The Most Recent Crypto Regulations Around the World

What words do we associate with cryptocurrencies? In the public consciousness, you would not be surprised to hear words like volatile, decentralized, risky, innovative, and unregulated. This reflects the journey that this asset class has taken since its inception. Cryptocurrencies have progressed at vastly different speeds across so many markets, and there are a range of good stories, and a fair amount of bad stories, too.

So, crypto regulation is anything but uniform. Unlike traditional financial markets that generally follow harmonized frameworks, the global crypto trading space is still a regulatory patchwork. In some countries, digital assets are embraced as engines of innovation; in others, they’re banned outright. In this article, we will tell you the latest crypto regulations in markets around the world.

Remember, with crypto, the only constant is change, so what is true at the time of writing could be out of the window tomorrow.

A brief history of crypto regulation

Why do governments feel they need to regulate crypto? Let’s get real. Governments feel the need to regulate crypto because it offers a potential challenge to the existing financial order, which is built around fiat currencies, central banks, and tightly controlled monetary systems.

Fiat money remains the globally accepted standard for trade, taxation, and sovereign economic policy. Cryptocurrencies, by design, operate outside these centralized frameworks, making it harder for governments to monitor capital flows, enforce anti-money laundering (AML) laws, collect taxes, and manage economic stability.

In this regard, it’s easy to understand why governments are keeping such a close eye on crypto. You will hear all sorts of valid reasons why this is the case:

• Unregulated crypto markets can facilitate illicit finance,

• They can enable tax evasion,

• They can destabilize monetary systems through speculative bubbles, and

• They can create vulnerabilities in investor protection and lead to scams.

Ultimately, regulation is a way to reassert governmental control, ensure financial transparency, and integrate digital assets into the broader financial system without allowing them to undermine sovereign economic authority. Governments don’t necessarily oppose innovation.

However, as hawkish as governments are, many policymakers (albeit begrudgingly) accept that innovation drives the world forward, and cryptocurrencies are doing exactly that, dragging finance out of stuffy boardrooms and into decentralized, real-time networks that anyone with Wi-Fi can access.

It’s messy, chaotic, and yes, wildly volatile, but so was every great invention before it changed the world. If history teaches us anything, it’s that progress doesn’t wait for permission. So, that said, where do the major economies currently stand when it comes to crypto regulation?

I. United States: The Tug-of-War for Jurisdiction

With Donald Trump in the White House for the second time, there is every chance that crypto regulation in this country takes a quantum leap as Trump is aggressively in favor of deregulating crypto. To be fair, critics question the level of Trump’s skin in the game, alleging that he is feathering his own nest and those of his friends, but it’s a bigger industry than just this single, albeit highly influential man.

The US has seen a fragmented and often contentious regulatory landscape. A "regulation by enforcement" approach, primarily led by the Securities and Exchange Commission (SEC), has characterized much of the past five years, leading to a lack of clear federal guidelines.

Lawmakers have struggled to pass comprehensive legislation, while states have also taken varied stances. Recent shifts in the political landscape, including statements from the current Trump administration, suggest a potential pivot toward a more innovation-friendly approach, though clarity is still somewhat hard to come by.

Current Standing & Legislation:

Regulatory Agencies:

SEC: Continues to assert jurisdiction over many cryptocurrencies, classifying them as "securities" under the Howey Test. It has pursued numerous enforcement actions against crypto companies for unregistered offerings, exchanges, and lending platforms. Gary Gensler (SEC Chair appointed by President Biden) had a stance that was broadly seen as cautious and enforcement-heavy.

Donald Trump began his second term as President and ensured there would be significant changes in the leadership and priorities of the SEC. Paul Atkins was confirmed as Chair, and has so far been far more permissive of cryptocurrency activities by:

• Prioritizing formal rulemaking over "regulation by enforcement"

• Focusing on clear guidelines for crypto issuance, custody, and trading

• Reversing restrictive policies like SAB 121 and withdrawing stifling proposed rules

• Promoting innovation through "innovation exemptions" and adapting legacy rules

Commodity Futures Trading Commission (CFTC): This body views Bitcoin and Ethereum (and potentially others) as "commodities" and regulates derivatives based on them. It advocates for its expanded role in regulating the spot crypto market.

Financial Crimes Enforcement Network (FinCEN): Focuses on Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) for virtual asset service providers (VASP), requiring registrations as Money Services Businesses (MSB).

