Original author: Pzai, Foresight News
In recent years, as the crypto market has attracted more and more attention from all walks of life, the demand for regulation of the crypto market has become more urgent. Different countries and regions have introduced their own distinctive regulatory policies based on their own economic, financial systems and strategic considerations. From the ongoing game between the US SEC and crypto companies, to the EUs comprehensive MiCA Act on crypto asset market regulation, to the difficult balance between innovation and risk in emerging economies, the global crypto regulatory landscape is showing unprecedented complexity and diversity. At this moment, let us unfold the world map of crypto regulation and explore the hidden veins under this global regulatory wave.
In the map, we divide countries into four categories: business clusters, fully compliant, partially compliant, and non-compliant. The criteria include the legal status of crypto assets (50%), regulatory framework and legislation implementation (30%), and exchange implementation (20%).
Asia
Greater China
Hong Kong
In Hong Kong, crypto assets are considered virtual assets rather than currencies and are regulated by the Securities and Futures Commission (SFC). Hong Kong implements a licensing system for stablecoins, and the Stablecoin Ordinance restricts licensed institutions from issuing Hong Kong dollar stablecoins. As for other tokens, NFTs are considered virtual assets; governance tokens are regulated in accordance with the rules of collective investment schemes.
In terms of the regulatory framework, Hong Kong amended the Anti-Money Laundering Ordinance in 2023, requiring cryptocurrency exchanges to obtain licenses. In addition, the Securities and Futures Commission (SFC) has also issued rules for virtual asset ETFs. The SFC is responsible for issuing licenses. HashKey and OSL have obtained the first batch of licenses, and more than 20 other institutions are applying. In terms of exchange landing, licensed exchanges are allowed to serve retail investors. It is worth noting that Bitcoin and Ethereum ETFs have been listed in Hong Kong in 2024.
Hong Kong aims to consolidate its position as an international financial center by actively embracing Web3 and virtual assets, especially allowing retail trading and launching virtual asset ETFs, in stark contrast to the strict ban in mainland China. The Hong Kong Securities Regulatory Commission forces exchanges to issue licenses and allows licensed exchanges to serve retail investors, while launching Bitcoin/Ethereum ETFs. Against the backdrop of a comprehensive ban on cryptocurrencies in mainland China, Hong Kong has chosen a completely different path and actively built a clear and regulated virtual asset market. Allowing retail participation and launching ETFs are key measures to attract global crypto capital and talent, enhance market liquidity and international competitiveness.
Taiwan
Taiwan is cautious about cryptocurrencies and does not recognize their currency status, but regulates them as speculative digital commodities and gradually improves the framework for anti-money laundering and security token issuance (STO).
Legal status of crypto assets: Taiwan currently does not recognize cryptocurrencies as currencies. Since 2013, the position of the Taiwan Central Bank and the Financial Supervisory Commission (FSC) is that Bitcoin should not be considered a currency, but a highly speculative digital virtual commodity. For tokens, such as NFTs and governance tokens, their legal status has not yet been clarified, but in practice, NFT transactions are subject to profit tax. Security tokens are recognized as securities by the FSC and are regulated by the Securities and Exchange Act.
Regulatory framework: Taiwan’s Anti-Money Laundering Act regulates virtual assets. The FSC has ordered that local banks are not allowed to accept Bitcoin or provide any Bitcoin-related services since 2014. For security token offerings (STOs), Taiwan has specific regulations that differentiate regulatory paths based on the issuance amount (NT$30 million). The FSC also announced in March 2025 that it is drafting a law specifically for virtual asset service providers (VASPs), aiming to move from a basic registration framework to a comprehensive licensing system.
License issuance: The FSC introduced new regulations in 2024 under the Anti-Money Laundering Act, requiring VASPs to register with the FSC before providing any virtual asset-related services (such as operating exchanges, trading platforms, transfer services, custody services, or underwriting activities). Failure to register may result in criminal penalties. For STOs, the issuer must be a Taiwan-registered joint-stock company, and the STO platform operator must obtain a securities dealer license and have a paid-in capital of at least NT$100 million.
Chinese mainland
The Chinese mainland has completely banned the trading of crypto assets and all related financial activities. The Peoples Bank of China believes that cryptocurrencies disrupt the financial system and facilitate criminal activities such as money laundering, fraud, pyramid schemes, and gambling.
In judicial practice, virtual currency has corresponding property attributes, and a consensus has basically been formed in judicial practice. Civil case law generally believes that virtual currency has the characteristics of exclusivity, controllability and liquidity in possession, similar to virtual goods, and recognizes that virtual currency has property attributes. Some cases cited Article 127 of the Civil Code Where the law has provisions for the protection of data and network virtual property, such provisions shall be followed and referred to Article 83 of the Minutes of the National Court Financial Trial Work Conference Virtual currency has some attributes of network virtual property, and determined that virtual currency is a specific virtual property and should be protected by law. In the criminal field, recent cases in the Supreme Peoples Court case library have also made it clear that virtual currency belongs to property in the sense of criminal law and has property attributes in the sense of criminal law.
