII. Bangko Sentral ng Pilipinas Considerations

The Bangko Sentral ng Pilipinas regulates certain activities involving virtual assets, especially businesses that exchange, transfer, safekeep, or administer virtual assets for others. These businesses are commonly referred to as virtual asset service providers.

An NGO merely receiving crypto for its own account as a donation is not necessarily acting as a virtual asset service provider. The NGO is not automatically regulated as an exchange simply because it accepts a crypto gift. However, regulatory risk increases if the NGO:

accepts crypto on behalf of others;
converts crypto for third parties;
holds crypto for beneficiaries, donors, or partner organizations;
operates a platform for exchanging or transferring crypto;
facilitates crypto transactions as a service;
pools crypto assets for investment;
issues its own token; or
solicits the public to buy, trade, or invest in tokens.

If the NGO uses a Philippine-regulated exchange or custodian to convert crypto into pesos, the exchange will typically perform its own customer identification and transaction monitoring. This can reduce, but not eliminate, the NGO’s own risk.

VIII. Securities Regulation Issues

Most ordinary crypto donations do not involve securities. A donor simply gives digital assets to the NGO without receiving an ownership interest, profit participation, voting right, dividend, or investment return.

Securities issues may arise, however, if the NGO:

issues its own token to donors;
promises that tokens will appreciate in value;
sells tokens to raise funds;
offers revenue-sharing or profit-sharing arrangements;
creates a donor token with tradable economic rights;
promotes a crypto investment scheme; or
pools funds for crypto trading.

If the crypto fundraising model resembles an investment contract, security, or collective investment scheme, the Securities and Exchange Commission may have jurisdiction. A simple donation campaign should avoid investment language. Donor acknowledgments should make clear that the donor receives no ownership interest, investment return, or enforceable economic benefit.

IX. Tax Treatment of Crypto Donations

The Philippine tax treatment of crypto donations can be complex because tax rules often depend on the status of the donor, the donee, the nature of the property, the valuation, and whether the NGO is accredited or tax-exempt.

A. Income Tax Treatment for the NGO

A legitimate donation received by a non-stock non-profit organization is generally not treated in the same way as ordinary business income. However, tax-exempt status is not automatic for all NGOs and does not necessarily apply to all income. The NGO must consider whether it is:

a non-stock non-profit corporation;
a charitable institution;
a foundation;
an educational, religious, civic, or social welfare organization;
accredited by the Philippine Council for NGO Certification, where relevant;
registered with the Bureau of Internal Revenue; and
compliant with annual filing and reporting requirements.

If the NGO later sells crypto at a gain, tax questions may arise. For example, if the crypto appreciates between the date of donation and the date of sale, the NGO may need to consider whether any gain is taxable, exempt, or reportable depending on its status and the use of proceeds.

The safest approach is to record the donation at fair value upon receipt, document the date and time of receipt, document conversion proceeds, and consult a tax professional for classification.

B. Donor’s Tax

Donations in the Philippines may be subject to donor’s tax unless exempt. Whether a crypto donation is subject to donor’s tax depends on the donor, the donee, the nature of the donation, and applicable exemptions.

Donations to certain accredited or qualified charitable, religious, educational, social welfare, cultural, or non-profit institutions may be exempt from donor’s tax, provided statutory conditions are met. One common requirement is that not more than a specified portion of the donation is used for administration, with the balance used for the institution’s stated purposes.

For crypto donations, valuation is crucial. The donor and NGO should document the fair market value of the crypto at the time of donation, the exchange rate used, the source of price data, wallet transaction hash, and date and time of transfer.

C. Deductibility for Donors

A donor may want to claim the donation as a deduction. Deductibility depends on whether the NGO is qualified under Philippine tax rules and whether the donor complies with documentation requirements. Not every donation to every NGO is automatically deductible.

The NGO should avoid promising tax deductibility unless it is certain of its accreditation and the donor’s eligibility. A safer acknowledgment says that the NGO has received the donation and provides details of the transaction, while advising the donor to consult their own tax adviser regarding deductibility.

D. Value-Added Tax

A pure donation without sale of goods or services should generally not be treated as a VATable sale by the NGO. But if the NGO gives substantial goods, services, advertising, sponsorship rights, commercial exposure, or other benefits in exchange for the crypto, the transaction may be recharacterized partly or wholly as a sale, sponsorship, barter, or service arrangement. This can create VAT or income tax consequences.

