Author: Insights4.vc Translation: Shan Ouba, Golden Finance
In 2025, global cryptocurrency regulation has entered a critical moment, and major jurisdictions are strengthening their supervision.
In Europe, the Markets in Crypto-Assets Regulation (MiCA) will take full effect in December 2024, establishing comprehensive standards for crypto services and stablecoins. At the same time, the United States is actively formulating the future direction of crypto regulation. On April 3, 2025, the U.S. House of Representatives Financial Services Committee passed the STABLE Act (H.R. 2392); and on March 13, 2025, the Senate Banking Committee passed the bipartisan GENIUS Act by 18 votes to 6.
At the global level, some key institutions are also influencing policy making: the Bank for International Settlements (BIS) published a research report in April 2025, recommending strict reserve requirements for stablecoins; the Financial Action Task Force (FATF) conducted a public consultation on the revision of the "Travel Rule" from February to April 2025, intending to include all crypto payments in the scope of application; the capital rules for crypto assets formulated by the Basel Committee officially came into effect on January 1, 2025.
In Asia, regulators are also following up quickly: the Hong Kong Securities and Futures Commission (SFC) issued new rules on crypto pledge in April 2025, further improving its exchange license system implemented in 2023; Singapore has completed the formulation of a stablecoin license framework since August 2023. In the Middle East, the Dubai Virtual Asset Regulatory Authority (VARA) led the way, issuing updated crypto marketing regulations in October 2024, while Bahrain updated its crypto rules in February 2024.
In emerging markets in Africa and Latin America, regulation is also advancing rapidly: Kenya received regulatory guidance issued by the International Monetary Fund (IMF) in January 2025; Brazil plans to implement crypto regulations in stages by the end of 2025; Argentina launched a regulatory sandbox in early 2025 to pilot tokenized securities.
Global Regulatory Heat Map
The maturity of global crypto regulation ranges from "comprehensive system" to "total ban."
Comprehensive regimes: The EU (MiCA), the UK (crypto regulation under the forthcoming FSM Act), Singapore (Payment Services Act and Stablecoin Regulatory Code), Hong Kong (licensing system), Switzerland and Australia all have detailed regimes. Japan, Canada and some Caribbean financial centers also have relatively mature crypto rules.
Advancing: The United States is debating major crypto regulations (such as the Stablecoin Act, FIT21), but has not yet formally legislated. South Korea implemented the Virtual Asset User Protection Act (VAUPA) in July 2024. Brazil laid the foundation through legislation in 2022, and the central bank aims to introduce the first phase of rules by the end of 2025; Governor Campos Neto said in October 2024 that stablecoin rules and a complete VASP framework will be introduced next year. India submitted a new Income Tax Bill in February 2025, which formally defines "virtual digital assets", but still retains a 30% tax rate and 1% TDS, and requires the Ministry of Finance to propose possible reforms by July 2025. South Africa and Israel are developing regulatory frameworks. Mexico, Colombia and the Philippines regulate crypto transactions and payments under their fintech laws.
Initial stage: Many countries are still in the exploratory stage. For example, Mexico allows crypto activities under its fintech law, but is still perfecting the details; Argentina and Ecuador are piloting tokenization regulatory sandboxes. African markets such as Kenya and Nigeria are studying crypto laws with the support of the IMF and the World Bank. In addition to Brazil and Argentina, Chile, Peru and other countries in Latin America are also paying close attention to the development of the crypto market.
Restrictive: Some countries only allow limited crypto activities. For example, Qatar’s new digital asset framework explicitly excludes cryptocurrencies and stablecoins; Saudi Arabia has no clear crypto regulations and is cautious about them. Other Gulf countries, such as Kuwait and Oman, have issued warnings or maintained low involvement.
Prohibition: Countries such as China and Vietnam have basically banned crypto trading and mining (for example, China has implemented a comprehensive crypto ban since 2021).
United States
Key Points: US policymakers are focusing on stablecoins and cross-agency regulatory coordination. In early 2025, the House of Representatives passed the STABLE Act (the "Stablecoin Transparency and Accountability Act") by a bipartisan vote of 32 to 17; the Senate Banking Committee advanced the GENIUS Act (the "Guiding and Establishing a National Innovation System for Stablecoins in the United States Act"). Both bills will establish strict reserve and information disclosure requirements for stablecoins backed by the U.S. dollar, and are currently awaiting a vote in Congress.
