The global digital asset legislation #数字资产法案 presents a differentiated regulatory landscape. China, based on the Cybersecurity Law, clearly categorizes the regulation of cryptocurrencies, tokens, etc., with responsibilities divided among institutions like the central bank. The U.S. FIT 21 Act distinguishes between securities and commodities attributes through the Howey test, with the SEC and CFTC collaboratively regulating exchanges. The EU MiCA Act strengthens anti-money laundering and investor protection, requiring token issuance white papers and licensed operations. Hong Kong and Singapore implement a VASP licensing system, restricting retail client leverage trading. Core elements include: entry qualifications, on-chain transaction monitoring, tax-neutral policies, and cross-border cooperation mechanisms, while facing challenges of price volatility and regulatory arbitrage.