However, banks in mainland China have been prohibited from engaging in cryptocurrency business since 2013. In September 2017, China decided to gradually close all virtual currency exchanges in the country within a limited time. In September 2021, the Peoples Bank of China issued a notice to completely ban services related to virtual currency settlement and provision of trader information, and clearly stated that those engaged in illegal financial activities will be held criminally liable. In addition, cryptocurrency mines have also been closed, and new mines are not allowed to be opened. Overseas virtual currency exchanges providing services to residents in China through the Internet are also considered illegal financial activities.
Singapore
Legal status of crypto assets: Singapore regards crypto assets as payment tools/commodities, which is mainly based on the provisions of its Payment Services Act. For stablecoins, Singapore implements a licensed issuance system. The Monetary Authority of Singapore (MAS) requires issuers to have a 1:1 reserve and conduct monthly audits. For other tokens, such as NFTs and governance tokens, Singapore adopts a case-by-case determination principle: NFTs are generally not considered securities, while governance tokens may be considered securities if they carry dividend rights.
Cryptocurrency regulatory framework: Singapores Financial Services and Markets Act, enacted in 2022, regulates exchanges and stablecoins. However, the new DTSP regulations that came into effect recently have significantly reduced the scope of license compliance, which may affect the offshore business of crypto projects and exchanges. The Monetary Authority of Singapore (MAS) usually issues three types of licenses to crypto companies: currency exchange, standard payment and large payment institutions. Currently, more than 20 institutions have obtained licenses, including Coinbase. Many international exchanges choose to set up regional headquarters in Singapore, but these institutions will be affected by the new DTSP regulations.
South Korea
In South Korea, crypto assets are considered legal assets but not legal tender, mainly based on the provisions of the Specific Financial Information Reporting and Utilization Act (Special Financial Act). Currently, the draft of the Digital Asset Basic Act (DABA) is being actively promoted, which is expected to provide a more comprehensive legal framework for crypto assets. The current Special Financial Act mainly focuses on anti-money laundering supervision. For stablecoins, the draft DABA proposes to require transparency of their reserves. For other tokens, such as NFTs and governance tokens, their legal status has not yet been clarified: NFTs are currently regulated as virtual assets, and governance tokens may be included in the category of securities.
South Korea implements a real-name exchange licensing system, and currently five major exchanges, including Upbit and Bithumb, have obtained licenses. In terms of exchange landing, the Korean market is mainly dominated by local exchanges, and foreign exchanges are prohibited from directly serving Korean residents. At the same time, the draft of South Koreas Digital Asset Basic Law (DABA) is being promoted, and it is proposed to require the transparency of stablecoin reserves. This strategy not only protects local financial institutions and market share, but also facilitates regulators to effectively monitor domestic trading activities.
Indonesia
Indonesia is undergoing a change in the regulatory authority of crypto assets from the Commodity Futures Trading Regulatory Authority (Bappebti) to the Financial Services Authority (OJK), heralding more comprehensive financial regulation.
Legal status of crypto assets: The legal status of crypto assets in Indonesia is not yet clear. With the recent transfer of regulatory authority, crypto assets are classified as digital financial assets.
Regulatory framework: Previously, exchanges were regulated under Indonesias Commodities Law. However, the recently enacted OJK Regulation No. 27 of 2024 (POJK 27/2024) transfers regulatory authority over crypto asset trading from Bappebti to the Financial Services Authority (OJK), which will take effect on January 10, 2025. This new framework sets strict capital, ownership and governance requirements for digital asset exchanges, clearing agencies, custodians and dealers. All licenses, approvals and product registrations previously issued by Bappebti remain valid to the extent they do not conflict with existing laws and regulations.
Licensing: The licensing authority has been transferred from Bappebti to OJK. Crypto asset traders must have a minimum paid-in capital of IDR 100 billion and must maintain a share capital of at least IDR 50 billion. Funds used for paid-in capital must not be derived from illegal activities such as money laundering, terrorist financing, or financing of weapons of mass destruction. All digital financial asset trading providers must fully comply with the new obligations and requirements of POJK 27/2024 by July 2025.
Exchange landing: Local exchanges such as Indodax are actively operating locally. Indodax is a regulated centralized exchange that provides spot, derivatives and over-the-counter (OTC) services and requires users to conduct KYC compliance.
Thailand
Thailand is actively shaping its cryptocurrency market, encouraging compliant trading and cementing its position as a global financial hub through tax incentives and a strict licensing regime.
Legal Status of Crypto Assets: In Thailand, owning, trading and mining cryptocurrencies is completely legal, and profits are subject to taxation in accordance with Thai law.
Regulatory framework: Thailand has enacted the Digital Assets Act. Notably, Thailand has approved a five-year capital gains tax exemption on income from cryptocurrency sales through licensed crypto asset service providers, which will last from January 1, 2025 to December 31, 2029. This measure aims to position Thailand as a global financial center and encourage residents to trade on regulated exchanges. The Securities and Exchange Commission (SEC) of Thailand is responsible for regulating the crypto market.