X. Accounting and Valuation

Crypto donations should be recorded in the NGO’s books with care. The NGO should have a consistent valuation policy.

At minimum, the records should show:

donor name and identifying information, unless anonymous donations are allowed under the policy;
date and time of receipt;
type of crypto asset;
amount received;
wallet address used;
transaction hash;
fair value in Philippine pesos at the time of receipt;
source of exchange rate or pricing data;
conversion date, if sold;
peso proceeds received;
exchange fees or gas fees;
board or officer approval, if required; and
purpose restrictions, if any.

Crypto is volatile. A donation worth ₱1,000,000 in the morning may be worth significantly more or less by the afternoon. For this reason, many NGOs adopt an immediate-conversion policy: crypto donations are converted to pesos as soon as reasonably practicable after receipt. This reduces market risk and simplifies budgeting.

However, immediate conversion does not eliminate the need to record the value at receipt and the proceeds upon sale. Any difference between recorded value and sale proceeds should be properly accounted for.

XI. Anti-Money Laundering and Counter-Terrorism Financing Risk

Crypto donations create serious AML and counter-terrorism financing risks. Even if an NGO is not itself a covered person under the Anti-Money Laundering Act, it should still adopt prudent controls. NGOs can be vulnerable to abuse because donors may attempt to use charitable channels to launder funds, hide the source of assets, evade sanctions, or move value across borders.

An NGO should conduct donor due diligence proportionate to risk. Relevant risk factors include:

large donation amounts;
anonymous or pseudonymous donors;
privacy coins or mixers;
donations from high-risk jurisdictions;
donations inconsistent with the donor’s known profile;
funds linked to darknet markets, scams, ransomware, hacking, sanctions, terrorism, or fraud;
pressure for urgent transfers to third parties;
donations subject to unusual restrictions;
requests to refund crypto to a different wallet; and
use of multiple wallets to avoid thresholds.

The NGO should reserve the right to reject, freeze, return, or report a donation when there are red flags. It should not accept crypto that appears connected to criminal activity.

XII. Anonymous Crypto Donations

Crypto can be pseudonymous, but not necessarily anonymous. Blockchain transactions may be visible, but wallet ownership may be unknown.

An NGO may receive anonymous donations, but anonymous crypto donations are higher risk. A prudent policy should set thresholds. For example:

small low-risk donations may be accepted with limited information;
medium-sized donations may require name, contact information, and donor declaration;
large donations should require identity verification, source-of-funds information, sanctions screening, and board or officer approval;
donations involving privacy coins, mixers, sanctioned addresses, or suspicious patterns should be rejected.

The NGO should also consider whether anonymous donations are consistent with its own governance rules, grant obligations, donor restrictions, and reporting commitments.

XIII. Foreign Donations

Crypto donations may come from foreign donors. The NGO must consider:

foreign currency and cross-border reporting issues;
sanctions and restricted-party risks;
AML risks involving foreign wallets or exchanges;
donor’s tax consequences;
conditions attached to foreign funding;
registration or reporting obligations with Philippine regulators;
restrictions under special laws, where applicable; and
reputational issues involving politically exposed persons or foreign state-linked donors.

If the NGO is involved in advocacy, election-related activity, political education, governance reform, or public policy work, foreign funding must be handled with special caution. Philippine laws restrict foreign participation in certain political and election-related activities. A crypto donation should not be used to obscure prohibited foreign influence.

XIV. Data Privacy

Crypto donation processing may involve collecting donor names, wallet addresses, identification documents, tax information, contact details, and source-of-funds declarations. These are personal data under Philippine data privacy law.

The NGO should have a privacy notice explaining:

what donor data is collected;
why it is collected;
legal basis for processing;
retention period;
who has access;
whether data is shared with exchanges, payment processors, auditors, regulators, or banks;
donor rights; and
contact details for privacy concerns.

The NGO should avoid publishing wallet addresses, donor identities, or transaction details in a way that compromises privacy unless the donor has consented or disclosure is legally required.

XV. Cybersecurity and Custody

Crypto custody is one of the most important practical issues. If the NGO controls its own wallet, loss of private keys may permanently destroy access to the funds. Theft, phishing, malware, insider fraud, or mistaken transfers can also cause irreversible loss.

