Crypto Compliance in Focus: Regulatory Views Across the US, UK, EU and APAC

The changing landscape presents both new opportunities and complex operating challenges. Compliance and risk teams are facing a fluid landscape where market dynamics and regulatory expectations are rapidly changing, requiring them to have a deep understanding of crypto assets and how they work, the attendant risks, and the regulatory requirements.

This article provides a primer on the current state of regulatory play for crypto assets across four major regions: the U.S., UK, EU and APAC.

The U.S.: From chaos to cohesion

Regulators in the U.S. traditionally have taken a measured approach toward innovation—opting to watch and understand the developments before stepping in to regulate. In the case of crypto, the initial lack of regulation significantly contributed to the early and rapid growth of the crypto industry. There is a strong consensus, however, that the U.S. waited too long to regulate cryptocurrency, and this delay, along with early attempts by competing regulators to shape the crypto landscape, had significant consequences, including exposing investors to fraud, market manipulation and systemic risk. These circumstances, which were marked by high-profile failures and enforcement actions, ultimately prompted bilateral calls for reform even before the last U.S. election.

However, it wasn’t until July 2025 that Congress, with the support of the pro-crypto Trump administration, passed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act and Digital Asset Market Clarity Act of 2025 (CLARITY), establishing the first cohesive federal framework for digital assets. The GENIUS Act establishes a federal regulatory framework for payment stablecoins—digital assets pegged to a fixed monetary value and intended for use in payments—which may only be issued by permitted payment stablecoin issuers (PPSIs), i.e., subsidiaries of insured depository institutions, federally chartered nonbank entities approved by the Office of the Comptroller of the Currency, and for issuers with less than $10 billion in issuance state-chartered entities approved by certified state regimes. The GENIUS Act prohibits algorithmic stablecoins from being classified as “payments stablecoins,” even if backed by 1:1 reserves.

The GENIUS Act also establishes reserve requirements, reporting requirements and consumer protections, and subjects PPSIs to the Bank Secrecy Act.

Meanwhile, the CLARITY Act ends the turf war between the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) by clearly defining regulatory authority and dividing digital assets into three categories:

1. Digital commodities: Assets intrinsically linked to blockchain functionality (Bitcoin, Ethereum), which are regulated by the CFTC.
2. Investment contract assets: Digital commodities sold via investment contracts (initial coin offering) that are initially regulated by the SEC but lose security status once they are traded in secondary markets.
3. Permitted payment stablecoins: Fiat-backed digital assets used for payments, which if “covered” are not considered securities and are not subject to SEC registration, but are subject to CFTC jurisdiction when used in trading or as collateral on registered platforms.

The GENIUS and CLARITY Acts have ushered in a new era of regulatory clarity and market maturity and, along with it, a broadly optimistic outlook for crypto in the United States.

For several countries, central bank digital currency (CBDC) factors into their crypto agenda. Although the Federal Reserve reportedly has been researching the risks and benefits of a CBDC, President Trump, who has described CBDCs as a “dangerous threat to freedom,”^[3] issued Executive Order 14178 in January prohibiting federal agencies from establishing, issuing or promoting a CBDC and directs federal agencies to terminate any related plans or initiatives.