International Coordination on Crypto Regulation: How Countries Are Aligning Rules for Digital Assets
Crypto Regulation Framework Comparison Tool
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Regulatory Comparison Results
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| Regulation Aspect | FSB | EU MiCA | UK-US Deal | FATF | IOSCO |
|---|---|---|---|---|---|
| Stablecoin Reserves | 100% cash reserves (recommended) | 100% cash or low-risk assets | Shared audit standards | Customer due diligence required | Requires reserve transparency |
| Exchange Licensing | Same activity = same rules | Mandatory licensing | Harmonized licensing | Anti-money laundering compliance | Securities rules apply |
| Enforcement | Coordinated global approach | Strong national enforcement | Joint enforcement actions | Global data sharing | International cooperation |
| Market Innovation | Balance between innovation and stability | Strict but predictable | Focus on market flexibility | Focus on compliance | Adaptable framework |
| Legal Definition | Activity-based regulation | Clear token classification | Alignment on activity types | Customer data requirements | Securities classification |
Important: Regulations are evolving rapidly. This comparison reflects current status as of mid-2025.
When Bitcoin first appeared, no one thought it would need a global rulebook. But today, crypto moves across borders faster than cash, and that’s created a mess. One country bans it. Another lets exchanges operate freely. A third taxes it like property. The result? Companies don’t know where to comply. Investors get caught in the middle. And bad actors exploit the gaps.
Why Global Coordination Isn’t Optional Anymore
Crypto isn’t local. A stablecoin issued in Singapore can be bought by someone in Nigeria, traded on a U.S.-based exchange, and settled through a blockchain node in Germany. If each country sets its own rules, the system breaks. That’s why regulators can’t work in silos anymore. The Financial Stability Board (FSB) is a global body that coordinates financial regulation among 93 member countries, including the U.S., EU, UK, Japan, and Australia. In July 2023, the FSB released its first major set of recommendations for crypto-assets and stablecoins. The core idea? Same activity, same risk, same regulation. If a crypto exchange offers leveraged trading, it should face the same capital and oversight rules as a traditional broker - no matter where it’s based. By October 2024, 88% of FSB members had started building rules for stablecoins. Sixty percent expected to fully align with the FSB framework by the end of 2025. That’s not perfect, but it’s the fastest global regulatory alignment ever seen in finance.The UK-US Tech Propensity Deal: A New Blueprint
While the FSB sets broad principles, real progress happens when two major economies team up. That’s what happened on September 18, 2025, with the UK-US Tech Propensity Deal - a landmark agreement to align digital asset regulation across the Atlantic. This isn’t just a handshake. It’s a working framework. The two countries agreed to:- Share regulatory data on crypto firms operating across borders
- Harmonize licensing requirements for crypto exchanges
- Coordinate enforcement actions against fraud and market manipulation
- Create joint oversight for stablecoin issuers
How the EU’s MiCA Regulation Compares
The Markets in Crypto-Assets (MiCA) regulation is the EU’s answer to crypto chaos. It went fully into effect in 2025 after years of drafting. Unlike the U.S.-UK approach, which leans toward innovation and market flexibility, MiCA is built on caution. Under MiCA:- All crypto asset issuers must publish detailed white papers approved by national regulators
- Stablecoins must hold 100% reserves in cash or low-risk assets - no crypto collateral allowed
- Exchanges must prove they can handle cyberattacks and operational failures
- Token holders get clear legal rights if a project fails
Other Key Players: IOSCO, FATF, and Central Banks
The International Organization of Securities Commissions (IOSCO) is another pillar of global coordination. In November 2023, it adopted 18 policy recommendations that apply traditional securities rules to Crypto Asset Service Providers (CASPs) - exchanges, wallets, and custody platforms. Then there’s the Financial Action Task Force (FATF). Its Recommendation 15 forces countries to require crypto firms to collect and share customer data - the same way banks do under anti-money laundering laws. As of mid-2025, FATF began its fifth round of country evaluations, putting pressure on nations that still allow anonymous crypto transfers. And don’t forget central banks. 91% of central banks are now exploring or testing their own digital currencies (CBDCs). That changes everything. When governments issue digital money, they’re not just competing with Bitcoin - they’re competing with the entire crypto ecosystem. Coordination now includes technical standards, interoperability, and even monetary policy.The Real Roadblocks to Harmony
Progress sounds good on paper. But here’s what’s still broken:- Regulatory arbitrage: Firms still move operations to places with weak rules - like offshore islands or countries with no crypto laws.
