Crypto Regulation Worldwide: The EU, the US, and Asia Compared

Why the regulation of crypto assets concerns owners too

A customer from Singapore wants to pay in stablecoins, a supplier from the US offers a discount for payment in crypto assets, and the bank asks whether the business holds crypto assets. In each of these cases the risk depends less on the technology than on the rules: who supervises the provider, what happens if it goes bankrupt, and what obligations does the business itself have?

This article therefore asks: How do the rules for crypto assets differ in the EU, the US, and Asia, and what does this mean for a business that deals with providers from different regions? To answer it, we first clarify the terms, then present the Brussels effect as the thinking model, go through the regions, weigh two readings, and finally derive a checklist.

What is regulated: tokens, providers, money laundering

Regulation of crypto assets applies at three points. First, to the tokens themselves, for example who may issue a stablecoin and what reserves it must hold. A stablecoin is a crypto asset whose value is pegged to a reference such as the euro or the dollar. Second, to crypto-asset service providers, meaning trading platforms, custodians, and exchange services, which need authorization and must keep customer funds separate. Third, to anti-money laundering, for example the obligation to send information on sender and recipient with transfers.

In a comparative legal analysis, Zhaksylykbayeva and Suleimenova (2026) examined eight countries, including the US, Singapore, China, and South Korea. They organize the rules by licensing, taxation, investor protection, and the fight against financial crime. These four fields are well suited for comparing regions because they apply regardless of the technology in question.

The thinking model: the Brussels effect

The legal scholar Anu Bradford has described how EU rules have an effect far beyond Europe. She calls this the Brussels effect: because the EU single market is large and wealthy, international companies adapt their products to European rules, and because it is expensive to maintain a separate version for each market, these rules then often apply worldwide. Well-known examples are data protection and product safety.

For crypto assets, the question is whether MiCA triggers such an effect or whether providers move to regions with looser rules. The counter-model is called regulatory arbitrage: companies settle where the rules are least burdensome, as Fintechs and supervision describes.

An analogy makes the difference tangible. A manufacturer of electrical appliances does not redesign its plugs for each country when a large market sets a standard; it adopts it. A retailer that sells only online, by contrast, can move its seat to the country that demands the least of it. Crypto providers have both options, and which one they choose determines how effective the rules are.

Rules for crypto assets take effect not where they are adopted but where providers have their customers.

The three regions at a glance

EU: one rulebook for 27 states

According to Annunziata (2025), with MiCA the EU created the first uniform rulebook for crypto markets in a union of several states. A provider authorized in one member state may offer services in all of them. E-money tokens, stablecoins tied to a currency, may only be issued by banks and e-money institutions, and holders have a right to redemption at par. Since the end of 2024, crypto service providers must also send information on sender and recipient with transfers. Details on stablecoins are described in Stablecoins and MiCA.

US: stablecoins regulated, the rest disputed

In the US it was long unclear whether a crypto asset counts as a security and thus falls under the securities regulator SEC, or as a commodity under the commodities regulator CFTC. The GENIUS Act of July 2025 created a federal law for stablecoins for the first time. A comprehensive market structure bill, the CLARITY Act, passed the Senate Banking Committee in May 2026 but failed to reach the necessary majority in the Senate in September 2026. According to an analysis by the law firm Orrick, its prospects in the current Congress have thus fallen considerably.

Asia: from bans to securities law

Japan licensed and supervised crypto exchanges early on. In July 2026, parliament decided to move crypto assets from payments law into the Financial Instruments and Exchange Act, with rules against insider trading. In a comparison of the EU, the UK, Singapore, and Japan, Hudima, Kamyshanskyi, Kulyk, and colleagues (2025) describe how Japan relies on strict reserve and custody rules for stablecoins, Singapore on flexibility, and that there is no consensus on the right approach. Hong Kong and Singapore combine licensing requirements with the ambition of being a financial center for crypto assets. On the Chinese mainland, trading and mining have been banned since 2021.

Two readings: a brake on innovation or a precondition for trust?

Bradford (2024) examined the first reading for the digital economy as a whole and rejects it. Europe's lag behind the US in technology companies, she argues, cannot be traced back to stricter rules. More important are an incomplete digital single market, fragmented capital markets, insolvency law that punishes failure harshly, and difficulties in attracting international talent. She speaks of a false choice between regulation and innovation.

I find this view convincing for crypto assets too, with one qualification. Whether MiCA slows innovation cannot yet be said after barely two years of full application. Polasik and co-authors (2025), cited in Stablecoins and MiCA, explicitly consider it too early. For businesses the question is secondary anyway. What matters to them is that clear rules make the risk in an individual transaction verifiable.

What this means for a business

From the Brussels effect and the comparison I derive a checklist that I call the three-level check. It helps before any cooperation with a crypto provider or before accepting a crypto payment from abroad.

1. Level 1: the provider

   Where is the provider based, and what authorization does it hold? In the EU, a crypto service provider has generally needed authorization under MiCA since July 2026. In Germany, BaFin is responsible and maintains a public company database.

2. Level 2: the token

   Who issues the token, and what rights do I have? An e-money token under MiCA gives a right to redemption at par; a stablecoin under US or Asian law may give different rights.

3. Level 3: my obligations

   What obligations apply to my business, for example regarding anti-money laundering checks, bookkeeping, and taxes? How the German Money Laundering Act affects small businesses is described in Money laundering obligations.

How crypto assets are held securely if a business holds them is covered in Holding crypto assets in a company. What happens when a provider without effective controls collapses is shown in FTX.

What follows beyond the individual case, and where the limits lie

The regulation of crypto assets follows a pattern that Fintechs and supervision describes with the Collingridge dilemma: rules only came once markets were large and the first collapses had happened. The major economic areas have now responded, but differently. The EU relies on one rulebook for all, the US on individual laws and regulators, Asia on a broad spectrum.

The limits of this assessment are clear. The overview is simplified and describes the situation in November 2026. In the US the situation can change with every new law, and in Japan the new rules will only take effect gradually. The comparative legal studies cited argue from legal texts, not from measurements of their effect.

Conclusion: what matters for businesses is the law behind the provider

To the guiding question: with MiCA, the EU has a single rulebook that has applied without transition periods since July 2026. Since 2025, the US has regulated stablecoins by federal law, while the rest of the market structure remains open. Asia ranges from a ban on the Chinese mainland to Japan, which places crypto assets under securities law. The Brussels effect explains why European rules can have an effect beyond the EU, and regulatory arbitrage explains why some providers move elsewhere nonetheless.

For a business, the conclusion is simpler than the comparison: work with providers whose authorization you can verify, and clarify which law applies to your money. This article is not investment or legal advice.

• Note the seat and authorization of every crypto provider you work with.
• Check the authorization in BaFin's company database or in the register of the competent EU supervisor.
• For stablecoins, clarify who issues them and what redemption right exists.
• Clarify with your tax adviser how crypto payments are booked and taxed.