License issuance: The Thai SEC is responsible for issuing licenses. Exchanges must obtain official permission and be registered as a Thai limited or public company. License requirements include minimum capital (50 million baht for centralized exchanges and 10 million baht for decentralized exchanges) and directors, executives and major shareholders must meet the fit and proper person standard. KuCoin has obtained the SEC license through acquisition.
Exchange landing: Local exchanges such as Bitkub are active locally and have the highest cryptocurrency trading volume in Thailand. Other major licensed exchanges include Orbix, Upbit Thailand, Gulf Binance and KuCoin TH. The Thai SEC has taken measures against five global crypto exchanges, including Bybit and OKX, to prevent them from operating in Thailand because they have not obtained local licenses. Tether has also launched its tokenized gold digital asset in Thailand.
Japan
Japan is one of the first countries in the world to explicitly recognize the legal status of cryptocurrencies, and its regulatory framework is mature and prudent.
Legal status of crypto assets: In the Payment Services Act, crypto assets are recognized as legal means of payment. For stablecoins, Japan has a strict bank/trust monopoly system, requiring them to be pegged to the yen and redeemable, while explicitly prohibiting algorithmic stablecoins. As for other tokens, such as NFTs, they are considered digital commodities; while governance tokens may be identified as collective investment plan interests.
Regulatory framework: Japan officially recognized crypto assets as a legal means of payment by revising the Payment Services Act and the Financial Instruments and Exchange Act (2020). The Financial Services Agency (FSA) is responsible for regulating the crypto market. The revised Payment Services Act also added a domestic holding order clause, allowing the government to require platforms to keep some user assets within Japan when necessary to prevent the risk of asset outflow. In terms of licensing, the FSA is responsible for issuing exchange licenses, and there are currently 45 licensed institutions. The key requirements for obtaining a Japanese cryptocurrency license include: having a local legal entity and office, meeting minimum capital requirements (more than 10 million yen, and specific fund holding regulations), complying with AML and KYC rules, submitting a detailed business plan, and conducting ongoing reporting and audits.
Exchange landing situation: The Japanese market is mainly dominated by local exchanges such as Bitflyer. If international platforms want to enter the Japanese market, they usually need to go through joint ventures (such as Coincheck).
Europe
European Union
As one of the jurisdictions with more complete and extensive judicial supervision in the global crypto field, Europe is becoming the first stop for compliance for many crypto projects. The EU has demonstrated its leadership as an important global jurisdiction in the field of cryptocurrency, and has established a unified regulatory framework through the Crypto Asset Market Regulation Act (MiCA).
Legal status of crypto assets: Under the MiCA framework, crypto assets are defined as legal payment tools but not legal tender. For stablecoins, MiCA has implemented strict supervision, requiring them to have a 1:1 fiat currency anchor and sufficient reserves, and only licensed institutions are allowed to issue them. MiCA divides stablecoins into asset reference tokens (ARTs) and electronic money tokens (EMTs) for supervision. For other tokens, such as non-fungible tokens (NFTs) and governance tokens, the EU adopts a classified regulatory approach: NFTs are generally regarded as unique digital assets and exempted from securities rules, while governance tokens are regarded as securities based on their functions and the rights they confer. MiCA currently does not cover security tokens, NFTs, and central bank digital currencies (CBDCs).
Regulatory framework: The EU passed the MiCA Act in June 2023, of which the stablecoin rules came into effect in advance in June 2024, and the Act came into full effect on December 30, 2024. The Act applies to 30 countries in Europe, including 27 EU member states and Norway, Iceland and Liechtenstein in the European Economic Area. MiCA aims to address issues such as legal ambiguity, stablecoin risks and insider trading, and to protect investors, maintain market integrity and financial stability through unified rules. It makes detailed provisions on the issuance of crypto assets, the authorization, operation, reserve and redemption management of service providers, and anti-money laundering (AML) supervision. In addition, MiCA also integrates the travel rules of the Funds Transfer Regulation (TFR), requiring crypto asset service providers (CASPs) to include sender and receiver information in each transfer to enhance traceability.
License issuance: MiCA adopts the model of one-place licensing, universal use, which means that CASP only needs to be authorized in one member state to operate legally under the jurisdiction of all member states, greatly simplifying the compliance process. CASP must be authorized by its own competent authority. Licensing requirements include good reputation, capabilities, transparency, data protection and compliance with the minimum capital requirements specified in Annex IV of MiCA, which range from 15,000 euros to 150,000 euros depending on the type of service. CASP is also required to have a registered office in an EU member state and at least one director is an EU resident.
Stablecoin landing situation: USDC and EURC issued by Circle have obtained MiCA compliance approval and are considered stablecoins that meet EU standards. Tether (USDT) has faced delisting by major exchanges such as Coinbase and Binance for its users in the EU due to its failure to comply with MiCAs strict stablecoin regulations.
U.K.
After Brexit, the UK did not copy MiCA in its entirety, but chose an independent but equally comprehensive regulatory path aimed at maintaining its competitiveness as a global financial center.
