In recent years, cryptocurrency regulation has shown two parallel main lines: one is that mature markets are incorporating the industry into traditional financial regulatory frameworks through legislation and rules; the other is that some countries are exploring blockchain and stablecoin applications in overseas or controlled scenarios while maintaining strict domestic restrictions. The European Union's Markets in Crypto-Assets Regulation (MiCA) has established unified market access, disclosure, and regulatory obligations, providing a clear compliance path from issuers to trading platforms, marking a shift in regulation from "prohibition or ambiguity" to "regulation."

In the United States, the regulatory stance exhibits a "dual-track" characteristic: on one hand, enforcement actions by agencies like the SEC continue, with frequent cases targeting fraud and unregistered securities offerings; on the other hand, regulatory officials have also expressed an openness to tokenization and collaboration with the industry in public forums, suggesting a search for balance between enforcement and promoting sustainable market innovation. This dual situation requires companies to manage compliance risks while actively communicating with regulators to seek viable business models.

China's strategy is more complex: domestically, it has maintained a high-pressure policy on cryptocurrency trading and mining for a long time, but has begun selective pilot programs for foreign or cross-border financial instruments—recent reports indicate that institutions with Chinese backgrounds have launched regulated stablecoins denominated in RMB overseas to support cross-border payments and trade settlements. This reflects China's differentiated path between "preventing capital and financial risks" and "promoting the international application of blockchain." This duality in the regulatory environment has significant implications for global market liquidity and financial infrastructure.

At the international standards level, the enforcement of anti-money laundering and the "travel rule" remains a focal point for regulatory cooperation. International organizations, including the FATF, continue to emphasize strengthening supervision of Virtual Asset Service Providers (VASP) and cross-border information sharing, requiring countries to consider both technical operability and regulatory enforceability when implementing these measures, which raises compliance thresholds for exchanges, custodians, and payment institutions.

Policy signals have been quickly digested by the market and reflected in price and capital flows: when regulation becomes clearer and supportive of innovation (such as some countries or institutions promoting tokenization and controlled stablecoin pilots), the market often sees a resurgence in risk appetite; conversely, sudden strong regulatory or enforcement events can trigger short-term volatility. Over the past few months, Bitcoin and mainstream tokens have shown strong volatility amid multiple regulatory news and policy developments, with investors' demand for policy certainty significantly increasing.

The short- to medium-term impacts on the industry can be summarized in three points: first, compliance costs and entry barriers are rising, prompting large institutions and traditional financial players to gain structural advantages; second, regulatory differentiation will drive business migration to friendly jurisdictions, but will also create a demand for cross-border regulatory coordination (such as passport mechanisms and information sharing); third, the combination of technology and compliance becomes key—on-chain and off-chain tools that can prove compliance (KYC/AML, auditable ledgers, custodial solutions) will become part of institutional competitiveness.

In conclusion, the current stage of regulatory evolution is not simply "tightening = negative" or "loosening = positive." The key lies in the clarity and enforceability of the rules—only a regulatory framework that is clear, predictable, and balances innovation with investor protection can bring about long-term healthy market development. For practitioners and investors, the short-term focus should be on compliance, paying attention to the process of cross-border regulatory coordination, and considering policy risk as a routine factor in asset allocation and business decision-making.

Related: Cryptocurrency ETPs recorded an outflow of $812 million last week, while Solana saw an inflow of $291 million against the trend.

Original: “Divergent and Coordinated Crypto Regulation: Market Reactions Under Tightening Policy”

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