Meanwhile, former President Trump publicly promoted a "national cryptocurrency strategy" and ordered the establishment of a crypto working group to study the U.S.'s Bitcoin reserve and digital asset reserve plan. In terms of regulation, both Democrats and Republicans have expressed concerns about the SEC's enforcement actions against issuers of crypto projects (for example, accusing token trading platforms of being unregistered securities). Related legislation, such as the FIT21 Act, aims to clarify that the SEC and CFTC regulate crypto assets separately to avoid overlapping responsibilities.
In this regard, the bipartisan FIT21 draft (co-sponsored by Senators Scott, Hagerty, and others) will clarify the division of responsibilities between the SEC and the CFTC, and introduce a new category of "licensed payment stablecoins" to be jointly regulated by the two agencies. Meanwhile, regulators are also taking action: the crypto task force led by SEC Commissioner Peirce is seeking public comment on topics such as custody, lending, pledging, and clearing, which could ease restrictions on crypto lending and pledging under securities regulations; CFTC leadership is inclined to classify most cryptocurrencies as "commodities."
In addition, bank regulators are also issuing guidance related to fintech and crypto custody (the OCC and FDIC have issued relevant guidance between 2022 and 2024). Overall, the market should pay close attention to the final vote on the Stablecoin and Exchange Act and prepare for regulatory actions by the SEC and CFTC. The emerging regulatory framework in the United States heralds clearer stablecoin standards and the redrawing of regulatory boundaries by the SEC and CFTC, which will strengthen market issuance controls and anti-fraud supervision.
European Union
Key points: The EU now has a unified crypto legal framework (MiCA), and anti-money laundering and money transfer regulations are also being strengthened. In May 2023, the EU officially adopted the MiCA Regulation, the first law to cover most crypto services. MiCA's provisions on registration/licensing, transparency, stablecoin reserves and consumer protection came into effect on December 30, 2024. Regulators in each member state are implementing the second phase (Level-2) details of MiCA, including stablecoin support mechanisms, trading platforms and technical standards for information disclosure.
At the same time, the European Banking Authority (EBA) and the Securities and Markets Authority (ESMA) are also improving the regulation of crypto in accordance with anti-money laundering/counter-terrorist financing regulations. It is worth noting that the EU's new "Travel Rule" regulation (No. 1113/2023) extends traditional fund transfer regulations to the crypto field and will come into effect at the end of 2024. In July 2024, the EBA issued the final "Travel Rule Guidelines", clarifying the information requirements for the initiator and recipient in crypto transfers. This means that European crypto exchanges and wallet services need to collect relevant user information for each transaction like banks.
In early 2025, national regulators will issue relevant supervisory statements. The EU is also finalizing a revised version of the Funds Transfer Regulation to unify anti-money laundering standards for wire transfers across Europe (including cryptocurrencies). In terms of law enforcement, ESMA is reviewing key markets (such as stablecoins), and the EBA has also issued crypto custody standards. The European Central Bank and member central banks are studying how MiCA can be connected to existing payment systems, and the EU has also debated wholesale CBDC pilots.
Currently, EU crypto market operators are under a clear legal framework: service providers must be registered in a member state (or use a 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 wilderness era" at the national level: cross-border token issuance and trading will be subject to strict supervision and capital requirements, and stablecoins must achieve 100% reserves.
MiCA Level-2 has been initiated: On April 29, 2025, the European Commission adopted the first MiCA Delegated Regulation (RTS on Market Manipulation Control), and more RTS rules will be introduced in the second half of 2025.
United Kingdom
Key Points: After a period of pause, the UK is fully bringing crypto under regulation. On the basis of the Financial Services and Markets Act 2023 (FSM Act), the UK government has confirmed that it will legislate for all major crypto activities (including stablecoins) at the same time, abandoning the original phased path.
At the end of 2024, the new government announced that it would expand the scope of regulation of the Financial Conduct Authority (FCA) to cover crypto trading, custody, exchanges and stablecoin issuance. The FSM Act has broadly defined “crypto-assets” since June 2023 and empowers the Treasury to designate crypto activities as regulated activities.
