This introduction sets the scope: a concise, country-level overview of key changes for 2024–2025 and practical steps firms can take to meet new compliance expectations.
Global markets have grown rapidly—market cap sits near $2.24 trillion with roughly $91 billion traded daily, led by Bitcoin and Ethereum. Illicit addresses sent about $22.2 billion to platforms in 2023, which is driving tighter rules and stronger enforcement.
Read on to see how FATF standards like KYC, transaction monitoring, sanctions screening, and Travel Rule obligations are shaping national frameworks. This section previews how asset classification, licensing, AML/CTF, and data sharing differ across jurisdictions.
Who should read this: compliance leads, product managers, founders, and legal teams working with cryptocurrency and digital assets across borders. Practical takeaways include scope, documentation needs, and which regulators enforce each regime.
The surge in market value and daily turnover has pushed regulators into a faster policy cycle. The sector reached about $2.24 trillion in market cap in September 2024, with roughly $91 billion traded each day. That scale raises systemic risk questions for governments and supervisors.
High-profile hacks and illicit flows add urgency. Nearly $2 billion was stolen through exploits through July 2022, and illicit addresses sent $22.2 billion to platforms in 2023. Those losses push stronger anti‑laundering and consumer protections.
Driver | Data point | Regulatory impact | Industry action |
---|---|---|---|
Market scale | $2.24T market cap; $91B/day | Systemic risk oversight | Stronger disclosures; resilience plans |
Illicit flows & hacks | $22.2B to platforms; ~$2B stolen | AML/CTF tightening | Enhanced monitoring; sanctions screening |
Policy momentum | 2025 US legislative activity | Federal role clarification | Compliance-by-design; Travel Rule readiness |
For further context on market trends and demand shifts, see market projections and analysis. Companies must embed controls early to operate across borders and meet evolving standards.
International guidance from the FATF now anchors national approaches to licensing and anti‑money laundering for virtual asset activity.
FATF amended Recommendation 15 to require that virtual asset service providers face registration or licensing similar to banks. This change pushes countries to adopt a common minimum of oversight while leaving room for local variation in scope and enforcement.
VASPs include firms that exchange fiat and virtual tokens, swap one token for another, transfer value, custody or administer keys, and offer financial services tied to an issuer’s token sale.
The FATF Travel Rule sets a $1,000/€1,000 cross‑border threshold for full originator and beneficiary data. Below that level, lighter data requirements apply, and some jurisdictions set different domestic thresholds.
Measure | Value | Notes |
---|---|---|
Travel Rule threshold | $1,000 / €1,000 | Full data for cross‑border transfers |
Adopted | 65 of 94 | Passed Travel Rule laws (Apr 2024) |
In progress | 15 jurisdictions | Legal or technical rollout underway |
Key controls include identity verification, sanctions and watchlist checks, continuous transaction monitoring, and timely suspicious activity reporting. Firms must map business lines to VASP definitions and test counterparty risk when partners are unregulated.
Practical takeaway: adopt interoperable, privacy‑preserving messaging for Travel Rule compliance and keep governance documentation ready for regulator exams.
How a government labels a token—security, commodity, property, or legal tender—drives who regulates it and how taxes apply. These labels affect licensing, disclosure duties, and market oversight across borders.
Securities treatment brings prospectus requirements, investor protections, and ongoing reporting under securities agencies. Firms offering tokens that meet a securities test must follow offering rules and stay audit-ready.
Commodities designations shift focus to market integrity, anti-manipulation rules, and derivatives oversight. Exchanges and trading platforms face tighter market conduct standards when a token is treated as a commodity.
Property classification, as with the IRS rule in the United States, creates capital gains events on spending, trading, or exchanging a digital asset. That tax stance affects accounting and product flows for U.S. firms.
Legal tender status, seen in El Salvador’s Bitcoin move, changes merchant acceptance duties and can affect tax payment options and investor signals, though enforcement and uptake vary.