Legal status of crypto assets: In the UK, crypto assets are explicitly considered personal property, a legal status that has been confirmed in a 2024 parliamentary bill. The bill aims to provide digital assets with the same legal protection as traditional property, thereby enhancing certainty for owners and traders. For stablecoins, the UK adopts prudential regulation, requiring them to be approved by the Financial Conduct Authority (FCA) and reserve assets must be segregated for custody. As for other tokens, such as NFTs, they are also considered property according to court precedents. The legal status of governance tokens depends on their specific use and may be classified as securities or utility tokens.
Regulatory framework: The Financial Services and Markets Act (2023) has brought crypto assets under regulation and revised the definition of designated investments in the Financial Services and Markets Act 2000 to include crypto assets. The Bank of England also regulates stablecoins, treating them as digital payment tools and requiring issuers to obtain FCA authorization. In addition, the Economic Crime and Corporate Transparency Act 2023 gives law enforcement agencies the power to freeze and recover illegal crypto assets. The Treasury has also released detailed proposals to create a financial services regulatory regime for crypto assets, including new regulated activities such as crypto asset trading platform operations.
License issuance: The FCA is responsible for issuing relevant licenses. Companies engaged in crypto asset business, including operating trading platforms, trading crypto assets as a principal, or providing custody services, need to obtain FCA authorization. Although there is currently no mandatory cryptocurrency exchange license in the UK, crypto asset companies must register with the FCA and comply with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations. Registration requirements include registering a company in the UK, having a physical office, maintaining detailed records, and appointing a resident director.
Russia
Legal status of crypto assets: Russia classifies crypto assets as property for confiscation, while stating that DFA is not a means of payment and that the central bank does not recognize cryptocurrencies as a means of payment. The Russian legal framework distinguishes between digital financial assets (DFA) and digital currencies. DFA is defined as a digital right, including a monetary claim or a security-related right, and is based on distributed ledger technology. According to the law, DFA is not considered a means of payment. Federal Law No. 259-FZ on Digital Financial Assets, Digital Currency, and Amendments to Certain Laws of the Russian Federation, promulgated on July 31, 2020, regulates the issuance and circulation of DFA. In addition, the law also recognizes mixed rights, that is, rights that include both DFA and the transfer of goods, intellectual property rights, or services.
Industry implementation: As an energy powerhouse, the crypto mining industry is relatively popular in Russia, and the Russian government began to implement two bills related to cryptocurrency mining in October and November 2024, introducing legal definitions and registration requirements for mining operations. Under the new legislation, only registered Russian legal entities and individual entrepreneurs are allowed to engage in cryptocurrency mining. Individual miners can operate without registration if their energy consumption does not exceed the limits set by the government.
Despite these laws, only 30% of cryptocurrency miners have registered with the Federal Tax Service since late 2024, meaning 70% of miners remain unregistered. Measures to encourage registration include tougher penalties, such as a new bill that increases fines for illegal mining from 200,000 rubles to 2 million rubles (about $25,500). Enforcement actions are ongoing, with recent reports of illegal mining farms being shut down and equipment being confiscated. The Russian Ministry of Internal Affairs has opened a case under Article 165 of the Russian Criminal Code.
Switzerland
Switzerland has been at the forefront of cryptocurrency regulation, known for its flexible token taxonomy and support for blockchain innovation.
Legal status of crypto assets: Although cryptocurrencies are legal in Switzerland, there are no specific regulations in Switzerland regarding the sale and purchase of virtual crypto assets or their use as a means of payment for goods and services, so these activities generally do not require special financial market licenses. The Swiss Financial Market Supervisory Authority (FINMA) classifies crypto assets according to their economic and practical uses, mainly into payment tokens, functional tokens and asset tokens, and regulates them accordingly. FINMA points out that these types are not mutually exclusive and there may also be hybrid tokens. Asset tokens are generally considered securities, while functional tokens are not considered securities if they have actual functions at the time of issuance, but may be considered securities if they have investment purposes.
Regulatory framework: Switzerland passed the Blockchain Act in 2020, which comprehensively defines token rights and amends several existing federal laws to integrate distributed ledger technology (DLT). FINMA has applied the Anti-Money Laundering Act to Virtual Asset Service Providers (VASPs) and published guidance on the Travel Rule in August 2019, which came into effect on January 1, 2020. In addition, the Act improves the framework for bookkeeping securities on the blockchain and increases legal certainty in bankruptcy law by explicitly providing for the segregation of crypto assets in bankruptcy.
License issuance: FINMA is responsible for issuing VASP licenses. Providing custody, exchange, trading and payment services for payment tokens are all subject to the Anti-Money Laundering Act, and relevant service providers must join the Self-Regulatory Organization (SRO) in advance. In certain specific cases, a FinTech license may be sufficient to replace a banking license, thereby reducing licensing requirements. Requirements for obtaining a Swiss crypto license include establishing a legal entity in Switzerland, meeting capital adequacy requirements (ranging from 20,000 to 100,000 Swiss francs depending on the type of license), implementing AML and KYC procedures, and complying with FATF travel rules. The canton of Zug has also piloted a crypto-friendly regulatory sandbox. Traditional banks such as ZKB and exchanges such as Bitstamp are already licensed to provide crypto services.