- Enforcement gaps: The SEC can fine a U.S. exchange. But if the same exchange is hosted on a server in Panama, who enforces it?
- Stablecoin risks: Even with MiCA’s 100% reserve rule, no global standard exists for how those reserves are audited. One issuer might use bank deposits. Another might use commercial paper. The risk isn’t the same.
- Legal chaos: Is a token a security? A commodity? A utility? The U.S. SEC says yes to some, the CFTC says others. No unified definition exists yet.
What’s Next? Sandboxes, Standards, and Shared Data
The most promising idea now? Cross-border regulatory sandboxes. SEC Commissioner Hester Pierce proposed letting regulated firms test new products across multiple jurisdictions under shared rules. Imagine a DeFi protocol that can legally operate under U.S. and UK rules at the same time - without needing two separate legal teams. No official sandbox has launched yet, but the UK-US deal includes language about exploring one. If it works, it could become the model for the rest of the world. Another key area: technical standards. Right now, every blockchain network has its own way of recording transactions. If regulators can’t read the data, they can’t enforce rules. Groups like the International Organization for Standardization (ISO) are starting to build shared protocols for crypto transaction reporting.Will We Ever Have One Global Rulebook?
Probably not. The world isn’t going to agree on everything. The EU will stay cautious. The U.S. and UK will push innovation. China will keep its own digital currency system separate. But that doesn’t mean failure. The goal now isn’t one rule for all. It’s no rule for none. If every country has at least basic standards - anti-fraud, transparency, reserve audits, KYC - then the system becomes safer. Firms can plan. Investors can trust. And innovation can thrive without chaos. The real win? When a startup in Brazil knows exactly what rules to follow to sell its token in Europe, the U.S., and Japan - without hiring five lawyers. That’s the future international coordination is building.Why can’t countries just copy each other’s crypto rules?
Because legal systems, economic goals, and political cultures are different. The EU prioritizes consumer protection above all. The U.S. values market freedom and innovation. China sees crypto as a threat to its monetary control. Copying rules doesn’t work if the underlying laws, courts, and enforcement tools don’t match.
What’s the biggest threat to international crypto coordination?
Regulatory arbitrage - when companies move operations to countries with weak or no rules. If one jurisdiction cracks down, others become safe havens. That undermines global efforts. Without strong cross-border enforcement, even the best agreements mean little.
Are stablecoins regulated the same everywhere?
No. The EU’s MiCA requires 100% cash reserves. The U.S. has no federal rule yet - some states treat them like money transmitters, others don’t regulate them at all. The FSB recommends reserve transparency and redemption guarantees, but enforcement varies. That’s why stablecoin runs - like Terra’s collapse - still happen.
How does the UK-US deal affect crypto businesses outside those countries?
It sets a new global benchmark. If you want to raise money from U.S. or UK investors, or list on major exchanges, you’ll need to meet their standards - even if you’re based in Singapore or Canada. It’s not law, but it’s market pressure. Firms that don’t comply risk being locked out of the world’s largest capital markets.
Will CBDCs make private crypto obsolete?
Not necessarily. CBDCs are government digital money - like an electronic version of cash. Crypto is decentralized, permissionless, and often used for things CBDCs can’t do - like private smart contracts or global DeFi lending. They’ll coexist. But CBDCs will force crypto to prove its value - or get pushed to the margins.
