Insights4.vc: Global Encryption Asset Regulatory Outlook (May 2025)

Author: Insights4.vc Translator: Shan Ouba, Golden Finance

In 2025, global cryptocurrency regulation enters a critical moment, with major jurisdictions strengthening regulatory efforts.

In Europe, the Markets in Crypto-Assets Regulation (MiCA) will come into full effect in December 2024, establishing comprehensive standards for crypto services and stablecoins. Meanwhile, the United States is actively shaping the future direction of crypto regulation. On April 3, 2025, the House Financial Services Committee passed the STABLE Act (H.R. 2392); while on March 13, 2025, the Senate Banking Committee supported the bipartisan GENIUS Act with a vote of 18 to 6.

At a global level, some key institutions are also influencing policy-making: The Bank for International Settlements (BIS) released a research report in April 2025, recommending strict reserve requirements for stablecoins; the Financial Action Task Force (FATF) conducted a public consultation from February to April 2025 regarding amendments to the "travel rule," aiming to include all crypto payments under its scope; the capital rules for crypto assets developed by the Basel Committee officially took effect on January 1, 2025.

In Asia, regulators are also rapidly catching up: The Hong Kong Securities and Futures Commission (SFC) issued new regulations on crypto staking in April 2025, further improving its exchange licensing system implemented in 2023; Singapore completed the framework for stablecoin licensing starting in August 2023. In the Middle East, the Dubai Virtual Assets Regulatory Authority (VARA) is leading the way, issuing updated crypto marketing regulations in October 2024, while Bahrain updated its crypto regulations in February 2024.

In emerging markets in Africa and Latin America, regulation is also advancing rapidly: Kenya received regulatory guidelines from the International Monetary Fund (IMF) in January 2025; Brazil plans to implement cryptocurrency regulations in phases by the end of 2025; Argentina launched a regulatory sandbox at the beginning of 2025 to pilot tokenized securities.

Global Regulatory Heatmap

The maturity of global cryptocurrency regulation ranges from "comprehensive systems" to "total prohibition."

• Comprehensive Regulations: The EU (MiCA), the UK (upcoming crypto regulations under the FSM bill), Singapore (Payment Services Act and stablecoin regulatory guidelines), Hong Kong (licensing system), Switzerland, and Australia all have detailed regulations. Japan, Canada, and some Caribbean financial centers also have relatively mature crypto rules.
• In Progress: The United States is debating significant crypto regulations (such as the Stablecoin Act and FIT21), but has not yet enacted formal legislation. South Korea implemented the Virtual Asset User Protection Act (VAUPA) in July 2024. Brazil laid the groundwork with legislation passed in 2022, with the central bank aiming to introduce phase one rules by the end of 2025; President Campos Neto stated in October 2024 that stablecoin rules and a complete VASP framework will be released next year. India submitted a new Income Tax Bill in February 2025, formally defining "virtual digital assets," but still maintains a 30% tax rate and 1% TDS, requesting the Ministry of Finance to propose possible reform suggestions by July 2025. South Africa and Israel are developing regulatory frameworks. Mexico, Colombia, and the Philippines are regulating crypto trading and payments under their fintech laws.
• Initial Stage: Many countries are still in the exploratory phase. For example, Mexico allows cryptocurrency activities under its fintech law but is still refining the details; Argentina and Ecuador are piloting tokenization regulatory sandboxes. African markets such as Kenya and Nigeria are researching cryptocurrency legislation with support from the IMF and World Bank. In Latin America, apart from Brazil and Argentina, countries like Chile and Peru are also closely watching the developments in the cryptocurrency market.
• Restrictive: Some countries only allow limited cryptocurrency activities. For example, Qatar's new digital asset framework explicitly excludes cryptocurrencies and stablecoins; Saudi Arabia currently has no clear regulations on cryptocurrencies and maintains a cautious attitude. Other Gulf countries, such as Kuwait and Oman, have issued warnings or remain minimally involved.
• Prohibition: Countries like China and Vietnam basically prohibit cryptocurrency trading and mining (for example, China has implemented a comprehensive ban on cryptocurrency since 2021).

