regulationsresearchcrypto payment regulationanalysisCountry Comparison Tables — Payment Services & Crypto Payment Regulation
Country Comparison Tables — Payment Services & Crypto Payment Regulation
June 4, 2026
55 min read
These tables mirror the canonical per-jurisdiction fact matrix for all 19 jurisdictions studied. Cells marked NOT VERIFIED reflect facts the underlying regulation files do not confirm — they are honest gaps, not omissions. Where the matrix states a fact precisely (a specific statute, date, or figure), the table reproduces it exactly. The eight thematic tables map to the matrix fields t1–t8.
1. Licensing & Registration Framework
| Jurisdiction | Primary Legislation | Licence Type | Min. Capital | Regulator | Passporting | Notes |
|---|---|---|---|---|---|---|
| US | Bank Secrecy Act; state money transmission acts; 23 NYCRR Part 200; GENIUS Act 2025 | FinCEN MSB registration; state MTL (49 states + DC; Montana none); NY BitLicense; OCC trust/GENIUS federal charter | FinCEN none; state MTL ~$1M-$2M net worth; NY BitLicense $500K net capital + $500K bond | FinCEN; state regulators (NMLS); NYDFS; OCC | No federal passporting | State MTL 18-24+ months nationwide |
| UK | FSMA 2000/2023; Cryptoassets Regulations 2026 (in force 25 Oct 2027); PSRs 2017; EMRs 2011; MLRs 2017 | FCA MLR crypto registration (current); full FSMA authorisation (from Oct 2027); PI; EMI | MLR: no minimum; PI EUR 20K-125K; EMI EUR 350K; fees GBP 2K (MLR) | FCA; Bank of England (systemic stablecoins); HMT; PSR | No (lost EU passporting post-Brexit) | ~51 FCA-registered; 86% rejection rate |
| EU | Regulation (EU) 2023/1114 (MiCA), Title V; PSD2; EMD2 | MiCA CASP licence; EMI (EMD2); PI (PSD2, from 2 Mar 2026); ART/EMT issuer authorisation | CASP EUR 50K (Cl.1) / 125K (Cl.2) / 150K (Cl.3); EMI EUR 350K; PI EUR 20K-125K | Home member-state NCA (AMF, BaFin, CSSF, MFSA); EBA (significant issuers); ESMA register | Yes — EU/EEA-wide | ~199 CASPs across 23 countries (12 Apr 2026) |
| Japan | Payment Services Act (Act No. 59 of 2009, as amended); FIEA; APTCP | CAESP; EPIESP; Fund Transfer (Type I/II/III); ECISBO intermediary (from 1 Jun 2026) | CAESP JPY 10M + positive net assets; EPIESP JPY 10M; practical startup JPY 1B+ | JFSA; JVCEA (SRO) | No | Foreign operators must localise |
| Singapore | Payment Services Act 2019; FSMA 2022 Part 9 | PSA SPI / MPI (incl. DPT Service, forthcoming Stablecoin Issuance Service); FSMA DTSP | SPI S$100K; MPI S$250K (+ deposit S$100K-200K); DTSP S$250K; stablecoin issuer min S$1M or 50% opex | MAS | No (PSA is Singapore-only) | 36 MPI-for-DPT licences (Jan 2026) |
| Hong Kong | AMLO (Sch. 4); SFO; Stablecoins Ordinance; PSSVFO | SFC VATP licence; HKMA stablecoin issuer licence; SVF; upcoming VA dealer/custodian + adviser/manager | VATP HKD 5-10M paid-up + HKD 3M liquid + 12 months opex; stablecoin issuer HKD 25M paid-up + HKD 3M liquid | SFC; HKMA; FSTB | No | 13 VATPs licensed (June 2026) |
| Australia | AML/CTF Act 2006 + Amendment Act 2024; Corporations Amendment (Digital Assets Framework) Act 2026 | AUSTRAC DCE/VASP(DASP) registration; ASIC AFSL for DAPs and TCPs (commences 9 Apr 2027) | No AUSTRAC capital floor (legacy DCE ~AUD 100); AFSL DAP/TCP capital NOT VERIFIED (pending ASIC) | AUSTRAC; ASIC; RBA | No | VASP enrolment from 31 Mar 2026; AFSL deadline 30 Jun 2026 |
| India | PMLA 2002 (as amended 7 Mar 2023); FIU-IND AML/CFT VDA Guidelines (8 Jan 2026) | FIU-IND registration as 'reporting entity' (AML/CFT only); no dedicated licence | NOT VERIFIED (AML-based; no published capital threshold) | FIU-IND, Dept of Revenue, Ministry of Finance | No | 49 exchanges registered (45 domestic + 4 offshore) |
| South Korea | Specified Financial Information Act (as amended 2020); VAUPA (effective 19 Jul 2024); Digital Asset Basic Act (Phase 2, pending) | KoFIU VASP registration (ISMS + real-name bank account); Phase 2 authorisation regime pending | NOT VERIFIED (no general VASP capital figure); stablecoin issuer KRW 5bn-50bn across draft bills | KoFIU (registration); FSC (policy); FSS (inspection) | No | 5 exchanges with real-name bank accounts |
| Canada | PCMLTFA; RPAA; provincial securities acts / NI 31-103; Stablecoin Act (Bill C-15) | FINTRAC MSB/Foreign MSB; RPAA PSP registration; CSA dealer (EMD/Restricted/Investment via CIRO) | FINTRAC none; RPAA NOT VERIFIED; CSA CIRO-member dealers min C$50,000 | FINTRAC; Bank of Canada (RPAA, Stablecoin Act); CSA/CIRO; OSFI; CRA | No (provincial variation; Ontario outside passport) | FINTRAC MSB 2-8 weeks; 80+ MSB registrations revoked 2025-26 |
| Brazil | Law 14,478/2022; BCB Resolutions 519/520/521; Joint Resolution 14 / Resolution 517 | SPSAV (3 mutually exclusive categories: Intermediary, Custodian, Broker); banks/brokers may notify | R$10.8M-R$37.2M by scope (intermediation-only R$9.2M, above R$13M with custody) | Banco Central do Brasil (BCB); CVM (securities) | No | Resolutions effective 2 Feb 2026; apply/notify by 30 Oct 2026 |
| El Salvador | Digital Assets Issuance Law (LEAD, 2023) + Aug 2024 reforms; Bitcoin Law (Decree 57, amended Decree 199); Investment Bank Law (Aug 2025) | BSP and DASP (dual-track); plus Investment-Bank/PSAD track | BSP/DASP: $2,000; Investment Bank/PSAD: $50M share capital + 8% equity/RWA | CNAD (sole digital-asset authority since Aug 2024); BCR; SSF | No | BSP/DASP actual ~5-6 months |
| France | Loi PACTE (2019-486); Ordinance 2024-936; Decree 2025-169; MiCAR (EU 2023/1114); CMF | MiCAR CASP (from national PSAN/DASP); ACPR PI; EMI | CASP EUR 50K / 125K / 150K; PI EUR 20K-125K; EMI EUR 350K | AMF (primary, CASP); ACPR (AML/CFT, payment/e-money, EMT issuance) | Yes (EU/EEA via MiCAR) | 100+ DASPs registered; hard CASP deadline 1 Jul 2026 |
| Germany | MiCAR (EU 2023/1114); KMAG (27 Dec 2024); ZAG; KWG; GwG | MiCAR CASP; ZAG PI; ZAG EMI; (former KWG crypto custody §32) | CASP EUR 50K / 125K / 150K; ZAG PI EUR 20K-125K; EMI EUR 350K | BaFin (primary NCA); Deutsche Bundesbank (joint supervisory role) | Yes (EU/EEA via MiCAR) | ~53 authorised CASPs (May 2026); national transition 31 Dec 2025 |
| Switzerland | Banking Act (Art. 1b); FinIA (proposed 2025 amendments); FMIA; AMLA; DLT Act | FinTech licence (Art. 1b); Banking licence; DLT trading facility; (proposed FinIA payment/crypto institution) | FinTech CHF 300K (or 3% of public deposits); Banking CHF 10M | FINMA; SNB; SROs (VQF, PolyReg, SO-FIT) | No (not EU; FinIA aims for equivalence) | FinTech licence 4-6 months; 2 crypto banks (Sygnum, AMINA) |
| Liechtenstein | TVTG (Blockchain Act, 1 Jan 2020); EEA MiCA Implementation Act (1 Feb 2025); MiCAR (via EEA); SPG; ZDG; EGG | TVTG TT service provider (10 categories); MiCAR CASP (Art. 60 simplified / Art. 63 full); ZDG PI/EMI | TVTG CHF 50K-250K; MiCAR CASP EUR 50K/125K/150K; PI EUR 20K-125K; EMI EUR 350K | FMA | Yes (EEA passporting via MiCAR) | 29 TT service providers (incl. 5 banks) |
| UAE | Dubai Law No. 4 of 2022 (VARA); Federal Decree-Law No. 6 of 2025; PTSR (June 2024); Federal Decree-Law No. 32 of 2025 (CMA) | VARA (7 VA activities); ADGM FSRA Cat 1-4; DFSA Crypto Token; CBUAE PTSR; CMA federal VASP registration | VARA AED 100K base + AED 500K-1.5M activity; ADGM USD 10K (Cat 4) to USD 10M (Cat 1) | VARA (Dubai); ADGM FSRA; DFSA (DIFC); CBUAE (federal); CMA (from 1 Jan 2026) | No (but cross-emirate via CMA-VARA register) | VARA two-stage ~4-10 months |
