For observers of crypto regulation, December 2024 feels like a long time ago. The global policy landscape today looks markedly different than it did 12 months ago. The pace of change has been remarkable, and it shows little sign of slowing.
Before we plunge into 2026, let’s take a look at some of the key regulatory changes in 2025: global trends, regional developments, and what we’re keeping an eye out for in 2026. For more detailed insight, check out our Road to Crypto Regulation Series and 2025 Geography of Cryptocurrency Report.
The global picture: Five digital asset policy trends
1. Implementation progress and frictions as regulation is rolled out
Over the past few years, we have seen considerable, albeit uneven, progress in building comprehensive regulatory frameworks for digital assets. With frameworks moving from theory to practice in 2025, the implementation phase has proven just as politically and operationally complex as the legislation itself.
The EU’s Markets in Crypto‑Assets (MiCA) Regulation took full effect at the start of 2025, but the shift from national, AML‑based regimes to the world’s first comprehensive crypto framework has been patchy. Despite extensive efforts by EU authorities — including European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA)’s work on detailed technical standards and supervisory convergence — divergent national interpretations and implementation challenges remain. Authorities and firms are still working through technical questions on how MiCA interacts with existing payments and investment services rules, particularly in its stablecoin regime: how to handle multi‑issuance models, how to treat e‑money tokens, and how MiCA should line up with the revised Payment Services Regulation and the Markets in Financial Instruments Directive (MiFID).
Similar implementation dynamics have emerged elsewhere. In Singapore, the rapid rollout of the Digital Token Service Provider rules under the Financial Services and Markets Act prompted a scramble among businesses to assess legal impact. Globally, Travel Rule implementation continues to pose challenges for both crypto businesses and regulators, including around the Sunrise Issue, the treatment of unhosted wallets, the adequacy of technical and risk expertise, and the interoperability of tools.
The fact that there has been varying progress and teething challenges in regulatory implementation is unsurprising, and we can expect the process of ironing out frictions and building compliance and supervisory capacity to continue in 2026 as regulation continues to mature.
2. Stablecoins take center-stage
The passage of the GENIUS Act in the United States has not only created a federal regulatory framework for issuers in the US, but has also created an international benchmark and accelerated global momentum for stablecoin policy development. Only a small number of jurisdictions have brought stablecoin regulation into force thus far (e.g. Japan, the EU and Hong Kong), but elsewhere policymakers from Korea to the United Kingdom have advanced plans to regulate stablecoin issuers. In doing so, they have had to consider a broad range of risks. Beyond value stability and attendant expectations of reserve adequacy, audits and attestation, industry and policymakers have engaged in discussions on stablecoin implications on financial stability, capital flow management, and AML/CFT.
We’re beginning to see regulation reconfigure usage patterns in the global stablecoin market, and that will increase over time. Europe has seen a rotation toward MiCA-compliant stablecoins as CASPs have been generally restricted from offering non-compliant ones. In the United States, the GENIUS Act places restrictions on the domestic offering of foreign-issued stablecoins. Looking ahead, rules on the distribution of unregulated stablecoins, and the flip side, mutual recognition or passporting, will play an important role in determining the global footprint of each stablecoin.
3. Tokenization gains traction
A strong theme in 2025 has been the tokenization of financial and real-world assets. Assets under management (AUM) of tokenized money market funds holding U.S. Treasuries rose above $8 billion in December 2025, while AUM for tokenized commodities such as gold has climbed above $3.5 billion. These figures are very small relative to global asset markets, but have exhibited strong growth in 2025.
Policymakers have generally taken a supportive, experiment‑first approach to tokenization in 2025. In Singapore, MAS used Project Guardian to move from pilots to playbooks, publishing an operational framework for tokenized funds and announcing plans to trial tokenized central bank bills, signalling interest in learning-by-doing. In the United States, the SEC convened a public roundtable on tokenization in May, followed up in July with “Project Crypto” to review how securities laws should apply on‑chain, and in December issued a no‑action letter allowing the Depository Trust Company (DTC) to allow for securities tokenization schemes — effectively bringing mainstream market plumbing into scope. In the EU, tokenization is increasingly framed as a strategic pillar to improve its capital markets’ competitiveness: the DLT Pilot Regime is under review, with ESMA putting forward recommendations to make the scheme more attractive and better aligned with the goal of building a truly unified, digital‑ready capital market.