As a result, the UK regulatory roadmap includes the passage of new secondary legislation in 2025 (such as amendments to the Regulated Activities Order) and regulatory rules issued by the FCA, covering listing and disclosure obligations for crypto trading platforms, market manipulation rules extended to crypto (i.e. the proposed MARC regime) and stablecoin redemption guarantees. The FCA has published a discussion paper on crypto custody and staking.
In January 2025, the government issued a decree excluding crypto staking from the definition of “collective investment schemes”, thereby giving the green light to compliant staking services. The FCA also plans to consult in 2025 on fund safety rules for crypto custody and how staking and lending can be included in the client funds regulatory framework.
In practice, authorized crypto firms will soon need a full FCA license, clear custody regimes 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. Crypto market abuses will also be subject to UK law once these regimes are implemented.
Asia
Key Points: Major hubs in Asia are establishing or upgrading their regulatory systems.
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 data requirements of the FATF "Travel Rule", giving regulators full visibility into transaction initiators and recipients. Stablecoins are classified as "electronic payment instruments". In March 2025, the Financial Services Agency (FSA) proposed legislation that would allow trust-based 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 the 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 expand supervision of crypto asset sales.
Hong Kong
In 2023, the Hong Kong Securities and Futures Commission (SFC) launched a new virtual asset trading platform licensing system, which will take effect in June 2023. By early 2025, the SFC had extended the rule to staking services. In April 2025, the SFC issued guidance allowing licensed platforms to offer crypto staking (such as Ethereum staking), but with strict conditions: the platform must have full control over the staking assets, have a robust information disclosure and risk management system, and obtain explicit regulatory approval. This reflects Hong Kong's broader policy direction, namely the "ASPIRe" strategy - recognizing the role of staking in network security while requiring strong investor protection measures. The SFC expects to complete the finalization of stablecoin regulatory rules in 2025, and preliminary public consultation has been launched in 2024.
Singapore
The Monetary Authority of Singapore (MAS) has implemented a mature crypto asset regulatory mechanism through the Payment Services Act since 2020. In August 2023, MAS issued a new stablecoin regulatory framework requiring all fiat-pegged cryptocurrencies (such as USDS-like currencies) to be fully backed by reserve assets and to hold these reserves in regulated institutions. Singapore is expected to finalize all remaining stablecoin-related rules by 2025.
South Korea
South Korea passed the Virtual Asset User Protection Act (VAUPA) in mid-2023 and it officially came into effect on July 19, 2024. The act provides extensive protections: crypto exchanges must segregate customer assets, hold insurance, perform operational reviews, and report suspicious activities. The Financial Services Commission (FSC) has announced that exchanges have strengthened their compliance systems in advance under VAUPA. More rules will be introduced in 2025, including stablecoin reserve and custody obligations.
Other Asian Regions
Singapore and Hong Kong continue to lead the development of regulatory frameworks. India is reassessing its crypto policy in light of global trends. Mainland China still maintains a strict prohibition on crypto trading. Emerging markets such as the Philippines and Malaysia are moderately regulating crypto exchanges and service providers, and the Indonesian central bank is also drafting a crypto licensing regime.
Middle East
Key Points: Gulf countries are rapidly building their own crypto regulatory systems.
Dubai (UAE)
Dubai’s Virtual Asset Regulatory Authority (VARA), established by Law No. 4 of 2022, has developed a comprehensive set of crypto regulatory rules. In October 2024, VARA issued new Marketing Regulations to govern all crypto advertising and promotion to UAE residents, replacing the previous executive order. VARA’s 2023 regulations cover the licensing and governance of exchanges, brokers and other crypto institutions. Between 2023 and 2025, VARA continued to expand its guidelines, with a particular focus on marketing and custody operations. In addition, Dubai's financial free zones DIFC and ADGM have also developed their own DLT (distributed ledger technology) regulatory frameworks, allowing the UAE to further consolidate its position as a regional crypto hub.
Bahrain
The Central Bank of Bahrain (CBB) established its own virtual asset regulator in 2022. In February 2024, the CBB updated its digital asset rules to align with international standards. Bahrain currently allows licensed crypto exchanges and custody service providers to operate, and enforces anti-money laundering/counter-terrorist financing regulations on virtual asset service providers (VASPs). The country's stock exchange, the Bahrain Exchange, is also exploring the possibility of tokenizing securities.