United States

Key Points Summary: U.S. policymakers are focusing on stablecoins and inter-agency regulatory coordination. At the beginning of 2025, the House passed the STABLE Act (i.e., "Stablecoin Transparency and Accountability Act") with a bipartisan vote of 32 to 17; the Senate Banking Committee is advancing the GENIUS Act (i.e., "Guiding and Establishing a National Innovation System for U.S. Stablecoins Act"). Both bills will impose stringent reserve and disclosure requirements on dollar-backed stablecoins and are currently awaiting a vote in Congress.

At the same time, former President Trump publicly advocated for a "National Cryptocurrency Strategy," ordering the establishment of a crypto working group to study the United States' Bitcoin reserves and digital asset reserve plans. In terms of regulation, both Democrats and Republicans have expressed concerns about the SEC's enforcement actions against crypto project issuers (for example, accusing token trading platforms of being unregistered securities). Relevant legislation such as the "FIT21 Act" aims to clarify the respective regulatory roles of the SEC and CFTC over crypto assets, avoiding overlapping responsibilities.

In this regard, the bipartisan draft FIT21 (co-sponsored by Senators Scott, Hagerty, and others) would clarify the division of responsibilities between the SEC and the CFTC, and introduce a new classification of "permissioned payment stablecoins," which will be jointly regulated by the two agencies. At the same time, regulators are taking action: SEC Commissioner Peirce's Crypto Task Force is seeking public comment on topics such as custody, lending, staking, and clearing, which could ease restrictions on crypto lending and staking under securities regulations; The CFTC leadership, on the other hand, tends to classify most cryptocurrencies as "commodities".

In addition, banking regulators are also releasing guidelines related to financial technology and crypto custody (the OCC and FDIC have issued relevant guidelines between 2022 and 2024). Overall, the market should closely monitor the final vote on stablecoin and exchange bills and prepare for regulatory actions from the SEC and CFTC. The regulatory framework emerging in the U.S. indicates clearer standards for stablecoins, and the SEC and CFTC redefining regulatory boundaries will strengthen market issuance control and anti-fraud regulation.

European Union

Key Summary: The EU now has a unified legal framework for cryptocurrencies (MiCA), with strengthened anti-money laundering and transfer regulations. In May 2023, the EU officially passed the MiCA regulation, which is the first law covering most cryptocurrency services. The provisions of MiCA regarding registration/licensing, transparency, stablecoin reserves, and consumer protection will take effect on December 30, 2024. Regulatory authorities in each member state are implementing the second phase (Level-2) of MiCA's rules, including technical standards for stablecoin support mechanisms, trading platforms, and information disclosure.

At the same time, the European Banking Authority (EBA) and the Securities and Markets Authority (ESMA) are also improving regulations on cryptocurrencies in accordance with anti-money laundering/anti-terrorist financing regulations. Notably, the EU's new "Travel Rules" regulation (No. 1113/2023) extends traditional funds transfer regulations to the cryptocurrency space and will come into effect by the end of 2024. In July 2024, the EBA published the final "Travel Rules Guidelines", clarifying the information requirements for the sender and receiver in cryptocurrency transfers. This means that cryptocurrency exchanges and wallet services in Europe must collect relevant user information for each transaction, similar to banks.

In early 2025, regulatory agencies from various countries will issue relevant supervisory statements. The EU is also finalizing a revised version of the Fund Transfer Regulation to unify anti-money laundering standards for wire transfers across Europe, including cryptocurrencies. In terms of enforcement, ESMA is reviewing key markets such as stablecoins, and EBA has also released standards for crypto custody. The European Central Bank and the central banks of member states are studying how MiCA can integrate with existing payment systems, and the EU has also begun discussions on wholesale CBDC pilot projects.

Currently, the operating parties in the EU cryptocurrency market are under a clear legal framework: service providers must register in a member state (or use the passport mechanism), comply with capital and custody rules, and fulfill KYC and travel rule obligations. For industry practitioners, this marks the end of the "crypto wild west era" at the national level: cross-border token issuance and trading will be subject to strict regulations and capital requirements, and stablecoins must achieve 100% reserves.