4. TradFi comes to crypto
In 2025, banks moved from the sidelines to the crypto arena with activities like crypto-based financial products, stablecoin issuance, custody, and trading. Underpinning this shift was a tilt in regulatory posture, particularly in the United States. Over the course of the year, the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC) and Federal Reserve have rescinded past statements and created more space for banks to engage with crypto. Equally importantly, the international banking standard-setter, the Basel Committee on Banking Supervision (BCBS), has signalled that it will revisit its standard for the prudential treatment of bank exposure to cryptoassets, acknowledging industry concerns that the standard is unduly restrictive.
Alongside this renewed interest has come clearer guidance on how banks should manage AML risk. The New York Department of Financial Services (NYDFS) and the Wolfsberg Group have each provided guidance on how banks should approach AML risk when providing services to crypto businesses and stablecoin issuers respectively.
In the EU, the implementation of MiCA and the regulatory clarity it provides have similarly given traditional financial institutions more confidence to move ahead with crypto and tokenization projects under a clearer, harmonized rulebook.
5. Financial crime and asset recovery in the spotlight
Growing crypto adoption also creates more opportunities for criminal abuse. Within the policy and law enforcement community, there is renewed urgency to enhance ecosystem resilience against money laundering and terrorism financing threats in crypto, step up asset recovery to prevent criminal reinvestment, and leverage public-private partnerships. FATF’s 2025 asset recovery guidance sets out best practices for seizing, managing, and ultimately returning cryptoassets, and explicitly encourages countries to use blockchain analytics and public‑private partnerships to improve outcomes.
Cyber-enabled fraud and scams have been a focal point. In the wake of the UK’s landmark authorized fraud reimbursement requirements, other jurisdictions such as Australia and Thailand have followed by articulating obligations for gatekeepers — financial institutions, technology platforms and more — to protect consumers against scams, and imposing penalties or loss-sharing requirements for those that fail to discharge their responsibilities. This has been accompanied by supervisory scrutiny over the adequacy of money mule detection and fraud monitoring safeguards.
On the operational front, the U.S. has imposed sanctions on key networks and facilitators, undertaken unprecedented asset seizures, and launched a “Scam Center Strike Force” to dismantle the transnational networks carrying out crypto-investment fraud. Other jurisdictions around the world have stepped up anti-scam operations with encouraging cases of successful seizures. Looking ahead, we should expect further policy action on this front as tackling financial crime in crypto remains core to building trust and institutional adoption.
The regional rundown: Convergence and fragmentation as policy agenda widens
United States: A new policy trajectory is driving market momentum
The most prominent shift in the global crypto landscape has been in the United States, where a new administration has replaced years of adversarial policy with an emphatic embrace of digital assets as a strategic imperative. In July, the President’s Working Group on Digital Assets published a comprehensive roadmap to strengthen U.S. leadership in digital assets, calling among other things for the swift implementation of GENIUS, the modernization of AML rules, the enactment of market structure legislation, and for the CFTC and SEC to use existing authorities to enable digital asset trading.
The CFTC and SEC have supported this pivot toward a more business-friendly environment. The SEC has dialled back on litigation-based regulatory enforcement against crypto firms, rescinded SAB 121, and announced Project Crypto, an SEC-wide initiative to overhaul securities laws and “enable America’s financial markets to move on-chain”. The CFTC announced a “crypto sprint” that takes a similar pro-innovation stance. Cross-agency collaboration has been stepped up, with the SEC and CFTC issuing a joint statement on the trading of spot crypto products and holding a joint roundtable in September.
There has also been a shift in tone from banking regulators. In April, the FDIC rescinded a prior notification requirement for FDIC-supervised institutions conducting all types of crypto activities. In July, the FDIC, OCC and Federal Reserve issued a statement discussing risk management considerations for banks conducting crypto-asset safekeeping. More recently in December, the Federal Reserve issued a policy statement indicating more openness for uninsured state member banks to engage in digital asset activities.
On the legislative front, the milestone passage of the GENIUS Act creates a federal regulatory framework for stablecoin issuers, mandating requirements around reserves, audits, and financial integrity. The work is not over; by July 2026, regulators are expected to promulgate final implementing regulations, ahead of a deadline of January 2027 to bring GENIUS into force. Meanwhile, progress has continued on market structure legislation with the House passing the CLARITY Act in July and the Senate Banking Committee and Agriculture Committees have released their own discussion drafts; however, further discussions have been punted to 2027, and amidst a crowded legislative agenda it remains to be seen how quickly progress will be made.
