News flow on June 29, 2026, is well-suited to be cut into a contrast map: on one side, the legislative clock in Washington is slowing down, with Galaxy Research lowering the subjective probability of the CLARITY Act passing in 2026 from 60% to 50%. The reason is straightforward—if the Senate Majority Leader cannot schedule the bill for a full vote before early July, the window for completing the review before the August Congressional recess will be nearly closed. Once it drags into September, it will entangle with the mid-term election cycle, and any ambition to "establish federal-level market structure and investor protection rules for the U.S. digital asset market" will first be diluted by election calculations and internal differences within committees. On the other side, the Dubai Virtual Assets Regulatory Authority (VARA) issued the 50th virtual asset service provider (VASP) license to Tribe Tokenisation FZE on the same day. Since the implementation of the Virtual Assets Law in 2022, VARA has provided a pathway for crypto firms from "application - controlled operation - full operation," and this licensing pace marks the first time a full integer is drawn digitally: 50 licensed institutions mean that, at least within this jurisdiction, compliance is no longer a distant legislative blueprint but a path that can be practically traversed by projects and institutions. Thus, the question is no longer just about how many committees the text of the CLARITY Act must be modified through, or how to resolve differences in conflict of interest clauses and developer protection clauses, but rather a more direct question: as comprehensive federal-level digital asset legislation in the U.S. still languishes in uncertain corridors, has the focus of global crypto regulation begun to shift from hesitant America to clearer and more predictable rule jurisdictions, represented by Dubai and the Middle East?

CLARITY Act slows down: probability of passage lowered

For the market, this uncertainty is no longer an abstract sentiment, but has been crystallized into a cold figure by Galaxy Research on June 29: the subjective probability of the CLARITY Act passing in 2026 has been lowered from 60% to 50%. Behind this assessment is the "half-placed" status of the bill in the Senate procedures—in May 2026, it passed the Senate Banking Committee but has not yet been moved to a full-floor vote schedule; meanwhile, the Banking Committee and the Agriculture Committee still have not reached an agreement on a unified text, particularly on the points of conflict of interest clauses and developer protection clauses in the BRCA, further diluting the political momentum to "quickly move to the voting button" in the short term.

The core reason given by Galaxy Research is not technical details, but the schedule. According to its assessment, if there is hope to complete the Senate review of the CLARITY Act before the August congressional recess, the Senate Majority Leader must add the full floor vote to the official agenda before early July, allowing enough time for debate, amendments, and voting; once this scheduling gate is missed, the review will likely be postponed to September, overlapping with the U.S. midterm election cycle, and the bill will no longer just be a financial regulatory issue but will become embroiled in campaign offensives, lobbying from different industries, and party calculations, with uncertainty consequently magnified. By lowering the probability to “fifty-fifty,” Galaxy Research is essentially reminding the market that in the coming weeks, the real pressures on the CLARITY Act are no longer just textual disputes, but the two time variables of Congressional scheduling and electoral politics.

Unification of text difficult: compliance gap for developers and platforms

From a legislative design perspective, the CLARITY Act was originally expected to end the "puzzle era" of U.S. digital asset regulation: providing a top-down set of fundamental rules at the federal level, clarifying the regulatory boundaries of market structure, and answering the baseline questions of investor protection. For developers, this means there can be a unified judgment on whether a code is viewed as a product, service, or merely expression; for platforms, it relates to which regulatory authorities different business activities, such as matching, custody, and self-operation, should report to from a federal perspective. However, to date, the Senate Banking and Agriculture Committees have still not formed a unified text for this bill, and what Galaxy Research sees is not just the narrowing of the time window but also the tearing of the text itself on key clauses.

The tearing is concentrated in two highly scrutinized directions in the industry: one is how to write the "conflict of interest" clause, and the other is how to set protection clauses for developers under the framework of the Blockchain Regulatory Certainty Act (BRCA). The former directly determines whether a platform can play dual roles as a trading venue and market participant and under what conditions; the latter relates to the extent to which open-source protocol contributors and core maintainers can be viewed as traditional "financial intermediaries." The lack of consensus on these clauses between the Banking and Agriculture Committees means that even the "unified draft version" cannot be discussed. For teams already operating in the U.S., there is a fragmented regulatory landscape among multiple agencies with standards not entirely unified, and now it is complicated by a division of a key federal bill version: lawyers find it difficult to tell developers which designs will be exempt in the final text, and compliance officers cannot confirm to the board which set of conflicting rules will frame the business forms in the next three to five years. In this prolonged waiting period for a unified text, the compliance gray area is instead magnified rather than suppressed.

Dubai’s 50th license: a regulatory experiment of issuing licenses before scaling

Unlike the repeated rewording of a foundational bill at the federal level in the U.S., Dubai chose another path at the time the Virtual Assets Law came into effect in 2022: first establish rules as a complete framework, and then specifically establish the Virtual Assets Regulatory Authority (VARA) to execute them as a single independent body. This authority, positioned as one of the world's first independent institutions to specifically regulate virtual assets, has treated the "licensing pathway" as a core product from the outset—who can enter the market and at what pace to scale is no longer left to the market to explore, but is written into the regulatory process.