The MiCA Level-2 phase has been initiated: On April 29, 2025, the European Commission passed the first MiCA delegated regulation (RTS on market manipulation control), and more RTS rules will be gradually introduced in the second half of 2025.

UK

Summary of Key Points: After a period of suspension, the UK is comprehensively incorporating cryptocurrency into regulation. Based on the 2023 Financial Services and Markets Act (FSM Act), the UK government has confirmed that it will legislate to regulate all major cryptocurrency activities (including stablecoins) simultaneously, abandoning the previously planned phased approach.

At the end of 2024, the new government announced that it would expand the regulatory scope of the Financial Conduct Authority (FCA) to cover cryptocurrency trading, custody, exchanges, and stablecoin issuance. The FSM Act has widely defined "cryptographic assets" since June 2023 and authorized the Treasury to designate cryptocurrency activities as regulated.

Therefore, the UK's regulatory roadmap includes: new secondary legislation (such as amendments to the Regulatory Activities Order) to be introduced by 2025, along with regulatory rules published by the FCA, covering the listing and disclosure obligations of crypto trading platforms, extending to market manipulation rules for crypto (i.e., the proposed MARC regime) and stablecoin redemption protections. The FCA has published a discussion paper on crypto custody and staking.

In January 2025, the government issued a decree that excluded crypto staking from the definition of "collective investment schemes," thereby opening the door for compliant staking services. The FCA also plans to consult in 2025 on the security rules for crypto custody and how staking and lending will be incorporated into the regulatory framework for client funds.

In fact, authorized crypto companies will soon need a full FCA license, clear custody mechanisms, and new disclosure processes. Banks and other UK businesses should be prepared to treat crypto assets as regulated investments and meet the corresponding capital and custody requirements. Misconduct in the crypto market will also be subject to sanctions under UK law after these systems are implemented.

Asia

Key Points: Major hubs in Asia are establishing or upgrading their regulatory frameworks.

Japan

Japan currently has one of the most advanced regulatory frameworks for digital assets in the world. All exchanges and custodians must register under the Payment Services Act, and from June 2023, all transfers must comply with the FATF "travel rule" data requirements, enabling regulators to have a comprehensive understanding of the information of transaction initiators and recipients. Stablecoins are classified as "electronic payment instruments." In March 2025, the Financial Services Agency (FSA) proposed legislation allowing trust-type stablecoins to invest up to 50% of their reserves in Japanese government bonds or time deposits. Around the same time, SBI VC Trade became the first institution to be licensed to issue USDC under this system. Consumer protection regulations are also being strengthened: a notice drafted in March 2025 requires stablecoin issuers to undergo annual audits by certified public accountants to verify asset segregation; updated guidelines have expanded the regulation of cryptocurrency sales activities.

Hong Kong

In 2023, the Hong Kong Securities and Futures Commission (SFC) launched a new licensing regime for virtual asset trading platforms, effective from June 2023. By early 2025, the SFC has expanded this regulation to staking services. In April 2025, the SFC issued guidelines allowing licensed platforms to offer crypto staking (such as Ethereum staking), but under strict conditions: the platform must have full control over the staked assets, possess robust information disclosure and risk management systems, and obtain explicit regulatory approval. This reflects a broader policy direction in Hong Kong, namely the "ASPIRe" strategy—recognizing the role of staking in network security while demanding strong investor protection measures. The SFC is expected to finalize the regulatory framework for stablecoins by 2025, with preliminary public consultations having already commenced in 2024.

Singapore

The Monetary Authority of Singapore (MAS) has implemented a mature regulatory framework for crypto assets through the Payment Services Act since 2020. In August 2023, MAS released a new regulatory framework for stablecoins, requiring all fiat-backed cryptocurrencies (such as those similar to USDS) to be fully supported by reserve assets, which must be held in regulated institutions. It is expected that Singapore will finalize all remaining stablecoin-related rules by 2025.

South Korea

South Korea passed the Virtual Assets User Protection Act (VAUPA) in mid-2023, which will officially take effect on July 19, 2024. The bill provides extensive protection measures: cryptocurrency exchanges must isolate customer assets, hold insurance, conduct operational reviews, and report suspicious activities. The Financial Services Commission (FSC) has announced that exchanges have already strengthened their compliance systems in advance according to VAUPA. More rules are expected to be introduced in the future, including stablecoin reserves and custody obligations.