Classification | Primary focus | Key impact |
---|---|---|
Securities | Investor protection | Prospectus, reporting |
Commodities | Market integrity | Derivatives rules |
Property / Legal tender | Tax & payments | Capital gains, merchant rules |
Practical step: maintain a jurisdictional matrix mapping each token’s classification to applicable rules and operational controls. This reduces legal surprises and helps align product design with local demands.
2025 marked a turning point as Congress and regulators moved from ad hoc enforcement to codified roles for digital markets.
Agency roles tightened. The securities exchange commission (SEC) keeps oversight of tokens deemed securities. The CFTC gains clearer authority over commodity-style tokens under the CLARITY Act framework, which passed the House and awaits Senate action.
FinCEN continues to enforce Bank Secrecy Act obligations for firms offering virtual value transfer services. The IRS still treats cryptocurrencies as property for tax reporting on trades, payments, and disposals.
Authority | Primary focus | Practical impact |
---|---|---|
SEC | Disclosure & market conduct | Issuer filings; exams |
CFTC | Commodities oversight | Derivatives & trading rules |
FinCEN / IRS | AML & tax | Reporting, suspicious activity filings |
State licensing still matters. Money transmitter and virtual currency laws impose capital, surety, and program standards for services that operate across states.
Practical advice: maintain robust AML/CFT controls, document token classification, and prepare for multi‑agency exams as implementation timelines for the GENIUS and CLARITY measures unfold.
The European Union created a single framework that brings issuers, CASPs, trading platforms, and wallet providers under shared rules. MiCA (Regulation (EU) 2023/1114) sets authorization, governance, and disclosure duties across the single market. ESMA and national authorities oversee implementation.
Who is in scope: CASPs include exchanges, custody services, and market operators that offer asset services to EU clients. Issuers must publish transparent disclosures and meet investor protection standards ahead of listing.
December 2024 was a pivotal compliance date. Firms needed authorization pathways, updated governance, and investor-facing disclosures. ESMA technical standards guide phased steps.
Measure | MiCA | TFR |
---|---|---|
Scope | Issuers, CASPs, wallets, platforms | CASPs; transfers & unhosted wallets |
Core duty | Governance, transparency, consumer protection | Travel Rule data; EDD for third‑country peers |
Effective | Phased to Dec 2024 | From Dec 30, 2024 |
TFR aligns with FATF travel rules, requiring originator and beneficiary data for cross‑border transfers. Verification of ownership or control for unhosted wallets raises onboarding friction but strengthens traceability.
Practical steps: upgrade Travel Rule tooling, enhance EDD for third‑country counterparties, and map whether overseas operations trigger authorization or require local partnerships. These measures aim to protect consumers and stabilize markets while enabling legal certainty for exchanges and issuers.
The United Kingdom has tightened oversight of digital asset services while aiming to keep London attractive for innovation.
The Financial Conduct Authority oversees AML/CTF for in‑scope activities under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.
In scope are exchanging crypto for money, token‑to‑token swaps, and running ATMs. Firms must register with the conduct authority and pass fit‑and‑proper checks.
The UK implemented the Travel Rule, so originator and beneficiary data must travel with transfers between eligible service providers. Stablecoin oversight has also expanded under the Financial Services and Markets Act 2023, aligning payment tokens with prudential and conduct standards.
Operational readiness — Travel Rule tooling, complaint handling, and incident reporting — plus active board oversight, help firms demonstrate strong compliance and secure a competitive position in London’s market.
Switzerland combines clear token law with firm supervisory expectations. The 2020 DLT law enables tokenization of rights and claims and supports issuance and trading of DLT securities under recognized legal forms.
Financial intermediaries such as exchanges, wallet providers, and trading platforms fall under the Anti‑Money Laundering Act (AMLA) and AMLO‑FINMA. FINMA enforces customer due diligence, transaction monitoring, and Travel Rule alignment for obliged entities.
Key benefits include legal certainty for institutional custody and token projects, while Swiss supervision keeps strict anti‑money laundering checks in place. Cross‑border services must heed client‑targeting rules and licensing triggers.
