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Cryptocurrency Market Regulation: How the Rules Are Changing in Russia, the US, Europe, and Asia

0 Reading time: 12 min. Сoinspot

Regulation of the cryptocurrency market is rapidly becoming one of the main topics for financial authorities: countries are revising the status of digital assets, introducing licenses for services, discussing stablecoins, taxes, central bank digital currencies, and user protection.

Cryptocurrency Market Regulation: How the Rules Are Changing in Russia, the US, Europe, and Asia

In recent weeks, several countries have announced new steps for the crypto market. Some authorities are focusing on licensing and control, others are developing central bank digital currencies, while others maintain strict bans. Stablecoins, cross-border settlements, anti-money laundering efforts, and the question of who can legally provide crypto services are coming to the forefront.

Briefly, the approaches of different jurisdictions are as follows:

  • The US and the UK: aligning rules; focus on stablecoins, tokenized assets, and cross-border tokenization.
  • The European Union: strict market access; only crypto services with a European license will be able to operate.
  • China: ban on domestic crypto operations; special attention to the role of stablecoins in international settlements.
  • Kazakhstan and Belarus: development of regulated infrastructure; emphasis on legal platforms, mining, crypto banks, and operations with digital assets.
  • Russia: preparation of the digital ruble and a licensing model for crypto services through the Central Bank.
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Why Regulating Cryptocurrencies Is Difficult

It is difficult to fit cryptocurrencies into traditional financial rules for several reasons. They often operate on decentralized networks, transactions easily cross national borders, and market participants can use services from different jurisdictions. Additional complexity arises from the pseudonymity of transactions, rapid technological changes, and the lack of unified international standards.

This is why regulators are trying to address several tasks at once: protecting investors, increasing market transparency, combating fraud and money laundering, and determining which companies can legally provide crypto services.

The main goal of regulation is not to stop the development of the crypto market, but to find a balance between innovation, transparent rules, and user protection.

The US and the UK Align Rules for Stablecoins

The US and the UK have prepared a joint roadmap to bring their approaches to stablecoins, tokenized assets, and digital money closer together. On July 14, the finance ministries of both countries presented recommendations and announced plans to test cross-border tokenization scenarios over the next year.

There is a special focus on a multi-currency ecosystem. In it, stablecoins, tokenized bank deposits, digital forms of fiat money, and other types of settlement instruments should coexist. For businesses, this could simplify international payments, and for regulators, it could provide more control over how a banking transaction is conducted and who is responsible for it.

In the US, debates continue in parallel around the CLARITY Act—a bill on the structure of the crypto market. It is supported by the team of US President Donald Trump. For crypto companies, the document could open new opportunities in the American market, but the banking sector and several organizations are actively opposed.

South Korea Includes Cryptocurrencies in the State Asset System

The Ministry of Finance and Economy of South Korea announced the preparation of a law on key national assets. It is intended to update the system for managing state property and, for the first time, include cryptocurrencies in it.

At a State Council meeting on July 13, the agency confirmed its course for developing local blockchain technologies and the crypto market. Plans also include promoting the central bank digital currency and creating a comprehensive legal framework for cryptocurrencies and stablecoins. For the state, cryptocurrency is gradually becoming not only a technological topic but also an asset in accounting that requires tracking, valuation, and control.

Japan Equates Crypto Assets to Financial Products

Japan has adopted amendments to the Financial Instruments and Exchange Act. Now, cryptocurrencies are officially recognized as financial products. According to The Block, crypto assets are allocated to a separate category, comparable to stocks and bonds.

The new rules tighten bans on insider trading, introduce mandatory annual disclosure of some data by issuers, and strengthen penalties for illegal operations. The tax on cryptocurrency income is expected to decrease to about 20% instead of the current 55%. This innovation is expected to take effect in January 2028.

The European Union Tightens Market Access

The European Union has launched new MiCA provisions that prohibit crypto services without a European license from operating within the bloc. Experts estimate that up to 80% of platforms serving clients in Europe before July 1 may be forced to cease operations.

About 10 million users will be affected: they will have to look for new platforms. The largest exchange, Binance, was unable to obtain a license in the EU. After this, BNB suggested users move to decentralized, unregulated platforms.

For the market, this is an example of a tough regulatory scenario: licenses increase transparency and client protection but simultaneously reduce the choice of platforms and may force users to transfer assets to other services.