Saudi Arabia
Saudi Arabia has not yet developed a dedicated crypto legal framework. Crypto trading is technically unregulated and not officially recognized. The Saudi Arabian Central Bank (SAMA) and the Capital Markets Authority (CMA) have repeatedly issued warnings about the risks of crypto investments. However, the country has shown interest in blockchain technology and is involved in the central bank digital currency project mBridge. Comprehensive crypto laws are not expected to be introduced before the late 2020s.
Qatar
In 2024, the Qatar Financial Center (QFC) launched a digital asset framework for QFC registered entities. The framework supports the tokenization of physical assets and DLT applications, but explicitly excludes cryptocurrencies and stablecoins. As a result, Qatar remains cautious, restricting direct crypto transactions but encouraging regulated tokenized financial applications.
Africa and Latin America Overview
Key Points:Emerging markets are actively exploring and gradually improving crypto regulation.
Most African countries are still in the exploration stage of crypto regulation. In January 2025, the International Monetary Fund (IMF) issued a technical assistance report for Kenya, recommending the establishment of classification standards for crypto assets, strengthening institutional coordination and improving anti-money laundering supervision. The Kenya Capital Markets Authority is drafting relevant legislation. Nigeria is re-examining its regulatory strategy for crypto exchanges due to being included in the gray list by FATF. South Africa's licensing system is online: since June 1, 2023, the FSCA has processed 420 CASP (crypto asset service provider) applications and approved a total of 248 licenses as of December 10, 2024; the enforcement and on-site review of the "travel rules" have been launched in the first quarter of 2025. Rwanda, Nigeria and other countries are currently focusing on the anti-money laundering compliance of VASPs.
Regulation in Latin America varies significantly. Brazil passed a national crypto law in 2023, and its central bank is implementing it in stages, and it is expected to release a draft by the end of 2024. Mexico still operates under the 2018 Fintech Law and has recently strengthened anti-money laundering reviews of crypto exchanges. Argentina, which had lax regulation for many years, passed Law No. 27,739 in March 2024 to bring VASPs under securities regulation; it also launched a tokenization pilot zone in April 2025 for on-chain securities testing. Chile and Colombia have issued relevant guidance, but they have not yet formed a complete legal system.
Cross-sector topics
Stablecoins
Global regulators 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% backed by reserves and redeemable at any time. BIS Document No. 156 (April 2025) specifically calls for "targeted stablecoin regulation" with a focus on reserve assets and stress-resistant design. The EU’s MiCA and some national laws require fiat-pegged currencies to have full asset backing and capital buffers. In the US, multiple congressional bills (e.g., the STABLE Act, the GENIUS Act, and proposed Federal Reserve rules) aim to require issuers to hold security reserves at regulated banks. Globally, regulators are expected to mandate proof of reserves and audits — in fact, some exchanges in jurisdictions such as Japan and parts of Europe are already required to publish proof of reserves disclosures. Stablecoin regulation is becoming a core theme in Basel’s prudential regulation and global AML regimes.
Financial Action Task Force AML/CFT (February 2025)
Continuous updates from the FATF are reshaping the compliance landscape for cryptocurrencies. In February 2025, the FATF convened a plenary to launch a public consultation on Recommendation 16 (“Transfer Rule”), which aims to ensure consistent originator/beneficiary data for all transfers. These revisions are expected to be completed by mid-2025 and may include structured messaging requirements (e.g. ISO 20022), lower de minimis thresholds, and expanded coverage of domestic and cross-border cryptocurrency payments. In addition, the FATF 2023-2024 Annual Report (published in January 2025) reiterates the obligation for jurisdictions to license or ban virtual asset service providers (VASPs) according to their standards. In practice, this means that licensed cryptocurrency exchanges around the world must implement strict KYC/AML controls. Many jurisdictions, including the EU, UK, and Canada, have begun to apply the FATF virtual asset guidance 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 156)
DeFi tokens and cryptocurrency staking activities are receiving increasing regulatory attention. BIS Paper 156 (April 2025) analyses the role of DeFi in financial markets and warns that without appropriate regulation, DeFi could spread financial risks. Regulators are currently considering how to bring decentralized finance under the regulatory umbrella. For example, Hong Kong’s April 2025 guidance treats “staking-as-a-service” providers as institutions subject to existing exchange licenses. Similarly, some central banks are looking at how to regulate lending and staking activities involving stablecoins through initiatives such as the Mariana Project. New guidance is expected in 2025-2026 covering stablecoin staking pools, liquidity provision and lending platforms - which will effectively apply the “same activity, same risk” principle to DeFi. For traditional financial institutions, this means that on-chain financial contracts need to be closely monitored, and custodians will also need to disclose any staking services provided to customers.