Office of the Comptroller of the Currency (OCC), Federal Reserve (FDIC): Have recently rescinded prior cautionary joint statements regarding banks engaging with digital assets (as of May 2025). This is a massive shift, as it instantly gives banks greater freedom to operate directly in crypto (e.g., custody services) and provide banking to crypto businesses, provided they maintain proper risk management. This aims to open doors for traditional financial institutions.

Key Legislation in Place (or its interpretation):

• No single comprehensive federal crypto law.

• Existing securities laws (e.g., Securities Act of 1933, Securities Exchange Act of 1934) are applied to crypto assets.

• Bank Secrecy Act (BSA) under FinCEN.

• State-level "BitLicense" in New York and other state-specific regulations for money transmitters.

Suggested Legislation:

Stablecoin legislation: There currently is strong bipartisan interest in establishing a federal framework for stablecoins, with the Senate advancing relevant bills as of May 2025. This is seen as a priority for the current Trump administration.

Market structure bills: Various proposals (e.g., Lummis-Gillibrand bill, Financial Innovation and Technology for the 21st Century Act - FIT21) are aimed at clarifying jurisdiction between the SEC and CFTC, defining different types of digital assets, and establishing consumer protection frameworks. These have faced legislative hurdles but remain a focus. Why is this important? Because it will allow clear regulatory ownership to be placed under defined agency control.

Administration's Stance: The second Trump administration has expressed a strong desire to make the US the "crypto capital of the world," advocating for pro-crypto legislation and establishing a strategic bitcoin reserve.

The Fed’s (Central Bank) Stance:

• It has previously expressed concerns about financial stability risks, consumer protection, and illicit finance associated with crypto.

• Acknowledges the potential for innovation but maintains a cautious approach regarding mainstream adoption of unbacked crypto assets.

• Continues to explore a Central Bank Digital Currency (CBDC) - "Digital Dollar" research and development, but no firm commitment to issuance, with mixed political support. The recent withdrawal of prior crypto directives for banks suggests a more pragmatic, though still risk-aware, engagement with digital assets.

II. Canada: Regulating Financial Intermediaries

Canada has generally adopted a more pragmatic approach than the US, focusing on regulating crypto as financial instruments and service providers.

The emphasis has been on investor protection, AML/CFT, and market integrity, largely through existing securities and money service business frameworks. There has often been a clear push to integrate crypto into the traditional financial system rather than an outright ban.

Current Standing & Legislation:

Securities regulators (CSA, OSC): The Canadian Securities Administrators (CSA), in coordination with provincial regulators like the Ontario Securities Commission (OSC), have clarified that many crypto assets, especially those involving an investment contract, fall under securities law.

National Instrument 31-103 (NI 31-103): Crypto asset trading platforms (CTP) are generally required to register as investment dealers and comply with securities regulations, including know-your-client (KYC) and custody requirements.

(Financial Transactions and Reports Analysis Centre of Canada (FINTRAC): This body regulates Money Services Businesses (MSB), which include virtual asset dealers and exchanges, for AML/CFT purposes.

Office of the Superintendent of Financial Institutions (OSFI): It has issued guidelines for federally regulated financial institutions (FRFI) on capital and liquidity treatment of crypto-asset exposures, setting limits on exposure (e.g., typically not higher than 1% of Net Tier 1 capital for Group 2 crypto-assets).

Legislation in Place: Application of existing securities laws, AML/CFT laws, and OSFI guidelines.

Suggested Legislation:

Tax reporting: Canada is committed to adopting the OECD's Crypto-Asset Reporting Framework (CARF) by 2027, with implementation proposed for 2026, increasing tax transparency and reporting requirements for crypto service providers.

Central Bank (Bank of Canada) Stance:

It monitors crypto asset markets for potential systemic risks but currently views them as not posing a significant threat to Canada's financial system due to limited interconnectedness with traditional finance.

That said, the central bank acknowledges the investment interest in Bitcoin but notes its limited use for payments.

It continues research into the potential need for a Central Bank Digital Currency (CBDC), but no decision has been made on its issuance. Focuses on the potential for CBDCs to enhance payments system efficiency and resilience.

III. United Kingdom: "Technology Neutral" but Robust Framework

The UK has aimed for a "technology-neutral" approach, intending to regulate crypto based on its function rather than its underlying technology.

While initially slower than the EU, the UK has been actively developing a comprehensive regulatory framework, particularly for stablecoins and broader crypto activities, regardless of the trading strategy, emphasizing innovation while mitigating risks.