Asia-Pacific: Divergent starting points, accelerating momentum
The Asia-Pacific has long been home to early-movers in crypto regulation such as Japan, Malaysia, and Thailand. Policy momentum broadened and accelerated in 2025, driven by a combination of market growth, competitive dynamics and policy spillovers from major Western jurisdictions. The region remains extremely diverse, but despite varied starting points, jurisdictions continued to build out comprehensive frameworks addressing market conduct and financial stability considerations.
In Japan, the region’s most mature crypto market, reforms are under way to regulate crypto as an investment product and adjust the tax treatment of crypto trading. South Korea has seen the first prosecution referrals for unfair trading practices under the Virtual Asset User Protection Act, and attention has turned to competing stablecoin bills. The steady drumbeat of policy announcements continued in Hong Kong, most notably proposals for the regulation of virtual asset custody and dealing; plans to enable local crypto trading platforms to access global liquidity; and most crucially, the enactment of the Stablecoin Ordinance in August 2025, with the first batch of licences expected in early 2026. Meanwhile, Singapore became one of the first countries in the region to undergo the fifth round of FATF Mutual Evaluations — the first time these peer reviews are fully assessing the effectiveness of a jurisdiction’s AML/CFT regime in respect of virtual assets.
Other markets have also seen regulatory restructuring. Indonesia effected the transfer of crypto oversight from commodities regulator Bappebti to financial supervisor OJK, signaling a shift toward treating crypto as a financial product. The Philippines saw the SEC extend authority over crypto assets through new rules emphasizing consumer protection and market integrity. Australia advanced digital asset legislation through the Corporations Amendment (Digital Assets Framework) Bill 2025, even as regulator ASIC sought to clarify the application of existing financial regulation to crypto businesses through an update to INFO 225.
Within APAC, the year’s most dramatic policy shifts occurred in Pakistan and Vietnam – jurisdictions with large informal crypto markets that had previously maintained restrictive or unclear stances. Pakistan replaced its trading ban with plans for comprehensive regulation, establishing both a Pakistan Crypto Council and a new Virtual Assets Regulatory Authority for licensing and supervision. Vietnam passed legislation recognizing the legal status of cryptocurrency and authorising a pilot exchange licensing program, bringing crypto from gray zone to spotlight.
Europe: Rubber hits the road as MiCA is implemented
The EU’s MiCA remains arguably the most comprehensive regulatory framework for cryptoassets globally. One year into its full applicability, we have seen over 90 firms authorized as CASPs and a clear diversification of EMT issuers, with growing uptake of euro‑denominated stablecoins as markets rotate toward MiCA‑compliant products and services. MiCA has also encouraged more traditional financial institutions to enter the market under a clearer, harmonized rulebook, supported by multiple RTS and ITS from ESMA and the EBA that guide regulators and firms on how to implement the regime in practice.
At the same time, MiCA remains a live test case. There are ongoing discussions on multi‑issuance models under MiCA, equivalence regimes, and the broader question of how EU payment services rules interact with MiCA where e‑money tokens are dual‑classified as both funds and crypto‑assets. In light of the EU’s objective to build a more competitive and efficient Savings and Investment Union (SIU) and create a true level playing field for all CASPs, the European Commission has also proposed reshaping the supervisory model by giving ESMA — the EU’s investment services authority — a direct role in authorising and supervising all CASPs.
On anti‑money laundering, the EU is also moving from uneven implementation to tighter harmonisation. The earlier 5th Anti‑Money Laundering Directive (5AMLD), which introduced AML/CFT obligations for VASPs, led to divergent approaches across member states; this is now being replaced by the directly applicable Anti‑Money Laundering Regulation (AMLR), which sets out more prescriptive AML/CFT expectations for all obliged entities, including CASPs, across the EU. AMLA — the new EU Anti‑Money Laundering Authority — will develop further guidance and clarifications to support consistent implementation of the AMLR which will become applicable across member states on 10 July 2027. AMLA has defined crypto-assets as an early priority and is expected to directly supervise firms, likely including CASPs, from 2028, signalling a shift toward more centralized, data‑driven AML oversight in the medium term.
