Crypto Regulation Compared: How the US, EU and Asia Approach Crypto

Crypto regulation looks very different depending on where you live. The European Union has written one rulebook for the whole bloc. The United States regulates crypto through existing agencies and, since 2025, a federal stablecoin law. Asia ranges from licensing hubs like Singapore and Hong Kong to a full ban in mainland China. This guide compares the three in plain language and explains what a trader on SorooshX should check.

What every regulator cares about

Across countries the goals are similar: protect customers from fraud and misleading promotions, stop money laundering and sanctions evasion, keep stablecoins properly backed, and keep markets fair. The differences are in how they get there: detailed rules written in advance, or enforcement case by case.

Nearly all major markets now apply the travel rule from the Financial Action Task Force (FATF): when a regulated platform sends crypto, it must pass identifying details about the sender and receiver, just as banks do for wire transfers.

European Union: one rulebook (MiCA)

The Markets in Crypto-Assets Regulation (MiCA) entered into force in June 2023. Its stablecoin rules applied from June 2024, and its rules for crypto-asset service providers from December 2024.

• Exchanges, brokers and custodians need a licence; one licence works across all EU countries.
• Stablecoin issuers must hold reserves, publish white papers and honour redemptions.
• Market-abuse rules, like those for stocks, now cover crypto.

The result is clear rules and higher compliance costs. Some products have been withdrawn from EU users as a result.

United States: agencies first, laws catching up

The US has no single crypto law. Instead:

• The SEC decides whether a token is a security using the Howey "investment contract" test and has brought many enforcement cases.
• The CFTC treats bitcoin and similar assets as commodities and oversees crypto futures and derivatives.
• In 2025 Congress passed the GENIUS Act, the first federal framework for payment stablecoins.

Broader market-structure legislation has been debated for years. For traders, this means rules can shift with court rulings and agency leadership.

Asia: from licensing hubs to bans

• Japan: exchanges must register with the Financial Services Agency and keep customer assets separate.
• Singapore: the Monetary Authority of Singapore licenses digital payment token services and limits marketing to the public.
• Hong Kong: the Securities and Futures Commission licenses virtual asset trading platforms, with a regime that started in June 2023.
• South Korea: exchanges must partner with banks for real-name accounts.
• Mainland China: crypto trading services have been banned since 2021.

Crypto regulation at a glance

	EU	US	Asia (examples)
Approach	One rulebook	Agencies + new laws	Country by country
Stablecoins	MiCA reserve rules	Federal law (2025)	Licensing in HK, SG, JP
Exchange licence	Yes, EU-wide passport	State and federal rules	Yes in JP, SG, HK; banned in CN

What this means if you trade on SorooshX

SorooshX is a non-custodial, on-chain exchange: you trade from your own wallet and SorooshX never holds your funds. That does not put you outside the law. Rules on trading, leverage and taxes apply to you where you live. SorooshX is not available in the United States or in OFAC-sanctioned jurisdictions. Before trading, check your local rules, and read our overview of where crypto regulation is heading.

Market commentary, not investment advice. Leveraged products can lose more than your margin.