Another direction is the digital euro. The European Central Bank announced that 36 banks have been selected for the pilot project. Testing of the local central bank digital currency will begin in the second half of 2027 and will last 12 months.

The EU directly links the digital euro to the protection of financial sovereignty. European authorities fear that the widespread use of dollar stablecoins could weaken the bloc’s position in settlements. In this context, international standards are also important: the Financial Action Task Force influences how countries supervise crypto services, online payments, and cross-border transfers via the internet. Other financial centers, including Switzerland, are responding to similar challenges.

China Maintains Ban and Monitors Stablecoins

China treats stablecoins with caution. In June, Wang Xin, head of the research department at the People’s Bank of China, stated that stable tokens are playing an increasingly significant role in international settlements. According to him, regulators need to closely monitor their impact on the global financial system and cross-border payments.

Wang Xin also noted that restrictions and the politicization of international payments can complicate foreign trade. Therefore, countries need safer, more neutral, and more efficient payment systems.

At the same time, within China, cryptocurrency trading and related services are banned. In February, the People’s Bank of China and eight specialized agencies reaffirmed the ban on any cryptocurrency operations in the country. Trading, token issuance, intermediary services, crypto-financial products, mining, as well as the production and sale of mining equipment are all considered illegal.

Kazakhstan Bets on Regulated Infrastructure

Kazakhstan President Kassym-Jomart Tokayev signed a decree on measures to stimulate and develop the digital asset industry. Operations with crypto are already allowed in the country on platforms operating within the Astana International Financial Center.

The new decree also legalizes mining on associated gas and provides for the development of mechanisms for using digital assets and stablecoins in cross-border settlements. This could strengthen Kazakhstan’s role as a hub for regulated crypto infrastructure.

The authorities want to gently transition users from foreign platforms to local regulated services. To this end, conditions will be created for the voluntary disclosure of assets on foreign crypto exchanges and their transfer into the domestic circuit. Income from crypto operations through Kazakhstan’s regulated infrastructure is expected to be exempt from individual income tax.

Belarus Expands Rules for the Crypto Market

The cryptocurrency market in Belarus has been regulated for several years. Citizens can conduct operations through residents of the special High Technologies Park regime. At the same time, transactions for buying and selling assets through HTP residents, mining, and some other crypto operations are not taxed.

In early July, HTP announced plans to expand legislation on crypto operations. The republic wants to legalize airdrops and copy trading.

On July 18, a decree by Belarus President Alexander Lukashenko on crypto banks is set to take effect. These organizations will link cryptocurrency and fiat operations. They will be allowed to work with 26 approved cryptocurrencies and conduct 11 types of operations, including:

  • Crypto deposits.
  • Token issuance.
  • Loans.
  • Staking.
  • Transfers.
  • Exchange.
  • Cryptocurrency storage.

The Bank of Russia recently spoke about joint work with the National Bank of Belarus on regulating the crypto market. Regulators are cooperating to make it easier for market participants from both countries to work with digital assets in a legal framework.

Russia Prepares Digital Ruble and Licenses for Crypto Services

From September 1, Russia is set to launch the Bank of Russia’s digital ruble into wide circulation. According to the regulator’s plan, it will help eliminate fees for citizens on any transactions, reduce business tariffs to a minimum, and cut administrative costs for budget payments.

From the same date, cryptocurrency operations may enter the Russian legal field if the law on digital currencies and digital rights is adopted. The document is already prepared for a second reading in the State Duma, with discussion expected in the coming week. Key provisions include licensing crypto service providers, allowing different categories of investors after testing, and restrictions for unqualified participants.

The new model assumes that only providers licensed by the Central Bank will be able to legally provide crypto services:

  • Exchanges.
  • Exchangers.
  • Depositories.
  • Brokers.
  • Management companies.

Qualified and unqualified investors will be able to access operations after testing, but restrictions will be provided for the latter. Violation of regulatory requirements will take the service outside the legal framework and create risks for clients.

For users, this means a transition from the gray zone to clearer rules. An online digital currency exchange service, exchange, or broker will be able to operate legally only if regulatory requirements are met, including risk control, client protection, and anti-money laundering measures. It is around such conditions that the new regulation of the cryptocurrency market in key regions is now being built.

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