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22 Comments
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Abby Daguindal
December 16, 2025 AT 18:52Wow. So now we’re supposed to trust regulators who couldn’t even stop the 2008 crash? Crypto’s the future because it’s *not* controlled by the same people who printed trillions and called it ‘stimulus.’ This ‘coordination’ is just Wall Street in fancy suits trying to strangle innovation before it even breathes.
They want ‘same activity, same regulation’? Then why aren’t they regulating banks the same way they want to regulate crypto? Hypocrisy is the new standard.
I’m not against rules-I’m against control disguised as safety. You can’t regulate what’s decentralized. You can only drive it underground.
And don’t get me started on MiCA. 100% reserves? That’s not regulation, that’s a bank in disguise. Where’s the innovation in that?
They’re not trying to fix the system. They’re trying to own it.
And if you think the SEC knows what they’re doing, I’ve got a DeFi protocol to sell you.
They’re terrified because crypto doesn’t need them. And that’s the real threat.
SeTSUnA Kevin
December 17, 2025 AT 10:12The FSB’s framework is fundamentally sound. The principle of ‘same activity, same risk, same regulation’ is not merely prudent-it is economically necessary. Fragmentation invites arbitrage, and arbitrage invites systemic risk. The UK-US alignment is a necessary first step toward functional interoperability. MiCA’s rigidity, while commendable for consumer protection, stifles capital formation. Innovation requires regulatory clarity, not bureaucratic overreach.
Madhavi Shyam
December 17, 2025 AT 20:24Let’s cut through the jargon: regulatory fragmentation = crypto’s biggest liquidity risk. CASPs need harmonized AML/KYC, not 197 different compliance checklists. MiCA’s 100% reserve rule is a good baseline, but without real-time audit protocols, it’s just theatre. The real win? Cross-border sandboxes. That’s where the innovation happens-not in lobbying offices.
Florence Maail
December 17, 2025 AT 21:55They’re all lying. Every single one of them. The FSB? Controlled by the same banks that crashed the economy. The UK-US deal? A trap to lock out everyone else. MiCA? A luxury for rich Europeans who can afford lawyers. CBDCs? They’re not digital money-they’re surveillance tools. You think they care about ‘innovation’? No. They care about control. They’re building a financial prison and calling it ‘stability.’
And don’t you dare say ‘but what about fraud?’-the banks are the biggest fraudsters. They just have better PR.
Don’t trust the system. Burn it down. 🤡
Chevy Guy
December 18, 2025 AT 03:07So the SEC and FSB are gonna save us from crypto by making it more like banks? Great. So now my DeFi wallet needs a W-9 and a notary stamp? And who’s gonna pay for that? Me? The guy who just bought a meme coin with his lunch money?
They don’t want to regulate crypto. They want to kill it. And they’re using ‘coordination’ as the shovel.
Meanwhile, Bitcoin’s still up. 😎
Rebecca Kotnik
December 19, 2025 AT 23:23While the current state of crypto regulation is undeniably fragmented and fraught with jurisdictional inconsistencies, the trajectory toward international alignment-however incremental-is both historically significant and economically rational. The Financial Stability Board’s recommendations, particularly the ‘same activity, same risk, same regulation’ principle, represent a foundational normative shift in global finance. The UK-US Tech Propensity Deal, while bilateral, introduces a replicable model of regulatory interoperability that could serve as a template for multilateral cooperation. The EU’s MiCA framework, though conservative, demonstrates that comprehensive legal architecture for digital assets is achievable. The critical challenge lies not in the technicalities of reserve audits or licensing harmonization, but in the political will to subordinate national sovereignty to systemic stability. Without shared technical standards for transaction reporting and cross-border enforcement mechanisms, even the most elegant regulatory frameworks will remain theoretical. The emergence of cross-border regulatory sandboxes, as proposed by Commissioner Pierce, may prove to be the most pragmatic innovation in this space-a laboratory for cooperation rather than a battlefield of competing jurisdictions.
