Global Crypto Regulations: Your Quick Guide
The wild west of crypto is over. Governments are rapidly building regulatory fences for exchanges to protect consumers and combat illicit finance. This means the rules change vastly depending on where you are.
Global Frameworks Setting the Pace:
• FATF (Financial Action Task Force): Their "Travel Rule" is key, forcing crypto exchanges (VASPs) to share transaction data above certain thresholds, mimicking traditional finance. Many countries are implementing this.
• MiCA (Markets in Crypto-Assets Regulation - EU): The EU's groundbreaking law. As of December 30, 2024, most rules for Crypto-Asset Service Providers (CASPs, including exchanges) are fully in effect, requiring licensing and strict compliance across the EU.
Regional Snapshot:
• North America:
◦ US: Still fragmented. SEC sees many crypto as securities, CFTC as commodities, FinCEN handles AML. "Regulation by enforcement" is common, but a push for federal clarity and a perceived shift towards a more crypto-friendly stance are active.
◦ Canada: More centralized, focusing on AML and securities.
• Europe (Post-MiCA):
◦ EU: MiCA is the new law. Exchanges must comply with comprehensive licensing, governance, and consumer protection rules.
◦ UK: Developing its own distinct post-Brexit regime, aligning with FATF but not MiCA. FCA is the key regulator.
• Asia:
◦ Hong Kong: Emerging as a regulated hub. Since June 2023, exchanges serving retail must be licensed with strict rules. Stablecoin regulation is coming by end-2025.
◦ Singapore: Strong regulatory hub under MAS, focused on licensing, AML, and consumer protection. MAS announced on June 6 that starting June 30, crypto firms providing services solely to customers outside of Singapore relating to digital payment tokens and tokens of capital market products will need to be licensed and that these licences will be extremely limited
◦ Japan & South Korea: Early adopters of strict licensing, real-name accounts, and AML/CFT.
◦ China (Mainland): Maintains a strict ban on crypto trading and mining.
• Australia:◦ Crypto is legal but not legal tender. AUSTRAC regulates exchanges for AML/CTF (including Travel Rule). ASIC oversees crypto as financial products. Upcoming regulations aim to broaden oversight.
• Africa & South America: A mix of developing frameworks, restrictions, and high adoption rates (e.g., Brazil has laws, Argentina high adoption but central bank bans banks from offering crypto). Regulatory clarity is still evolving.
The Road Ahead:
The trend is clear: more regulation is coming. Expect clearer asset classifications, stronger AML/CFT, enhanced consumer protection, and increased operational resilience requirements for exchanges globally. While full global harmony is distant, international cooperation is driving a gradual convergence of standards. For crypto exchanges, adapting to this maturing regulatory environment is key to survival and growth.