The Shift in Crypto Rulemaking
The battle over crypto rules has moved off blockchains and into politics, boardrooms, and closed-door meetings. Laws, not technology, will shape crypto’s future.
Globally, from Washington D.C. to Dubai, policymakers negotiate and debate crypto’s regulation. Industry players invest heavily in lobbying to influence outcomes.
Crypto Regulation in the U.S.
Washington remains the hub of crypto lobbying. The industry spent over $18.4 million on federal lobbying in early 2025, according to Sludge. The overall U.S. lobbying market grew 12% in the first half of 2025 to $2.5 billion.
Crypto lobbying surged by 1386% over seven years, rising from $2.7 million in 2017 to more than $40 million in 2023. Major contributors include Apollo Global Management, Coinbase, Ripple Labs, Binance.US, and Andreessen Horowitz.
In July 2025, President Donald Trump signed the GENIUS Act, the first U.S. law focused on stablecoins. It requires issuers to hold full reserves in cash or Treasury assets and report regularly.
The proposed CLARITY Act, passed by the House in July 2025, aims to clarify whether crypto tokens are securities or commodities. It now awaits Senate review with bipartisan support.
Also, in April 2025, the House approved the CBDC Anti-Surveillance State Act to block the Federal Reserve from issuing a digital dollar.
Europe’s Unified Approach
Europe’s digital industry spent around €151 million ($173 million) on lobbying in 2025, focusing on frameworks like MiCA. Key crypto exchanges such as Kraken, Coinbase, and Bitpanda are active in shaping EU policies.
MiCA, rolled out since 2024, creates a single regulatory framework across EU states. It sets licensing standards, reserve requirements for stablecoins, and consumer protections.
The European Commission plans to expand the power of the European Securities and Markets Authority (ESMA). This move would make ESMA an EU-wide regulator, overseeing stock exchanges, crypto platforms, and clearinghouses. A draft proposal is expected by the end of 2025.
Asia’s Practical Regulations
Asian governments focus on clear rules and compliance rather than lobbying. Singapore’s Monetary Authority (MAS) enforces strict licensing and anti-money laundering standards. Financial and customer fund protections are mandatory.
Japan, learning from the Mt. Gox collapse, treats crypto exchanges like financial institutions. In 2025, it classified crypto as a financial product to provide better investor protection.
Hong Kong requires crypto exchanges to be licensed since 2024. A stablecoin framework effective August 2025 mandates full reserves and bans unlicensed stablecoins for retail users.
South Korea passed the Virtual Asset User Protection Act in July 2024. It demands fund segregation, security measures, and suspicious activity reports from crypto exchanges.
India taxes crypto trades at 30% and applies a 1% transaction levy. It currently uses existing financial laws to regulate crypto, with broader legal frameworks under development.
China banned crypto trading and mining in 2021 but leads in central bank digital currency with the digital yuan, used widely since 2014 in several cities.
The Middle East’s Strategic Regulation
The Middle East uses crypto regulation to build reputation and influence. Dubai’s VARA and Abu Dhabi’s ADGM license major exchanges with clear rules.
Bahrain’s central bank licensed firms including Binance in 2024. Saudi Arabia is exploring CBDC projects with the UAE, taking a more cautious regulatory stance.
Global Regulation Challenges
The Financial Stability Board (FSB) warned in October 2025 that crypto rules differ widely worldwide. Only a few countries, like Bermuda and the Bahamas, have comprehensive rules for crypto lending and borrowing.
Regulatory gaps allow crypto firms to move to jurisdictions with lighter oversight, a practice called regulatory arbitrage. Binance has shifted bases multiple times, seeking friendlier laws.
FSB Secretary-General John Schindler noted that fragmented regulation might increase market risks, especially with rising leverage in poorly supervised areas.
Lobbying and Its Impact on Crypto Policy
In the U.S., lobbying strongly influences crypto rules. Firms spend millions to hire lobbyists, super PACs, and think tanks. The goal is to shape legislation and who controls regulatory policy.
Europe favors negotiation and policy consultations instead of aggressive lobbying. The MiCA framework reflects this more coordinated approach.
Asia relies less on lobbying, focusing on compliance and clear rules set by governments. Regions aim to regulate before allowing industry feedback.
Who Will Define Crypto’s Future?
The future of crypto regulation depends on global cooperation and trust. The U.S., Europe, Asia, and the Middle East all adopt different strategies.
Decisions made today will determine whether crypto integrates into the global financial system or remains marginal. Ultimately, trust in governance will shape crypto’s role worldwide.