Sue Bumgarner
December 20, 2025 AT 04:57Let’s be real-this whole ‘global coordination’ thing is just Europe and the UK trying to boss America around. We don’t need their rules. MiCA is a socialist dream for rich people who don’t want to take risks. The U.S. leads the world in innovation. Why are we letting some EU bureaucrat tell us how to run our crypto markets? We’ve got the best tech, the best talent, the best investors. Why should we bend over for them? If they want to play by their rules, fine. But don’t expect us to follow. America doesn’t follow. We lead.
Kayla Murphy
December 21, 2025 AT 06:06Change is scary, but we’re building something amazing here. Every time someone says ‘regulate it to death,’ I think of the startups in Nairobi, Lagos, and Bogotá who just need a fair shot. Global rules aren’t about control-they’re about access. If a kid in India can launch a token and know the rules in Europe and the U.S., that’s power. That’s freedom. Keep pushing. Keep building. We’ve got this. 💪
Kelsey Stephens
December 23, 2025 AT 00:48I appreciate how much effort is going into this. It’s messy, sure-but that’s because we’re trying to do something no one’s ever done before: create global rules for a borderless tech. I’ve talked to devs who are terrified of compliance. I’ve talked to regulators who are overwhelmed. The solution isn’t perfection-it’s progress. Sandboxes, shared data, pilot programs. Let’s start small, learn fast, and scale smart. We’re not failing. We’re evolving.
Craig Nikonov
December 24, 2025 AT 23:35They’re calling this ‘coordination’? More like a corporate power grab. The FSB? A cabal of central bankers in suits. MiCA? A luxury tax on innovation. The UK-US deal? A cartel to lock out the rest of the world. And don’t get me started on FATF’s KYC demands-next they’ll be scanning your crypto wallet like it’s a passport. This isn’t regulation. It’s financial colonization.
Donna Goines
December 25, 2025 AT 11:54They say ‘no rule for none’-but what if the rule is that you can’t own crypto unless you’re a U.S. citizen? What if the ‘global standards’ are just U.S. rules with a fancy name? MiCA looks nice on paper, but who’s auditing the auditors? And if the SEC says a token is a security, but the CFTC says it’s a commodity… who wins? The lawyers. Always the lawyers. This whole system is rigged. They’re not fixing crypto-they’re killing it with paperwork.
Greg Knapp
December 27, 2025 AT 09:19So the EU says stablecoins need 100% reserves but doesn't care how they're stored? That's like saying your car needs a seatbelt but you can drive with no brakes
And the US can't even agree if it's a security or a commodity? Bro what
And the FSB? More like FSB-Feds Still Baffled
They're all just guessing and making up rules as they go and calling it 'coordination'
Meanwhile Bitcoin just keeps going up
lol
Elvis Lam
December 28, 2025 AT 09:43Let’s get real: the real bottleneck isn’t regulation-it’s infrastructure. No one’s talking about how regulators can’t even read blockchain data. If a stablecoin issuer uses commercial paper as reserves, how does a regulator in Tokyo verify that in real time? We need standardized on-chain reporting protocols-like ISO 20022 for crypto. Until then, all these ‘frameworks’ are just PowerPoint slides. The UK-US sandbox idea? That’s the only thing with teeth. Let’s pilot it. Test it. Break it. Fix it. Then scale it. Stop talking. Start building.
