Global picture of cryptocurrency regulation: US, EU, Asia

The global picture of cryptocurrency regulation is very complex and diverse, influenced by different attitudes in different regions and countries, the pace of technological development and openness to cryptocurrencies.

Here we review how cryptocurrency regulation currently looks in three major regions of the world: the United States, the European Union and Asia.

The United States

In the United States, cryptocurrency regulation falls under the jurisdiction of a number of regulatory authorities, including the Financial Crimes Enforcement Network (FinCEN), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and the Internal Revenue Service (IRS).

In the United States, cryptocurrencies are currently classified as "commodities" and are subject to rules and regulations governing financial transactions, including anti-money laundering and anti-terrorist financing measures.

However, the SEC is actively investigating cryptocurrencies, particularly ICOs and cryptocurrency investment funds. ICOs and other token sales are often considered securities offerings and are therefore subject to the securities laws.

European Union

In the European Union, cryptocurrency regulation has traditionally been the responsibility of Member States, but there is growing interest in the subject at EU level.

The EU has addressed the regulation of cryptocurrencies in part through its 5th Directive on the Prevention of Money Laundering and Terrorist Financing (AMLD5), which sets out that companies dealing in cryptocurrencies must comply with anti-money laundering legislation.

The EU has also developed the Cryptocurrency Securities Act (MiCA), which provides a comprehensive framework for regulating cryptocurrencies across the EU, including stablecoins.


In Asia, the spectrum ranges from a liberal approach to strict regulation. China, for example, banned ICOs in 2017 and cryptocurrency exchanges in 2019. The Chinese central bank is currently working on its own digital currency, the digital yuan.

Other countries, such as Japan and South Korea, are relatively more accepting of cryptocurrencies.

In Japan, Bitcoin is officially a currency and cryptocurrency exchanges are strictly regulated. South Korea is one of the largest cryptocurrency markets in the world, but the government also actively regulates the sector, including tax rules for cryptocurrencies.

These trends illustrate that the global picture of cryptocurrency regulation is very diverse and constantly evolving. Regulators are constantly trying to keep pace with the evolution of technology and are adopting different strategies to regulate cryptocurrencies.