| Bahrain | CBB Rulebook Volume 6 Crypto-Asset Module (CRA), issued Feb 2019 | CASP Categories 1-4 (CRA Module); separate PSP licence; SIO stablecoin licence | BHD 25K (Cat 1) to BHD 300K (Cat 4) (~$66K-$795K); paid-up in local banks | Central Bank of Bahrain (CBB) — single regulator | No | CBB target 60 calendar days |
| Nigeria | Investments and Securities Act 2025 (s.357(c)); SEC Digital Asset Rules (2022, amended 2024, effective June 2025) | VASP categories: DAX, Custodian, DAOP, DAPO, AVASP, RATOP; ARIP provisional route | Post-Circular 26-1 (16 Jan 2026): NGN 2bn (DAX/Custodian), NGN 1bn (DAOP/RATOP), NGN 500m (DAPO), NGN 300m (AVASP); deadline 30 Jun 2027 | SEC; CBN (bank-account guidelines) | No (NOT VERIFIED) | Only Busha & Quidax provisionally licensed |
2. Stablecoin Regulation
| Jurisdiction | Dedicated Stablecoin Framework | Reserve Requirements | Redemption Rights | Approved Issuers | Key Stablecoin Provisions |
|---|---|---|---|---|---|
| US | GENIUS Act (enacted 18 Jul 2025) — first federal payment-stablecoin statute | 1:1 in permitted assets (cash, T-bills <93 days, repos, govt MMFs); segregated; rehypothecation prohibited; no yield to holders | At par | Three issuer types: IDI subsidiaries; Federal Qualified PSIs (OCC); State Qualified PSIs (capped $10B) | Regulations due 18 Jul 2026; six of seven regulators issued proposed rules (Fed Board pending); effective earlier of 18 Jan 2027 or 120 days after final rules |
| UK | Dedicated qualifying-stablecoin framework under FSMA (NOT PSRs 2017); dual FCA + BoE — not yet in force | FCA: 1:1 in fiat/HQLA, segregated, independent verification. BoE systemic (Nov 2025): ~60% short-term sterling UK gov debt + 40% unremunerated BoE deposits | At par | None yet authorised | No operational regime as of June 2026; FCA Policy Statements due Summer 2026; BoE dropping individual holding limits (19 May 2026) for aggregate issuance caps |
| EU | MiCA EMT (Title IV) and ART (Title III); full application from 30 Dec 2024 | EMT: ≥30% in separate credit-institution accounts (60% for significant EMTs), remainder in low-risk liquid instruments; segregated, third-party custodians | At par, any time, free of charge (Art. 49) | Circle (USDC/EURC); SG-Forge (EURCV, ACPR EMI 1 Jul 2024) | Tether USDT and PayPal PYUSD non-compliant (delisted for EEA); non-EUR EMT usage caps: 1M tx / EUR 200M daily |
| Japan | Electronic Payment Instruments (EPI) framework under PSA (2022 amendments, effective 1 Jun 2023) | Fiat-denominated, redeemable at par on demand; trust-beneficiary issuers may invest in JGBs/US Treasuries (3-month) up to 50% | At par on demand | First EPIESP SBI VC Trade (USDC, Mar 2025); first yen issuer JPYC (registered 18 Aug 2025, launched 27 Oct 2025) | Only banks, trust companies/banks, registered fund transfer providers may issue; foreign trust-type stablecoins admitted via PSA from 1 Jun 2026 |
| Singapore | MAS Stablecoin Regulatory Framework (finalised 15 Aug 2023) — single-currency stablecoins (SCS); 'Stablecoin Issuance Service' forthcoming | 100% backing in HQLA in pegged currency; segregated with MAS-approved custodians; monthly checks + annual audit | At par within 5 business days | Paxos (USDG, full approval 1 Jul 2025); StraitsX (XSGD/XUSD, MPI Jul 2024) | SCS pegged to SGD or any G10 currency, issued in Singapore; framework not yet enacted as binding PSA rules (4 Jun 2026) |
| Hong Kong | Stablecoins Ordinance (effective 1 Aug 2025) — dedicated FRS licensing; HKMA is licensing authority | 100% reserve backing at all times (market value ≥ par); high-quality, high-liquidity, minimal-risk assets; segregated via trust | At par | First two issuer licences granted 10 Apr 2026 (Anchorpoint Financial; HSBC) after 77 expressions of interest | HKD 25M paid-up capital for issuers; ≥1/3 independent non-exec directors |
| Australia | No dedicated stablecoin licensing regime; captured by overlapping AUSTRAC/ASIC/RBA frameworks | NOT VERIFIED (no dedicated stablecoin reserve regime) | NOT VERIFIED | None named | Stablecoin as financial product may require AFSL/PDS; DAP regime brings stablecoin-trading platforms under AFSL (commences 9 Apr 2027) |
| India | No stablecoin regime | None | None | None | RBI argues CBDCs should be prioritised over stablecoins (Dec 2025 Financial Stability Report) |
| South Korea | No dedicated regime in force; central to pending Digital Asset Basic Act (Phase 2) | Proposed: 100%+ reserves in HQLA (bank deposits/government bonds), full redemption, customer fund segregation; yield on idle balances prohibited | Proposed: full redemption rights | None | Bill (8 Apr 2026) classifies stablecoins as payment instruments under FX Transactions Act; bank-vs-fintech issuer dispute unresolved; not enacted |
| Canada | Federal Stablecoin Act (Bill C-15, Royal Assent 26 Mar 2026) — first national framework; CSA interim VRCA track in parallel | 1:1 (assets ≥ par); reference currency + HQLA only; qualified custodians, segregated creditor-protected accounts; monthly reporting | At par (creditor-protected) | USDC remains principal CSA-Approved Stablecoin | Enacted but substantive provisions NOT YET IN FORCE — come into force by Governor-in-Council order (expected 2027) |
| Brazil | Resolution 521 classifies fiat-referenced stablecoin transactions as FX operations; ~90% of crypto volume is stablecoins | Full backing in fiat currency or public-debt securities; algorithmic stablecoins banned | Subject to FX regulations | NOT VERIFIED | Resolution 561 bans crypto/stablecoin settlement in regulated eFX rails (effective 1 Oct 2026), but licensed SPSAV/bank stablecoin rails under 521 remain permitted |
| El Salvador | Stablecoin issuance regulated by CNAD under LEAD; sole CNAD oversight since Aug 2024 | NOT VERIFIED (no specific reserve composition/backing rules detailed) | NOT VERIFIED | Issuers must obtain DASP licence (e.g., USDT) | In force under LEAD; 0% VAT on digital asset services for licensed entities |
| France | MiCAR EMT/ART (stablecoin provisions applicable since 30 Jun 2024); ACPR authorises EMTs, AMF oversees ARTs | EURCV backed 1:1 by bank deposits/HQLA in segregated custody; daily reserve reports published | At par (MiCA Art. 49) | SG-FORGE (EURCV — first MiCA-compliant EMT, ACPR EMI 1 Jul 2024) | EURCV ~EUR 105.9M in circulation (4 Jun 2026); USDCV (USD EMT) launched on MetaMask 15 Apr 2026, ~USD 12.6M |
| Germany | MiCAR EMT/ART (applicable since 30 Jun 2024); BaFin competent authority | Per MiCAR — reserves in secure low-risk assets (EMT ≥30%/60% credit-institution deposits) | At par any time (MiCA Art. 49) | No major domestic stablecoin issuer named | EMT-PSD2 dual authorisation: from 2 Mar 2026 CASPs whose EMT transfer/custody activities are payment services need PSD2 (ZAG) authorisation |
| Switzerland | FINMA stablecoin guidance (Guidance 06/2024, 26 Jul 2024); proposed Regulated Stablecoins category (Oct 2025 consultation) | Proposed: fully backed, segregated; reserves only as bank sight deposits or HQLA; FINMA maintains regulatory list | Proposed: at par | None (proposed regime) | PROPOSED/not enacted — Oct 2025 consultation closed 6 Feb 2026; current AMLA applies to issuers, full backing per Guidance 06/2024 |
