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Australia's first comprehensive digital asset law, passed on 1 April 2026. Requires crypto exchanges and custody providers to obtain an Australian Financial Services Licence (AFSL). Creates two new regulated categories: Digital Asset Platforms and Tokenised Custody Platforms. AFSL deadline 30 June 2026.
Bahrain was one of the first countries in the Middle East to regulate crypto. The Central Bank of Bahrain's Crypto-Asset Module (CRA) requires licensing for crypto-asset service providers and applies a comprehensive AML/CFT, consumer protection and capital framework. Bahrain is an established regional crypto hub alongside Dubai.
Canada requires all crypto businesses to register with FINTRAC as Money Services Businesses (MSBs) and comply with AML/CFT laws. Platforms offering crypto securities must also register with provincial securities regulators (CSA/CIRO). Travel Rule applies above CAD 1,000. CARF implementation effective January 2026.
EU regulation requiring financial entities — including MiCA-authorised CASPs — to manage ICT risk, conduct resilience testing, and report major ICT incidents. In force from 17 January 2025.
A time-limited EU regime for trading and settling tokenised securities on distributed ledger technology under a controlled sandbox.
The EU's comprehensive regulatory framework for crypto-assets, setting harmonised licensing, conduct, disclosure and consumer protection rules for issuers and service providers across all 27 member states.
EU regulation requiring all crypto-asset service providers to collect and transmit originator and beneficiary information on every crypto transfer, regardless of amount. In force from 30 December 2024 with no grace period.
Global AML/CFT standard setting the baseline for how countries regulate virtual assets and VASPs. Recommendation 15 (updated 2019) requires countries to license/register VASPs, apply AML/CFT measures, and implement the Travel Rule. Only 1 of 138 assessed jurisdictions is fully compliant as of 2025.
Mandatory licensing regime for all centralised virtual asset trading platforms in Hong Kong, operated by the SFC under the AMLO since June 2023. Requires fit-and-proper tests, 98% cold storage of client assets, full KYC/AML, and the Travel Rule for transfers above HKD 8,000.
Hong Kong's first dedicated stablecoin law, in force from 1 August 2025. Requires HKMA licensing for all issuers of fiat-referenced stablecoins in or from Hong Kong. Minimum paid-up capital of HKD 25 million, full reserve backing, and strict AML/CFT and Travel Rule obligations.
Landmark Japanese bill to reclassify crypto assets as financial instruments under the Financial Instruments and Exchange Act (FIEA), shifting oversight from a payments to a securities framework. Cabinet approval on 10 April 2026. The bill was submitted to the National Diet in May 2026 and is currently under parliamentary debate. Expected to take effect fiscal year 2027 if passed. Reclassification covers approximately 105 listed crypto assets including Bitcoin, Ether and XRP. Introduces insider trading prohibitions, mandatory annual issuer disclosures, and raises penalties for unregistered sales (prison terms up to 10 years; fines up to JPY 10 million).
Japan's foundational crypto regulatory framework under the Payment Services Act, requiring FSA registration for all crypto asset exchange service providers. Mandates 95%+ cold storage of customer assets, annual audits, full KYC/AML, and the Travel Rule. One of the world's most established crypto regulatory regimes, in place since 2017.
Singapore-incorporated entities providing digital token services to overseas customers must be licensed under the FSMA from 30 June 2025. MAS has stated it will generally not issue licences — effectively requiring most offshore-facing Singapore crypto entities to cease or relocate operations.
Singapore's primary licensing framework for crypto businesses serving local customers. Requires Major or Standard Payment Institution licences for digital payment token (DPT) services. Strict AML, consumer protection, asset segregation and Travel Rule requirements. 33 licensed operators as of 2025.
South Korea's two-phase crypto regulatory framework. Phase 1: VAUPA (in force July 2024) requires 80% cold storage, segregated customer deposits at banks, insurance against hacking, and bans on market manipulation. Phase 2: DABA (enacted June 2025) adds stablecoin licensing, foreign VASP oversight, and expanded FSC enforcement powers.