Other Asian Regions

Singapore and Hong Kong continue to lead the development of regulatory frameworks. India is reassessing its cryptocurrency policies in line with global trends. Mainland China maintains a strict ban on cryptocurrency trading. Emerging markets like the Philippines and Malaysia are moderating regulations on cryptocurrency exchanges and service providers, while Indonesia's central bank is also drafting a cryptocurrency licensing system.

Middle East

Key Point: Gulf countries are rapidly building exclusive cryptocurrency regulatory systems.

Dubai (UAE)

The Virtual Assets Regulatory Authority (VARA) of Dubai was established by Law No. 4 of 2022 and has since developed a comprehensive set of cryptocurrency regulations. In October 2024, VARA issued new "Marketing Regulations" to manage all cryptocurrency advertising and promotions targeting UAE residents, replacing the previous executive order. The regulations from VARA in 2023 cover licensing and governance for exchanges, brokers, and other cryptocurrency entities. From 2023 to 2025, VARA continues to expand its guidelines, with a particular focus on marketing and custody services. Additionally, Dubai's financial free zones, DIFC and ADGM, have also established their own DLT (Distributed Ledger Technology) regulatory frameworks, further solidifying the UAE's position as a regional cryptocurrency hub.

Bahrain

The Central Bank of Bahrain (CBB) established its own virtual asset regulatory authority in 2022. In February 2024, the CBB updated its digital asset rules to align with international standards. Bahrain currently allows licensed crypto exchanges and custodial service providers to operate and enforces anti-money laundering/anti-terrorism financing regulations on virtual asset service providers (VASPs). The country's stock exchange, the Bahrain Bourse, is also exploring the possibilities of security tokenization.

Saudi Arabia

Saudi Arabia has yet to establish a dedicated legal framework for cryptocurrency. Cryptocurrency trading is technically unregulated and not officially recognized. The Saudi Central Bank (SAMA) and the Capital Market Authority (CMA) have issued multiple warnings about the risks of cryptocurrency investments. However, the country has shown interest in blockchain technology and has participated in the central bank digital currency project mBridge. A comprehensive cryptocurrency law is not expected to be introduced before the late 2020s.

Qatar

In 2024, the Qatar Financial Centre (QFC) launched a digital asset framework for QFC-registered entities. This framework supports the tokenization of physical assets and DLT applications, but explicitly excludes cryptocurrencies and stablecoins. Therefore, Qatar remains cautious, limiting direct cryptocurrency trading while encouraging regulated tokenized financial applications.

Overview of Africa and Latin America

Key points: Emerging markets are actively exploring and gradually improving cryptocurrency regulation.

Most countries in Africa are still in the exploration phase of crypto regulation. In January 2025, the International Monetary Fund (IMF) released a report on technical assistance for Kenya, recommending taxonomy standards for cryptoassets, strengthening institutional coordination, and improving anti-money laundering supervision. The Kenya Capital Markets Authority is in the process of drafting relevant legislation. As a result of being greylisted by the FATF, Nigeria is revisiting its regulatory strategy for crypto exchanges. South Africa's licensing regime is live: since June 1, 2023, the FSCA has processed 420 CASP (Cryptoasset Service Provider) applications, and a total of 248 licenses have been approved as of December 10, 2024; Enforcement and on-site review of the "travel rules" will be launched in the first quarter of 2025. Countries such as Rwanda and Nigeria are currently focusing on anti-money laundering compliance for VASPs.

Regulatory differences in Latin America are significant. Brazil passed national-level cryptocurrency legislation in 2023, with its central bank implementing it in phases, and a draft is expected to be released by the end of 2024. Mexico continues to operate under the 2018 Fintech Law and has recently strengthened anti-money laundering reviews for cryptocurrency exchanges. Argentina has had loose regulations for years but passed Law No. 27,739 in March 2024, bringing VASPs under securities regulation; a tokenization pilot zone for on-chain securities testing is also set to launch in April 2025. Chile and Colombia have issued relevant guidelines but have not yet formed a complete legal system.