| Liechtenstein | MiCAR EMT/ART applicable from 1 Feb 2025 (via EEA); TVTG Token Container Model for out-of-scope tokens | Per MiCAR reserve/own-funds requirements | At par (MiCA Art. 49) | No significant domestic issuance yet | EEA-licensed EMT/ART issuers can passport across EU/EEA |
| UAE | CBUAE PTSR (issued 7 Jun 2024, effective 6 Jul 2024); ADGM FRT Framework (effective 1 Jan 2026) | 100% reserves in liquid HQLA; ≥50% as cash in UAE banks; redeemable at par within one business day | At par within one business day | USDU (USD-backed, approved Jan 2026); DDSC (AED-backed; IHC/Sirius/FAB, final approval Feb 2026) | Dirham Payment Tokens need full CBUAE licence; Foreign Payment Tokens need registration; algorithmic stablecoins and privacy tokens banned |
| Bahrain | Dedicated SIO (Stablecoin Issuance & Offering) Module, Rulebook Vol 6, effective July 2025 | Strict 1:1; cash/AA- bank deposits, central bank debt, repos; segregated custodian accounts; annual audits | At par within 5 business days | AX Coin Bahrain B.S.C. (c) — first licence granted 3 Jun 2026 | Issuer must be Bahraini Joint Stock Company; yield-bearing permitted; algorithmic NOT VERIFIED whether prohibited |
| Nigeria | SEC stablecoin framework under ISA 2025, unveiled 24 Jul 2025 | cNGN: 100% backed by Naira reserves at licensed custodian banks; pegged 1:1 to NGN | NOT VERIFIED (verifiable reserves, regular audits required) | cNGN issued by Wrapped CBDC Limited under SEC oversight | cNGN (Africa's first regulated stablecoin) launched 3 Feb 2025; SEC framework formalised July 2025 |
3. Tax Treatment of Crypto Payments
| Jurisdiction | Classification | Capital Gains / Income Rate | VAT/GST on Crypto | Payment-Use Treatment | Notable Features |
|---|---|---|---|---|---|
| US | Property (IRS Notice 2014-21); every crypto payment is a taxable disposition; no de minimis | Short-term at ordinary rates up to 37%; long-term 0/15/20% | No federal sales tax; state sales tax on FMV of goods/services | Each payment triggers capital gain/loss (FMV minus basis) | Form 1099-DA broker reporting from 2025 (basis 2026); Form 8300 for $10,000+ receipts |
| UK | Cryptoassets legal but not legal tender; HMRC CRYPTO manual | CGT annual exempt amount GBP 3,000 (2025/26); 18% (basic) / 24% (higher/additional) | Crypto-to-fiat exchange VAT-exempt (Hedqvist, post-Brexit); goods/services VAT due normally | Using crypto to pay is a disposal at market value; crypto as payment for services subject to Income Tax + NICs | CARF reporting from 1 Jan 2026 (international exchange from 2027) |
| EU | Layered taxonomy (EMTs, ARTs, other); income tax not harmonised at EU level | Not harmonised; each member state applies own rules | VAT-exempt for crypto-to-fiat (CJEU Hedqvist C-264/14); payments treated as barter at market value | Merchant crypto receipts taxable at FMV at transaction time | DAC8 (Directive (EU) 2024/2850) reporting from 1 Jan 2026, first reports 2027 |
| Japan | Crypto assets are 'property value' (not legal tender); EPIs separately classified | Miscellaneous income at progressive 5-45% + 10% local (up to 55%); 20% flat rate expected from tax year 2027 (tied to FIEA) | Crypto transactions exempt from consumption tax (10%) since 1 Jul 2017 | No consumption tax; gains on disposal/use taxable as income | Further reduction to a 15% crypto CGT proposed (under legislative consideration, Mar 2026) |
| Singapore | Digital Payment Tokens (DPTs) under PSA; not legal tender | No capital gains tax; if trading is a business, corporate 17% / individual progressive up to 24% | Qualifying DPTs exempt from GST since 1 Jan 2020 (service fees taxable at 9% GST) | Crypto received as payment taxable as income; staking rewards >S$300/year taxable | No CGT is structural; staking-reward de minimis at S$300 |
| Hong Kong | Territorial tax system; no dedicated crypto tax legislation; not legal tender | No capital gains tax; trading profits generally not taxable unless trading as a business | No VAT/GST in Hong Kong | Entities trading crypto as a business subject to 16.5% profits tax on HK-sourced profits | Tax-free jurisdiction for investment gains |
| Australia | Property (not legal tender, not currency); potentially a financial product | CGT event on disposal; 50% CGT discount for assets held >12 months (individuals) | GST-free when crypto used as payment (since 1 Jul 2017); goods/services for crypto attract normal GST | Crypto received as payment/mining/staking/airdrops may be assessable income | 50% CGT discount after 12 months |
| India | Virtual Digital Assets (VDAs) for tax purposes only; not legal tender | 30% flat on VDA income (Section 115BBH; +4% cess/surcharge); no slab benefit, no loss offset, no carry-forward | NOT VERIFIED | Using crypto for payments triggers a 30% taxable 'transfer'; 1% TDS (Section 194S) above INR 50,000/year (INR 10,000 specified persons) | Most punitive regime among studied jurisdictions |
| South Korea | Virtual assets legal to trade/hold; not legal tender, currency, or financial instruments under current law | Planned crypto income tax repeatedly deferred (most recently to 2027); taxable as income once implemented | NOT VERIFIED | Crypto income tax deferred to 2027; no current crypto-gains tax in force | Deferred 2022 → 2023 → 2025 → 2027 |
| Canada | Commodity under Income Tax Act (CRA); not legal tender | 50% inclusion (2025); from 2026: 50% up to $250K, 66.67% above $250K; business income fully taxable | GST/HST applies to goods/services purchased with crypto | Using crypto is a taxable disposition based on ACB; receiving crypto as payment is income at FMV | T1135 if holdings exceed C$100,000; CARF reporting begins 2027 |
| Brazil | Private movable goods (bens móveis) / financial assets; not legal tender; not securities by default | Progressive 15%-22.5% with R$35,000 monthly exemption (in force); offshore 15% flat (Law 14,754/2023) | NOT VERIFIED; proposed IOF on crypto/stablecoin FX (0.38%-3.5%) deferred/NOT enacted | Crypto for purchases triggers capital-gains event; crypto as payment is ordinary income at BRL FMV; paid via DARF | Flat 17.5% under MP 1303/2025 rejected (251-193) and expired Oct 2025 — never in force |
| El Salvador | Bitcoin is a voluntary payment method (no longer legal tender since Jan 2025); other digital assets under LEAD | 0% capital gains for licensed entities; individuals generally not subject on Bitcoin profits | 0% VAT on digital asset services for licensed entities (RPSAD registry) | 0% transfer tax for licensed entities; tax payments must now be in USD only; fiat-service income taxed at 30% corporate rate | Foreign investors contributing 3+ BTC qualify for same exemptions |
| France | Crypto-assets legal; flat tax regime on capital gains | Flat tax (PFU) 31.4% effective 1 Jan 2026 (12.8% income + 18.6% social); EUR 305 annual exemption; progressive option available | VAT-exempt for crypto-to-fiat (CJEU Hedqvist); standard VAT on goods/services bought with crypto | Disposal to fiat and purchase of goods/services taxable; crypto-to-crypto NOT taxable | DAC8 reporting from 1 Jan 2026 |
| Germany | Crypto as private assets (Privatvermögen) — units of account/financial instruments; not legal tender | Tax-free if held >12 months; if <1 year taxable as other income (§23 EStG) where annual gains exceed EUR 1,000; income tax up to 45% + 5.5% solidarity | Crypto-to-fiat VAT-exempt (Hedqvist C-264/14); goods/services bought with crypto subject to normal VAT | Crypto as salary/payment taxable at market value on receipt; corporate gains as business income | Strong incentive for long-term holding (tax-free after 12 months) |