Area | Swiss framework | Practical impact |
---|---|---|
Legal base | DLT law (2020) | Tokenization of securities; clear property rights |
AML oversight | AMLA / AMLO‑FINMA | CDD, monitoring, FINMA supervision |
Operational rules | FINMA guidance & Travel Rule | Data exchange; interoperability expectations |
Market effect | Permissive but structured | Innovation with clear compliance paths |
Under the Monetary and Financial Code and PACTE law, France requires registration for many digital asset activities. The Autorité des Marchés Financiers (AMF) oversees DASPs that offer custody, fiat-asset exchange, token-to-token trading, and platform operations.
Custody mandates focus on secure key controls, asset segregation, and clear recovery procedures to protect client holdings. Platform operators must run AML/CTF systems, market integrity controls, and transparent fee disclosures.
Advisory and portfolio services carry suitability duties, conflicts management, and strict recordkeeping. The EU Transfer of Funds Regulation enforces Travel Rule data flows and requires due diligence on third-country counterparties for cross-border transfers.
Area | AMF expectation | Practical action |
---|---|---|
Registration scope | Custody, exchanges, platforms, advisory | Prepare governance, contracts, and AML manuals |
Operational controls | Key management, cybersecurity, BCP | Deploy HSMs, incident playbooks, CISO reporting |
Market conduct | Transparency, fees, marketing scrutiny | Clear risk statements and ad reviews before launch |
Cross-border | TFR / Travel Rule alignment | Implement interoperable messaging and EDD |
Practical takeaway: map French registration to MiCA authorization plans, tighten consumer protection disclosures, and ready IT controls for AMF review. These steps help service providers scale into EU markets while keeping client safeguards front and center.
C regulators in the Netherlands and Estonia have stepped up supervision, demanding stronger governance, custody controls, and Travel Rule readiness for cross‑border transfers.
Netherlands (Wwft): De Nederlandsche Bank requires Wwft registration for firms that exchange fiat and virtual value and for custodian wallet providers. Registered firms must run AML programs, maintain governance records, and submit to ongoing supervision.
Estonia expanded its AML Act to cover wallet, exchange, and transfer services, plus offerings on behalf of issuers. The FIU enforces Travel Rule data flows, strong KYC, monitoring, and timely reporting.
Jurisdiction | Scope | Practical impact |
---|---|---|
Netherlands | Wwft registration; DNB supervision | AML programs, governance checks |
Estonia | Expanded AML Act; FIU oversight | Stronger KYC, reporting, enforcement |
Both | Travel Rule via TFR | Harmonize tooling and onboarding |
Practical takeaway: firms and service providers operating across the EU should align Travel Rule systems and governance to meet regional rules and reduce audit risk in each country.
Belgium requires firms that offer exchange services between fiat and digital assets, and custodian wallet providers, to register with the FSMA. The Law on the prevention of money laundering and terrorist financing sets AML/CTF duties for obliged entities.
Key obligations include customer due diligence, ongoing monitoring, and prompt suspicious transaction reporting. Firms must document AML programs and keep clear audit trails.
Cross‑border activities aimed at Belgian clients can trigger local registration under marketing or activity thresholds. Strong sanctions screening and geographic risk assessments aligned to EU high‑risk lists are essential.
Practical steps: maintain regular internal audits, staff training, incident response plans, and business continuity measures to show an effective compliance culture to the FSMA.
Area | FSMA expectation | Practical action |
---|---|---|
Authorization | Register exchanges & custodians | Submit governance, policies, and KYC manuals |
AML/CTF | CDD, monitoring, STRs | Deploy screening, transaction rules, and reporting workflows |
Operational resilience | Safeguard client assets | BCP, incident playbooks, regular audits |
Singapore combines openness to innovation with strict licensing and consumer rules for digital payment token services. Firms must map activities to the Payment Services Act and decide if they take possession of money or tokens—this decision determines licensing needs.
Under the Payment Services Act, MAS licenses Digital Payment Token (DPT) service providers that deal in or take possession of money or DPTs. Activities that only facilitate exchanges without custody are generally excluded from the “dealing” threshold.