Basel Cryptocurrency Prudential Rules
In June 2023, the Basel Committee finalized the capital standards for crypto assets, which will take effect on January 1, 2025. Based on these criteria, banks must classify cryptocurrency exposure into two categories:
Group 1: Tokenized traditional assets and algorithmic stablecoins that meet strict criteria
Group 2: All other assets, such as Bitcoin and Ethereum
Category 2 crypto assets that do not pass the hedge test (Category 2b) now have a risk weight of 1,250%; any bank whose total Category 2 exposure exceeds 1% of Tier 1 capital must be charged 1,250% on the excess, and if it exceeds 2%, all Category 2 holdings will be subject to a 1,250% weighting. Algorithmic stablecoins or non-redeemable stablecoins are explicitly excluded from Category 1 eligibility. These measures effectively block large banks from participating in pure cryptocurrencies. In addition, the rules introduce a short-term “infrastructure-plus” risk weight for any crypto-related lending. Banking regulators in the United States and Europe have confirmed their intention to enforce these standards. The practical impact is that any traditional financial institution that intends to hold or lend cryptocurrencies must set aside a significant amount of capital, reducing earnings potential and requiring strong collateral management.
Tax Transparency (OECD CARF)
To combat cryptocurrency-related tax evasion, the Crypto-Assets Reporting Framework (CARF), adopted by the Organization for Economic Cooperation and Development (OECD) in 2023, is being implemented worldwide. According to the OECD Secretary-General’s report to the G20 Finance Ministers, as of February 2025, 66 jurisdictions have committed to launching CARF exchanges, 54 of which will 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 will need to ensure that their AML/KYC systems are capable of collecting and storing this data. By 2025, a series of domestic regulations and international agreements are expected to put CARF into practice. Companies that fail to comply may face penalties and enforcement actions as tax authorities will begin to require detailed reports on customer balances and transactions.
Strategic Impact and Risk Checklist
Regulatory Arbitrage
Different regulatory regimes around the world present both opportunities and risks. Crypto-friendly markets such as Dubai, Singapore, and Switzerland may attract more issuance and development activities, while more strictly regulated regions such as China, Qatar, and some US states may experience capital outflows. Firms need to clearly understand in which markets their products can be legally offered and where key players (such as banks, exchanges, and custodians) operate. However, with the promotion of global frameworks such as FATF and Basel, globally coordinated regulation is gradually reducing the existence of "regulatory safe havens". Firms' compliance strategies must cover all operating regions and take a holistic approach.
Capital occupation impact
According to the new Basel regulations in 2025, banks will face higher capital occupation for crypto assets. Asset management companies that hold crypto assets indirectly through banking channels will also face an increase in weighted risk capital. This will push up leverage costs and reduce returns. For example, a bank-backed crypto fund may need to prepare an additional 20–30% of capital for every $1 invested. Institutions should immediately model the impact and consider transferring some crypto businesses to non-bank entities to optimize capital efficiency.
Custody and Cybersecurity
Increased regulation makes custody a risk focus. Countries are increasingly requiring custodians to use cold wallets, regular audits, and asset segregation. Recent high-profile cyber attacks have highlighted the need for a strong custody infrastructure - including multi-signature wallets, insured custody mechanisms, and operational transparency. Regulators such as ESMA and the UK 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 need to invest heavily in resilient systems, regulatory compliance, and customer protection, otherwise they may face enforcement risks for fraud or breach of fiduciary duty.
Tokenization of Assets
Multiple jurisdictions are preparing to introduce legal frameworks for the tokenization of real-world assets (RWA). The EU and UK are exploring the listing of security tokens; Japan’s DLT pilot covers government bonds; and 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 custody and market-making business opportunities, but also bring new risks of smart contracts and system interoperability. Companies should evaluate platform partnerships and compliance procedures related to asset traceability and transfer restrictions as early as possible.