America
USA
The regulatory landscape of crypto assets in the United States shows significant interstate differences and a lack of unified legislation at the federal level, leading to high market uncertainty. With the inauguration of Trump and the change of the SEC, policy promotion has accelerated greatly, and the federal cryptocurrency regulatory bill is already on the verge of being enacted.
Legal status of crypto assets: The legal status of crypto assets in the United States shows significant interstate differences. At the federal level, the Internal Revenue Service (IRS) considers it as property, while New York State defines it as a financial asset. For stablecoins, the draft GENIUS Act proposes that payment stablecoins should not be considered securities, but requires that they must have 100% high liquidity reserves. For other tokens, such as NFTs and governance tokens, the U.S. Securities and Exchange Commission (SEC) leads their classification, where NFTs may be considered securities, while governance tokens are mostly identified as securities.
Regulatory framework: There is currently no unified cryptocurrency bill at the federal level in the United States. The SEC mainly regulates tokens based on securities laws. In addition, New York State has a BitLicense licensing system. The GENIUS stablecoin bill is currently under review. In terms of photography, the United States mainly implements state-level licenses (such as the New York State Department of Financial Services NYDFS, etc.) and money service business (MSB) registration for anti-money laundering. For example, New York State has a strict BitLicense licensing system that requires cryptocurrency companies operating in New York State to obtain this license. Many other states have also introduced or are reviewing their own crypto asset legislation. For example, some states have revised the Uniform Commercial Code (UCC) to adapt to digital assets, or have made specific requirements for operators of cryptocurrency self-service terminals. In addition, crypto companies engaged in money transmission, exchange and other businesses need to register as money service businesses (MSBs) with FinCEN and comply with federal anti-money laundering and anti-terrorist financing requirements. This includes implementing KYC procedures, monitoring suspicious transactions and reporting them.
Exchange landing situation: Major cryptocurrency trading platforms such as Coinbase, Kraken, and Crypto.com operate in compliance in the United States, and Binance US has recently launched the USD deposit function in the United States. However, due to previous regulatory uncertainties, some international cryptocurrency exchanges choose not to enter the US market or only provide limited services. The SEC also took enforcement actions against some exchanges that claimed to operate unregistered securities transactions during previous administrations.
El Salvador
El Salvador has had a unique journey with the legal status of crypto assets. The country recognized Bitcoin as legal tender in 2022, but later abandoned this position due to pressure from the International Monetary Fund (IMF). Currently, Bitcoin is not legal tender, but private use is still allowed after a 2025 reform.
In terms of regulatory framework, El Salvador has enacted the Digital Asset Issuance Law (2024). The National Digital Asset Commission (NCDA) is responsible for supervision and plans to issue licenses. However, the country has not yet established a comprehensive licensing system. Although the government actively promotes cryptocurrency taxation, there are currently no mainstream exchanges operating on a large scale.
Argentina
Argentina’s severe economic instability and high inflation have driven the widespread adoption of cryptocurrencies, prompting the government to gradually improve its regulatory framework, especially for virtual asset service providers (VASPs).
Legal status of crypto assets: In Argentina, cryptocurrencies are legal, allowed to be used and traded, but since the constitution stipulates that the central bank is the only currency issuer, cryptocurrencies are not considered legal tender. Crypto assets can be classified as currencies for transaction purposes, and contracts can be settled using crypto assets. For stablecoins and tokens (such as NFTs, governance tokens), Argentina currently has no specific legislation to clarify their legal status.
Regulatory framework: Although the new government (President Milley) supports cryptocurrencies, there is currently no dedicated cryptocurrency bill. However, Argentina enacted Law No. 27739 in 2024 to include Virtual Asset Service Providers (VASPs, known as PASVs in Argentina) in its legal and financial framework. The framework forces VASPs to comply with Anti-Money Laundering (AML) and Know Your Customer (KYC) processes to combat money laundering and regulate the industry, in line with the international guidelines of the Financial Action Task Force (FATF).
License issuance: Starting in 2024, VASPs must register with the Argentine financial regulator Comisión Nacional de Valores (CNV) to provide crypto services. Registration requirements include: screening and verifying customer identities, reporting new customer registrations, conducting risk assessments, maintaining detailed records (including transaction and customer data), monitoring suspicious transactions, and establishing internal controls. Entities that fail to comply will face fines, legal action, or license revocation.
middle East
United Arab Emirates
Legal Status of Crypto Assets: The UAE has taken a proactive approach to cryptocurrencies and blockchain technology, aiming to position itself as a global fintech and digital innovation hub. Cryptocurrencies are legal in the UAE under a clearly defined regulatory framework. The Dubai Financial Services Authority (DFSA) defines crypto tokens as cryptographically secure digital representations of value, rights or obligations that can be used as a medium of exchange, payment or investment purposes. It specifically excludes excluded tokens and investment tokens. Only crypto tokens approved by the DFSA are allowed in the DIFC, with limited exceptions. The Abu Dhabi Global Market (ADGM) classifies stablecoins as virtual assets when they fall under regulated activities.