Current Standing & Legislation:

Financial Conduct Authority (FCA): The primary regulator for crypto in the UK has focused on consumer protection, financial promotions, and AML/CFT. Firms involved in crypto activities often need to register with the FCA for AML purposes.

HM Treasury: Has been leading the policy development for the future regulatory regime.

Financial Services and Markets Act (FSMA) 2000 (Amendments): Draft legislation was published in April 2025 to bring a wider range of cryptoasset activities within the regulatory remit. This includes:

• Defining "qualifying cryptoassets" and "qualifying stablecoins" as specified investments

• Classifying activities like operating a cryptoasset trading platform, dealing in cryptoassets as principal, and safeguarding cryptoassets as regulated activities, requiring FCA authorization

• Applying the Financial Promotion Order (FPO) to cryptoasset promotions

• Amending Money Laundering Regulations (MLR)

Stablecoin Regulation: There are specific proposals for issuing fiat-referenced stablecoins, requiring issuers to maintain one-to-one reserves and be authorized by the FCA. These are a key focus for implementation soon.

Digital Securities Sandbox (DSS): Launched in September 2024 by the FCA and Bank of England to enable firms to test digital asset technology in financial markets under a "test" regulatory regime.

Legislation in Place: Primarily existing AML/CFT regulations (Money Laundering Regulations 2017) and financial promotion rules.

Suggested Legislation:

The draft legislation mentioned above, with a strong intent for parliamentary approval and implementation in 2026, including final FCA rules. Further consultations are ongoing (e.g., on stablecoin issuance and crypto custody).

Central Bank (Bank of England) Stance:

• It works closely with HM Treasury and FCA on the regulatory framework, particularly for systemic stablecoins.

• Welcomes proposals for stablecoin regimes, seeing potential for efficiency in payments. For systemic stablecoins, the Bank of England will publish complementary consultation papers.

• Actively exploring the possibility of a digital pound (CBDC), currently in the research and design phase, but no decision on issuance has been made. Views it as a potential complement to cash, not a replacement, for future payments.

IV. Eurozone: MiCA Leading the Way

The Eurozone has become a frontrunner in comprehensive crypto regulation, resulting in the landmark Markets in Crypto-Assets (MiCA) regulation.

The purpose of this proactive approach is to create a harmonized legal framework across all 27 EU member states, providing legal certainty for businesses and investors.

Current Standing & Legislation:

MiCA (Markets in Crypto-Assets) Regulation: This is the cornerstone.

■ Status: Entered into full force in December 2024, with various provisions having phased application dates.

■  Scope: Covers the issuance, marketing, and trading of crypto-assets (excluding NFTs, though this is under review) and related services.

Key Provisions:

Authorization for CASPs: Crypto-asset service providers (CASP) must be authorized by national competent authorities (NCA) and meet stringent requirements (e.g., capital, governance, consumer protection, conflict-of-interest management).

Stablecoin Regulation: Specific rules for "asset-referenced tokens" (ART) and "e-money tokens" (EMT), requiring issuers to be authorized and maintain reserves.

Market Abuse: There are strong provisions to prevent insider trading and market manipulation in crypto.

Whitepapers: Regulators have introduced requirements for issuers of crypto assets to publish whitepapers with clear and fair information.

Passporting: Once authorized in one EU member state, CASPs can "passport" their services across the entire Eurozone.

Transfer of Funds Regulation (TFR): Requires crypto service providers to collect and share information on senders and recipients of crypto transfers, aligning with FATF "travel rule" recommendations.

Digital Operational Resilience Act (DORA): Enhances cybersecurity and operational resilience requirements for financial entities, including crypto firms.

Legislation in Place: MiCA is the primary comprehensive regulation. TFR and DORA also apply.

Suggested Legislation:

While MiCA is largely in place, the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) are continually developing Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) to operationalize MiCA, refining specific aspects. Potential future legislative reviews might address areas like DeFi or NFTs in greater detail.

Central Bank (European Central Bank - ECB) Stance:

So, the ECB views cryptocurrencies as risky, volatile, and not suitable as a reliable store of value or means of payment due to their inherent instability.

It raises concerns about financial stability risks, particularly with growing interconnectedness between crypto and traditional finance, and a lack of visibility into non-bank financial institutions' crypto activities.

It is actively exploring the development of a digital euro (CBDC), seeing it as a way to safeguard strategic autonomy, monetary sovereignty, and enhance the payment system for EU businesses and individuals, rather than relying on private stablecoins or foreign digital currencies.