Planned wallet rules expand the perimeter. Expect custody standards, segregation of client assets, and higher operational resilience requirements when wallets hold client keys or funds.
MAS requires AML/CTF controls, technology risk management, and clear disclosures in marketing to protect retail users. The Travel Rule is implemented; obliged entities must collect, store, and securely transmit originator and beneficiary data.
Enforcement has been active, so firms should maintain robust governance, audit trails, liquidity and segregation controls, and timely incident reporting aligned with MAS notices.
Singapore’s regime aims to foster innovation while keeping consumer protection and financial stability central.
Hong Kong has built a clear licensing route and supervisory playbook for virtual asset trading platforms. The Securities and Futures Commission (SFC) licenses platform operators and sets fit‑and‑proper tests, custody standards, and investor protections for retail access.
Licensing and custody: applicants must show governance, segregation of client assets, cold storage thresholds, and robust cybersecurity. The SFC expects transparent listing and delisting policies and product due diligence before retail admission.
AML/CFT and Travel Rule: licensed firms follow detailed anti‑money laundering guidance that requires customer due diligence, ongoing monitoring, suspicious transaction reporting, and Travel Rule data sharing with counterparties.
Duty | Practical impact | Supervisor |
---|---|---|
Licensing & fit tests | Formal approval; governance evidence | SFC |
AML/CFT & Travel Rule | CDD, monitoring, data sharing | SFC / HKMA |
Custody & market safety | Segregation, cold storage, audits | SFC |
Practical takeaway: firms and service providers should prepare for rigorous reporting, governance attestations, and IT audits. Meeting SFC and HKMA expectations creates a foundation for trusted exchanges and safe market access in Hong Kong.
Regulatory focus in Seoul and Tokyo centers on clear account links, platform transparency, and strong consumer protections. Both markets require formal registration and active supervision to keep flows traceable and users safe.
South Korea enforces the Act on the Reporting and Use of Specific Financial Transaction Information. VASPs must register with the FSC, run comprehensive AML controls, and partner with banks for real‑name accounts. Platforms publish proof‑of‑reserves and maintain fast incident reporting to limit losses.
Japan recognizes cryptocurrencies as a payment form under the Payment Services Act. Exchanges must register with the FSA, segregate client assets, and apply strict KYC and consumer safeguards. Both markets demand continuous monitoring and timely suspicious activity reports to deter money laundering.
Jurisdiction | Scope | Primary duty |
---|---|---|
South Korea | VASPs & services | Real‑name banking & AML |
Japan | Exchanges & custody | FSA registration & client segregation |
Both | Cross‑border listings | Due diligence on token provenance |
Practical takeaway: firms should align onboarding, custody, and monitoring to local expectations so payment recognition and consumer protection work together to preserve market integrity in each country.
The Americas show a mix of strict oversight and pragmatic response to market demand. Some markets provide clear licensing and investor access, while others balance grassroots use with regulatory caution.
Canada requires trading platforms to register with provincial securities regulators and FINTRAC. Firms that hold or move assets often qualify as money service businesses and must meet MSB rules.
FINTRAC duties include reporting, monitoring, and recordkeeping. Canadian markets also allow spot cryptocurrency ETFs on the TSX, which broaden investor access under securities oversight.
Brazil’s 2022 law tightened exchange registration with the CVM and raised AML controls for providers. The framework aims to improve market integrity and protect retail users.
The Central Bank of Brazil is developing a digital real to modernize payments and support financial stability. That project shapes how exchanges and wallet services connect to national rails.
Argentina shows strong grassroots adoption driven by remittances and inflation hedging. At the same time, tax rules and reporting obligations are still evolving, which creates operational uncertainty.
In 2023 the central bank restricted banks from offering crypto services, raising onboarding and custody challenges for firms. Market entrants should tailor strategies to licensing triggers, data localization, and consumer protections across the region.
The Gulf is emerging as a testbed for clear licensing and fast innovation. Dubai’s VARA, plus ADGM and DIFC free zones, give defined pathways for exchanges, custodians, and token issuers. These frameworks help service providers plan market entry and meet governance expectations.
