Jurisdiction(s):
United Kingdom

Global cryptoasset regulation: a comparative analysis of EU MiCA harmonisation, the UK’s innovation-led oversight, US regulation-by-enforcement, and prohibitionist regimes in China, India and beyond

Published on: 07 October 2025

Published by a LexisNexis Arbitration expert

Legal News

Article summary

As cryptoassets cement their status as a favoured conduit for cross-border investment and financial services, governments have embraced an array of regulatory strategies and approaches. A core attraction of cryptoassets is their capacity to support dealings outside conventional state scrutiny, letting participants transact with substantial anonymity via decentralised exchanges, privacy-focused coins, mixing services, and stealth addresses. However, these attributes equally heighten the hazards linked to cryptoassets, notably their propensity to facilitate unlawful conduct including money laundering, terrorist financing, and ransomware operations. This piece sets out a comparative review of the ways various jurisdictions are tackling the regulation and oversight of cryptoassets and exchanges and trading platforms to address such threats. Responses span agile, tech-responsive regulatory regimes intended to evolve in tandem with the technology and ongoing innovation, through to stricter policies seeking to exclude decentralised cryptoassets from national markets altogether. In April 2023, the EU enacted the Markets in Crypto-Assets Regulation (MiCA), establishing one of the earliest extensive and harmonised supranational rulebooks for cryptoassets at a supranational level ( Grinhaus and Vaziri, 2025, para 1.3.01 )...

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