*This article has been automatically translated. Please refer to the original article for accurate content.
If you follow the regulatory developments surrounding cryptocurrencies, December 2024 already feels like a long time ago. The current global policy environment has changed dramatically compared to just 12 months ago. The pace of change is so rapid that it shows little sign of slowing down.
So, before we look ahead to 2026, let’s take a look back at the major regulatory changes that took place in 2025. We’ll cover global trends, regional developments, and topics that will be of particular interest in 2026. For more background and analysis, please see the Chainalysis Road to Crypto Regulation series and the 2025 Geography of Cryptocurrency Report .
Five major trends in digital asset policy
1. Progress in regulatory implementation and friction during implementation
Over the past few years, countries and regions have made progress in developing comprehensive regulatory frameworks for digital assets. While progress has varied, significant progress has been made overall. However, progress has been uneven across countries and regions.
As we move from the "legislation stage" to the "actual implementation stage" in 2025, it becomes clear that the implementation process itself is just as politically and practically complex as the legislation itself.
In the EU, MiCA (Markets in Crypto-Assets) will be fully implemented in early 2025. This will mark a shift from a system that has previously relied on individual rules centered on AML (anti-money laundering) to the world's first comprehensive set of common rules for crypto assets. However, the progress of this transition is not uniform across member states.
Although ESMA (European Securities and Markets Authority) and EBA (European Banking Authority) are working to harmonize technical standards and supervisory systems, differences remain between countries in the interpretation and implementation of the provisions. With regard to stablecoin systems in particular, the following issues are still being sorted out in practice:
How to handle the "multi-issue model" in which multiple businesses jointly issue and operate bonds
How to define the position of e-money tokens (electronic money tokens)
How to align it with existing regulations such as the Payment Services Regulation and MiFID (Markets in Financial Instruments Directive)
A major practical challenge is clarifying the relationship between these "new cryptocurrency rules" and the "existing rules for payment and investment services."
Similar "implementation challenges" are being seen in other regions. For example, in Singapore , the rapid rollout of Digital Token Service Provider regulations under the Financial Services and Markets Act has left businesses scrambling to assess the legal impact. Globally, the implementation of the Travel Rule has also posed challenges for both businesses and regulators. Specifically, the following issues are likely to arise:
The emergence of the "sunrise problem" (gaps arising due to differences in the implementation dates between countries)
How to handle unhosted wallets (personal wallets that do not go through exchanges, etc.)
To what extent can both regulators and businesses secure expertise in technology and risk?
How to ensure interoperability (compatibility) between tools used by each company and country
As such, even after the "rulemaking" is complete, it is natural that there will be differences in the progress of actual implementation and that troubles and challenges unique to the early stages will arise. As these regulations mature, efforts to eliminate friction and improve compliance and oversight capabilities are expected to continue in 2026.
2. The rise of stablecoins and restructuring of rules
The United States has passed the GENIUS Act , a comprehensive stablecoin law.
This not only established a common federal framework for stablecoin issuers in the United States, but also created an international benchmark (standard reference model) that will influence the policies of other countries, accelerating efforts to advance stablecoin policies around the world.
Currently, laws regarding stablecoins have only been enacted in a few countries and regions, including Japan, the EU, and Hong Kong. However, countries such as South Korea and the UK are also working on designing systems for regulating issuers. Discussions are not limited to technical issues such as "methods for stabilizing prices," "adequacy of reserve assets," and "audits and attestations (third-party verification)." They are also considering the impact on the entire financial system, including financial stability, capital flow management, and AML/CFT.
As regulations are put in place, the way stablecoins are used around the world is gradually being restructured. For example, in the EU, an increasing number of Crypto-Asset Service Providers (CASPs) are unable to offer stablecoins that do not comply with MiCA, or are being severely restricted from doing so. As a result, we are seeing a shift in funds back into stablecoins that comply with MiCA.
In the United States, the GENIUS Act has placed certain restrictions on the conditions under which stablecoins issued overseas can be offered in the U.S. Going forward, the following points are expected to have a significant impact on the international presence of each stablecoin.
To what extent should the circulation of unregulated stablecoins be regulated?
