With the U.S. Senate's passage of the GENIUS Act and Washington headed towards a new age of crypto clarity, regulators globally are battling to catch up with their own frameworks—cementing what most are calling the "great convergence" of digital asset regulation.
This week alone, the UK's Financial Conduct Authority (FCA), the Bank of England, and Middle East regulators from Dubai to Bahrain have brought new proposals and concrete deadlines, all racing to keep pace with America's regulatory drive and the EU's MiCA regime.
Who's Moving, and When?
The U.S. may have grabbed the headlines with its federal stablecoin bill, but the global domino effect is evident. In the UK, the FCA has also stated that it will bring the most important crypto activity—trading, custody, and stablecoin issuance—within the regulated perimeter by 2026, abandoning its previous phased approach.
The Bank of England is bringing new capital and custody requirements for banks and payment institutions handling digital assets, consulting in Q3 2025 and final rules published in early 2026.
Across the Channel, the EU's MiCA regime is entirely in effect with the first of the delegated regulations on market abuse and reserve backing for stablecoins implemented in April. National supervisors are releasing supervisory statements and harmonising AML rules, and the European Banking Authority is also finalising standards on crypto custodianship.
Meanwhile, the Middle East is moving fast: Dubai’s VARA has announced stricter marketing and licensing standards for exchanges, and Bahrain has refreshed its crypto rules with an eye on cross-border cooperation and FATF compliance.
Not All Rulebooks Are Alike
Despite the rush for global standards, regulatory divergence remains a major challenge. The EU's MiCA regime, for example, demands 100% reserve backing of stablecoins and consistent licensing across member states, but others like Germany and France are taking even tougher requirements.
The UK is also going its own way, with the FCA planning bespoke rules for staking, custody, and market abuse, and excluding staking from the definition of "collective investment schemes" to permit regulated DeFi services.
In Asia, Japan is imposing additional capital requirements for crypto-exposed banks, Singapore and Hong Kong are focusing on licensing, staking, and stablecoin regimes.
The Middle East, mainly Dubai and Abu Dhabi, is focusing on cross-border data sharing and disclosure, and there is heavy pressure to implement FATF Travel Rule compliance.
Survival in a Multi-Jurisdictional Maze
For cryptocurrency exchanges, the new reality is one of rapid innovation—or becoming obsolete.
Industry leaders are placing large bets on compliance tech, from robotic know-your-customer/anti-money-laundering systems to real-time transaction surveillance and reporting software.
Others are hiring compliance attorneys and building cross-border compliance units to navigate the jigsaw puzzle of laws, or even considering strategic relocations to friendlier jurisdictions.
Some exchanges are piloting blockchain-based reporting systems and digital sandboxes to verify compliance with new requirements for data transparency and data governance, specifically as the OECD's Crypto-Asset Reporting Framework (CARF) is implemented in over 60 jurisdictions by 2027.
The global prudential standards of the Basel Committee, which become effective in 2026, will also require exchanges and banks to hold higher capital levels against exposures to crypto, once more enhancing the compliance burden.
Towards (or Away from) Global Standards?
Whereas the GENIUS Act and MiCA have set new heights, the global regulatory landscape remains patchwork, with geographies varying in their balance of innovation, consumer protection, and risk.
The next 12–18 months will be crucial as deadlines approach and local regulators lock in rulebooks. For the industry, success will depend on agility—adapting to local environments while building foundations for a world where cross-border collaboration and harmonized standards become non-negotiable, but unavoidable.
Bottom Line
As Washington takes the lead, regulators abroad are crafting their own crypto rulebooks.
For exchanges and investors, next year will be a test of flexibility, foresight, and the ability to thrive in a world where crypto regulation is at last becoming global.