| Switzerland | Tokens classified by economic function (payment/utility/asset); stablecoins as payment tokens | Tax-free for private investors (non-professional); professionals taxed as income; wealth tax 0.3%-1%; income tax federal 0-11.5%, cantonal 0-~34.5% | Crypto used as means of payment VAT-exempt; exchange services VAT-exempt as financial services | Crypto as salary/for services taxable as income at market value; SFTA publishes year-end valuations | OECD CARF from 1 Jan 2026 |
| Liechtenstein | Crypto legal; favorable tax environment (TVTG Token Container Model) | Tax-free for private investors (speculative profits not taxable); professional traders taxed as business income | No VAT on cryptocurrency transactions | Crypto received as income taxable at market value; corporate tax 12.5% flat (min CHF 1,800) | No standalone wealth tax (movable assets notionally valued ~4% subject to income tax) |
| UAE | NOT VERIFIED (no crypto-payment tax treatment detailed in file) | NOT VERIFIED | NOT VERIFIED | NOT VERIFIED | Zero personal income tax is structural (general UAE feature) |
| Bahrain | NOT VERIFIED (no crypto-payment tax treatment detailed in file) | NOT VERIFIED | NOT VERIFIED | NOT VERIFIED | Zero personal income tax is structural (general Bahrain feature) |
| Nigeria | Crypto gains as chargeable gains (individuals); VASP profits as corporate income (effective from 2026) | Individuals: progressive personal income tax up to 25% (superseding prior flat 10% CGT) | NOT VERIFIED | Payments in virtual assets taxable; VASPs pay 30% corporate income tax and report transaction-level data to FIRS | Mining/staking/airdrops/payments-in-VA taxable |
4. AML/KYC & Travel Rule
| Jurisdiction | AML Framework | Travel Rule Status | Threshold | KYC / Unhosted Wallet Rules | FATF Alignment |
|---|---|---|---|---|---|
| US | BSA/AML program for all MSBs (31 CFR 1022.210); OFAC screening | Applies to CVC per FIN-2019-G001 (31 CFR 1010.410(f)) | $3,000 or more | SAR at $2,000+; CTR at $10,000+ | Partial (threshold above FATF recommendation) |
| UK | MLRs 2017 (Reg 14A); FCA risk-based supervision; SARs to NCA | MLRs 2022 amendments (SI 2022/860), effective 1 Sep 2023 | No minimum — applies to ALL transfers (stricter than FATF $1,000) | CDD at onboarding; EDD for high-risk/PEPs; 5-year retention; MLRO required | High (stricter than FATF minimum) |
| EU | TFR (EU 2023/1113, since 30 Dec 2024); AMLR (EU 2024/1624) from 10 Jul 2027; AMLA (1 Jul 2025, Frankfurt) | Yes — originator/beneficiary info on every transfer regardless of amount | No de minimis for CASP-to-CASP; EUR 1,000 for unhosted-wallet ownership verification | CDD for cash EUR 3,000+; EU cash limit EUR 10,000; self-hosted verification over EUR 1,000 | High |
| Japan | Act on Prevention of Transfer of Criminal Proceeds (APTCP); CAESPs/EPIESPs are 'specified business operators' | Implemented — JVCEA rules from Apr 2022; statutory guidelines from 30 Dec 2024 | No minimum threshold (Section 7); peer tables cite JPY 30,000 / JPY 100,000 | Identity verification at account opening; beneficial ownership at 25%+; records 7 years | High (early implementer since 2017) |
| Singapore | MAS Notice PSN02 (AML/CFT for DPT service); FATF Rec 16 aligned | Implemented under PSN02; tiered by transaction value | All transfers: name + account/reference; enhanced PII for transfers of S$1,500 or more | Self-hosted transfers not subject per se (EDD/ownership verification applies); records ≥5 years | High |
| Hong Kong | AMLO AML/CTF for licensed VATPs; FATF-aligned | In force — originator/beneficiary info on VA transfers, aligned with FATF Rec 16 | Aligned with FATF (no specific HK threshold cited) | CDD + beneficial ownership; record-keeping minimum 6 years | High |
| Australia | AUSTRAC AML/CTF Act 2006 (as amended 2024); FATF Recs 15 & 16 aligned | Enacted via Amendment Act 2024; deferred to 1 Jul 2026 (no exemption, domestic + cross-border) | Aligned with FATF standards | Risk-based CDD; thresholds via SMR/TTR/IFTI reporting | High |
| India | PMLA-based compliance via FIU-IND registration; FATF member | Tightened Travel Rule norms from Jan 2026; enhanced scrutiny on unhosted wallets and P2P | NOT VERIFIED (no specific threshold cited) | EDD mandatory for all users from Jan 2026 (anonymous trading no longer permitted); records 5 years | Partial (no comprehensive VASP framework, AML-only) |
| South Korea | AML/CTF under Specified Financial Information Act; KoFIU supervision | Implemented via amended Act; active since Mar 2022; data provided on request within 3 business days | Virtual asset transfers over KRW 1 million (~USD 842) | CDD/EDD; STR to KoFIU; real-name verified bank accounts for fiat trading | High |
| Canada | PCMLTFA via FINTRAC; FATF-aligned (R.10, R.15) | Mandatory for crypto transfers over C$1,000; sender/recipient data collection and transmission | C$1,000 | KYC for transactions C$1,000+; LCTR/LVCTR for C$10,000+; STR no threshold | High |
| Brazil | BCB Resolution 520 AML/CFT aligned with FATF; STRs to COAF; UN sanctions (Law 13,810/2019) | Phased: Phase 1 (Feb 2026-Feb 2027) identify + transmit when possible; Phase 2 (Feb 2027-Feb 2028) mandatory full exchange | NOT VERIFIED — no specific monetary threshold; identification required for all transfers | Full customer identification for all clients; self-hosted wallet owners identified | Progressing (phased approach) |
| El Salvador | FATF-aligned AML/KYC (R.10, R.15); KYT real-time monitoring mandatory; SARs to CNAD | NOT VERIFIED — Travel Rule not specifically detailed; KYT and KYC mandatory | NOT VERIFIED | No specific monetary KYC threshold; MLRO and compliance officer resident in El Salvador required | Aligned in principle; Travel Rule detail not verified |
| France | ACPR primary AML/CFT supervisor; TFR (EU 2023/1113); EBA Guidelines via AMF DOC-2025-02 (from 30 Dec 2025) | Yes — implemented via TFR | No de minimis threshold | Full KYC for all clients; EDD for high-risk relationships | High |
| Germany | GwG (Money Laundering Act); CASPs/PIs/EMIs are obliged entities; Funds Transfer Reg (2023/1113); KMAG BaFin AML powers | Yes — originator/beneficiary info on all crypto transfers; all CASPs from 30 Dec 2024 | No de minimis threshold — applies to all transfers | Identity verification for all relationships/transactions above EUR 1,000; EDD for high-risk/PEPs | High |
| Switzerland | AMLA for all financial intermediaries; non-FINMA-licensed must affiliate with FINMA-recognised SRO (VQF, PolyReg, SO-FIT) | Yes — FINMA Guidance 02/2019 (effective 1 Jan 2020) | CHF 1,000 (simplified DD threshold; full CDD above) | FINMA guidance on intermediaries; full CDD above CHF 1,000 | High |
| Liechtenstein | Due Diligence Act (SPG) for all TVTG TT service providers; TFR (via EEA); MiCAR AMLR via EEA | Yes — FATF Travel Rule via TFR (adopted into EEA law); FMA published specific guidance | Not specified in file (TFR-based) | CDD for all relationships; EDD for high-risk/PEPs; simplified DD for lower-risk; 5-year retention | High |