Free zones require robust KYC, transaction monitoring, and Travel Rule readiness. Firms must show strong IT controls, substance, and sanctions compliance to win licenses and bank relationships.
Firms eyeing the Gulf should map VARA, ADGM, and DIFC paths and plan for varied bank risk appetites. For a regional risk analysis, see regional risk analysis.
A focused compliance checklist helps firms map KYC, monitoring, and Travel Rule duties to operations.
Minimum data: collect full name, residential address, and date of birth. Verify these against government‑issued ID and an independent address source.
Steps: identification, liveness proof, document verification, then address validation. Keep evidence and timestamps for audit trails.
For practical onboarding standards, review our KYC requirements and adapt to U.S. thresholds and risk profiles.
Design scenarios to spot anonymity, rapid in/out flows, and structuring around thresholds.
Collect and store originator and beneficiary data for transfers at or above the FATF $1,000/€1,000 threshold. Note that 65 of 94 jurisdictions had passed Travel Rule laws as of April 2024, with 15 in progress.
Establish secure transmission, validate the counterparty VASP status, and apply enhanced due diligence where third‑country rules are weak or incomplete.
Area | Core action | Goal |
---|---|---|
KYC | Verify ID, liveness, address | Accurate customer identity |
Monitoring | Detect complex/structuring patterns | Identify laundering risks |
Travel Rule | Collect/share originator/beneficiary data | Cross‑border traceability |
The policy landscape is converging toward clearer standards, even as local nuances remain significant. Global moves—from U.S. legislation and EU MiCA/TFR to FATF Travel Rule adoption—are creating predictable expectations for service providers and platforms dealing in crypto and cryptocurrency.
Compliance by design now unlocks market access. Firms should invest in KYC, monitoring, sanctions screening, and data‑security for assets and operations. Keep a dynamic jurisdictional matrix to track licensing triggers and Travel Rule duties.
Practical next steps: prioritize controls, document testing, and coordinate with banks and regulators. Governments and supervisors will refine rules across countries, so stay proactive to scale responsibly and reduce friction in cross‑border activity.
A Virtual Asset Service Provider (VASP) is an entity that conducts one or more services related to digital assets, including exchange, custody, transfer, or offering wallet services. Under FATF guidance, this covers centralized exchanges, custodians, broker‑dealers that handle digital assets, and certain wallet providers that control private keys. Many national authorities — for example, FinCEN in the United States, the Financial Conduct Authority in the UK, and the Monetary Authority of Singapore — apply similar scopes when licensing or supervising service providers.
The Travel Rule requires VASPs to collect and share required originator and beneficiary information for transfers that meet a set threshold. This promotes traceability of funds and helps detect illicit flows. Adoption varies: the EU’s Transfer of Funds Regulation (TFR) implements Travel Rule obligations in member states, while other jurisdictions have phased-in approaches. Technical interoperability and secure data exchange remain key compliance challenges.
Classification depends on the jurisdiction and the asset’s economic characteristics. The U.S. Securities and Exchange Commission (SEC) may treat certain tokens as securities under Howey-test principles, while the Commodity Futures Trading Commission (CFTC) viewsBitcoin and some tokens as commodities. Many countries classify tokens as property for tax purposes. Regulatory labels affect licensing, disclosure, custody rules, and market conduct obligations.
Multiple agencies share oversight. The Securities and Exchange Commission (SEC) regulates securities offerings and trading platforms for tokens deemed securities. The Commodity Futures Trading Commission (CFTC) oversees derivatives and may treat some tokens as commodities. FinCEN enforces anti‑money‑laundering (AML) rules and supervises money transmitter compliance, while the IRS handles tax reporting. Coordination among these bodies has increased in 2025 through legislative and administrative steps.
Yes. Many U.S. states enforce money transmitter laws or specialized digital asset licensing regimes. Companies often need state money transmitter or virtual currency licenses in addition to federal compliance. This creates a dual layer of obligations covering custody standards, capital requirements, reporting, and consumer protection.
