Is cryptocurrency regulation globalized?

93% of the Financial Stability Board ( FSB ) members have now planned or have already established an encryption asset regulatory framework, and 88% of members have done the same for stablecoins. This unprecedented legislative surge marks a shift in regulation from decentralized oversight to structured legal Compliance.

From the implementation of the EU's “Markets in Crypto-Assets Regulation” ( MiCAR ) across the EU to the shift in the U.S. from “enforcement-based regulation,” the global regulatory ecosystem is rapidly moving toward establishing clearer rules for digital assets. However, not all countries are in sync. Some jurisdictions support innovation and investment, while others are tightening controls to address risks and volatility.

This article analyzes the cryptocurrency regulatory situation in 2025 by continent, focusing on the most influential legal developments in 14 countries across 7 regions.

The overall trend of cryptocurrency regulation in 2025

General Trends in Cryptocurrency Regulation 2025

As digital assets mature, cryptocurrency regulation in 2025 shows that the world is shifting towards a more complex and balanced framework. Governments are no longer debating whether to regulate cryptocurrency, but rather how to regulate it. The following significant trends are defining this year's legal landscape:

1. Shift towards regulatory clarity

Various jurisdictions are codifying laws that previously existed in decentralized guidance or administrative rulings. In the United States, the FIT21 Act and the evolving GENIUS stablecoin legislation mark a shift from passive enforcement to proactive rule-making. Similarly, the MiCAR, which is now fully effective across the European Union, provides a unified legal framework for encryption asset service providers ( CASPs ) and issuers.

Why it matters: Legal clarity fosters trust. Businesses and institutional investors are more likely to enter a market with a clear and predictable Compliance pathway.

2. Emphasize Investor Protection

From Canada to Singapore, the renewed focus on consumer safety is evident. Regulators are rolling out stronger Know Your Customer ( KYC ) and Anti-Money Laundering ( AML ) frameworks, restricting misleading advertising and requiring full disclosure of investment risks. Many frameworks now include specific obligations regarding custody, reporting, and asset segregation.

Why it matters: As cryptocurrency integrates into traditional finance, expectations for investor protection, risk transparency, and due diligence remain aligned.

3. The Rise of the Stablecoin Framework

2025 marks a turning point for stablecoins. The EU's MiCAR implements comprehensive Compliance requirements for electronic money tokens (EMTs) and asset-referenced tokens (ARTs), including capital and reserve requirements. In the United States, proposed legislation leans towards bank-issued stablecoins rather than government-backed digital currencies, indicating a preference for market-driven innovation over centralization.

Why it matters: Stablecoins are crucial for payments and decentralized finance ( DeFi ). Clear rules allow these tools to scale within a regulated ecosystem.

4. Regional encryption center and licensing system

Some countries are positioning themselves as crypto havens. Hong Kong, the UAE, and Switzerland offer tailored licensing systems to attract blockchain startups and institutional capital. These centers provide streamlined Compliance processes while maintaining strict oversight.

Why it matters: A licensing system reduces regulatory uncertainty while supporting economic growth and innovation.

5. Fill the gaps using existing laws

In jurisdictions without specific encryption laws, authorities apply traditional financial and securities legislation. For example, while India is awaiting comprehensive legislation, it utilizes its anti-money laundering and tax frameworks to regulate the industry.

Why it matters: While this provides short-term oversight, it may lead to confusion regarding asset classification and regulatory jurisdiction.

Specific examples of countries

The global legal landscape for cryptocurrencies in 2025 reflects an increasing convergence on principles such as investor protection, anti-money laundering Compliance, and licensing, but there are significant differences in implementation. Here is a selection of key analyses from major countries in various regions.

North America

United States

In 2025, the United States is at a legislative crossroads. The 21st Century Financial Innovation and Technology Act (FIT21) is progressing through Congress, proposing a clear delineation of regulatory responsibilities between the SEC and CFTC. Regulation of stablecoins is advancing through the GENIUS Act, which outlines requirements for issuer reserves, audits, and consumer protection mechanisms. Despite these advancements, the legal environment remains complex, with federal and state rules overlapping.

Canada

Canada maintains a pragmatic regulatory framework in which encryption is not regarded as legal tender but is regulated as a commodity. The Canadian Securities Administrators ( CSA ) require all cryptocurrency trading platforms serving Canadians to register. Canada is one of the first countries to approve cryptocurrency ETFs and continues to focus on investor protection through strict Compliance, custody, and reporting standards.