Regulatory framework: The main regulatory bodies in the UAE include:
Central Bank of the United Arab Emirates (CBUAE): Regulates financial activities, including cryptocurrency trading and banking services, within the UAE, ensuring financial stability and consumer protection. Responsible for overseeing fiat-to-cryptocurrency transactions.
Securities and Commodities Authority (SCA): Regulates financial markets within the UAE, including digital securities and commodities. Works with the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) and the Virtual Asset Regulatory Authority (VARA) in Dubai to align standards.
Virtual Asset Regulatory Authority (VARA): Dubai’s dedicated virtual asset regulator, established in 2022. Focused on compliance, investor protection and market stability.
Dubai Financial Services Authority (DFSA): Regulates financial services involving crypto tokens within the Dubai International Financial Centre (DIFC).
Abu Dhabi Global Market (ADGM): has a comprehensive regulatory framework for virtual assets, digital securities and derivatives within its financial free zone, which is overseen by the Financial Services Regulatory Authority (FSRA).
This collaborative approach to regulation ensures that digital assets are integrated into the legal system, promoting innovation while preventing abuse.
License issuance: In terms of license issuance, Dubai VARA 2.0 (June 2025) introduces a number of updates, including strengthening margin trading controls (only qualified and institutional investors, retail leveraged products are prohibited, VASPs must strictly manage collateral, monthly reports and compulsory liquidation mechanisms), formally recognize asset-referenced virtual assets (ARVA), regulate token distribution (issuance/distribution requires VARA permission, white papers must be transparently disclosed and misleading propaganda is prohibited), establish a structured licensing system for eight core activities (consulting, brokerage transactions, custody, etc.) (each activity requires a separate license, and capital adequacy, risk control and other requirements are clarified) and strengthen supervision measures (expanded on-site inspections, quarterly risk assessments, fines and criminal referrals, a transition period of 30 days, and full enforcement on June 19, 2025); the FSRA of the Abu Dhabi Global Market (ADGM) supervises the implementation of virtual asset regulations. Licensing requirements include clearly defining service types (custody, trading, etc.), complying with capital/anti-money laundering/cybersecurity standards, and submitting business plans and other documents. The 2025 revised version simplifies Accepted Virtual Assets (AVA) The certification process gives FSRA product intervention rights and prohibits privacy tokens and algorithmic stablecoins; the Dubai Financial Services Authority (DFSA) regulates crypto token-related financial services within DIFC, requiring tokens to pass identification standards such as regulatory status and transparency. Stablecoins must have stable prices, isolated reserves and monthly verification. Privacy/algorithmic tokens are prohibited. Mainstream tokens such as Bitcoin have been identified and a tokenization regulatory sandbox has been launched.
Saudi Arabia
Saudi Arabia has taken a cautious stance towards cryptocurrencies, with its regulatory framework influenced by both Sharia principles and the need to maintain financial stability.
Legal Status of Crypto Assets: Saudi Arabia has taken a cautious approach to cryptocurrencies, largely due to Sharia-related restrictions. Cryptocurrencies are completely banned in the banking system, and financial institutions are prohibited from trading in cryptocurrencies. Private ownership of cryptocurrencies is not prosecuted, but trading and exchange are strictly restricted. The Saudi Arabian Central Bank (SAMA) issued a warning about the risks of cryptocurrencies in 2018 and tightened its ban on financial transactions in cryptocurrencies in 2021. Religious interpretations, such as a Sharia ruling issued by Dar al-Ifta declaring them haram (unlawful) due to fraud and lack of real collateral, influence these bans. Some stablecoins or tokens are considered halal (legal) if they are pegged to real assets.
Regulatory framework: The Saudi Arabian Monetary Authority (SAMA) and the Capital Markets Authority (CMA) have stressed a prudent approach to cryptocurrency innovation, balancing technological advancement with financial system stability. In July 2024, Mohsen AlZahrani was appointed to lead SAMAs virtual asset initiative, highlighting its commitment to the controlled integration of fintech innovation. This is part of a broader regulatory shift that aims to avoid a blanket ban and instead interact with global trends and regional successes such as the UAEs VARA regime. SAMA is actively promoting blockchain adoption and attracting international financial institutions such as Rothschild and Goldman Sachs to participate in tokenization projects. Saudi Arabia is promoting its own digital currency as part of its Vision 2030. In 2019, SAMA and the UAE Central Bank conducted interoperability tests for cross-border CBDC transactions as part of the Aber Project. Saudi Arabia joined the mBridge CBDC pilot project in 2024. The country is leading the way in wholesale CBDC pilot projects, which aim to facilitate domestic settlements and cross-border transactions for financial institutions.
License issuance: The Saudi Capital Market Authority (CMA) announced that regulations for security token offerings (STOs) will be issued by the end of 2022, and applications can be submitted on the CMA digital platform. Launched in 2017, CMAs Fintech Lab has been committed to creating a suitable business environment for fintech startups. STOs in Saudi Arabia are supervised by the CMAs strict securities regulations. Key considerations for STOs include: registration requirements (detailed documents, prospectuses), disclosure obligations (transparent and accurate information, financial statements, risk factors) and anti-fraud measures. CMAs regulations also include investor certification requirements, limiting participation in STOs to qualified investors who can independently assess risks. The tokenization of traditional financial assets is a key area of focus, and a legal framework is needed to address ownership, transferability and regulatory issues related to tokenized assets to ensure that smart contracts comply with legal principles.
