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International Coordination on Crypto Regulation: How Countries Are Aligning Rules for Digital Assets

International Coordination on Crypto Regulation: How Countries Are Aligning Rules for Digital Assets

Michael James 14 December 2025 22 Comments

Crypto Regulation Framework Comparison Tool

Compare Regulatory Frameworks

Select two or more frameworks to compare key regulations for stablecoins, exchanges, and enforcement

Select frameworks to compare:

FSB (Financial Stability Board)

MiCA (EU)

UK-US Tech Propensity Deal

FATF

IOSCO

Regulatory Comparison Results

Tip: Click column headers to sort by specific regulation criteria.

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

Why does this matter? The U.S. and UK together control over 40% of global crypto trading volume. If they speak with one voice, other countries have to listen. China and the EU are watching closely - not because they’ll copy it, but because they don’t want their markets cut off from Western capital.

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

MiCA is strict. It’s also predictable. That’s why many institutional investors now prefer to list tokens under MiCA rules. But critics say it’s too slow. Startups struggle under the compliance load. The EU doesn’t have a sandbox for testing new DeFi models - something the U.S. is now exploring.

Young traders in a futuristic exchange hall as a regulator balances a stablecoin under cherry blossoms.

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.

The GENIUS Act, a U.S. bill introduced in 2025, tries to fix some of this by defining stablecoins as a new asset class. But it’s still in Congress. Meanwhile, the SEC’s Regulatory Flexibility Agenda for Spring 2025 lists dozens of proposed rules - but implementation is stuck waiting for FINRA to update its guidance after pulling its joint crypto statement in May 2025.

A girl in Brazil sees a glowing web connecting her startup to global crypto hubs at night.

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.