South America

Argentina

Due to the increasing adoption rate, Argentina's regulatory framework has rapidly evolved. The Financial Intelligence Unit (UIF) and the National Securities Commission (CNV) have introduced licensing requirements for Virtual Asset Service Providers (VASPs), including regulations on cybersecurity, operational isolation, and KYC standards. As of the third quarter of 2025, Compliance has become a mandatory requirement, reflecting Argentina's shift from informal guidance to enforceable rules.

Brazil

Brazil enacted a landmark law in 2022 that defined virtual assets and allocated regulatory responsibilities to the Brazilian Central Bank ( BCB ) and the Securities Commission ( CVM ). In 2025, BCB will regulate encryption services related to payments and stablecoins, while CVM will handle investment-related products. Brazil's framework is comprehensive and supports innovation while maintaining strict anti-money laundering Compliance.

Western Europe

United Kingdom

The UK is no longer bound by EU directives and has adopted a phased approach to regulate encryption currency. The Financial Services and Markets Act of 2023 grants the FCA oversight over stablecoins, and the Treasury is finalizing legislation covering a broader range of encryption assets by 2025. The FCA's approach emphasizes consumer protection, mandatory disclosure, and bans on certain retail marketing practices.

Switzerland

Switzerland, thanks to its progressive DLT legislation implemented since 2021, remains a global center for encryption. The Swiss Financial Market Supervisory Authority ( FINMA ) mandates strict anti-money laundering Compliance, including adherence to the FATF travel rule for self-custody wallets. The new guidelines released in 2024 address stablecoin reserves and risk management issues, reinforcing the country's high standards.

Eastern Europe

Poland and the Czech Republic

As EU member states, these two countries are implementing the encryption asset market regulation ( MiCAR ), which will be fully applicable in June 2024. National regulatory authorities are now incorporating MiCAR's provisions regarding stablecoins, asset-backed tokens, and service provider licensing into domestic law. Both countries are actively issuing local guidelines to support the EU's coordinated approach.

Middle East

United Arab Emirates

The UAE has consolidated its role as a regulatory leader through the Dubai Virtual Assets Regulatory Authority ( VARA ) and the Abu Dhabi Global Market ( ADGM ). The updated rulebook, effective in mid-2025, addresses issues related to custody, margin trading, and marketing standards. The federal SCA and local regulatory bodies now operate under a coordinated framework, and cryptocurrency adoption has become widespread across various industries.

Israel

Israel primarily regulates encryption through its anti-money laundering framework. Virtual asset service providers must register with the Israel Money Laundering and Terror Financing Prohibition Authority. Although there are currently no specific encryption laws, new tax rulings and Compliance standards are being considered as the market matures.

Asia

India

India continues to regulate encryption through taxation and anti-money laundering measures, while final legislation is still pending. The 2022 federal budget introduced a 30% tax on encryption gains and a 1% transaction withholding tax (TDS). By 2025, service providers must comply with the reporting requirements of the Prevention of Money Laundering Act (PMLA). A national cryptocurrency bill is expected to be introduced by the end of the year.

Hong Kong

Hong Kong implements a different legal system from mainland China and actively positions itself as a digital asset center. The Securities and Futures Commission ( SFC ) has introduced a licensing system for cryptocurrency exchanges and is finalizing its stablecoin regulatory framework. Under strict conditions, access for retail investors to encryption has been cautiously expanded to protect investors.

Oceania

Australia

Australia classifies cryptocurrency as property and requires exchanges to register with AUSTRAC to comply with anti-money laundering/anti-terrorism financing regulations. The Treasury's consultation in 2025 focuses on defining custody and licensing obligations for cryptocurrency, particularly concerning stablecoins and centralized exchanges. The government aims to introduce a licensing regime based on a functional approach.

New Zealand

New Zealand has taken a position similar to that of Australia. Cryptocurrency service providers are required to comply with the 2009 Anti-Money Laundering and Counter-Terrorism Financing Act. Although the market size is small, strong regulation is maintained through the Financial Markets Authority ( FMA ).

Sub-Saharan Africa

Kenya

Kenya is developing a national encryption currency framework. Although the Central Bank of Kenya (CBK) has issued warnings regarding digital assets, it is also launching consultations in 2024 aimed at designing a structured regulatory approach focused on anti-money laundering and consumer protection.