Switzerland applies existing financial market laws to crypto using a technology-neutral, principle-based approach. Crypto companies must join a FINMA-supervised SRO or obtain direct FINMA authorisation. The DLT Act (2021) integrated blockchain into civil and financial law. New dedicated crypto-institution licence category proposed October 2025, expected 2026-2027.
New UAE federal framework effective 1 January 2026, establishing the Capital Market Authority (CMA, formerly SCA) as the primary federal regulator for virtual assets. Introduces 8 licensed activity categories, extraterritorial reach, and a federal token admission gateway that applies even to VARA-licensed platforms.
UAE Central Bank's framework for stablecoin services covering issuance, conversion, and custody/transfer of payment tokens. In force July 2024. Only AED-denominated or CBUAE-registered foreign stablecoins may be used for payments. Algorithmic stablecoins and privacy tokens explicitly prohibited.
Dubai's bespoke crypto regulatory framework operated by VARA, the world's first dedicated virtual asset regulator. Mandatory licensing across seven activity categories. Rulebook v2.0 published May 2025. Over 20 licensed entities. VARA's role is evolving alongside the new federal CMA framework effective January 2026.
UK implementation of the FATF Travel Rule requiring cryptoasset businesses to collect and share sender and recipient information on crypto transfers above GBP 1,000. In force since 1 September 2023 — the UK was one of the first countries to implement.
UK rules requiring all crypto promotions targeting UK consumers to be fair, clear and not misleading, with mandatory risk warnings, a 24-hour cooling-off period and appropriateness testing. In force since 8 October 2023. Breach is a criminal offence.
The UK's comprehensive FSMA-based regulatory framework for cryptoassets, covering licensing, conduct, prudential standards, market abuse, admissions and disclosures. Statutory Instrument (SI 2026/102) enacted February 2026. Regime takes effect 25 October 2027. FCA authorisation gateway: pre-application support service (PASS) opens July 2026; application window opens 30 September 2026 and closes 28 February 2027. Existing MLR-registered firms must re-apply — there is no automatic conversion. Firms missing the window enter a transitional run-off regime, allowing existing contracts only with no new business.
US AML framework applying to crypto businesses as "money services businesses" (MSBs). Requires registration with FinCEN, AML programme, KYC/CIP, suspicious activity reporting (SARs) and currency transaction reporting (CTRs). Applies to exchanges, custodians and wallet providers.
Comprehensive US market structure bill that would clarify SEC and CFTC jurisdiction over digital assets and establish registration regimes for crypto exchanges, brokers and dealers. Passed the House 294-134 in July 2025. The Senate Banking Committee approved the bill 15-9 on 14 May 2026, with two Democrats joining all Republicans. The bill now moves to the full Senate floor; advocates aim for passage before the August 2026 recess. Still requires reconciliation with the House version and a final House vote before reaching the President.
The first US federal law governing payment stablecoins. Signed by President Trump on 18 July 2025. Only "permitted payment stablecoin issuers" may issue payment stablecoins in the US. Full implementing regulations required by July 2026 with the regime taking effect by January 2027.
US sanctions obligations apply fully to crypto businesses. OFAC requires screening of all customers and transactions against the SDN list. Facilitating transactions with sanctioned entities or jurisdictions — knowingly or unknowingly — can result in civil and criminal liability. Strict liability applies for some violations.
Landmark joint interpretation issued by the SEC and CFTC on 17 March 2026 (effective 23 March 2026 upon Federal Register publication) establishing the first formal classification framework for crypto assets under US federal law. Introduces a five-category token taxonomy: digital commodities, digital collectibles, digital tools, stablecoins, and digital securities. Names 16+ major cryptocurrencies including Bitcoin, Ether, Solana and XRP as digital commodities (not securities). Clarifies treatment of staking, mining, airdrops and token wrapping. Binding on both agencies. A formal rulemaking proposal exceeding 400 pages — including an "innovation exemption" and safe harbor provisions — is expected within weeks.