| UAE | Federal Decree-Law No. 20 of 2018 (AML) + Cabinet Decision No. 10 of 2019; CDD/EDD; FIU STR | VARA fully implemented FATF Travel Rule as of 19 Jun 2025 (Rulebook v2.0); CBUAE has its own VA Travel Rule | AED 3,500 (~USD 953) | Full originator/beneficiary info for transfers above AED 3,500 | High (UAE removed from FATF grey list Feb 2024) |
| Bahrain | CBB Rulebook Vol 6 AML/CFT Module; FATF-aligned; MENAFATF member, largely compliant | FATF Travel Rule compliance required | NOT VERIFIED | CDD/EDD required; specific threshold not stated | High (MENAFATF member) |
| Nigeria | ISA 2025 mandatory KYC/AML/CFT; NFIU STR reporting; CBN VASP AML/CFT pilot (from 2 Apr 2026) | FATF Travel Rule being implemented via CBN April 2026 supervisory pilot (cross-border tracking) | NOT VERIFIED | KYC/AML/CFT mandatory under ISA 2025 | Improving (exited FATF grey list Oct 2025) |
5. Consumer Protection
| Jurisdiction | Safeguarding / Asset Segregation | Cold Wallet Mandate | Disclosure & Retail Restrictions | Refund / Chargeback | Complaints / Dispute Resolution |
|---|---|---|---|---|---|
| US | GENIUS Act 1:1 segregated reserves, no rehypothecation, redemption rights for payment stablecoins | No federal mandate | GENIUS plain-language redemption + monthly reserve disclosure; Reg E not applicable to crypto | CFPB Reg E expansion to crypto withdrawn 15 May 2025; no federal error-resolution for non-stablecoin crypto | CFPB retains UDAAP authority; state AGs enforce (GENIUS preserves state consumer law) |
| UK | PSRs/EMRs safeguarding; PS25/12 new rules from 7 May 2026 (annual audit, daily reconciliations); no FSCS for crypto | Proposed | Financial promotions regime (PS23/6): clear/fair/not misleading, risk warnings; 24-hour cooling-off; incentives banned | PSRs 2017 unauthorised-tx refund (liability capped GBP 35) do NOT apply to crypto/stablecoin — noted gap | FOS for FCA-authorised firms only (not Warning List); FCA consulting on extending FOS to crypto |
| EU | EMT reserve segregation; MiCA Art. 49 at-par redemption; PSD2 safeguarding of client funds | No specific mandate | PSD2 transparency for EMT transfers from 2 Mar 2026; MiCA white-paper disclosure; SCA required | No traditional chargeback; PSD2 Art. 76 refund for unauthorised tx by next business day; max payer liability EUR 50 | MiCA Art. 71 complaints-handling free of charge; PSD2 error-resolution for EMT payments from 2 Mar 2026 |
| Japan | Among strictest globally — customer fiat held in trust (bank-separated); annual segregation audit; EPIESPs segregate user EPIs | ≥95% of customer crypto in cold wallets; hot-wallet portion fully backed by issuer's own cold-stored assets | CAESPs must provide adequate pre-transaction info; advertising restrictions; JVCEA risk disclosure | NOT VERIFIED (no specific refund/chargeback rule cited) | Fair complaint-resolution; mandatory participation in financial ADR |
| Singapore | Customer DPTs/moneys segregated and held in trust; separate addresses; daily reconciliation; operationally independent custody | ≥90% of customer DPTs in offline cold wallets | Guidelines PS-G03 (effective 4 Oct 2024): mandatory risk warnings; near-prohibition on public/mass-media ads; restricted influencer endorsements; suitability assessment | Credit/charge card purchases of DPTs blocked for retail (no specific chargeback rule) | MAS supervisory framework; retail lending and staking of customer tokens prohibited |
| Hong Kong | VATP client-asset protection; robust custody, hot/cold wallet segregation; insurance/compensation | Required (segregation) | SFC investor protection rules; fit-and-proper standards; risk disclosure | NOT VERIFIED (no crypto-specific refund/chargeback rule cited) | SFC investor protection framework; HKMA enforcement for stablecoin issuers |
| Australia | No AUSTRAC client-asset rule; custody safeguards arrive via Digital Assets Framework Act 2026 (standards pending) | NOT VERIFIED | ASIC: PDS + Design and Distribution Obligations for financial-product tokens; DAP/TCP operators must provide clear disclosure | NOT VERIFIED (no crypto-specific refund/chargeback rule) | DAP/TCP operators must offer dispute resolution; ASIC oversight |
| India | NOT VERIFIED (no dedicated client-money/asset-segregation rule in AML registration) | No mandate | NOT VERIFIED (no crypto-specific consumer-disclosure regime; tax + AML only) | NOT VERIFIED | NOT VERIFIED |
| South Korea | Customer deposits segregated and entrusted to a bank (interest to customers); mandatory insurance/reserves for hacking | ≥80% of customer virtual assets in cold wallets (monthly calc) | VAUPA user-protection framework; FSC/FSS oversight | Credit card purchases of crypto prohibited (no specific chargeback rule) | FSS inspection; FSC corrective orders, business suspension, administrative fines |
| Canada | CSA dealers: client asset segregation, qualified custodians, insurance; RPAA safeguarding; Stablecoin Act segregated creditor-protected reserves | NOT VERIFIED | RPAA operational/disclosure obligations; CSA dealer disclosure for securities-classified crypto | NOT VERIFIED (no specific crypto refund/chargeback regime detailed) | NOT VERIFIED (no specific crypto complaints mechanism detailed) |
| Brazil | Client assets segregated from firm holdings and cannot be used by the SPSAV (Resolution 520) | NOT VERIFIED | Resolution 520 operational/prudential standards; detailed monthly FX reporting; counterparties identified | NOT VERIFIED (no specific crypto refund/chargeback regime detailed) | NOT VERIFIED (no specific crypto complaints mechanism detailed) |
| El Salvador | Mandatory cybersecurity standards for storage/handling; KYT real-time monitoring | No mandate | NOT VERIFIED (no specific consumer disclosure regime detailed) | NOT VERIFIED | NOT VERIFIED |
| France | EURCV reserves in segregated custody; ACPR prudential safeguards; MiCA at-par redemption | No specific mandate | AMF conduct rules; MiCA white-paper; AMF DASP whitelist for consumer verification | MiCA/PSD2 framework (per EU); no France-specific chargeback regime stated | AMF consumer warnings; civil liability for unregistered providers; MiCA complaints handling |
| Germany | EMI safeguarding of client funds (segregation or insurance); CASP own funds/insurance; MiCA at-par redemption | No specific mandate | MiCAR white-paper (20 working days advance); BaFin name-and-warn lists; MiCA conduct rules | Per MiCA/PSD2 (PSD2 refund rights for EMT payments from 2 Mar 2026); no Germany-specific chargeback regime | MiCA complaints handling; BaFin supervisory channels |
| Switzerland | FinTech licence: no privileged bankruptcy status (no deposit insurance); DLT Act bankruptcy segregation for custodied crypto | No specific mandate | FINMA stablecoin guidance; proposed mandatory whitepaper for Regulated Stablecoins | Not specified in file | FINMA supervisory channels; 2025 Annual Report reframes crypto stance toward consumer protection |
| Liechtenstein | Per MiCAR/TVTG; FMA client-protection oversight; strong banking-access support (Bank Frick) | No specific mandate | MiCAR disclosure/white paper; FMA public register of TT service providers | Per MiCA/EEA framework; no Liechtenstein-specific chargeback regime stated | FMA supervisory channels; MiCA complaints handling |
