Author: Sybille Mueller, Director, Streets Consulting
The digital asset landscape is evolving at a breakneck pace, powered by innovation and a growing acknowledgement from governments that crypto has transformative potential. Across the globe, key players are creating robust regulatory frameworks and stimulus packages to weave digital assets into the fabric of their financial systems. Here, we examine the strategic moves being made in the UK, USA, European Union, the Middle East, and the Far East, as they lay the foundations for digital finance to flourish.
In a clear signal of intent, the Chancellor issued a new remit to the Bank of England’s Financial Market Infrastructure Committee, actively encouraging greater innovation. On the same day, an update on the Digital Gilt Instrument (DIGIT) pilot outlined plans for on-chain settlement over DLT to drive market momentum. The government is also committed to ensuring English and Welsh law effectively supports asset tokenisation, providing the clarity needed for new forms of issuance and ownership.
Crucial regulatory testbeds for new digital solutions are now live, including the Digital Securities Sandbox (DSS). The UK is establishing a regulatory framework for stablecoins, recognising their potential in retail, cross-border, and wholesale settlement, with regulators set to explore their use within the DSS. The Financial Conduct Authority (FCA) announced it would allow retail access to crypto exchange-traded notes (cETNs) on approved UK exchanges from 8 October 2025, though the ban on retail cryptoasset derivatives remains.
To align private sector efforts with international initiatives, a ‘Digital Markets Champion’ will be appointed. The ongoing exploration of a digital pound also remains a key part of the UK’s future payments vision.
The FCA‘s latest consultation on regulating UK cryptoasset activities closed in June 2025 and is designed to bring cryptoasset trading platforms, intermediaries, staking, and crypto lending within the existing UK regulatory system. Final policy statements are expected in 2026. Meanwhile, the FCA has also launched a consultation on the application of the FCA Handbook for Regulated Cryptoasset Activities, looking at how its extensive rulebook, covering everything from senior management and operational resilience to consumer protection, should be applied to digital asset firms. This consultation closes in November 2025.
Under new leadership since January 2025, the SEC is shifting to a more crypto-friendly approach, establishing a task force to resolve asset classification issues and streamline registration. The successful launch of Bitcoin ETFs and the anticipated approval of staked ETFs in 2025 and beyond are solidifying the US as a leader in regulated digital asset investment products.
The United States is moving from fragmented oversight towards significant regulatory clarity for digital assets. A landmark moment came on 18 July 2025, when the Senate passed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. This federal framework mandates that payment stablecoins be fully backed by liquid assets and introduces a dual state-federal supervisory model. Crucially, it prohibits a U.S. Central Bank Digital Currency (CBDC) without congressional approval.
Legislative progress also includes the Digital Asset Market Clarity (CLARITY) Act of May 2025, which aims to define the jurisdictional boundaries between the CFTC and the SEC. Earlier, the Trump Administration’s Executive Order 14178 (January 2025) had directed a working group to deliver a coordinated regulatory framework by late July 2025, focusing on jurisdictional clarity and support for regulated, privately-issued, dollar-backed stablecoins.
The EU has established a comprehensive and harmonised framework with the Markets in Crypto-Assets Regulation (MiCAR). Fully applicable from 30 December 2024 – with stablecoin provisions in force since June 2024—MiCAR provides a single set of rules for crypto-asset issuers and service providers across all member states. This covers authorisation, transparency, consumer protection, and market integrity.
While MiCAR includes a transitional “grandfathering” period until mid-2026, several countries like Germany and Ireland have implemented stricter or shorter timelines, creating some inconsistencies. MiCAR is part of a broader Digital Finance Package that includes new anti-money laundering regulations (AMLR and AMLA-R), the Travel Rule (WTR II), and the Digital Operational Resilience Act (DORA).
Meanwhile, the European Central Bank (ECB) entered a two-year preparation phase for a retail digital euro in October 2023. A decision on development is expected by the end of 2025, with the earliest possible issuance estimated for 2027, aiming to bolster resilience and financial inclusion.
The Middle East is rapidly emerging as a hub for digital assets, with countries implementing proactive regulations to attract FinTech investment. The UAE is at the forefront, where Dubai’s Virtual Assets Regulatory Authority (VARA) released a robust regulatory framework in February 2023 to license and supervise Virtual Asset Service Providers (VASPs). The UAE is also pursuing the tokenisation of $16 billion in real estate by 2033 and offers a tax-friendly environment with no personal income or capital gains tax on crypto. Its central bank is defining a Digital Dirham strategy and has participated in international CBDC projects like Aber and mBridge.
Saudi Arabia appointed a “Crypto Chief ” at its central bank (SAMA) and activated a licensing stream for digital assets. It also explored a dual-issued digital currency for cross-border settlement in Project Aber. After an initial ban, Qatar introduced new digital asset regulations in September 2024, focusing primarily on “Investment Tokens”. Bahrain has been a pioneer, establishing a virtual asset regulatory regime in February 2019 and launching a FinTech regulatory sandbox in December 2021.
The Monetary Authority of Singapore (MAS) continues its proactive stance, expanding its Payment Services Act to include custodial services and cross-border money transfers. It has finalised a specific regulatory regime for single-currency stablecoins pegged to the Singapore dollar or G10 currencies. MAS is also developing a “live” wholesale CBDC and exploring a shared ledger infrastructure via its Global Layer One (GL1) initiative.
At the same time, Hong Kong SAR actively positions itself as a global Virtual Asset (VA) hub, Hong Kong’s Virtual Asset Trading Platform (VATP) Framework now governs exchanges and token listings. The Stablecoins Bill, expected to pass in 2025, will require issuers to be licensed by the HKMA. The city also successfully launched spot VA ETFs in 2024.
In Japan, The Financial Services Agency (FSA) is undertaking a major restructuring. In 2026, cryptocurrencies will be reclassified as financial products under the Financial Instruments and Exchange Act (FIEA). This move, along with tax reforms introducing a 20% flat capital gains tax, aims to eliminate ambiguity and attract institutional capital. The approval of the first yen-pegged stablecoin (JPYC) in late 2025 and expected spot Bitcoin ETFs by mid-2026 will further bolster the market.
South Korea is rapidly implementing legislation to become a major digital asset hub. A key policy is the creation of a Korean won-backed stablecoin, fully collateralised by reserves in regulated banks. New crypto lending rules for 2025 cap annual interest rates at 20% and restrict loans to top-20 cryptocurrencies to curb speculative risk.
The global landscape is defined by a rapid acceleration of regulatory development. From the UK’s strategic “Leeds Reforms” to the US pursuit of clarity with the GENIUS Act and the EU’s comprehensive MiCAR framework, leading economies are working to harness the benefits of digital finance while managing its risks. The Middle East is cultivating dynamic hubs, while the Far East showcases a diverse array of innovative strategies. This collective effort signals a global race, with the UK determined to solidify its reputation as a forward-thinking financial hub at the forefront of this digital revolution.
46-48 East Smithfield, London, E1W 1AW