Whether regulatory authorities in each country and region will "mutually recognize" each other's oversight results or allow a single authorization to be offered in multiple countries through a "passporting system"
3. Advances in tokenization (digital securitization of government bonds, gold, etc.)
A prominent theme for 2025 will be the tokenization of financial and real assets, which is the movement to treat assets such as U.S. Treasury bonds and gold as tokens (digital securities) on the blockchain.
For example, the assets under management of tokenized money market funds (funds that invest in short-term financial products) backed by U.S. Treasury bonds exceeded $8 billion as of December 2025, and the assets under management of tokenized products backed by commodities such as gold also grew to over $3.5 billion . While still small in scale compared to the traditional financial market as a whole, 2025 can be said to have been a year of strong growth.
In 2025, regulatory authorities around the world generally adopted a stance that emphasized experimentation and was proactively supportive. Specific examples include:
In Singapore, the central bank, MAS, has evolved its private blockchain platform from a pilot to a production-ready framework through Project Guardian, and has also announced plans to pilot tokenized central bank notes.
In the United States, the Securities and Exchange Commission (SEC) held a public roundtable on the topic of tokenization in May, and in July, a project called "Project Crypto" was launched to consider how securities laws could be applied to blockchain transactions. In December, the DTC (the securities settlement organization) issued a "no-action letter" approving a securities tokenization scheme (a letter indicating that it does not consider it illegal), making the future in which tokenization is incorporated into the core of market infrastructure more of a reality.
The EU is currently reviewing its DLT pilot regime, positioning tokenization as one of the pillars for enhancing the competitiveness of capital markets. ESMA has put forward proposals to make the regime more attractive to investors and businesses, while also realizing truly integrated, digitally enabled capital markets.
4. Full-scale entry of traditional finance (TradFi)
In 2025, traditional financial institutions, including banks, began to fully enter the cryptocurrency market, offering financial products linked to cryptocurrency prices, stablecoin issuance, custody (storing customer assets), and trading services.
The background to this is a shift in the attitude of regulators, particularly in the US. During 2025, the FDIC (Federal Deposit Insurance Corporation), OCC (Office of the Comptroller of the Currency), and Federal Reserve Board (Fed) revised their previously cautious and restrictive statements to broaden banks' exposure to crypto assets.
Additionally, the Basel Committee on Banking Supervision (BCBS), the international banking regulatory rule-maker, has indicated it intends to reconsider capital requirements for banks' cryptocurrency exposures, responding to industry concerns that current standards are overly strict.
The guidelines also provide clear guidelines for banks on AML risk management when providing services to cryptocurrency businesses and stablecoin issuers. The New York State Department of Financial Services (NYDFS) and Wolfsberg Group have each published guidelines explaining how banks should assess and manage risks when dealing with cryptocurrency-related clients.
In the EU, the implementation of MiCA and the resulting clarification of rules will make it easier for traditional financial institutions to advance cryptocurrency and tokenization projects under a harmonized rulebook.
5. Increased focus on financial crime and asset recovery
As the use of cryptocurrencies expands, so do the opportunities for their misuse for criminal purposes. As a result, policymakers and law enforcement agencies around the world are urgently required to address the following three points:
Strengthening measures against the risk of money laundering and terrorist financing using crypto assets
Strengthening asset recovery to prevent criminal proceeds from being used again for crime
Utilizing public-private partnerships (cooperation between law enforcement agencies and private businesses)
The 2025 Asset Recovery Guidance from the Financial Action Task Force (FATF) outlines best practices for seizing, managing, and returning crypto assets to victims, and clearly emphasizes the importance of utilizing blockchain analysis tools and public-private partnerships.
Cyber fraud and investment fraud, which have been on the rise in recent years, are also a major focus. The UK has introduced rules for compensating victims of "authorized payment fraud," strengthening the movement to hold banks and other intermediaries responsible for remittances. Following this, Australia and Thailand have also introduced regulations that impose certain obligations on gatekeepers such as financial institutions and technology platforms, as well as sanctions and loss sharing in the event of breach of these obligations.
In line with these developments, supervisory authorities are stepping up their checks on whether systems for detecting money mules (such as accounts with borrowed names) and monitoring fraudulent transactions are sufficient.