Recommended safeguards include:

using reputable regulated exchanges or custodians where appropriate;
avoiding personal wallets of officers or staff;
using multi-signature wallets for significant holdings;
requiring dual approval for transfers;
separating fundraising wallets from operating wallets;
limiting access to private keys;
storing recovery phrases securely offline;
prohibiting key storage in ordinary email, chat, or cloud notes;
maintaining a wallet access register;
requiring board oversight for large transactions;
using hardware wallets where self-custody is necessary;
periodically reviewing access rights;
documenting all transactions; and
having an incident response plan.

The NGO should never allow one person to have unchecked control over crypto assets.

XVI. Should the NGO Hold Crypto or Convert It Immediately?

An NGO may decide to hold crypto, convert it immediately, or use a hybrid approach. From a legal-risk and governance perspective, immediate conversion is often safer.

A. Advantages of Immediate Conversion

Immediate conversion:

reduces volatility risk;
simplifies accounting;
avoids speculation concerns;
makes budgeting easier;
reduces custody risk;
helps ensure funds are used for charitable purposes;
minimizes the risk of trustees being accused of imprudent investment; and
reduces audit complexity.

B. Risks of Holding Crypto

Holding crypto exposes the NGO to:

price volatility;
liquidity risk;
cybersecurity risk;
custody failures;
possible impairment or valuation issues;
donor criticism if value falls;
regulatory uncertainty;
board accountability for investment decisions; and
questions about whether the NGO is speculating with charitable assets.

If the NGO chooses to hold crypto, the board should adopt an investment policy expressly allowing digital assets and defining limits, risk controls, permitted assets, custody requirements, reporting, and exit rules.

XVII. Restricted Donations

A donor may attach restrictions to a crypto donation, such as requiring that funds be used for disaster relief, scholarships, medical assistance, legal aid, or a specific project.

The NGO should accept restricted donations only if:

the restriction is lawful;
the restriction is consistent with the NGO’s purposes;
the NGO can comply administratively;
the restriction does not create private benefit;
the restriction does not require unlawful discrimination;
the restriction does not compromise independence;
the restriction does not involve prohibited political activity; and
the restriction is documented in writing.

The NGO should not accept a restriction requiring it to transfer crypto to a third-party wallet without proper vetting. That may indicate money laundering, sanctions evasion, or misuse of the NGO.

XVIII. Refunds and Return of Crypto Donations

Refunds require caution. A common crypto laundering tactic is to donate crypto and then ask for a refund to a different wallet, bank account, or person.

A crypto donation policy should provide that:

donations are generally final;
refunds are discretionary and subject to legal review;
refunds, if allowed, should be returned only to the original sending wallet or verified donor account where lawful and feasible;
refunds may be made in pesos rather than crypto;
refunds are not allowed if there are AML, sanctions, fraud, or legal concerns;
the NGO may deduct transaction fees or losses where appropriate; and
the NGO may report suspicious transactions to competent authorities.

XIX. Use of Third-Party Crypto Donation Processors

Many NGOs prefer to use a crypto donation processor rather than directly custody crypto. A processor may:

receive crypto from donors;
convert it into fiat;
remit pesos or foreign currency to the NGO;
issue transaction reports;
conduct compliance screening;
provide donor receipts; and
reduce custody risks.

However, the NGO should conduct due diligence on the processor. It should review:

regulatory status;
location and licensing;
AML controls;
sanctions screening;
fees;
conversion timing;
custody arrangements;
data privacy terms;
cybersecurity standards;
reporting format;
dispute procedures;
contractual liability; and
termination rights.

Using a processor does not fully transfer legal responsibility. The NGO remains responsible for its own governance, records, donor policies, and use of funds.

XX. Banks and Off-Ramping Issues

Even if accepting crypto is lawful, banks may scrutinize peso deposits derived from crypto conversion. Philippine banks may ask for:

proof of donation;
donor information;
transaction history;
exchange records;
source of funds;
board resolution;
NGO registration documents;
tax registration;
audited financial statements; and
AML policies.

The NGO should maintain a complete documentation trail so it can explain crypto-related deposits to banks, auditors, and regulators.

XXI. Receipts and Donor Acknowledgments

The NGO should issue a written acknowledgment for crypto donations. It should include:

NGO name;
donor name, unless anonymous;
date and time of receipt;
type and amount of crypto;
wallet address or transaction hash;
peso value at time of receipt;
valuation source;
statement that no goods or services were provided in exchange, if true;
restrictions, if any;
whether the donation was converted to pesos;
disclaimer that tax deductibility depends on applicable law and donor circumstances; and
authorized signature or official electronic confirmation.