Cross-domain Themes

stablecoin

Regulators around the world are converging on strict stablecoin standards. Following major fiat-pegged currencies such as USDC, the Bank for International Settlements (BIS) and central banks have also emphasized that stablecoins must be 100% reserve-backed and redeemable at any time. BIS Document No. 156 (April 2025) specifically calls for "targeted stablecoin regulation", with a focus on reserve assets and resilient designs. The EU's MiCA and some national laws stipulate that fiat-pegged currencies must be fully asset-backed and capital-buffered. In the U.S., several congressional bills, such as the STABLE Act, the GENIUS Act, and proposed Federal Reserve rules, are designed to require issuers to hold safe reserves at regulated banks. Globally, regulators are expected to enforce proof-of-reserves and audits – in fact, some exchanges in jurisdictions such as Japan and parts of Europe have been required to issue proof-of-reserve disclosures. Stablecoin regulation is becoming a central theme of Basel prudential regulation and the global anti-money laundering regime.

Financial Action Task Force Anti-Money Laundering/Counter-Terrorist Financing (February 2025)

Ongoing updates to the FATF are reshaping the crypto compliance landscape. In February 2025, the FATF convened a plenary session to launch a public consultation on Recommendation 16 (the "Transfer Rules"), which aims to ensure that originator/beneficiary data is consistent across all transfers. These revisions are expected to be completed by mid-2025 and may include structured messaging requirements (e.g., ISO 20022), lowering minimum thresholds, and expanding coverage for domestic and cross-border cryptocurrency payments. In addition, the FATF Annual Report 2023-2024 (published in January 2025) reiterates the obligations of jurisdictions to license or ban virtual asset service provider (VASP) in accordance with their standards. In practice, this means that licensed crypto exchanges around the world must implement strict KYC/AML controls. Many jurisdictions, including the European Union, the United Kingdom, and Canada, have begun to apply the FATF's virtual asset guidelines published in 2019. As a result, any global crypto payment provider must comply with bank-like anti-money laundering requirements or risk countermeasures.

DeFi and Staking (BIS Document No. 156)

The DeFi tokens and cryptocurrency staking activities are receiving increasing regulatory attention. The Bank for International Settlements' Document No. 156 (April 2025) analyzes the role of DeFi in financial markets and warns that without appropriate regulatory measures, DeFi could spread financial risks. Regulators are currently considering how to incorporate decentralized finance into the regulatory framework. For example, the guidelines released in Hong Kong in April 2025 regard "staking-as-a-service" providers as entities regulated under existing exchange licenses. Similarly, some central banks are exploring ways to regulate lending and staking activities involving stablecoins through initiatives like the "Mariana Plan." New guidelines are expected to be issued in 2025-2026, covering stablecoin staking pools, liquidity provision, and lending platforms—effectively applying the "same activity, same risk" principle to DeFi. For traditional financial institutions, this means closely monitoring on-chain financial contracts, and custodians will also need to disclose any staking services offered to clients.

Basel Cryptocurrency Prudential Regulations

In June 2023, the Basel Committee finalized the capital standards for crypto assets, which will take effect on January 1, 2025. According to these standards, banks must categorize their cryptocurrency risk exposures into two categories:

• Group One : Tokenized traditional assets and algorithmic stablecoins that meet strict standards
• Group 2 : All other assets, such as Bitcoin and Ethereum.

Class 2 crypto assets (Class 2b) that did not pass the hedging test now have a **risk weight of 1250%; any bank with a total exposure of Class 2 exceeding 1% of tier 1 capital must charge a fee of 1250% on the excess, and if it exceeds 2%, then all Class 2 holdings will be subject to a 1250% weight. Algorithmic stablecoins or non-redeemable stablecoins are explicitly excluded from Class 1 eligibility. These measures effectively prevent large banks from participating in pure cryptocurrencies. Furthermore, these rules introduce a short-term "infrastructure add-on" risk weight for any loans related to cryptocurrencies. Regulatory agencies in the U.S. and Europe have confirmed their intention to enforce these standards. The practical impact is that any traditional financial institution intending to hold or lend cryptocurrencies must set aside significant capital, thereby reducing profit potential and requiring robust collateral management.