Operationally, the United States is working to disrupt international cryptocurrency investment fraud networks through sanctions against key networks and their intermediaries, unprecedented asset seizures , and the establishment of a " Scam Center Strike Force. " Countries, including those in the Asia-Pacific region, are also stepping up their anti-fraud measures, with an increasing number of successful cryptocurrency seizures .
In order to increase trust in cryptoassets and expand their institutional adoption by banks, institutional investors, and others, it is expected that policy responses and practices in these areas will continue to be strengthened.
Regional trends (convergence and division)
US: New policy trajectory accelerates market
In the global cryptocurrency landscape, the United States will see the biggest changes in 2025. The new administration has revised its previous confrontational and restrictive policy stance and made clear its intention to embrace digital assets as a strategically important field.
In July 2025, the Presidential Task Force on Digital Assets published a comprehensive roadmap that outlined the following:
Rapid implementation of the GENIUS method
Modernizing AML Regulation
New legislation on market structure
The Commodity Futures Trading Commission (CFTC) and the SEC will use their existing authorities to create a framework to enable digital asset trading.
The CFTC and SEC have also helped shift the focus to a more "business-friendly environment." The SEC has scaled back lawsuit-based enforcement against crypto companies and rescinded accounting guidance known as SAB121. They also announced Project Crypto, a company-wide goal to "move U.S. financial markets onto the blockchain." The CFTC is also pursuing what it calls a "crypto sprint."
The two institutions have strengthened their collaboration through a joint statement on trading in spot crypto products and a joint roundtable in September 2025.
There has also been a shift in the attitudes of bank regulators. In April 2025, the FDIC lifted its requirement for supervised institutions to provide prior notice of crypto-related activities. In July, the FDIC, OCC, and Federal Reserve published their risk management guidelines for cryptocurrency custody. In December, the Federal Reserve issued a statement expressing a positive stance toward state-affiliated banks that are not subject to deposit insurance engaging in digital asset activities.
On the legislative side, the GENIUS Act established a common federal framework for stablecoin issuers, setting out requirements for reserve asset holdings, audit requirements, and financial integrity (a mechanism to prevent fraud). Specific implementation work will now begin in earnest, with a final version expected to be formulated by July 2026. The deadline for implementation is January 2027, and regulators will continue to fine-tune the details.
Meanwhile, with regard to legislation related to market structure, the House of Representatives passed the Clarity Act in July 2025, and the Senate Banking Committee and the Senate Agriculture Committee each released discussion drafts. However, coordination on how to consolidate these bills and finalize them is expected to be postponed until after 2027, and with many priorities, it is unclear how quickly this will progress.
Asia-Pacific: Diverse Starting Points, Increasing Momentum
In the Asia-Pacific (APAC) region, some countries, such as Japan, Malaysia, and Thailand, are ahead of the curve in cryptocurrency regulations. In 2025, the momentum for regulatory development was building broadly and rapidly, driven by market expansion, competition among countries, and the influence of policies in developed countries. While each country is starting from a different point, many countries are developing comprehensive frameworks that cover both market conduct (such as investor protection) and financial stability.
The situation in major countries and regions is as follows:
As one of the most mature cryptocurrency markets, Japan is currently undergoing reforms to regulate cryptocurrencies as investment products and a review of its tax system.
In Korea,
In South Korea, the first unfair trading case under the Virtual Asset User Protection Act has been referred to the prosecution. Several stablecoin-related bills have also been submitted to the National Assembly simultaneously, and attention is focused on which bills will ultimately be adopted.
Hong Kong is actively developing its virtual asset regime, with proposed custody and dealing regulations, plans to allow local trading platforms to access global liquidity, and the passage of the Stablecoin Ordinance in August 2025. The first licenses are expected to be issued in early 2026.
Singapore was the first country in the region to undergo the FATF's Fifth Mutual Evaluation (a full-scale evaluation that includes an assessment of the effectiveness of virtual assets and VASPs), making it more important than ever to demonstrate how well AML/CFT measures in the cryptocurrency space actually work.
Other countries are also undergoing restructuring.
In Indonesia, the regulatory jurisdiction over crypto assets has been transferred from the Commodity Futures Agency (Bappebti) to the Financial Supervisory Agency (OJK), and the direction has been indicated to treat crypto assets as "financial products" rather than "commodity."