Market Making and Liquidity
Regulators are focusing on crypto market-making mechanisms, especially automated liquidity pools. Capital and anti-money laundering obligations will reshape the way banks and brokers participate. Transparency standards such as “proof of reserves” may become mandatory requirements for exchanges. Traditional financial trading desks should expect that they will only be able to trade with counterparties that have completed KYC in the future, and capital occupation caused by volatility may limit proprietary trading capabilities. Risk management teams should update stress testing scenarios to include crypto market volatility and chain reaction risks, especially during crises, when correlation with traditional assets may increase sharply.
Actionable Recommendations
Develop an overall crypto strategy: Develop a comprehensive board-level strategy covering compliance, information technology, fund management and risk control, and set up a cross-departmental team to closely follow the developments of MiCA, Basel and FATF.
Strengthen anti-money laundering and tax mechanisms: Upgrade KYC and transaction monitoring systems to meet crypto-related standards and ensure that the system can support OECD CARF reporting requirements, including digital and auditable collection of customer identity and tax residency data.
Reassess capital and financial limits: Incorporate the 2025 Basel crypto capital rules into internal models, update financial exposure limits, and consider optimizing capital efficiency through special purpose vehicles (SPVs).
Ensure the security of the custody infrastructure: Only work with regulated custodians or develop institutional-grade self-operated solutions. Use multi-signature cold storage, configure insurance, conduct regular audits, and clearly disclose customer rights.
Train employees: Continuously train legal, compliance, and front-office teams. Appoint a full-time crypto compliance officer to proactively address regulatory risks.
Future Outlook (2025–2027)
Legislative Developments
The EU may launch the "MiCA-2" plan to refine stablecoin and ESG-related rules. The UK will publish detailed secondary regulations under the Financial Services and Markets Act (FSM Act) from 2025. The United States is expected to introduce a comprehensive cryptoasset framework, possibly through the FIT21 Act or the Digital Commodity Market Reform Act. The bipartisan stablecoin bill (submitted in February 2025) intends to clarify issuer responsibilities.
Regulatory trends
Regulation is shifting to an "activity-based" approach. The Basel Committee and IOSCO are expected to jointly issue guidance on custody and lending supervision. The BIS Innovation Center's "Project Mariana" and CBDC-related projects (such as mBridge and Project Dunbar) influence central banks' positions on crypto interoperability. "Proof of reserves" may become a regulatory requirement - Singapore MAS, Japan FSA, etc. are already exploring relevant disclosure mechanisms.
Market structure evolution
Tokenized trading of government bonds is gradually emerging. It is expected that by 2027, many places will pilot "on-chain T-Bills" (tokenized treasury bonds), repo markets and blockchain-collateralized lending businesses. These developments, coupled with programmable regulation, are expected to completely change the structure of fixed income markets. Regulated crypto ETFs will expand, and the integration of traditional and decentralized markets will accelerate.
CBDC Collaborative Development
Wholesale CBDC (central bank digital currency) projects will continue to advance. BIS-led mBridge is entering its third phase, with multiple central banks participating in multiple CBDC pilots. ASEAN+3, China's e-CNY and the United States' retail CBDC research will continue to influence global central bank strategies. Central banks are increasingly focusing on the interoperability between CBDC and stablecoins, as shown in Singapore's Project Dunbar.
Technology and Compliance Advances
AI and machine learning will enhance transaction monitoring and anomaly detection, and vendors such as Chainalysis and TRM continue to expand 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 needs of the next generation of the crypto ecosystem.
Focus on the timeline (Q2 2025 to Q4 2027)
2025-Q2: FATF completes revision of the "Travel Rule"; Hong Kong completes stablecoin licensing details; the US Senate deliberates on the "STABLE Act"; the EU releases MiCA secondary regulations.
2025-Q3: BIS releases crypto policy document; Singapore releases security token guidelines; South Africa improves crypto regulations; OECD releases first CARF report; India reviews crypto tax regulations.
2025-Q4: Basel Committee releases crypto capital FAQ; US Comptroller General releases stablecoin regulatory guidance; UK FCA finalizes custody rules; EU updates AMLR and includes crypto content; Bermuda and El Salvador announce CBDC plans.
2026-Q1: MiCA and UK crypto regulations are officially implemented; OECD CARF begins reporting; US releases stablecoin regulatory framework; Brazil completes the first phase of crypto exchange rules.
2026-Q2: BIS and IOSCO release digital asset risk report; Japan expands encryption regulations; Australia implements "travel rules"; G20 evaluates encryption and CBDC progress; Basel begins monitoring encryption climate risks.