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The European Union and U.S. lawmakers are racing to finalize sweeping regulatory frameworks for digital assets, with the EU pushing to centralize oversight under the European Securities and Markets Authority (ESMA) and the U.S. Senate nearing a bipartisan bill to clarify federal agency roles. These efforts reflect growing urgency to address market fragmentation, systemic risks, and the rapid evolution of crypto ecosystems.
The EU's proposal, expected to be unveiled in December, would grant ESMA direct authority over cross-border crypto exchanges, stock markets, and clearing houses, mirroring the U.S. Securities and Exchange Commission (SEC) model. This move aims to unify the bloc's fragmented regulatory landscape, where national agencies currently apply rules inconsistently. European Central Bank (ECB) President Christine Lagarde has been a vocal advocate, arguing that centralized supervision is essential to mitigate risks from large, cross-border firms and stabilize the capital markets union, a
. However, smaller member states like Luxembourg and Dublin have resisted the plan, warning it could disadvantage their financial hubs and concentrate power in larger economies, as .
The EU's initiative aligns with broader Capital Markets Union goals, which seek to reduce compliance costs for startups and enhance competitiveness against global rivals like the U.S. and the UK. ESMA Chair Verena Ross emphasized that centralized oversight would eliminate inefficiencies and strengthen investor trust, according to
. Meanwhile, France has raised concerns about enforcement gaps under the Markets in Crypto-Assets (MiCA) regulation, with regulators considering blocking cross-border "passporting" for crypto firms. The proposal could address these issues by standardizing MiCA enforcement under ESMA, Coinotag argues.In the U.S., the Senate Agriculture Committee is set to release a revised Crypto Market Structure Bill this week, defining agency jurisdictions and clarifying compliance rules for stablecoins, decentralized finance (DeFi), and staking. The bill assigns the Commodity Futures Trading Commission (CFTC) oversight of digital commodities and spot markets, while the SEC retains authority over securities. This framework aims to resolve years of ambiguity and provide a predictable legal environment for exchanges, stablecoin issuers, and DeFi projects, according to
. Bipartisan negotiations have tempered earlier tensions, with compromises on DeFi regulations and innovation protections.Globally, other nations are also advancing digital asset integration. Kyrgyzstan launched Bereket Bank, its first institution dedicated to virtual assets, as part of a strategy to attract foreign investment and modernize financial infrastructure, FinanceFeeds reported. The bank, proposed by Binance founder Changpeng Zhao, operates independently of government control and aims to channel profits into social programs. Meanwhile, partnerships like Bitget's collaboration with Fasanara Capital highlight the growing institutional interest in tokenized finance and liquidity solutions, according to
.The EU's and U.S.'s regulatory races underscore a critical juncture for digital assets. While the EU seeks to replicate Wall Street's centralized model to unify its markets, the U.S. is balancing innovation with oversight to avoid stifling growth. Both approaches face political and practical challenges, from resistance to centralization in the EU to partisan debates in the U.S. Yet, as markets evolve, clarity and enforceable frameworks will be key to fostering trust and global competitiveness.
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