Tax Transparency (OECD CARF)

In order to combat tax evasion related to cryptocurrencies, the OECD ( has implemented the Crypto Asset Reporting Framework ) (CARF) globally as of 2023. According to a report submitted by the OECD Secretary-General to the G20 Finance Ministers, by February 2025, 66 jurisdictions have committed to launching CARF exchanges, with 54 set to launch in 2027 and another 12 in 2028. CARF requires cryptocurrency exchanges and custodians to report user transaction data to tax authorities, similar to the FATCA and CRS frameworks. In practice, large cryptocurrency companies need to ensure that their AML/KYC systems can collect and store this data. By 2025, a series of domestic regulations and international agreements are expected to put CARF into effect. Companies that fail to comply may face penalties and enforcement actions, as tax authorities begin to demand detailed reports on customer balances and transactions.

Strategic Impact and Risk List

( Regulatory Arbitrage

The differences in global regulatory systems bring both opportunities and risks. Crypto-friendly markets like Dubai, Singapore, and Switzerland may attract more issuance and development activities, while regions with stricter regulations (such as China, Qatar, and certain U.S. states) may experience capital outflows. Companies need to clearly understand in which markets their products can be legally offered and where key participants (such as banks, exchanges, and custodians) operate. However, with the push from global frameworks like the FATF and Basel, the existence of "regulatory havens" is gradually diminishing. Companies' compliance strategies must cover all operating regions and take a holistic approach.

) Impact of Capital Occupation

According to the Basel III regulations set for 2025, banks will face higher capital requirements regarding crypto assets. Asset management companies that indirectly hold crypto assets through banking channels will also experience an increase in weighted risk capital. This will drive up leverage costs and reduce returns. For example, a bank-supported crypto fund may need to hold an additional 20-30% in capital for every dollar invested. Institutions should immediately model and assess the impact and consider transferring some crypto operations to non-bank entities to optimize capital efficiency.

Custody and Network Security

Increased regulation has made custody a key risk area. Countries are increasingly requiring custodians to adopt cold wallets, conduct regular audits, and implement asset segregation. Recent high-profile cyberattack incidents have highlighted the necessity of establishing robust custody infrastructure—including multi-signature wallets, insured custody mechanisms, and operational transparency. Regulatory agencies such as ESMA and the UK's FCA are actively reviewing custody standards. Under the MiCA framework, European custodians must implement client asset segregation. Traditional financial institutions (TradFi) entering the crypto custody space must invest heavily in resilient systems, regulatory compliance, and client protection, or they may face enforcement risks for fraud or breach of trust.

Asset Tokenization

Multiple jurisdictions are preparing to introduce legal frameworks for the tokenization of real-world assets (RWA). The EU and the UK are exploring the listing of security tokens; Japan's DLT pilot projects cover government bonds; several stock exchanges in the Middle East are testing digital bonds. TradFi institutions should prepare for the tokenization of bonds, stocks, and even loans. This will expand custodial and market-making opportunities but also introduce new risks related to smart contracts and system interoperability. Companies should assess platform partnerships and compliance procedures related to asset traceability and transfer restrictions early on.

Market Making and Liquidity

Regulatory agencies are focusing on crypto market-making mechanisms, particularly automated liquidity pools. Capital and anti-money laundering obligations will reshape the participation of banks and brokerages. Transparency standards such as "proof of reserves" may become mandatory requirements for exchanges. Traditional financial trading desks should anticipate that in the future, trading will only occur with counterparties that have completed KYC, and capital usage due to volatility may limit proprietary trading capabilities. Risk management teams should update stress testing scenarios to incorporate the volatility of the crypto market and the risks of cascading reactions, especially as the correlation with traditional assets may surge during crises.