The acknowledgment should avoid guaranteeing a tax benefit unless the NGO is legally certain.

XXII. Sample Crypto Donation Policy Clauses

An NGO’s crypto donation policy may include the following principles:

The NGO may accept cryptocurrency donations only in furtherance of its lawful non-profit purposes.
The board authorizes management to accept only approved crypto assets.
The NGO may reject donations from anonymous, high-risk, sanctioned, suspicious, or unlawful sources.
The NGO will generally convert crypto donations into Philippine pesos as soon as reasonably practicable unless the board approves holding the asset.
The NGO will record the fair value of crypto donations in Philippine pesos at the time of receipt.
The NGO will maintain records of wallet addresses, transaction hashes, conversion records, donor information, and restrictions.
No officer, trustee, employee, or volunteer may use a personal wallet to receive NGO crypto donations unless expressly authorized in writing under emergency procedures.
Transfers from NGO wallets require at least two authorized approvals.
The NGO will comply with applicable tax, accounting, AML, data privacy, and reporting obligations.
Refunds are discretionary and subject to review.
The NGO will not issue tokens, investment rights, profit-sharing interests, or tradable benefits to donors without legal review.
The policy will be reviewed periodically due to the evolving nature of crypto regulation.

XXIII. Governance Duties of Trustees and Officers

Trustees and officers of an NGO have fiduciary duties. They must act in good faith, with diligence, loyalty, and care. Accepting crypto without adequate controls may expose them to criticism or liability if the NGO suffers losses due to volatility, theft, fraud, or regulatory non-compliance.

Good governance requires:

board-level authorization;
risk assessment;
written policies;
segregation of duties;
transparent accounting;
audit trails;
donor screening;
periodic reporting to the board;
conflict-of-interest controls; and
legal and tax review for significant donations.

Trustees should avoid treating crypto acceptance as a casual technology decision. It is a financial governance decision.

XXIV. Public Solicitation and Fundraising Materials

When soliciting crypto donations from the public, an NGO should ensure that its public materials are accurate and not misleading.

Fundraising pages should state:

the NGO’s legal name;
registration details;
purpose of the campaign;
accepted crypto assets;
whether donations are converted to pesos;
whether donations are refundable;
whether donor information is required;
whether donors receive goods, services, or benefits;
tax acknowledgment language;
privacy notice; and
contact information.

The NGO should avoid language implying that donors are investing, buying tokens, earning returns, joining a profit-sharing project, or receiving financial upside.

XXV. Political, Election, and Advocacy Restrictions

NGOs engaged in advocacy should be careful when accepting crypto donations, especially from foreign donors or anonymous sources. Philippine law is sensitive to foreign participation in elections and certain political activities.

Crypto should not be used to hide the source of funds for:

election campaigns;
partisan political activity;
candidate support;
political advertisements;
campaign-related expenditures;
prohibited lobbying or influence operations; or
activities restricted by law.

If the NGO works in governance, human rights, policy advocacy, election monitoring, or public-sector reform, it should apply enhanced due diligence to crypto donations and document independence from donor control.

XXVI. Disaster Relief and Emergency Fundraising

Crypto donations may be useful during disasters because they allow fast cross-border transfers. However, emergency conditions also increase fraud and compliance risks.

For disaster campaigns, the NGO should:

publish official wallet addresses only through verified channels;
warn donors against fake wallets;
use separate wallets per campaign where feasible;
immediately convert funds if needed for relief operations;
maintain transparent public reporting;
document disbursements;
screen large or unusual donations; and
avoid transferring crypto directly to unverified beneficiaries or local partners.

XXVII. NFTs and Non-Fungible Token Donations

NFT donations raise additional issues. Unlike major cryptocurrencies, NFTs can be difficult to value and liquidate. Their value may depend on market hype, intellectual property rights, authenticity, royalties, and platform liquidity.

Before accepting an NFT, the NGO should ask:

Who owns the NFT?
Does the donor have the right to transfer it?
Does it include copyright or only token ownership?
Is there an active market?
How will the NGO value it?
Can it be sold?
Are there royalties or transfer restrictions?
Is the NFT connected to fraud, stolen art, or sanctions?
Will accepting it damage the NGO’s reputation?

Many NGOs should accept NFTs only after specific legal and board review.