As of June 29, 2026, VARA has already issued VASP licenses to 50 institutions, including Tribe Tokenisation FZE. The issuance of the 50th license, in itself, is a signal: this system is no longer a "sandbox concept," but a regulatory tool that has been repeatedly utilized and is capable of supporting a regional financial center. More crucially, in the design of VARA, obtaining a license does not equate to being able to immediately open operations to the public; all licensed institutions must first enter a "controlled operation phase"—conducting services within a limited scope under regulatory oversight, verifying risk control and compliance processes in a real environment. For regulators, this is a mechanism to lock systemic risk behind a "half-open gate"; for institutions, it equates to exchanging compliance pilot operations for expected visibility of future full-scale operations. While the U.S. is still debating who will write the rules, Dubai has transformed regulation from abstract principles into executable operational sequences through the "application - controlled operation - full operation" path. This experiment of issuing licenses before scaling is increasingly providing a concrete reference framework for global compliance.

Project site selection and licensing planning: funds testing between the U.S. and Dubai

For new projects preparing to launch, the primary question today is no longer "to go or not to go to the U.S." but "how to distribute risks in the uncertain layer between the U.S. and the clearly expected Dubai." On one side is the U.S. federal framework, which is still stuck in the negotiation stage over text like the CLARITY Act. Galaxy Research on June 29, 2026, lowered the probability of the act passing within the year from 60% to 50%, noting that if the Senate Majority Leader does not schedule it before early July, the review will likely be delayed until September, coinciding with the mid-term elections, effectively telling institutions: there is no consensus on the timetable, and political noise is increasing. On the other side is Dubai, which implemented the Virtual Assets Law back in 2022, and by June 29, 2026, VARA has issued VASP licenses to 50 institutions, including Tribe Tokenisation FZE, incorporating "application - controlled operation - full operation" into an operational pathway. For trading platforms and asset tokenization companies, the U.S. offers the abstract promise of "there will eventually be a set of federal rules," while Dubai provides a concrete roadmap of "as long as the conditions are met, proceed along this production line."

In this comparison, funds are beginning to test the waters with their feet: institutions based in the U.S. or targeting the dollar market are mostly choosing to remain observant, keeping research and experimental products in an environment where the rules have yet to be solidified; while teams eager to rapidly expand asset tokenization businesses and capture the "first-comer compliance" label prefer to establish their operations in Dubai, first acquire VARA's VASP license, and go through the controlled operation phase to lock their business model into a regulatory predictable path. For institutional investors, this "U.S. observation + Dubai implementation" dual-track layout serves as a hedge—one part of the funding bets on the federal market structure that the CLARITY Act will eventually bring, while another part occupies an already formed compliance center through holding equities of licensed entities or partnerships. However, this cross-jurisdictional "regulatory arbitrage" has clear boundaries: Dubai's controlled operations do not represent a regulatory lowland; rather, it is about gradually scaling while ensuring continuous disclosures and onsite supervision. Furthermore, once the U.S. federal framework materializes in the future, how to determine the outreach scope of offshore licensed businesses to U.S. investors, and how to deal with historical compliance standards, will all pose potential retrospective risks. Therefore, project site selection and licensing planning are shifting from "where regulation is more lenient" to "under which predictable set of rules which types of responsibilities are assumed." The real competition lies in who can compress compliance costs and regulatory flexibility to a balance they can endure between the uncertain U.S. and the accelerating formation of Dubai.

Regulatory track in the second half of 2026: who can provide the market with certainty

The regulatory track in the second half of 2026 has already been locked by two timelines: one is the "scheduling timeline" of the U.S. CLARITY Act, and the other is the "licensing timeline" of Dubai's VARA. Galaxy Research has lowered the subjective probability of the act passing in 2026 from 60% to 50%, specifically pointing out that whether it is scheduled on the Senate agenda in early July and whether it can complete the review before the August recess is the only window for the U.S. to provide federal-level certainty to the digital asset market; once the vote is pushed into September, the review process will overlap with the mid-term election cycle, reshuffling the legislative outcomes and landing pace. In contrast, Dubai's licensing pathway, led by VARA under the existing framework of the Virtual Assets Law, has entered an "expansion phase"—by June 29, it has issued VASP licenses to 50 institutions, including Tribe Tokenisation FZE, continuously releasing predictable compliance space through a stair-step arrangement of "application - controlled operation - full operation." This comparison of "U.S. legislative observation period vs. Dubai licensing expansion period" is not only redrawing the map of project registration locations and capital flows but also changing the pricing method of compliance itself: in the second half of the year, both institutions and individual users should avoid betting on the political and legislative fortunes of a single jurisdiction. Instead, they should disperse regulatory risks through multi-location layouts, business segmentation, and compliance redundancy in a landscape where the U.S. federal framework has yet to take shape and Dubai's regulatory path is relatively clear, because what truly needs management is the uncertainty accumulated over time and geography.

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