And while MiCA and AML obligations are the central pillars, CASPs must also comply with other frameworks — most importantly the Digital Operational Resilience Act (DORA) — which significantly raises expectations around cyber and operational resilience and will be a major determinant of firms’ overall compliance readiness.
United Kingdom: Crypto regulation steps out of the margins
For several years, UK cryptoasset activity was effectively regulated only at the margins, first through the Financial Conduct Authority’s (FCA) AML regime and later via a targeted cryptoasset promotions regime.
2025 has been a pivotal year for UK crypto policy: Alongside the Bank of England’s work on a regime for systemic stablecoins — including proposals on holding limits and the composition of reserve assets — the year culminated with three FCA consultations proposing a comprehensive regime for cryptoasset activities, a bespoke disclosure and market abuse framework, and prudential rules for crypto firms. Notably, the package expands the regulatory perimeter to also cover lending, borrowing, and staking – going beyond MiCA in key areas – adopting a substance‑over‑form approach to decentralization and De-Fi by imposing equivalent obligations where a controlling entity can be identified.
Middle East: Stablecoins, tokenization and institutional crypto markets
In the Middle East, 2025 was about building regulatory architecture for the region’s rapidly expanding, and increasingly institutional, crypto markets. The UAE further consolidated its role as the regional hub: the Central Bank, Dubai’s VARA and Abu Dhabi’s FSRA continued to refine and operationalize mature licensing regimes for exchanges, custodians and other crypto service providers, tightened marketing, conduct and market‑integrity rules, and advanced stablecoin and payment‑token frameworks that deliberately prioritize payments, settlement and tokenized finance over purely speculative use cases. These frameworks place strong emphasis on full reserve backing, clear redemption rights and robust governance, with growing interest in local‑currency and institutionally issued stablecoins as building blocks for regulated digital‑asset markets.
Elsewhere in the Gulf, Saudi Arabia and Qatar moved beyond experimentation toward clearer policy direction: Qatar introduced a more structured digital‑asset framework, while Saudi Arabia doubled down on tokenization, CBDC pilots and carefully scoped DeFi‑adjacent innovation — signalling a gradual expansion of the regulatory perimeter rather than blanket permissiveness.
At the regional level, MENAFATF reinforced FATF alignment and mutual‑evaluation readiness as 2025 priorities, underlining that VASPs across the Middle East now face rising AML/CFT expectations and that risk‑based, data‑driven supervision is quickly becoming the norm.
Latin America: From grassroots adoption to structured oversight
In Latin America, 2025 marked a clear turn from reactive, AML‑only oversight toward more structured regulatory frameworks that better reflect the region’s already high levels of grassroots crypto adoption.
Brazil continued to set the benchmark, building on its 2022/23 Virtual Assets Law with detailed secondary rules on licensing, governance, conduct, prudential expectations, and supervisory reporting for virtual asset service providers — making it the region’s de facto reference point for a comprehensive crypto regime.
Other major markets, notably Argentina and Mexico, began to move beyond fragmented or primarily AML‑focused approaches toward broader models that also address consumer protection, market integrity and operational risk, even if legal certainty and supervisory capacity still vary across jurisdictions.
Throughout the region, regulators are paying much closer attention to the systemic role of stablecoins — particularly their use in cross‑border payments, trade settlement, and inflation hedging — and are starting to define clearer requirements around issuance, reserve backing, redemption rights, and intermediary obligations, with FATF alignment and upcoming mutual evaluations serving as a common anchor for AML/CFT expectations and supervisory priorities.
Africa: Retail-led crypto adoption meets emerging regulatory frameworks
Africa in 2025 showed how regulation is slowly catching up with already‑entrenched, real‑world crypto use. Sub‑Saharan Africa remained the world’s third‑fastest‑growing crypto region, with on‑chain transaction volumes up more than 50% year‑over‑year and activity dominated by transfers under $10,000 — a pattern that highlights retail‑led adoption and crypto’s role in addressing frictions in payments, remittances and basic access to financial services.
On the supervisory side, South Africa has clearly emerged as the continent’s regulatory anchor. Cryptoassets are now classified as financial products and a large cohort of crypto‑asset service providers (CASPs) has moved into the licensing perimeter. While CASPs are subject to AML/CFT obligations from 2022, crypto Travel Rule obligations went live in 2025. In parallel, the South African Reserve Bank has stepped up analytical and policy work on stablecoins and tokenized money, signalling a trajectory toward a fuller prudential and conduct regime even as bespoke stablecoin legislation is still being developed.