| UAE | Payment token reserves 100% safeguarded (≥50% cash in UAE banks); USDU reserves 1:1 in safeguarded onshore accounts | NOT VERIFIED | NOT VERIFIED (specific consumer disclosure provisions not detailed) | Payment tokens redeemable at par within one business day | NOT VERIFIED |
| Bahrain | Stablecoin reserves segregated with authorised custodians; PII insurance required for CASPs | NOT VERIFIED | Whitepaper required for stablecoin issuers (purpose, structure, supply, reserves) | Stablecoin holders have direct legal right to redeem at par within 5 business days | NOT VERIFIED |
| Nigeria | Asset segregation standards; operational resilience requirements for VASPs | NOT VERIFIED | NOT VERIFIED (SEC digital asset rules; specific consumer disclosure provisions not detailed) | NOT VERIFIED | Investments and Securities Tribunal for dispute resolution under ISA 2025 |
6. Enforcement Actions & Penalties
| Jurisdiction | Notable Enforcement Actions | Maximum Penalties | Enforcement Posture |
|---|---|---|---|
| US | Paxful $3.5M (Dec 2025); BTC-e $110M; Block/Cash App $40M NYDFS + $80M multi-state; Samourai Wallet founders 4-5 yrs; Roman Storm convicted on 18 U.S.C. 1960 unlicensed money transmitting (Aug 2025); jury deadlocked on ML/sanctions counts; DOJ seeks Oct 2026 retrial | 18 U.S.C. 1960: up to 5 years imprisonment + fines; BTC-e $110M largest CMP cited | Fragmented multi-agency (FinCEN CMPs, state regulators, DOJ, SEC/CFTC) |
| UK | FCA v HTX (filed 21 Oct 2025) — first offshore crypto financial-promotion enforcement (pre-trial); ~317 of 368 registrations refused/withdrawn; ~20 firms banned (2024); 1,600+ consumer alerts (2024) | Not specified as a single figure; criminal prosecution (s.49 MLRs); injunctive/civil relief (FSMA s.21) | Assertive (Warning List, website/app removals, registration refusal) |
| EU | USDT delisting (H2 2024-Q1 2025); PYUSD suspension (Jan 2025); France (AMF) EUR 62M fine; 17 Apr 2026 ESMA wind-down statement | Up to EUR 5,000,000 (natural person) or 12.5% of annual turnover (legal entity); >EUR 540M aggregate since enforcement began (Nov 2025); AMLA up to 10% turnover or EUR 10M | Active (post-MiCA enforcement ramping up) |
| Japan | Coincheck (2018, JPY 58bn NEM theft); FTX Japan (2022); DMM Bitcoin (2024, ~USD 305M theft, closed); 5 foreign exchanges warned (2024), apps removed (Feb 2025) | Unregistered operation: up to 3 years imprisonment and/or JPY 3M fine (FIEA bill, Cabinet 10 Apr 2026, would raise to 10 years / JPY 10M) | Active (graduated; crisis-responsive) |
| Singapore | Three Arrows Capital (reprimanded); Hodlnaut (CAD investigation, interim judicial management); Terraform Labs/Do Kwon (no SG licence; Do Kwon extradited to US) | Operating without licence: up to S$250,000 (+ up to S$25,000/day for continuing offences) and imprisonment; June 2025 reiteration of up to S$200,000 + imprisonment | Active (tightening post-2022 failures) |
| Hong Kong | HKMA powers: corrective actions, external advisers, statutory manager, licence revocation/suspension; several VATP applications withdrawn/rejected | Licence suspension up to 6 months; revocation; statutory manager appointment (no single max fine cited) | Active (SFC + HKMA dual enforcement) |
| Australia | ASIC v Web3/Block Earner (High Court heard 12 Mar 2026, judgment reserved); ASIC v Finder Wallet (appeal dismissed); ASIC v Bit Trade/Kraken (ongoing); AUSTRAC suspended/refused nine providers early 2025 | Unlicensed conduct: civil and criminal penalties incl. fines up to 10% of annual turnover | Developing (ASIC + AUSTRAC) |
| India | Oct 2025: FIU-IND non-compliance notices to 25 offshore VDA providers under Section 13 PMLA (apps/URLs blocked); Income Tax Act 2025 Section 446 penalties from 1 Apr 2026 | Section 446: Rs 200/day for non-furnishing; Rs 50,000 for inaccurate info or due-diligence failure; ~INR 2.8bn FY2024-25 penalties (industry-reported, NOT VERIFIED) | Moderate (FIU + CBDT tax enforcement) |
| South Korea | First VAUPA market manipulation case brought within months of implementation; VASP owners without authorised bank account face fines or up to 5 years imprisonment | Unfair gains <KRW 500M: min 1 yr or 3-5x gains; KRW 500M-5bn: min 3 yrs; KRW 5bn+: 5 years to life imprisonment | Developing (VAUPA enforcement regime new) |
| Canada | Cryptomus/Xeltox C$176.9M (Oct 2025, FINTRAC record, 2,593 violations); KuCoin C$14M (Sept 2024); 80+ MSB registrations revoked 2025-26 (51 in single day 24 Mar 2026) | Post-C-12 per-violation AMPs: C$40K (minor) / C$4M (serious) / C$20M (very serious); cumulative cap greater of C$20M-C$30M or 3% gross global revenue; criminal up to C$5M / 5 years | Active (multi-agency; intensified 2025-26) |
| Brazil | NOT VERIFIED — specific BCB enforcement actions/amounts pre-2026 limited; Resolution 561 directly affects firms like Nomad and Braza Bank | Tax non-compliance fines BRL 1,500 to 3% of undeclared amount; unregistered operators face mandatory cessation after 30 Oct 2026 | Emerging (framework newly operational Feb 2026) |
| El Salvador | NOT VERIFIED — specific CNAD enforcement actions not verified in public reporting as of June 2026; framework relatively new | Fines on legal entities up to 1,200 minimum wages; natural persons up to 500 minimum wages; licence suspension/revocation | Low (untested) |
| France | AMF first DASP registration withdrawal Sept 2022 (AML/CFT); EUR 62M fine (largest single MiCA penalty); Law 2025-532 privacy-coin restrictions | Unauthorised operation after 1 Jul 2026: up to 2 years' imprisonment and EUR 30,000 fine (CMF); EUR 62M largest single AMF/MiCA fine | Active |
| Germany | DAO1 warning (2025, unauthorised AI-bot crypto trading); 2025 court upheld BaFin warnings/cease-and-desist against crypto issuer for MiCAR offering/prospectus violations | Per MiCA Art. 111 (EU-level) — up to EUR 5M / 12.5% turnover; no Germany-specific maximum figure stated | Conservative-Active (name-and-warn) |
| Switzerland | FlowBank declared bankrupt by FINMA (2024); one FinTech licence revoked; 2024: 235 unauthorized-deposit + 232 unauthorized-intermediation investigations; FINMA Guidance 01/2026 on custody risks | Not specified in file; FINMA 2025 Annual Report — 55 enforcement proceedings concluded (vs 38 in 2024), ~450 investigations, 300+ warning-list entries | Moderate (enforcement rose sharply in 2025) |
| Liechtenstein | FMA has not published significant enforcement actions against crypto firms to date (small registrant base, collaborative culture) | Not specified in file | Moderate (proportionate, dialogue-oriented) |
| UAE | Binance first global ADGM licence; Crypto.com (Foris DAX ME) first UAE VASP SVF licence (May 2026) | CBUAE: administrative fines up to AED 1 billion (~USD 272m); unlicensed AED 50,000-500m and/or imprisonment; VARA Travel Rule up to AED 100m or 15% of annual income | Developing |
| Bahrain | Rain Financial 2024 USD 16m loss (DOJ-attributed Lazarus Group social-engineering hack) | NOT VERIFIED (specific monetary penalty caps not stated in file) | Developing |
| Nigeria | Feb 2021 CBN banking ban (reversed Dec 2023); ISA 2025 stricter penalties for Ponzi/fraudulent offerings | Tax non-reporting: NGN 10,000,000 first month + NGN 1,000,000 each subsequent month, plus possible SEC licence suspension/revocation | Emerging (post-reversal) |
7. Cross-Border & Settlement Finality