In the Philippines, the Securities and Exchange Commission (SEC) has expanded its powers through new regulations, emphasizing consumer protection and market integrity.
In Australia, the Corporations Amendment (Digital Assets Framework) Bill 2025 is under consideration, and the Securities and Investments Authority (ASIC) has updated INFO 225 to provide greater clarity on how existing financial regulations apply to digital assets.
Pakistan and Vietnam have shown particularly strong shifts in APAC. Both countries have large informal cryptocurrency markets, but were previously restrictive or unclear on crypto.
- Pakistan has lifted its ban on cryptocurrency trading and moved towards comprehensive regulation, establishing the Pakistan Crypto Council and the new Virtual Assets Regulatory Authority to handle licensing and oversight.
Vietnam has granted legal status to crypto assets and established a pilot program for crypto exchanges, moving the crypto asset market from a "gray zone" to a formal one.
Europe: MiCA regulations come into full operation
The EU's MiCA regulation is currently the most comprehensive cryptocurrency regulatory framework in the world. One year after its full implementation, the number of licensed cryptocurrency service providers (CASPs) has exceeded 90. The number of issuers of electronic money tokens (EMT) has also diversified, and the use of euro-denominated stablecoins has expanded.
The publication of multiple RTS/ITS (detailed technical standards) by ESMA and EBA has also provided practical guidance for the implementation of MiCA, encouraging traditional financial institutions to enter the crypto asset and tokenization business.
At the same time, MiCA has become an important test case for confirming the effectiveness and challenges of the system in actual operation. For example, ongoing discussions are being held on the following points:
How to deal with a "multi-issuance model" where the issuance scheme spans multiple entities
How to assess equivalence with systems outside the EU
If EMT can be considered both a "fund" and a "crypto asset," how will it relate to EU payment regulations?
In order to achieve the EU's vision of a Savings and Investment Union (SIU) and a truly "level playing field" for CASPs, the European Commission is proposing a redesign of the supervisory model, including giving the investment services authority ESMA direct powers to authorise and supervise all CASPs.
In the area of AML, there is a move away from the previously country-specific 5AMLD (Fifth Anti-Money Laundering Directive) to the EU-wide, directly applicable "AMLR," which imposes clearer and more uniform expectations on all obligated parties, including CASPs.
The new EU AMLA (EU-level AML Authority) is developing additional guidance for consistent implementation of the AMLR, which is scheduled to come into effect on July 10, 2027. AMLA has prioritized crypto assets and aims to directly supervise companies, including CASPs, from 2028. In the medium term, this means that instead of supervision being fragmented in each country, we will move to a system in which data is collected and analyzed centrally at the EU level and AML supervision is based on the results.
While MiCA and AMLR are at the core, CASP must also comply with other frameworks, such as the Digital Operational Resilience Act (DORA), which significantly raises the bar for operational resilience against cyberattacks and system failures, significantly impacting the overall compliance structure of CASP.
Britain: Moving from a marginal position
In the UK, for the past few years, the only regulations in place were the Financial Conduct Authority's (FCA) AML system and the limited restrictions on the advertising and solicitation of cryptocurrencies that were subsequently introduced, and regulations on cryptocurrencies have effectively remained peripheral.
However, 2025 marks a turning point for the UK. The Bank of England has begun considering the design of a system for stablecoins of a size that could have an impact on the entire financial system (so-called "systemic stablecoins"), including how large they should be considered significant, how much they should be allowed to hold, and how to structure the reserve assets that would back them.
At the end of the year, the FCA published three consultation documents, which included:
A comprehensive system covering all cryptocurrency activities
A framework for disclosure and market manipulation regulations specific to crypto assets
Prudential regulation of cryptocurrency companies (regulations on capital adequacy and risk management)
Of particular note are the following:
The regulations also include the lending and borrowing of crypto assets (so-called lending/borrowing) and staking (the act of depositing crypto assets and receiving rewards).
The scope of the regulations is broader than MiCA, and decentralized finance (DeFi) will be evaluated based on substance rather than form alone, and if a substantial controlling entity can be identified, it will be subject to the same obligations as other businesses.