South Africa

The Financial Sector Conduct Authority ( FSCA ) announced in 2022 that crypto assets are financial products, requiring providers to obtain licenses. South Africa is expanding its framework to include stablecoins and staking services, while also preparing to align with global anti-money laundering standards by updating its FICA Act.

Nigeria

Despite the Central Bank of Nigeria continuing to prohibit banks from providing services to encryption companies, ownership and peer-to-peer use remain legal. The Securities and Exchange Commission ( SEC ) has released draft rules for digital asset exchanges and is advancing broader regulations to ensure oversight of token issuance and wallet providers.

Country Overview Table: 2025 Cryptocurrency Compliance

Important considerations

While the regulation of cryptocurrency is evolving globally in 2025, the differences in legal frameworks present several key challenges and decision points for both cryptocurrency businesses and users alike.

1. Jurisdictional Segmentation

One of the most complex issues is regulatory inconsistency. For example, while the EU has coordinated cryptocurrency regulation through MiCAR, the United States continues to operate under a federal/state split system. Similarly, countries like Nigeria and India apply existing anti-money laundering or tax laws without specific regulations for cryptocurrency.

2. Tax and Reporting Obligations

Taxation remains a core enforcement mechanism. India imposes a uniform tax rate of 30% on earnings and a 1% withholding tax on transfers, while Canada treats cryptocurrency as a commodity, subjecting it to capital gains tax. In many jurisdictions, even non-cash events such as staking rewards or airdrops can trigger tax liabilities for cryptocurrency transactions.

3. Anti-Money Laundering and Know Your Customer Requirements

Almost all jurisdictions now require virtual asset service providers (VASPs) to implement KYC protocols and comply with FATF travel rules. Countries like Switzerland even enforce this regulation on self-custody wallets, while the EU's AMLR will soon be centrally regulated under the new AMLA agency.

4. Stablecoin Compliance

Stablecoins are under special scrutiny. The EU now regulates stablecoins as electronic money tokens (EMTs) or asset-referenced tokens (ARTs), requiring licenses, reserves, and risk controls. In the US, the GENIUS Act has proposed similar standards but does not support CBDCs.

5. Integration with Traditional Finance

From Switzerland's tokenized securities to the EU's pilot issuance of digital bonds, regulators are paving the way for the integration of encryption finance. This provides opportunities for Compliance innovation, but also increases the complexity of scrutiny and licensing.

Future Outlook

As we move into 2025, cryptocurrency regulation shows signs of integration and expansion. Here are the developments to come:

1. Legislative Momentum

We expect to see significant developments in the following areas:

U.S. Congress: May pass FIT21 and GENIUS bills;

India: Introduces its long-awaited national encryption currency bill;

Israel and South Africa: Expanding the anti-money laundering framework into comprehensive cryptocurrency legislation.

2. Stricter stablecoin standards

More countries will follow the EU's MiCAR model, requiring issuers to hold fully backed reserves and obtain electronic money licenses. This may shift stablecoin operations to bank-level institutions and facilitate interoperability with CBDCs.

3. Regulatory Technology ( RegTech ) Growth

As data requirements increase—from transaction transparency to reserve audits—VASPs will adopt AI-driven RegTech tools to meet real-time Compliance obligations.

4. Achieve coordination through global institutions

It is expected that the Financial Stability Board ( FSB ) and the International Organization of Securities Commissions ( IOSCO ) will issue binding implementation indicators for DeFi, stablecoin, and cross-border enforcement. These will serve as reference points for national legislators.

5. The Maturity of African Regulation

Kenya, Nigeria, and South Africa are expected to become regional leaders by launching coordinated cryptocurrency frameworks that combine support for innovation with consumer protection.

Summary

The regulation of cryptocurrency in 2025 depicts a landscape of accelerated legal clarity in major jurisdictions. The trend is shifting from reactive enforcement to proactive policies based on financial stability, investor protection, and market integrity.

However, challenges remain. Companies must navigate the patchwork of national regulations, prepare for more stringent tax and anti-money laundering scrutiny, and establish systems that are both technologically reliable and compliant. As the encryption industry enters its next phase, regulatory intelligence will become a competitive advantage, not just a legal necessity. **$GRASS **$CROSS **$BLESS **