Major cryptocurrency licensing regimes are not converging on a single global model; instead, they are evolving around jurisdiction-specific objectives. That is the central theme of “MiCA Decoded,” a 12-part weekly series on Bitcoin.com News co-authored by LegalBison’s co-founding and managing directors Aaron Glauberman, Viktor Juskin, and Sabir Alijev.
About the Series
MiCA Decoded examines how the European Union’s Markets in Crypto-Assets (MiCA) framework fits within a broader patchwork of global crypto regulation. The series, produced in collaboration with LegalBison, aims to clarify where licensing requirements align or diverge across key markets and what those differences mean for exchanges, wallet providers, token issuers, and other crypto-asset service providers.
Regulatory Divergence vs. Convergence
While industry observers often anticipate harmonization, the current trajectory suggests jurisdictions are prioritizing local policy goals:
- European Union (MiCA): A comprehensive framework that standardizes licensing and conduct rules for crypto-asset service providers (CASPs) and introduces categories for stablecoins (asset-referenced tokens and e-money tokens). Stablecoin provisions began applying in 2024, with broader CASP rules following from late 2024 across the bloc.
- United States: No single federal crypto statute; oversight is driven by existing securities and commodities laws, federal agencies, and state-level regimes (e.g., money transmitter licenses and New York’s BitLicense).
- United Kingdom: A risk-based approach led by the Financial Conduct Authority, including anti–money laundering registration and financial promotion rules, with phased expansion toward a fuller crypto regime.
- Singapore: Licensing under the Payment Services Act for digital payment token service providers, with a strong focus on AML/CFT controls and a specific framework for stablecoins.
- Dubai (UAE): A dedicated Virtual Assets Regulatory Authority (VARA) regime with activity-based permissions for virtual asset service providers.
- Hong Kong: A licensing framework under the Securities and Futures Commission for virtual asset trading platforms, centered on investor protection and market integrity.
These examples illustrate how policy aims—ranging from consumer protection and financial stability to innovation and market competitiveness—drive different licensing obligations, token classifications, and supervisory approaches.
Why It Matters
For crypto businesses and market participants, regulatory divergence raises practical challenges: mapping activities to licensing categories, managing cross-border compliance, interpreting token classifications, and adapting to evolving stablecoin and custody standards. MiCA Decoded seeks to provide structured, jurisdiction-by-jurisdiction analysis to help readers understand obligations, timelines, and the operational impacts of each framework.
What to Watch
- The rollout and enforcement of MiCA’s CASP and stablecoin requirements across EU member states.
- Ongoing rulemaking and enforcement trends in the U.S. amid the absence of a comprehensive federal law.
- Refinements to licensing scopes, marketing rules, and investor safeguards in the UK, Singapore, Dubai, and Hong Kong.
As regulatory models continue to evolve, the series underscores a key takeaway: firms should not assume global convergence but instead plan for jurisdiction-specific compliance strategies.