Middle East: Stablecoins, Tokenization, and the Institutional Market
In the Middle East, the development of a regulatory architecture has progressed in line with the expansion and institutionalization of the cryptocurrency market.
The UAE (United Arab Emirates) has solidified its position as a hub in the region, with authorities such as the Central Bank, Dubai's VARA, and Abu Dhabi's FSRA operating mature licensing regimes for exchanges and custody, while also enforcing marketing, conduct, and market integrity rules. The UAE is also advancing a stablecoin and payment token regime with a focus on payments and tokenized finance.
These systems place emphasis on the following points:
Full reserve (100% reserve)
Clear redemption rights (the right to get the principal back at any time)
Strong governance (internal control and risk management)
As a result, there is growing interest in stablecoins denominated in local currencies and issued by regional financial institutions.
Elsewhere in the Gulf, Saudi Arabia and Qatar have moved beyond the pilot phase and have clarified their policy direction.
Qatar has introduced a more structured digital asset framework.
Saudi Arabia is focusing on innovation in tokenization, CBDC (central bank digital currency) pilots, and “DeFi-like” areas with risk-sensitive institutional designs, gradually expanding the scope of its regulations.
At a region-wide level, MENAFATF (the Middle East and North Africa regional body for the FATF) has made alignment with FATF standards and preparation for mutual assessment a priority for 2025. This raises AML/CFT expectations for VASPs (cryptoasset service providers) in the Middle East, and indicates that risk-based and data-driven supervision is becoming the norm.
Latin America: Towards a structural regulatory framework
By 2025, Latin America has clearly transitioned from reactive, AML-centric supervision to a more systematic and structured regulatory framework that takes into account the already high levels of grassroots adoption of crypto assets.
- Building on the comprehensive law on virtual assets such as cryptocurrencies and stablecoins enacted in 2022-2023, Brazil has established detailed lower-level rules (provisions equivalent to government or ministerial ordinances) on VASP licensing, governance, conduct regulations, prudential requirements, supervisory reporting, etc. As a result, Brazil is quickly becoming a "de facto benchmark (standard model)" throughout the region.
In other major markets such as Argentina and Mexico,
There has been a shift from an ad hoc approach and an approach focused solely on AML to a broader model that also includes consumer protection, market integrity, and operational risks (such as system failures and internal fraud), although differences in legal certainty and supervisory capacity remain across countries.
Across the region, there is a lot of attention being paid to the role of stablecoins, especially:
International remittance
trade settlement
Hedge against inflation (a means of preserving value)
As a result, there is a movement to clarify the requirements for stablecoin issuance, reserve assets, redemption rights, and obligations of intermediaries.
Alignment with FATF standards and upcoming mutual evaluations provide a common basis for determining AML/CFT expectations in the region and supervisory priorities.
Africa: Micro-utility drives adoption and new regulatory frameworks
In Africa, regulations are gradually catching up with the established real-world adoption of crypto assets. Sub-Saharan Africa ranked third among global regions for cryptocurrency market growth in 2025. On-chain transaction volume grew by more than 50% year-on-year, with many of these transactions being small amounts of less than $10,000. This highlights the important role crypto assets play in improving payments, remittances, and financial access.
In terms of supervision, South Africa has emerged as a regulatory anchor on the continent. Cryptoassets are now classified as financial products, and numerous CASPs are now subject to licensing. AML/CFT obligations will be imposed from 2022, and the Travel Rule will come into effect in 2025. The South African Reserve Bank is strengthening its analysis and policy considerations of systems that treat stablecoins and fiat currencies such as bank deposits as tokens on blockchains. While independent legislation targeting stablecoins has not yet been enacted, the direction is already clear: the full-scale introduction of prudential and conduct regulations in the future.
While on-chain trading volumes remain very high in Nigeria, the country is still undergoing a gradual review of its cryptocurrency policy, using securities regulations and an AML/CFT framework to oversee exchanges and other intermediaries, while remaining cautious about the impact on the local currency and exchange rate.
Many major countries are also focusing on the use of stablecoins in key trade and remittance routes (so-called payment corridors) with the Middle East and Asia. The focus is on implementing FATF-aligned AML/CFT requirements, including transaction monitoring, travel rule implementation, and risk-based supervision. We are moving beyond borderline discussions to data-driven supervision of actual economic flows.