XXVIII. Stablecoins

Stablecoins may appear less risky because they are designed to track fiat currency, usually the U.S. dollar. However, they still involve risk.

Stablecoin risks include:

issuer risk;
reserve risk;
de-pegging risk;
sanctions risk;
smart contract risk;
chain risk;
exchange risk;
custody risk; and
regulatory risk.

A stablecoin donation should not be treated as equivalent to a bank deposit. It remains a digital asset and should be subject to crypto controls.

XXIX. When Should an NGO Refuse a Crypto Donation?

An NGO should consider refusing a crypto donation when:

the donor refuses reasonable identity checks for a large donation;
the funds appear linked to illegal activity;
blockchain analytics indicate exposure to hacks, scams, ransomware, darknet markets, mixers, or sanctioned addresses;
the donor demands secrecy inconsistent with law or governance;
the donor imposes improper restrictions;
the donation would compromise the NGO’s independence;
the crypto asset is illiquid or impossible to value;
accepting it would violate grant agreements or internal policy;
the donor requests a suspicious refund arrangement;
the cost of compliance exceeds the value of the donation; or
acceptance would create serious reputational harm.

The power to accept donations includes the power to reject them.

XXX. Practical Compliance Checklist

Before accepting crypto donations, a Philippine NGO should complete the following checklist:

Review Articles of Incorporation and By-Laws.
Confirm that accepting donations is within the NGO’s purposes.
Obtain board approval.
Adopt a crypto donation policy.
Decide whether to hold or immediately convert crypto.
Select permitted crypto assets.
Establish wallet or custodian arrangements.
Prohibit use of personal wallets.
Implement dual-control approvals.
Create donor due diligence thresholds.
Prepare AML and sanctions screening procedures.
Prepare donor acknowledgment templates.
Establish valuation methodology.
Coordinate with accountant and auditor.
Review tax consequences.
Prepare privacy notice.
Train staff handling donations.
Maintain records of all transactions.
Review bank off-ramp requirements.
Periodically report crypto activity to the board.

XXXI. Suggested Board Resolution Language

The board may adopt language similar to the following:

“RESOLVED, that the Corporation is authorized to accept donations in cryptocurrency and other digital assets, subject to applicable law, the Corporation’s Articles of Incorporation and By-Laws, and such policies as may be approved by the Board;

RESOLVED FURTHER, that management is authorized to establish accounts, wallets, custody arrangements, and relationships with regulated exchanges or service providers for the limited purpose of receiving, converting, safeguarding, and accounting for crypto donations;

RESOLVED FURTHER, that crypto donations shall generally be converted into Philippine pesos as soon as reasonably practicable unless otherwise approved by the Board;

RESOLVED FURTHER, that the Corporation shall maintain appropriate donor due diligence, anti-money laundering, sanctions screening, cybersecurity, accounting, tax, and recordkeeping controls;

RESOLVED FINALLY, that management shall submit periodic reports to the Board regarding crypto donations received, converted, rejected, refunded, or held.”

XXXII. Legal Risk Summary

The main risks are not caused by the mere act of accepting crypto. The risks arise from poor controls. The most important legal and operational risks are:

accepting funds from illegal or sanctioned sources;
failing to identify high-risk donors;
treating crypto as informal money outside accounting records;
using personal wallets;
losing private keys;
failing to value donations properly;
promising tax deductibility without basis;
issuing tokens that may be treated as securities;
engaging in exchange or custody activity without understanding regulatory implications;
using foreign crypto funds for restricted political activities;
failing to protect donor personal data;
suffering losses from volatility; and
failing to document board authority and audit trails.

XXXIII. Conclusion

An NGO in the Philippines is generally allowed to accept crypto donations. Cryptocurrency is not legal tender, but it may be voluntarily received as a form of donated property. The legality of acceptance depends on the NGO’s corporate authority, non-profit purpose, governance controls, tax treatment, AML safeguards, accounting records, donor due diligence, and compliance with applicable regulations.

The most prudent approach is for the NGO to secure board approval, adopt a written crypto donation policy, accept only approved assets, screen donors and wallets based on risk, avoid personal custody, use reputable exchanges or custodians, record the peso value at the time of receipt, issue careful acknowledgments, and generally convert crypto to pesos promptly unless the board has approved a specific holding strategy.

In short: crypto donations are not prohibited, but they should not be accepted casually. For a Philippine NGO, the lawful path is governance first, compli