V. China: The Great Firewall for Crypto

China has pursued one of the world's most aggressive and comprehensive crackdowns on cryptocurrency activities. Starting with restrictions on exchanges and ICOs, it escalated to an effective blanket ban on crypto mining and trading, citing financial stability risks, energy consumption concerns, and illicit activities.

This approach is a major contrast to its parallel push for blockchain technology development and a central bank digital currency.

Current Standing & Legislation:

Outright Ban:

People's Bank of China (PBOC) and other regulators (September 2021): Issued a joint notice (Notice No. 237) declaring all cryptocurrency-related transactions illegal, including trading, order matching, token issuance, and derivatives.

Mining Ban: Significant crackdown on crypto mining operations, forcing most miners to relocate out of mainland China.

Overseas Platforms: Providing online crypto services to Chinese residents by overseas platforms is also considered illegal.

Exemptions: China has generally not banned blockchain technology itself, recognizing its potential for various applications outside of speculative crypto trading.

Hong Kong: Notably, Hong Kong operates under a separate regulatory regime. It has been actively establishing itself as a crypto hub, with a licensing regime for virtual asset trading platforms (VASP) launched in June 2023, allowing licensed exchanges to offer retail trading services. This creates a significant contrast with mainland China.

Legislation in Place: Regulatory notices and directives from various government bodies; legal framework for prohibiting crypto activities.

Suggested Legislation:

While a ban is in place, the primary "mooted" development is the continued expansion and official launch of China's CBDC. Hong Kong, however, is exploring enhanced digital asset regulations, including for stablecoins.

Central Bank (People's Bank of China - PBOC) Stance:

This body strongly opposes speculative crypto trading and private cryptocurrencies, viewing them as a threat to financial stability, monetary sovereignty, and a facilitator of illicit activities.

It is also actively developing and piloting the digital yuan (e-CNY), its own Central Bank Digital Currency (CBDC). This is a strategic priority aimed at modernizing the payment system, enhancing financial inclusion, and potentially challenging the dominance of traditional payment networks and foreign currencies. The PBOC's focus is on a centrally controlled digital currency.

VI. Japan: Balancing Innovation and Investor Protection

Japan was an early mover in crypto regulation, particularly after the Mt. Gox hack. Its approach has focused on regulating crypto exchanges and assets as financial instruments, emphasizing consumer protection, AML/CFT, and fostering innovation within a regulated environment. It has often been seen as one of the more crypto-friendly major economies.

Current Standing & Legislation:

Payment Services Act (PSA): This act was amended to define cryptocurrencies as "crypto-assets" and require crypto exchanges to be registered with the Financial Services Agency (FSA). It imposes strict requirements on exchanges, including segregation of client assets and robust AML/CFT measures.

Financial Instruments and Exchange Act (FIEA): Applies to crypto assets that resemble securities ("security tokens"), bringing them under the scope of existing securities regulations.

New Stablecoin Law (Effective June 2023): Recognized stablecoins as digital money, requiring them to be linked to the yen or other fiat currencies and guaranteeing redemption at face value. Only licensed banks, trust companies, and registered money transfer agents can issue stablecoins. This is a significant step toward clear stablecoin regulation.

Recent Legislative Action (Post-DMM Bitcoin Hack - May 2024): Japan has enacted a stringent new law mandating domestic custody of customer assets for crypto exchanges and enhancing AML measures. This was a direct response to a significant hack, aiming to restore investor confidence and ensure asset recoverability. It also authorizes direct crypto usage within apps.

Legislation in Place: Amended PSA, FIEA, and the new Stablecoin Law.

Suggested Legislation:

Tax Reform: The ruling Liberal Democratic Party's Web3 Project Team has proposed classifying crypto-assets as a distinct asset class under FIEA and shifting tax treatment from miscellaneous income (high progressive rates) to a flat 20% separate financial income taxation, with loss carry-forward provisions. This signals a desire to make Japan more attractive for crypto businesses.

Central Bank (Bank of Japan - BOJ) Stance:

Monitors crypto developments closely, acknowledging their potential impact on financial stability.

Has been actively engaged in experiments and research regarding a Central Bank Digital Currency (CBDC) - "Digital Yen." Currently in the proof-of-concept phase, exploring technical feasibility and potential use cases, but no decision on issuance has been made. The BOJ's cautious approach emphasizes extensive public and private sector engagement.

While not directly regulating crypto, the BOJ's monetary policy decisions (e.g., quantitative easing/tightening) can indirectly influence capital flows into risk assets like crypto.