Bahrain
Legal status of crypto assets: Bahrain is a pioneer in cryptocurrency and blockchain regulation in the Middle East. It has established a comprehensive regulatory framework through the Crypto Assets Module (CRA) under the Capital Markets Rulebook of the Central Bank of Bahrain (CBB). It clarifies that crypto assets are cryptographically secure digital representations of value or rights (excluding central bank digital currencies).
Regulatory framework: CRA sets legal and operational norms for crypto asset providers, covering licensing, risk management, consumer protection and other aspects, and will be revised in March 2023 to strengthen customer asset protection and anti-money laundering measures. The regulations ensure transparency and compliance, are consistent with FATF standards, promote innovation through the FinTech Bay and regulatory sandbox, and clarify that some virtual asset businesses are exempt from regulation.
License issuance: Those engaged in regulated crypto asset services in Bahrain must obtain a CBB crypto asset license, which covers services such as order processing and trading. VASP licenses are divided into four categories, with different types corresponding to different minimum capital requirements and annual fees. Applicants must be Bahrain companies and must meet multiple requirements such as registration, business plan, and compliance. Violators will face heavy fines, license revocation, or even imprisonment.
Israel
Legal status of crypto assets: Israel does not have a comprehensive law specifically for cryptocurrencies. Cryptocurrencies are considered assets rather than currencies for tax purposes. Profits from sales are subject to a 25% capital gains tax. Currency-to-currency conversions are taxable events, and income from crypto businesses is taxed as ordinary income. Cryptocurrency transactions are generally not subject to VAT, but exchange service platforms may need to pay it. Mining businesses are subject to corporate income tax, and transactions require documentation.
Regulatory Framework:
CMA: It has been the supervisory authority since 2016, requiring virtual currency brokers and custodians to be licensed, setting standards such as a million-new shekel share capital, and supervising stablecoin pilots.
ISA: Regulate cryptocurrency securities-related activities, issue guidance on applicable regulations, allow non-bank members to provide crypto services in August 2024, regulate by token type, and promote legislative reforms.
Bank of Israel: Release stablecoin principles in 2023, propose full reserve and licensed supervision, study digital shekel, launch testing and carry out challenge activities in 2024.
License issuance: According to relevant laws, crypto service providers must be licensed, and they must be Israeli entities, meet the equity requirements, and have no criminal record. After the revision of ISA, non-bank institutions are allowed to conduct crypto business, implementing the closed garden model. Anti-money laundering regulations are implemented, and the stablecoin pilot is supervised by CMA.
Africa
Nigeria
Nigeria’s cryptocurrency regulatory landscape has undergone a notable transformation, moving from an initially restrictive stance to a more formal and comprehensive regulatory framework.
Legal status of crypto assets: The Central Bank of Nigeria (CBN) initially took restrictive measures in February 2021, instructing banks and financial institutions to close accounts involving cryptocurrency transactions, although individuals were not prohibited from owning cryptocurrencies. However, in December 2023, the CBN lifted restrictions, allowing banks to provide services to cryptocurrency companies licensed by the Securities and Exchange Commission (SEC). Banks are now required to open designated accounts for virtual asset service providers (VASPs), conduct extensive KYC procedures and monitor the flow of funds. This shift recognizes the need to regulate VASPs. ISA 2025 (Investment and Securities Act 2025) explicitly defines digital assets as securities and commodities, expanding the scope of the SECs supervision. The SECs position is that crypto assets are considered securities unless proven otherwise, and the burden of proof lies with the operator, issuer or promoter. This covers a wide range of digital and crypto assets such as stablecoins, utility tokens, asset-referenced tokens and e-money tokens.
Regulatory Framework: Nigeria’s regulatory environment has undergone a significant shift from prohibition to regulation. The CBN’s initial “ban” was deemed ineffective, pushed trading to P2P networks, and created a regulatory conflict with the SEC’s early recognition of digital assets. The coming to power of a new government may have played a role in the policy shift, prioritizing regulation over prohibition to achieve oversight and taxation. This evolution marks the maturation of a regulatory approach aimed at integrating the crypto economy into the formal financial system for better oversight, risk management (AML/CFT), and potential taxation.
Licensing: The SEC’s digital asset rulebook, New Rules for Digital Asset Issuance, Platforms and Custody (2022), consolidated by ISA 2025, provides statutory support for the SEC to regulate VASPs. A VASP license is mandatory for any platform that matches orders, converts cryptocurrencies into fiat, or holds assets for users, including over-the-counter trading platforms operated through social media. Failure to comply may result in penalties, including cessation of operations, fines, and prosecution of directors. The SEC has expanded its Accelerated Regulatory Incubation Program (ARIP) to speed up the approval of VASPs, and the ARIP is now included in the Revised Digital Asset Rules as a path to registration. The time in the ARIP must not exceed 12 months. Section 30 (Financial Institutions) of Nigeria’s Anti-Money Laundering Act, 2022, classifies cryptocurrency operators as reporting entities. Mandatory requirements include registering with the Nigeria Financial Intelligence Unit (NFIU), filing suspicious activity reports (SARs), monitoring transactions, and classifying customers by risk. Failure to comply may result in fines or enforcement action.