Topics to watch in 2026
The policy calendar for 2026 already includes many important milestones. In the United States, market structure legislation remains a key policy issue, but it is unclear how quickly negotiations will progress after the new year, given other priorities.
In the area of taxation, the Crypto-Asset Reporting Framework is being implemented, with several countries committing to the first information exchange by 2027.
Stablecoin regulation takes shape
Authorities in countries and regions that have not yet fully developed and implemented stablecoin systems are expected to move forward with the creation of systems and the implementation of these systems through 2026.
In the United States, federal and state authorities are expected to issue final rules by July 2026 that will outline how the GENIUS Act will be implemented, including how issuers will be licensed and supervised at the federal level and the requirements for stablecoins issued overseas to be offered in the United States.
Singapore needs to finalize the stablecoin scheme bill, as well as its specific operating rules and guidance.
In the UK, the FCA is consulting on a specific conduct and market framework for stablecoins, while the Bank of England is focusing on the prudential regulation and financial stability treatment of systemic stablecoins.
However, many challenges are expected to remain even in 2026. In October 2025, the Financial Stability Board (FSB) noted that even in jurisdictions that have already implemented stablecoin frameworks, "robust risk management, adequate capital buffers, and recovery and resolution planning requirements are often still insufficient."
Additionally, the FATF is also considering the level of AML/CFT expectations for stablecoin issuers, particularly regarding the monitoring of transactions in secondary markets (such as exchanges). In line with this, the FATF plans to publish an analysis on stablecoins in the first quarter of 2026, which is expected to serve as an important guideline for countries considering what kind of regulations they should aim for.
Increased focus on AML and cyber risks
As digital assets become more deeply integrated into the global financial infrastructure, regulators are stepping up their oversight and regulation of the resulting systemic risks. While cryptoassets were once viewed as niche vehicles used for darknet transactions, they have now evolved into specialized money laundering networks supporting a wide range of crimes. New schemes using cryptoassets to evade sanctions, such as A7A5 , are also emerging.
With the scope of the FATF's fifth mutual evaluation expanding, the pressure to demonstrate the effectiveness of AML/CFT will continue to be on both regulators and industry.
At the same time, the more activity moves onto the blockchain, the greater the impact of operational failures (such as system failures or key management errors): By 2025, cryptocurrency theft is expected to exceed $34 billion, with at least $20 billion of that attributable to North Korea-related attacks.
Against this backdrop of threat environment, regulators are expected to further tighten their oversight of custody structures, private key management, and incident response capabilities.
Additionally, multi-layered cybersecurity frameworks, which have traditionally been considered "best practices," may become the minimum required supervisory standard.
This is because there is growing recognition that operational failures in the security of cryptoassets could have far-reaching and serious implications for national security and the stability of the financial system.
Growing fragmentation of regulations surrounding cross-border transactions
By its very nature, the cryptocurrency market is global and transnational. However, regulations are generally implemented on a country-by-country basis. Apart from supranational frameworks such as the EU, there are currently very few "passport systems" that allow cryptocurrency businesses to operate in multiple countries with a common license, or mechanisms (mutual recognition) where national authorities recognize each other's licenses and supervisory results.
Cryptocurrency-related companies that operate globally must obtain licenses in each country and region and establish compliance systems in accordance with the rules of each country and region, which significantly increases costs and administrative burdens.
Furthermore, even if the regulatory goals of each country are similar, differences in the details of the rules can cause friction in cross-border transactions. For example, if stablecoin reserve assets, redemption conditions, disclosure requirements, etc. vary slightly from country to country, it will be difficult to operate the same stablecoin globally.
Furthermore, if differences in rules for exchanges prevent local users from accessing global order books (a board that collects orders from around the world), liquidity and price formation may become fragmented by country, creating an unfavorable situation for investors.
Given these concerns, 2026 will be a year of intense interest to see progress on the following:
- To what extent can inconsistencies in rules regarding cross-border transactions be reduced?
- How to establish a system for information sharing and joint supervision among national authorities
- How far will the introduction and expansion of passport systems and mutual recognition frameworks proceed?
These are the main developments in cryptocurrency regulation in 2025 and points to watch for in 2026.
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