VII. South America: A Diverse and Evolving Landscape

South America has a highly diverse crypto regulatory landscape, driven by a lot of economic conditions, inflation rates, and political priorities. While some nations have embraced crypto due to economic instability or for financial inclusion, others have taken a more cautious or even prohibitive stance. However, the region remains a hotbed for crypto adoption, particularly for payments and as an inflation hedge.

Current Standing & Legislation (Focus on major economies):

Brazil:

Approach: Progressive and relatively clear. It recognizes crypto assets as a legitimate investment class, so, you could take advantage of a crypto bear market with confidence if you were a regular trader..

Legislation (Law 14.478/2022): Came into effect in June 2023. Establishes a legal framework for crypto-asset services, defining them as "virtual assets" and requiring Virtual Asset Service Providers (VASP) to be licensed by the Central Bank of Brazil (BCB) or the Brazilian Securities Commission (CVM), depending on the asset's classification. Focuses on AML/CFT and consumer protection.

Mooted: Ongoing discussions about specific regulations for stablecoins and clearer definitions within the existing law.

Argentina:

Approach: High crypto adoption due to persistent inflation and capital controls. The regulatory approach has been evolving, although sometimes contradictory.

Current Standing: No comprehensive crypto-specific law. Crypto assets are generally treated as intangible assets for tax purposes. The central bank (BCRA) has issued some restrictions.

Legislation: Application of existing tax laws.

Central Bank Ban (May 2023): The Central Bank of Argentina prohibited financial institutions from offering crypto-related services to customers, citing risks to financial stability and consumer protection.

Mooted: Various legislative proposals have been mooted to regulate crypto assets, often with a focus on investor protection and AML/CFT, but none have passed comprehensively.

Colombia:

Approach: Adopting an innovative approach, including regulatory sandboxes.

Current Standing: No specific crypto law, but the financial regulator, Superintendencia Financiera de Colombia (SFC) has launched a regulatory sandbox program (La Arenera) to allow controlled testing of crypto-related business models.

Legislation: Crypto exchanges operate under existing financial regulations, primarily concerning AML/CFT.

Mooted: Development of a comprehensive crypto regulation is anticipated, informed by the sandbox experiments.

Chile:

Developing a regulatory framework that integrates fintech and crypto.

Current Standing: The Financial Market Commission (CMF) supervises financial institutions, and crypto exchanges are subject to AML regulations.

Fintech Law (Passed 2023): This law includes provisions for crypto assets and service providers, aiming to regulate a broad spectrum of fintech activities, including those involving digital assets.

Mooted: Further secondary regulations and specific guidelines under the Fintech Law are expected.

El Salvador: (We’re giving you a brief mention for context, as it's an outlier)

Approach: Bitcoin became legal tender in September 2021.

Legislation: Bitcoin Law. Issued Bitcoin bonds.

Central Bank: The Central Bank of El Salvador (BCR) supervises traditional financial institutions, but the country's unique Bitcoin adoption creates a distinct financial landscape. The IMF has repeatedly advised caution against its legal-tender status.

Central Banks' Stance

They are generally cautious, citing volatility, consumer protection, and financial stability risks.

Many are actively researching and exploring Central Bank Digital Currencies (CBDC) as a safer alternative to private crypto, aiming to enhance financial inclusion, reduce costs, and strengthen payment systems.

Brazil's Central Bank (BCB): Is developing its own CBDC, the "Digital Real," with advanced proof-of-concept stages, aiming to enhance asset tokenization.

Argentina's Central Bank (BCRA): Has taken a prohibitory stance on banks offering crypto services due to financial risks, while the country grapples with high crypto adoption.

The IMF has noted the potential benefits of CBDCs in LAC for financial inclusion and payment system resilience, while advising caution on unbacked crypto assets.

The bottom line

The global crypto regulatory landscape is made up of several different approaches. Some countries are sprinting to embrace digital assets as engines of progress, while others are building walls to contain what they see as financial disruption.

From MiCA in the EU to China’s outright bans, and from the U.S. tug-of-war between the SEC and CFTC to Japan’s structured but innovation-friendly model, the world is still figuring out how to fold crypto into the fabric of modern finance.

That said, regulation is no longer a question of if, but how fast and how far. For traders, investors, and builders, the message is clear: stay informed, stay compliant, and stay agile, because crypto isn’t waiting for permission, and neither is the next big shift in the financial system.