Nigeria, by contrast, continues to pair very high on‑chain activity with a more incremental recalibration of policy. Authorities have shifted away from episodic restrictions and towards a more structured approach, using securities and AML/CFT frameworks to bring exchanges and other intermediaries into scope, while remaining cautious about monetary and FX implications.
Across key African markets, regulators are paying closer attention to stablecoin usage in cross‑border trade and payment corridors linking Africa with the Middle East and Asia, and are increasingly focused on operationalizing FATF‑aligned AML/CFT requirements — from transaction monitoring and Travel Rule implementation to risk‑based supervision — so they can move beyond perimeter debates and toward data‑driven oversight of actual economic flows.
What we’ll be watching in 2026
The policy calendar for 2026 is already full of deadlines and developments. In the US, market structure legislation will remain on the policy agenda, although it is uncertain how quickly Congress will be able to resume negotiations in the new year given competing priorities. In the area of taxation, implementation of the Crypto-Asset Reporting Framework will proceed as a number of countries have committed to conducting the first exchanges of information by 2027.
Stablecoin regulation will continue to take shape globally
National regulators that have not yet developed or implemented stablecoin regulation will continue to make progress. By July 2026, U.S. federal and state regulators are required to promulgate final regulations to implement the GENIUS Act. This will include processes to license and regulate federal stablecoin issuers, and establishing criteria that foreign stablecoin issuers must meet in order to offer their stablecoins in the U.S. In Singapore, draft legislation to implement a stablecoin regime will need to be finalized, alongside subsidiary legislation and guidance. In the UK, the FCA is consulting on a tailored conduct and market framework for stablecoins, while the Bank of England is focused on the prudential and financial-stability treatment of systemically important stablecoins.
Despite momentum in 2026, a good deal remains to be done. The Financial Stability Board flagged in October that even where stablecoin regulation has been implemented, “critical gaps include insufficient requirements for robust risk management practices, capital buffers, and recovery and resolution planning”. Similar consideration is being given to AML/CFT expectations for stablecoin issuers, particularly with regard to secondary market monitoring. Accordingly, the FATF is scheduled to issue its analysis on stablecoins in the first quarter of 2026, and this will help guide regulatory expectations globally.
Greater attention to AML and cyber risk
As digital assets become increasingly embedded in global financial infrastructure, regulators are also intensifying scrutiny of the systemic risks this integration creates. Cryptocurrency has evolved from a niche tool for darknet transactions to a component of professional money laundering networks supporting a diverse range of crime types. The potential for crypto-enabled sanctions evasion has also surfaced in novel ways, such as the A7A5 stablecoin. All this coincides with the widening of the fifth round of FATF mutual evaluations, which will exert continued pressure on regulators and industry to demonstrate the effectiveness of their AML/CFT safeguards.
Meanwhile, with more activity moving onto blockchains, the potential impact of operational failures increases. Cyber hacks and theft are a particular concern, with over $3.4 billion in cryptocurrency stolen during 2025 and at least $2 billion of that attributed to DPRK-linked actors. The threat landscape may drive regulatory focus towards comprehensive cyber risk management, with supervisors scrutinizing custody arrangements, key management practices, and incident response capabilities with increasing rigor. Multi-layered cybersecurity frameworks will go from being best practice to baseline supervisory expectations as regulators recognize that operational failures in crypto security could have broader national security and financial stability implications.
Cross-border fragmentation will be growing concern
While crypto markets are global, regulation remains national, and passporting or mutual recognition agreements remain distant except in supranational arrangements like the EU. International crypto businesses that wish to scale operations will face growing licensing and compliance costs in order to serve each market.
In addition, while most jurisdictions are striving to achieve similar outcomes through regulation, cross-border inconsistencies in rules can nonetheless create friction. For instance, small but material differences in reserve, redemption, and disclosure requirements across jurisdictions can be challenging for global stablecoin arrangements. Crypto-asset exchange regulation that prevents local users from tapping into global order books can fragment liquidity and price discovery, to the detriment of investors.
With these concerns precipitating, the industry will be closely observing in 2026 whether regulators make progress on reducing cross-border inconsistencies, building cross-border information sharing and supervisory structures, and considering passporting or mutual recognition frameworks.
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