In the past year, there has been a clear divergence in the regulation of crypto assets: some jurisdictions have incorporated cryptocurrencies into their financial regulatory frameworks through explicit legislation, while others seek a balance between crackdown and pilot programs. The European Union's Markets in Crypto-Assets (MiCA) has established unified market access and information disclosure requirements, promoting trading platforms, issuers, and wallet service providers to accept authorization and supervision, and setting basic rules for stablecoins and asset-backed tokens, providing a benchmark for cross-border compliance.
At the same time, international regulatory coordination is also strengthening. The International Organization of Securities Commissions (IOSCO) recently pointed out that the "tokenization" of assets may bring new systemic risks, calling for stricter regulatory scrutiny of related trading, custody, and valuation mechanisms to prevent contagion risks from transmitting to traditional finance. Such industry warnings are prompting regulators to consider market interconnectedness and risk transmission channels more in their rule design.
In the United States, the regulatory path shows stronger enforcement selectivity—federal regulators have adjusted their judicial actions against large exchanges and service providers in recent years, with some cases being withdrawn or settled, reflecting the tug-of-war between regulation and industry over legal positioning and resource priorities. Although regulatory uncertainty has increased compliance costs in the short term, it has also driven market participants to strengthen self-examination and governance practices.
China continues to promote a digital currency strategy centered on the central bank digital currency (eCNY), while maintaining strict restrictions on domestic crypto trading and ICOs; however, relevant authorities are also exploring stablecoin solutions priced in fiat currency to enhance the international use of the renminbi. This parallel model of "sovereign digital currency + offshore innovation" has formed a governance path different from that of Europe and the United States.
In addition, several countries are accelerating specific regulations on stablecoins; for example, some economies plan to include stablecoins in regulatory frameworks similar to those for banks or payment instruments, with central banks or financial regulatory agencies responsible for supervision or licensing. The direct effect of tightening regulation is to push the market towards compliance and centralized infrastructure, while also stimulating discussions on the impact of compliance costs and financial inclusivity.
In summary, global regulatory trends present three main lines: first, legalization and homogenization (such as MiCA) provide cross-border predictability; second, macroprudential and consumer protection take priority, with regulatory focus expanding from trading to custody, valuation, and stabilization mechanisms; third, geopolitical and policy divergence leads to a "puzzle-like" regulation, requiring companies to make localized arrangements and enhance technological governance in their compliance paths. Investors and practitioners should adjust product design, risk management, and regulatory dialogue strategies with compliance as a prerequisite. Regulation and innovation will continue to shape each other, but in the short term, the uncertainty of rules and enforcement remains a major source of risk in the market.
Related: Visa pilots stablecoin payment services funded by fiat currency for U.S. businesses
Original text: “Global Evolution of Crypto Regulatory Frameworks and Practical Challenges”
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