| Jurisdiction | Cross-Border Model | Settlement Finality Framework | Blockchain System Designated? | CBDC Status |
|---|---|---|---|---|
| US | CFPB Remittance Transfer Rule (Reg E Subpart B) for providers >500 transfers/yr; FinCEN BSA; correspondent-banking friction | No federal finality statute; UCC Article 12 adopted in 34 jurisdictions; qualifying-purchaser take-free rule | No | No US retail CBDC; GENIUS Act permits stablecoin issuers to access Fedwire, FedNow, National Settlement Service |
| UK | Post-Brexit — UK PIs/EMIs lost EU/EEA passporting (since 1 Jan 2021); expansive territorial scope; restrictive Overseas Persons Exemption | FSMA 2023 digital settlement assets (DSAs); Settlement Finality Regulations 1999; Digital Securities Sandbox (Gate 2: contractual finality; stablecoins/e-money excluded as settlement assets) | No | BoE ambition for atomic settlement in sterling central-bank money via RTGS (targeted 2028); digital pound under consultation |
| EU | MiCA passporting (Art. 59(7), 65) EU/EEA-wide; PSD2 passporting; SEPA access for licensed PIs/EMIs; non-EUR EMT usage caps apply | SFD 98/26/EC applies only to designated systems; NO blockchain payment system designated as of March 2026; DLT Pilot Regime (EU 2022/858) permits CBM/CoBM/EMT settlement in sandbox | No | ECB digital euro in preparation; pilot Q3 2026/late 2027, potential first issuance ~2029; positioned as public alternative to stablecoins |
| Japan | FEFTA requires residents to report cross-border crypto payments/receipts exceeding JPY 1 million; no foreign-licence recognition; Bybit exiting Japan in 2026 | No specific blockchain settlement-finality legislation; legally unclear under Civil Code; Act on Book-Entry Transfer covers tokenised securities only; EPIs gain contractual finality via redeem-at-par | No | Not launched |
| Singapore | No passporting (PSA is Singapore-only); separate licences per ASEAN jurisdiction; Project Nexus connecting PayNow/FAST expected live 2026 | Payment and Settlement Systems (Finality and Netting) Act 2002 — designates SIPS/SWIPS (MEPS+, CLS, FAST); technology-neutral but no blockchain/DPT system designated (early 2026) | No | Wholesale CBDC focus (Project Ubin/Ubin+); live wholesale-CBDC trial on SGD Test Network (Nov 2025) |
| Hong Kong | VATPs may integrate order books with global affiliate platforms (SFC 3 Nov 2025 circulars); active marketing to HK investors triggers licensing | NOT VERIFIED (no crypto-specific settlement-finality statute cited) | No | e-HKD Pilot — Phase 2 report Oct 2025; HKMA prioritising wholesale e-HKD; preparatory work targeted H1 2026 |
| Australia | Domestic registration only — no EU-style passport; crypto payment facilitators now within RBA payment-system perimeter (Payments System Modernisation Act 2025) | NOT VERIFIED (no crypto-specific settlement-finality statute cited) | No | CFR/RBA examining; no retail CBDC commitment |
| India | Domestic registration only — no passport; offshore platforms serving Indian users must register or face Section 13 PMLA notices and URL/app blocking | NOT VERIFIED (no crypto settlement-finality statute cited) | No | Digital rupee (e-Rupee) pilot ~10M users, 16 banks; circulation INR 771.7 crore (down ~24% YoY as of 31 Mar 2026); BRICS cross-border CBDC pilots |
| South Korea | Domestic VASPs must use won-denominated trading pairs; pending stablecoin classification as FX-payment instrument under FX Transactions Act | NOT VERIFIED (no crypto-specific settlement-finality statute cited) | No | Bank of Korea conducting large-scale digital won tests; AI-driven payment features targeted for 2026 |
| Canada | FINTRAC Travel Rule for cross-border transfers >C$1,000; RPAA captures fiat on/off-ramps; Foreign MSB registration for non-resident operators | NOT VERIFIED (no specific crypto settlement-finality statute detailed) | No | NOT VERIFIED — no active retail CBDC noted; Bank of Canada is the stablecoin and RPAA supervisor |
| Brazil | Stablecoin transactions treated as FX (Resolution 521); Resolution 561 bars eFX providers from crypto/stablecoin cross-border settlement (effective 1 Oct 2026); eFX investment transfers capped USD 10,000/transaction | NOT VERIFIED — no specific settlement-finality statute; cross-border must use traditional FX or non-resident BRL accounts | No | Drex (CBDC) pivoted away from blockchain (Aug 2025); targeting 2026 launch; Pix processed 7 billion transactions in Oct 2025 |
| El Salvador | NOT VERIFIED — no specific cross-border crypto-payment rules detailed; domestic licence only, no passporting | NOT VERIFIED (no specific settlement-finality statute detailed) | No | No CBDC program; economy is dollarized (USD official currency); no announced digital-dollar plans (June 2026) |
| France | MiCAR Art. 65 EU/EEA passporting; PSD2 passporting; SWIFT tokenized-bond settlement pilot with EURCV (15 Jan 2026) | Per EU framework (SFD 98/26/EC); no France-specific blockchain finality regime stated | No | Aligned with ECB digital euro; SG-FORGE/Bpifrance EURCV public-infrastructure adoption (17 Apr 2026) |
| Germany | MiCAR Art. 65 EU/EEA passporting (Bitpanda licence passportable across all 27 EU states); ZAG/PSD2 passporting | Per EU SFD; eWpG (Electronic Securities Act, in force 10 Jun 2021) enables electronic bearer bonds and crypto securities register (DLT) | No | Aligned with ECB digital euro (AMLA headquartered in Frankfurt) |
| Switzerland | Not an EU member; no MiCA applicability; proposed FinIA reforms aim for international equivalence | DLT Act ledger-based securities (CO Art. 973d-973i); SDX licensed as exchange + CSD; bankruptcy segregation for custodied crypto | No (but SDX licensed as exchange + CSD) | SNB wholesale-CBDC pilot (Project Helvetia III) on SDX extended 30 Jun 2025 to run until at least mid-2027 |
| Liechtenstein | EEA membership — MiCAR CASPs passport across entire EU/EEA with single FMA authorisation (Art. 65); TVTG alone gave no passporting | Per EU/EEA framework (no Liechtenstein-specific blockchain finality regime stated) | No | Not specified in file |
| UAE | CMA-VARA unified register (mutual VASP recognition, cross-emirate operation); CBUAE cross-border fund transfer under RPSCS; Federal Decree-Law No. 6 of 2025 captures VA payment services | NOT VERIFIED | No | Digital Dirham (CBDC) wholesale + retail; first AED 50m cross-border payment to China via mBridge (Jan 2024); retail rollout Q4 2025 (live launch NOT VERIFIED); mBridge world's first operational multi-CBDC platform |
| Bahrain | CRA Module applies to entities operating within or from Bahrain (principal/agent/custodian/exchange) | NOT VERIFIED | No | NOT VERIFIED (no retail/wholesale CBDC program detailed in file) |
| Nigeria | CBN April 2026 pilot tracks cross-border transactions; crypto used for remittances amid FX constraints; licence authorises Nigeria-only operation (no passporting — NOT VERIFIED) | NOT VERIFIED | No | eNaira retail CBDC launched 25 Oct 2021 (first African); modest adoption (<0.5% active by Oct 2023); CBN pivoting toward wholesale CBDC model |
8. Regulatory Model Summary
| Jurisdiction | Regulatory Model | Regulator Count | Stablecoin Model | Maturity | Spectrum Position |
|---|---|---|---|---|---|
