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The state of crypto regulation: What changed and what’s coming

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For anyone tracking crypto regulation, December 2024 already feels like a distant memory. Over the past year, the global policy landscape has shifted dramatically, with changes coming fast and showing no signs of slowing down.

As 2026 approaches, it is worth reviewing the key regulatory developments of 2025: global trends, regional shifts and what to watch for in the year ahead.

Five digital asset policy trends emerge

In its latest report, Chainalysis outlines five digital asset policy trends that have emerged this year.

Implementation progress and frictions as regulation is rolled out

In recent years, progress on comprehensive crypto regulation has been significant, though uneven. As frameworks moved from theory into practice in 2025, the implementation phase has proven just as complex, both politically and operationally, as the legislation itself.

The EU’s MiCA Regulation came fully into effect, but national interpretations and technical questions, especially around stablecoins and alignment with existing financial rules, remain.

Similar challenges emerged elsewhere: Singapore’s Digital Token Service Provider rules required rapid legal assessments, and global Travel Rule adoption continues to test firms and regulators on unhosted wallets, technical expertise and tool interoperability.

Given these challenges, uneven progress in implementation is expected. Regulatory frictions, compliance hurdles and the building of supervisory capacity are likely to remain key themes as frameworks continue to mature into 2026.

Stablecoins take center stage

The U.S. GENIUS Act has established a federal framework for stablecoin issuers, setting an international benchmark and accelerating global regulatory momentum. While only a few jurisdictions, including Japan, the EU and Hong Kong, have fully implemented stablecoin rules, others, including Korea and the UK, are advancing regulations. Policymakers are addressing a wide range of risks, from value stability and reserve adequacy to financial stability, capital flows and AML/CFT concerns.

Crypto regulation is already shaping market behavior. In Europe, usage has shifted toward MiCA-compliant stablecoins, while the U.S. restricts domestic use of foreign-issued stablecoins. Going forward, rules on unregulated stablecoins and mutual recognition will strongly influence their global reach.

Tokenization gains traction

2025 saw strong growth in tokenized financial and real-world assets, with money market funds reaching over $8 billion AUM and tokenized commodities like gold exceeding $3.5 billion. While still small relative to global markets, the trend is accelerating.

Policymakers have largely adopted a supportive, experiment-first approach. Singapore’s MAS moved from pilots to operational frameworks for tokenized funds.

In the United States, the SEC convened a public roundtable on tokenization in May, followed up in July with “Project Crypto” to review how securities regulati should apply on‑chain, and in December issued a no‑action letter allowing the Depository Trust Company (DTC) to allow for securities tokenization schemes, effectively bringing mainstream market plumbing into scope.

In the EU, tokenization is increasingly framed as a strategic pillar to improve its capital markets’ competitiveness: the DLT Pilot Regime is under review, with ESMA putting forward recommendations to make the scheme more attractive and better aligned with the goal of building a truly unified, digital‑ready capital market.

TradFi comes to crypto

In 2025, banks stepped into crypto through products, stablecoin issuance, custody and trading, supported by more accommodating regulation. In the U.S., the Federal Deposit Insurance Corporation (FDIC), Office of the Comptroller of the Currency (OCC) and Federal Reserve relaxed prior restrictions, while the Basel Committee signaled a review of prudential standards for crypto exposure. Guidance on AML risk from the NYDFS and Wolfsberg Group has further clarified expectations for banks engaging with crypto firms and stablecoin issuers.

In the EU, MiCA’s implementation has provided traditional financial institutions with a clearer, harmonized framework, boosting confidence in crypto and tokenization initiatives.

Financial crime and asset recovery in the spotlight

As crypto adoption grows, so do opportunities for criminal abuse, prompting policymakers and law enforcement to strengthen AML/CTF measures, asset recovery and public-private cooperation. FATF’s 2025 guidance highlights best practices for seizing, managing and returning cryptoassets, emphasizing blockchain analytics and partnerships.

Cyber fraud and scams remain a key focus. Following the UK’s fraud reimbursement rules, countries like Australia and Thailand have introduced obligations for gatekeepers to protect consumers, with penalties for non-compliance. Operationally, the U.S. has imposed sanctions, conducted major asset seizures, and launched a “Scam Center Strike Force,” while other jurisdictions have increased anti-scam actions. Further policy action is expected as addressing financial crime is crucial to building trust and supporting institutional adoption.

Crypto MENA

Middle East: Stablecoins, tokenization and institutional crypto markets

In the Middle East, 2025 was about building regulatory architecture for the region’s rapidly expanding and increasingly institutional crypto markets.

The UAE further consolidated its role as the regional hub: the Central Bank, Dubai’s VARA and Abu Dhabi’s FSRA continued to refine and operationalize mature licensing regimes for exchanges, custodians and other crypto service providers, tightened marketing, conduct and market‑integrity rules, and advanced stablecoin and payment‑token frameworks that deliberately prioritize payments, settlement and tokenized finance over purely speculative use cases.

These frameworks place strong emphasis on full reserve backing, clear redemption rights and robust governance, with growing interest in local‑currency and institutionally issued stablecoins as building blocks for regulated digital‑asset markets.

Elsewhere in the Gulf, Saudi Arabia and Qatar moved beyond experimentation toward clearer policy direction: Qatar introduced a more structured digital‑asset framework, while Saudi Arabia doubled down on tokenization, CBDC pilots and carefully scoped DeFi‑adjacent innovation, signalling a gradual expansion of the regulatory perimeter rather than blanket permissiveness.

At the regional level, MENAFATF reinforced FATF alignment and mutual‑evaluation readiness as 2025 priorities, underlining that VASPs across the Middle East now face rising AML/CFT expectations and that risk‑based, data‑driven supervision is quickly becoming the norm.

Read: Stablecoins usher in a new era in Saudi Arabia’s payments, trade and investment

Looking ahead

The 2026 policy calendar is already packed. In the U.S., market structure legislation remains on the agenda, though progress will depend on Congressional priorities. On taxation, the Crypto-Asset Reporting Framework will move forward, with several countries planning their first exchanges of information by 2027.

In 2026, jurisdictions that have not yet implemented stablecoin rules are expected to make progress. In the U.S., federal and state regulators must finalize GENIUS Act regulations by July, covering licensing and criteria for foreign issuers. Singapore will finalize draft legislation and guidance, while the UK is consulting on conduct and market rules, and the Bank of England is addressing prudential treatment for systemically important stablecoins.

As digital assets integrate into global financial infrastructure, regulators are stepping up scrutiny of systemic risks. Crypto has evolved from a niche tool to a vehicle for money laundering, sanctions evasion and other crimes, with FATF’s fifth-round mutual evaluations increasing pressure on regulators and industry to strengthen AML/CFT safeguards.

Operational and cyber risks are also rising. In 2025, over $3.4 billion in crypto was stolen, much linked to DPRK actors. Regulators are expected to make robust cyber risk management, including custody, key management and incident response, baseline supervisory expectations, reflecting the broader financial stability and national security implications of operational failures.

Crypto markets are global, but regulation remains largely national, creating rising licensing and compliance costs for international businesses. Even small differences in reserve, redemption and disclosure rules can challenge global stablecoin arrangements, while restrictions on cross-border exchange access can fragment liquidity and price discovery.

In 2026, the industry will be watching whether regulators make progress on reducing cross-border inconsistencies, improving information sharing and exploring passporting or mutual recognition frameworks.

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