Executable Suggestions

• Develop a Comprehensive Crypto Strategy: Formulate a comprehensive strategy at the board level that covers compliance, information technology, capital management, and risk control, and establish a cross-departmental team to closely monitor developments in MiCA, Basel, and FATF.
• Strengthen Anti-Money Laundering and Tax Mechanisms: Upgrade KYC and transaction monitoring systems to meet cryptocurrency-related standards, ensuring the system can support OECD CARF reporting requirements, including the digital and auditable collection of customer identity and tax residency data.
• Reassess Capital and Financial Limits: Incorporate the 2025 Basel Cryptocurrency Capital Rules into internal models, update financial exposure limits, and consider optimizing capital efficiency through Special Purpose Vehicles (SPVs).
• Ensure the security of custodial infrastructure: Only cooperate with regulated custodians or develop institutional-grade self-custody solutions. Implement multi-signature cold storage, configure insurance, conduct regular audits, and clearly disclose customer rights.
• Training Employees: Continuously conduct training for legal, compliance, and front office teams. Appoint a dedicated crypto compliance officer to proactively address regulatory risks.

Future Outlook (2025–2027)

Legislative Dynamics

The EU may launch the "MiCA-2" plan to refine rules related to stablecoins and ESG. The UK will publish detailed secondary regulations based on the Financial Services and Markets Act (FSM Act) starting in 2025. The US is expected to introduce a comprehensive framework for crypto assets, possibly through the FIT21 Act or the Digital Commodities Market Reform Act. The bipartisan stablecoin bill (submitted in February 2025) aims to clarify the responsibilities of issuers.

Regulatory Trends

Regulation is shifting towards an "activity-based" supervision approach. The Basel Committee and IOSCO are expected to jointly release guidelines for custody and lending regulation. The BIS Innovation Hub's "Project Mariana" and CBDC-related projects (such as mBridge and Project Dunbar) influence central banks' positions on crypto interoperability. "Proof of Reserve" may become a regulatory requirement — regulators like Singapore's MAS and Japan's FSA are already exploring related disclosure mechanisms.

Market Structure Evolution

The tokenization of government bond trading is gradually rising. By 2027, many regions are expected to pilot "on-chain T-Bills" (tokenized government bonds), repurchase markets, and blockchain collateralized lending services. These developments, along with programmable regulation, are expected to fundamentally change the structure of the fixed income market. Regulated crypto ETFs will expand, and traditional and decentralized markets will accelerate their integration.

CBDC Collaborative Development

Wholesale CBDC (Central Bank Digital Currency) projects will continue to advance. The mBridge, led by the BIS, is entering its third phase, with multiple central banks participating in various CBDC pilot projects. ASEAN+3, China's e-CNY, and the research on retail CBDCs in the United States will continue to influence global central bank strategies. Central banks are increasingly emphasizing interoperability between CBDCs and stablecoins, as demonstrated by Singapore's Project Dunbar.

Technological and Compliance Advances

AI and machine learning will enhance trading surveillance and anomaly detection, with vendors like Chainalysis and TRM continuously expanding their capabilities. Privacy-preserving KYC technologies, such as zero-knowledge proofs and digital identity wallets, will be tested as regulatory compliance tools. Institutions are also preparing for quantum-resistant cryptography and distributed identity standards to meet the demands of the next generation of the crypto ecosystem.

Attention Schedule (Q2 2025 to Q4 2027)

• 2025-Q2: FATF completes the revision of the "travel rule"; Hong Kong finalizes the licensing regulations for stablecoins; the U.S. Senate reviews the "STABLE Act"; the EU releases the MiCA Level 2 regulations.
• 2025-Q3: BIS releases crypto policy document; Singapore issues guidelines for security tokens; South Africa improves crypto regulations; OECD publishes first CARF report; India reviews crypto tax regulations.
• 2025-Q4: The Basel Committee releases FAQ on crypto capital; The US Comptroller publishes stablecoin regulatory guidelines; The UK FCA finalizes custodial rules; The EU updates AMLR to include crypto content; Bermuda and El Salvador announce CBDC plans.
• 2026-Q1: MiCA and UK crypto regulations officially implemented; OECD CARF begins reporting; US releases stablecoin regulatory framework; Brazil completes the first phase of cryptocurrency exchange rules.
• 2026-Q2: BIS and IOSCO publish report on digital asset risks; Japan expands crypto regulations; Australia implements "travel rule"; G20 assesses progress on crypto and CBDC; Basel begins monitoring crypto climate risks.