Key jurisdictions across the globe are changing their regulatory postures on cryptocurrency to better balance innovation and oversight and attract major industry players to their shores.
The US has reversed course under President Trump’s second term, introducing pro-crypto policies, clearer regulatory boundaries, and new laws like the GENIUS Act and CLARITY Act, focusing on stablecoins and market clarity. Meanwhile, the UK adopts a consultative approach via the FCA, focusing on stablecoins and custody through industry feedback. The EU, already implementing MiCAR, offers a unified regulatory framework, though transition challenges persist, particularly for stablecoin compliance. Singapore leads in Asia with a licensing regime under the MAS, strong AML controls, and stablecoin regulations supporting responsible innovation and asset tokenization. The UAE offers a layered regulatory model via free zones like ADGM and DIFC, with Dubai’s VARA and Abu Dhabi’s FSRA tailoring rules for both innovation and institutional-grade oversight.
For firms, success in this complex landscape depends on understanding jurisdictional differences, participating in regulatory consultations, and maintaining agile, well-resourced compliance programs. Adapting to evolving rules is crucial not only to minimize risk but also to capture strategic opportunities in the rapidly maturing crypto ecosystem.