Markets in Crypto‑Assets (MiCA) sets pan‑European rules for issuers, custody providers, trading platforms, and stablecoin governance. It creates transparency, consumer safeguards, and capital or governance requirements for certain token classes. Key implementation milestones progressed through 2024, and secondary technical standards continue to be phased in, including rules tied to travel rules via the Transfer of Funds Regulation.
The Transfer of Funds Regulation extends Travel Rule‑style obligations to transfers involving identifiable intermediaries. It also sets out expectations for verification of transactions with unhosted wallets — such as enhanced due diligence and risk‑based measures — to reduce anonymity risks in cross‑border transfers.
The FCA requires registration for crypto asset service providers, AML/CTF compliance, and adherence to consumer protection standards. Firms must implement KYC, transaction monitoring, sanctions screening, and governance measures. The UK has emphasized market integrity and clear disclosure to retail investors while phasing in Travel Rule implementation.
Switzerland combines permissive innovation policy with structured AML and DLT laws. The Swiss Financial Market Supervisory Authority (FINMA) applies existing financial legislation where appropriate and issues guidance for token classification, custody, and issuer obligations. Licensing and compliance focus on investor protection and anti‑money‑laundering controls.
France’s DASP (Digital Asset Service Provider) regime requires providers offering custody, exchange, brokerage, or advisory services to register or obtain an approval from Autorité des marchés financiers (AMF). Obligations include investor disclosure, custody standards, AML/KYC measures, and ongoing supervision for services in scope.
The Netherlands expanded Wwft registration and applied Travel Rule obligations, reinforcing customer due diligence and reporting duties. Estonia updated its AML Act to broaden VASP obligations, increase supervisory powers, and raise compliance expectations for local and passporting entities.
Belgium’s Financial Services and Markets Authority (FSMA) requires registration for trading platforms and custodian wallet providers. Firms must comply with AML measures, client asset protections, and operational resilience standards to operate in the Belgian market.
The Monetary Authority of Singapore (MAS) licenses activities under the Payment Services Act, covering dealing in digital payment tokens, exchange services, custodial services, and payment facilitation. Licenses vary by activity and risk profile; MAS also enforces AML/KYC, client segregation, and conduct rules, and has signaled further wallet‑specific requirements.
Hong Kong’s Securities and Futures Commission (SFC) and Hong Kong Monetary Authority (HKMA) set a licensing regime for virtual asset trading platforms. Authorized platforms must meet AML/CFT guidelines, custody standards, and Travel Rule data sharing, plus investor suitability and disclosure obligations.
South Korea enforces real‑name banking for fiat on‑ramps, rigorous reporting regimes, and platform-level obligations to prevent fraud and money laundering. Japan treats certain tokens under the Payment Services Act, requiring registration, strict custody standards, and strong consumer protections administered by the Financial Services Agency (FSA).
Canada’s FINTRAC requires exchange registration, AML/KYC programs, and reporting obligations; Canada also supports ETFs and regulated product frameworks. Brazil has strengthened exchange oversight and explored central bank digital currency (CBDC) initiatives. Argentina shows high retail adoption with evolving tax and reporting rules to address volatility and capital flows.
The UAE, through ADGM, DIFC, and VARA in Dubai, has led with specialized licensing frameworks and clear AML/KYC rules to attract businesses. Saudi Arabia has taken a more cautious stance, focusing on pilot programs and measured entry, while both regions emphasize regulatory clarity to balance innovation and risk.
Core compliance pillars include robust KYC (identity verification, liveness checks, proof of address), sanctions screening, transaction monitoring for complex or unusual patterns, and Travel Rule readiness for data collection and secure sharing. Red flags include inconsistent customer information, rapid layering of funds, use of mixing services, and frequent transfers to high‑risk jurisdictions.
Firms should implement systems to collect required originator and beneficiary details, integrate secure data exchange protocols, and establish counterpart due diligence processes. Testing interoperability with counterpart VASPs, encrypting data in transit, and updating policies to reflect jurisdictional thresholds will reduce operational and compliance risk.