Global Regulators Accelerate Crypto Rules Following US Senate's GENIUS Act

The U.S. Senate's passage of the GENIUS Act has marked the beginning of a new era of clarity in crypto regulation, prompting global regulators to accelerate their own frameworks. This "great convergence" of digital asset regulation is evident as authorities worldwide race to keep pace with America's regulatory drive and the EU's MiCA regime.

In the UK, the Financial Conduct Authority (FCA) has announced plans to bring key crypto activities—trading, custody, and stablecoin issuance—within the regulated perimeter by 2026, abandoning its previous phased approach. The Bank of England is also introducing new capital and custody requirements for banks and payment institutions handling digital assets, with consultations set for Q3 2025 and final rules to be published in early 2026.

Across the Channel, the EU's MiCA regime is fully in effect, with the first delegated regulations on market abuse and reserve backing for stablecoins implemented in April. National supervisors are releasing supervisory statements and harmonizing AML rules, while the European Banking Authority is finalizing standards on crypto custodianship.

In the Middle East, regulators are moving swiftly. Dubai’s Virtual Asset Regulatory Authority (VARA) has announced stricter marketing and licensing standards for exchanges, while Bahrain has refreshed its crypto rules with a focus on cross-border cooperation and FATF compliance.

Despite the global push for standardization, regulatory divergence remains a significant challenge. The EU's MiCA regime, for instance, mandates 100% reserve backing for stablecoins and consistent licensing across member states, but countries like Germany and France are imposing even stricter requirements. The UK is also charting its own course, 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, while Singapore and Hong Kong are focusing on licensing, staking, and stablecoin regimes. The Middle East, particularly Dubai and Abu Dhabi, is prioritizing cross-border data sharing and disclosure, with heavy pressure to implement FATF Travel Rule compliance.

For cryptocurrency exchanges, the new regulatory landscape demands rapid innovation to avoid obsolescence. Industry leaders are investing heavily in compliance technology, including robotic know-your-customer/anti-money-laundering systems and real-time transaction surveillance and reporting software. Others are hiring compliance attorneys and building cross-border compliance units to navigate the complex web of laws, or even considering strategic relocations to more favorable jurisdictions.

Some exchanges are piloting blockchain-based reporting systems and digital sandboxes to ensure compliance with new requirements for data transparency and governance, particularly 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, effective in 2026, will also require exchanges and banks to hold higher capital levels against exposures to crypto, further increasing the compliance burden.

While the GENIUS Act and MiCA have set new benchmarks, the global regulatory landscape remains fragmented, with varying balances of innovation, consumer protection, and risk. The next 12–18 months will be pivotal as deadlines approach and local regulators finalize their rulebooks. For the industry, success will hinge on agility—adapting to local environments while laying the groundwork for a future where cross-border collaboration and harmonized standards are essential.

As Washington takes the lead, regulators worldwide are crafting their own crypto rulebooks. For exchanges and investors, the coming year will be a test of flexibility, foresight, and the ability to thrive in a world where crypto regulation is finally becoming global.