Bradley Cassidy
December 29, 2025 AT 12:42Man I just read this whole thing and I’m like… wow we’re actually kinda doing it? Like not perfectly but like… kinda? The FSB thing is wild, I didn’t realize 88% of countries are already working on stablecoin rules. And the UK-US thing? That’s huge. I know MiCA’s strict but honestly? After Terra, I get it. Maybe we don’t need one rule for all, but we sure as hell need at least one rule for *most*. I’m just hoping the sandboxes actually happen before another coin crashes and takes a million people’s savings with it. 🤞
Sean Kerr
December 31, 2025 AT 01:25Y’all need to chillllll 😌
Regulation isn’t the enemy-chaos is. I’ve seen people lose everything because some ‘DeFi protocol’ had no audit, no team, no nothing. MiCA? It’s annoying? Yeah. But it’s also the difference between someone sleeping at night and someone crying over their phone at 3am.
And the UK-US deal? That’s the future. Not ‘one rule for all’-but ‘one clear path to play.’
Let’s not break what’s starting to work. Let’s make it better. 🙏
Patricia Amarante
December 31, 2025 AT 22:33Finally someone gets it. I run a small crypto shop in Austin. Last year I had to hire three lawyers just to figure out if I could sell a token to someone in Germany. This ‘coordination’ stuff? It’s not about control. It’s about not going broke trying to comply. If I know the rules in the U.S. and the EU match, I can focus on building-not lawyering. Thank you for writing this.
Mark Cook
December 31, 2025 AT 22:41So the FSB says ‘same activity, same regulation’… but the SEC still says Bitcoin is a commodity and also a security depending on the day? 🤡
Also, who’s auditing the auditors? Who checks if the ‘100% reserves’ are real? Or if they’re just fake bank statements?
And why does everyone ignore that China’s CBDC is already tracking every transaction? We’re building a cage for crypto while they’re building a cage for people.
Either way, we’re losing.
Jack Daniels
January 1, 2026 AT 12:43They’re all going to fail. The regulators, the exchanges, the investors. Crypto’s too big, too fast, too wild. You can’t cage lightning. You can’t regulate trustless systems with paperwork. This whole thing is a funeral march dressed up as progress. I’m just waiting for the collapse. It’s coming. And when it does, no one will be surprised.
Samantha West
January 1, 2026 AT 17:44There is a metaphysical dimension to this regulatory fragmentation: the tension between the decentralization ethos of blockchain and the centralized epistemology of nation-states. We are attempting to impose sovereign jurisdiction upon a technology that fundamentally rejects jurisdiction. This is not a policy problem-it is a civilizational contradiction. The ‘same activity, same regulation’ principle is a noble aspiration, but it assumes a shared ontology of value that does not exist. The West believes in property rights. China believes in control. The Global South believes in survival. These are not regulatory differences-they are ontological fractures. No amount of FSB memoranda will heal them.
Shruti Sinha
January 3, 2026 AT 16:29India’s still figuring out crypto, but I’m glad someone’s trying to fix this mess. MiCA’s too strict. U.S. is too loose. UK-US deal? Finally something practical. If we can get audit transparency for stablecoins, that’s 80% of the problem solved. The rest? Let the market decide. Just don’t let the fraudsters win.
Terrance Alan
January 4, 2026 AT 00:11They keep talking about coordination like it’s some noble cause. But let’s be honest-this is about power. Who controls the money? Who gets to say what’s legal? The same people who owned the banks in 2008. The same people who got bailed out. Crypto was supposed to be the reset button. Now they’re putting it back in the same cage. They don’t want innovation. They want control. And they’re using ‘safety’ as the excuse. It’s the same script. Always the same script. We’re not building a better system. We’re just rebranding the old one.
George Cheetham
January 4, 2026 AT 19:52Think of this not as regulation, but as translation. We’re not trying to make one language-we’re trying to make everyone understand each other. MiCA speaks in legal precision. The U.S. speaks in market freedom. China speaks in state control. The FSB? It’s the dictionary. And the sandboxes? They’re the language labs. The goal isn’t uniformity. It’s mutual comprehension. When a startup in Brazil can operate under U.S. and EU rules without hiring five lawyers? That’s not regulation. That’s liberation.