South Africa
South Africa has taken a pragmatic and evolving approach to cryptocurrency regulation, treating it as a financial product and working towards a comprehensive compliance framework.
Legal status of crypto assets: In South Africa, the use of crypto assets is legal, but they are not considered legal tender. For regulatory purposes, crypto assets are officially recognized as financial products under the Financial Advisory and Intermediary Services Act 2002 (FAIS). This classification requires providers of financial services related to crypto assets to obtain a license as a Financial Services Provider (FSP).
Regulatory framework: South Africa declares crypto assets as financial products rather than currencies, providing a clear legal basis for regulation within the existing financial services legal framework. The South African Reserve Bank (SARB) has said that exchange control regulations do not regulate the transfer of cryptocurrencies into and out of South Africa, suggesting that reform is needed. The Intergovernmental Fintech Working Group (IFWG) also recommended revising Excon to include crypto assets in the definition of capital. The tax position on cryptocurrencies is clear: income tax and capital gains tax (CGT) will apply. The South African Reserve Bank (SARB) prefers to use the term crypto assets rather than currency.
Licensing: The Financial Sector Conduct Authority (FSCA) is the lead regulator for crypto service providers. The licensing process for Crypto Asset Service Providers (CASPs) was launched on June 1, 2023, and existing institutions were required to submit license applications by November 30, 2023. As of December 10, 2024, the FSCA has approved 248 of 420 CASP license applications, of which 9 were rejected. Licensing requirements include company registration, FSP license application (including crypto asset sub-category), meeting suitability requirements, and mandatory anti-money laundering/counter-terrorism financing (AML/CFT) compliance. CASP was officially listed as a responsible agency under the Financial Intelligence Centre Act (FICA) on December 19, 2022. As the responsible agency, CASP is required to: register with the Financial Intelligence Centre (FIC), implement customer identification and verification (KYC/CDD), appoint compliance officers, train employees, conduct business risk assessments for anti-money laundering/terrorist financing/proliferation financing, establish and maintain risk management and compliance programs, submit regulatory reports (SARs), and conduct sanctions screening. The FIC has issued a directive requiring the implementation of the travel rule for crypto asset transfers by April 30, 2025. The travel rule applies to all transactions, regardless of the amount, and a wider range of information is required for transactions of R5,000 and above.
Summarize
The global cryptocurrency regulatory landscape is in a state of continuous evolution, showing a clear trend of both convergence and divergence.
Converging trends
Globally, Anti-Money Laundering (AML) and Counter-Terrorism Financing (CFT) have become the general consensus and core requirements of cryptocurrency regulation. The comprehensiveness of the EUs Markets in Crypto-Assets Regulation Act (MiCA) and its one-place licensing, universal model are becoming an important reference for other jurisdictions around the world to formulate their own regulations.
In addition, regulators generally tend to classify crypto assets according to their functions and economic substance, rather than adopting a one-size-fits-all regulatory approach. This classification includes payment tokens, functional tokens, asset tokens, security tokens, and commodity tokens. This refined asset classification method helps to impose supervision more accurately, avoid excessive or insufficient supervision, and promote global consensus on asset characterization.
Differentiation trend
Despite the convergence, the legal status of crypto assets still varies greatly around the world. From complete prohibition (such as mainland China and Egypt) to being recognized as a legal payment tool (such as Japan), to being regarded as personal property (such as the United Kingdom) or a financial product (such as South Africa), the fundamental legal characterization of crypto assets varies significantly from country to country. This fundamental difference means that global crypto companies still need to face complex legal environments and compliance challenges when conducting cross-border operations.
challenge
The main challenges facing global cryptocurrency regulation currently include:
Difficulties in cross-jurisdictional coordination: Despite some convergence driven by FATF and MiCA, countries still find it difficult to achieve fully consistent regulation due to their own economic, political and legal systems. This fragmentation leads to regulatory arbitrage, high compliance costs and regulatory vacuums.
The speed of technological development and regulatory lag: The development speed of blockchain and crypto technology far exceeds the update speed of traditional legislation and regulatory frameworks. New crypto products, services and business models (such as DeFi, NFT, DAO) continue to emerge, making it difficult for regulators to quickly formulate adaptable and forward-looking regulations.
The ongoing game of balancing innovation and risk: Governments and regulators are trying to find a balance between encouraging financial technology innovation to seize the opportunities brought by the digital economy and effectively preventing money laundering, terrorist financing, insufficient consumer protection and financial stability risks. This game process is complex and full of uncertainty, requiring continuous policy adjustments and market feedback.
In summary, global cryptocurrency regulation is moving towards a more mature and sophisticated direction, but its inherent complexity and dynamism, as well as the differentiation caused by differences in national conditions among countries, will continue to be an important background for the development of the global crypto market in the next few years.
