Countries around the world exhibit diverse policies towards cryptocurrencies, with some nations embracing them positively while others impose strict restrictions. This diversity stems from varying national economic priorities, levels of technology adoption, and considerations for financial stability. Major trends include:
Regulatory Standardization: As the cross-border nature of cryptocurrencies becomes more prominent, the demand for international cooperation and regulatory standardization increases. Institutions like the Financial Action Task Force (FATF) promote the global application of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) standards.
Central Bank Digital Currency (CBDC): Many countries are exploring or developing central bank digital currencies to address the challenges posed by cryptocurrencies and enhance payment efficiency.
Balancing Innovation and Protection: Countries seek to balance encouraging blockchain technology innovation with protecting investors and maintaining financial stability.
Major Regional Dynamics
1. United States
Strategic Reserve Plan: At the beginning of 2025, the Trump administration proposed establishing a 'U.S. Crypto Strategic Reserve' aimed at holding Bitcoin (BTC), Ethereum (ETH), XRP, Solana (SOL), and Cardano (ADA) to solidify America's leadership in the global digital asset space. This plan is being advanced through executive orders, but the specific scale and funding sources await congressional approval.
Regulatory Progress: The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) still have disputes regarding the classification and regulatory responsibilities for cryptocurrencies. Proposals like the (Financial Innovation and Technology Act) (FIT for the 21st Century Act) have been put forward, but progress is slow.
Market Impact: Policy expectations boost market sentiment, and after the announcement on March 2, cryptocurrencies like XRP and SOL surged in the short term, but subsequent uncertainties led to a pullback.
2. European Union (EU)
MiCA Framework: The EU launched the Markets in Crypto-Assets Regulation (MiCA) in May 2023, which is the world's first comprehensive cryptocurrency regulatory framework and will be fully implemented by December 2024. MiCA requires Crypto Asset Service Providers (CASPs) to obtain licenses and strengthens investor protection and trading transparency.
Stablecoin Regulation: Starting January 2025, all transactions must disclose the identities of the sender and receiver, with unapproved stablecoins like Tether excluded from the compliance issuance list.
Objective: To unify internal EU rules, reduce regulatory arbitrage, and promote market integration.
3. Asia
Japan: Cryptocurrencies are regarded as legal property, and exchanges must comply with strict identity verification rules to prevent money laundering. Recent policies have further optimized the environment, attracting more international companies.
South Korea: The (Virtual Asset User Protection Act) will come into effect in July 2024, aimed at enhancing transaction security and combating fraud.
China: Since 2021, comprehensive bans on cryptocurrency trading and mining have been implemented, but research and development of blockchain technology are still supported. Hong Kong has launched a 'Crypto Center Roadmap' to attract crypto companies within a compliance framework.
India: Following the lifting of the trading ban in 2020, regulatory progress has been slow, and the (Cryptocurrency and Official Digital Currency Regulation Bill) has yet to be enacted.
4. Other Regions
United Kingdom: The Financial Conduct Authority (FCA) requires crypto firms to register, and the Bank of England is focusing on stablecoin regulation to enhance consumer convenience and prevent financial crime.
Brazil: New regulations implemented in June 2023, central bank oversees crypto assets with a focus on fraud prevention.
El Salvador: The first country in the world to adopt Bitcoin as legal tender, continuing to promote experiments with the crypto economy.
Global Coordination Efforts
FATF Guidance: The FATF requires Virtual Asset Service Providers (VASPs) to comply with the same AML/CTF rules as traditional financial institutions, promoting global regulatory consistency.
Role of International Organizations: The World Economic Forum (WEF) and the Bank for International Settlements (BIS) advocate coordinated policies to manage risks and unleash technological potential through research and recommendations (such as the WEF's (Pathway to Crypto Asset Regulation) white paper).
G20 Discussions: During India's G20 presidency in 2023, cryptocurrency policy became a key topic, with the International Monetary Fund (IMF) proposing macro policy recommendations and emphasizing the need to avoid adopting cryptocurrencies as legal tender to protect national sovereignty.
Challenges and Outlook
Challenges:
Regulatory Arbitrage: Differences in national policies may lead companies to relocate to regions with looser regulations.
Privacy Issues: CBDCs and strict KYC requirements raise concerns about personal privacy.
Market Volatility: Policy uncertainty exacerbates price volatility, as seen with the recent market speculation triggered by MtGox's transfer of 12,000 BTC.
Outlook:
In the coming years, global cryptocurrency policies may trend toward greater coordination, especially in the areas of stablecoins and cross-border payments.
Technological innovations (such as zero-knowledge proofs) may drive a balance between privacy and compliance.
If the U.S. implements strategic reserves, it may reshape the global cryptocurrency market landscape.