| US | Fragmented multi-agency federal + 50-jurisdiction state patchwork; converging toward federal stablecoin framework via GENIUS Act | 50+ | Federal (GENIUS Act) | Maturing/transitional — GENIUS enacted, rules in proposed stage; CLARITY Act not yet enacted | Balanced (evolving toward accommodative) |
| UK | Multi-regulator, phased (AML reg 2020 → financial promotions 2023 → full FSMA authorisation 2027); dual FCA + BoE stablecoin | 2 (+ HMT, PSR) | Emerging (dual FCA non-systemic + BoE systemic) | Incomplete — framework not in force until 25 Oct 2027; ~51 registered; 86% rejection | Position 3 — Balanced-Restrictive (3.0) |
| EU | Comprehensive harmonised regional framework (single rulebook + passporting); dual MiCA-PSD2 licensing for EMT transfers | 27+ NCAs (+ ESMA/EBA/AMLA) | MiCA EMT/ART | Mature/operational — MiCA fully applicable since 30 Dec 2024; ~199 CASPs, 20 EMT issuers, 0 ART issuers | Position 4 — Balanced (4.0) |
| Japan | Multi-category licensing (CAESP/EPIESP/Fund Transfer/ECISBO) under PSA, transitioning toward FIEA securities-style regulation | 1 + SRO (JFSA + JVCEA) | EPI framework (banks/trust companies) | Advanced — world's first exchange licensing (2017); PSA-to-FIEA transition 2025-2027 | Balanced |
| Singapore | Comprehensive activity-based licensing (PSA SPI/MPI + FSMA DTSP) with dedicated stablecoin framework; single integrated regulator | 1 (MAS) | Dedicated SCS framework | Advanced — among first with comprehensive stablecoin framework | Balanced (increasingly restrictive for consumer-facing services) |
| Hong Kong | Dual-regulator hub model (SFC VATP + HKMA stablecoin issuer licensing), competing with Singapore | 2 (SFC + HKMA) | Stablecoins Ordinance | Advanced/maturing — institutional-grade frameworks, retail access permitted | Permissive |
| Australia | Dual-regulator (AUSTRAC AML + ASIC conduct + RBA payments) moving to AFSL licensing for digital asset platforms | 3 (AUSTRAC + ASIC + RBA) | Under development (no dedicated regime) | Maturing — generational overhaul (2024-2027) | Balanced |
| India | Tax-and-enforcement model (no comprehensive legislation); FIU-IND AML registration + punitive tax + RBI CBDC promotion | 3+ (FIU-IND + RBI + future SEBI) | None | Immature on framework — comprehensive bill repeatedly deferred | Balanced |
| South Korea | Strict VASP registration + dedicated user-protection act (VAUPA); real-name banking gate; moving toward Phase 2 Digital Asset Basic Act | 2-3 (KoFIU + FSC + FSS) | None (pending Phase 2) | Maturing — user-protection regime in force; Phase 2 still pending/delayed | Balanced |
| Canada | Multi-layered federal + provincial (FINTRAC AML, Bank of Canada RPAA + Stablecoin Act, CSA/CIRO, OSFI, CRA); activity-based | 5+ (federal + provincial; 14+) | Enacted (Stablecoin Act, not yet in force) | Maturing — RPAA in force; Stablecoin Act enacted but not in force (expected 2027) | Balanced |
| Brazil | Bank-led prudential model: BCB primary, stablecoin-as-FX classification, Basel-aligned capital framework | 2 (BCB + CVM) | Stablecoin-as-FX (Resolution 521) | Maturing — comprehensive framework operational 2 Feb 2026; one of Latin America's most developed | Balanced |
| El Salvador | Permissive dual-track voluntary-Bitcoin + DASP licensing (plus institutional investment-bank/PSAD); reversed from mandatory Bitcoin legal tender under IMF pressure | 2-3 (CNAD + BCR + SSF) | CNAD oversight under LEAD | Maturing but lightly tested — CNAD sole authority since Aug 2024; legal-tender reversal undermined predictability | Permissive |
| France | Mature national PSAN/DASP regime transitioning to MiCAR CASP; dual AMF/ACPR supervision; flagship euro stablecoin (EURCV) | 2 (AMF + ACPR) | MiCA EMT/ART (via EU) | Very mature — 100+ DASPs; MiCA early mover; orderly transition to 1 Jul 2026 | Position 3 — Balanced-Restrictive (3.4) |
| Germany | Dual KMAG + MiCAR framework; pioneering national crypto custody regime (2020) transitioned to EU-harmonised CASP; enforcement-oriented | 1 (+ Bundesbank joint role) | MiCA EMT/ART (via EU) | Very mature/conservative — BaFin leads EU with ~53 CASPs (May 2026) | Position 3 — Balanced-Restrictive (3.3) |
| Switzerland | Permissive, technology-neutral integration into existing financial law (DLT Act omnibus); proposed purpose-built payment/crypto institution categories | 1 (FINMA) + SROs | None dedicated (proposed Regulated Stablecoins) | Mature ecosystem (Crypto Valley); two FINMA-licensed crypto banks; FinIA reform a closed consultation | Position 5 — Balanced-Permissive |
| Liechtenstein | Pioneering standalone Blockchain Act (TVTG) + Token Container Model, now an EU/EEA passporting gateway via MiCAR; permissive | 1 (FMA) | MiCA EMT/ART (via EEA) | Established for small jurisdiction — 29 TT service providers; first CASP authorisations H1 2026 | Position 5 — Balanced-Permissive |
| UAE | Multi-regulator, zone-based permissive architecture (VARA/ADGM FSRA/DFSA/CBUAE/CMA) with dedicated stablecoin (PTSR/FRT) regimes | 5 (VARA + ADGM + DFSA + CBUAE + CMA) | CBUAE PTSR / ADGM FRT | Mature global hub — comprehensive frameworks across zones; Federal Decree-Law No. 6 of 2025 overhaul | Permissive |
| Bahrain | Single-regulator (CBB) permissive sandbox-to-license model; dual CASP+PSP licensing | 1 (CBB) | CBB SIO Module | Mature/early-mover — first MENA crypto regs (2019), pioneering July 2025 stablecoin framework | Permissive |
| Nigeria | Securities-based — crypto regulated as securities under capital markets law (SEC-led), with CBN bank-access and AML/CFT overlay | 3 (SEC + CBN + supporting agencies) | SEC stablecoin framework (ISA 2025) | Maturing — moved from 2021 prohibition to ISA 2025 structured regulation; only 2 exchanges provisionally licensed | Balanced |
9. Data Coverage Assessment
The following table identifies where the matrix verifies data versus marks it NOT VERIFIED across the seven thematic dimensions, to support ongoing research priorities.
| Jurisdiction | Licensing | Stablecoins | Taxation | AML/Travel Rule | Consumer Protection | Enforcement | Cross-Border |
|---|---|---|---|---|---|---|---|
| US | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| UK | Complete | Complete (proposed) | Complete | Complete | Complete | Complete | Complete |
| EU | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| Japan | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| Singapore | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| Hong Kong | Complete | Complete | Complete | Complete | Partial | Complete | Partial (CBDC only) |
| Australia | Partial (transitioning) | Partial | Complete | Complete | Partial | Complete | Partial |
| India | Partial | None | Partial | Partial | Gaps | Complete | Partial |
| South Korea | Partial | Partial (pending) | Partial (deferred) | Complete | Complete | Complete | Partial |
| Canada | Complete | Complete (not in force) | Complete | Complete | Partial | Complete | Partial |
| Brazil | Complete | Complete | Complete | Complete | Partial | Partial (new framework) | Partial |
| El Salvador | Complete | Partial | Complete | Partial | Gaps | Partial | Gaps |
| France | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| Germany | Complete | Complete | Complete | Complete | Complete | Complete | Complete |
| Switzerland | Complete | Complete (proposed) | Complete | Complete | Complete | Complete | Complete |
| Liechtenstein | Complete | Complete (via EEA) | Complete | Complete | Complete | Partial | Partial |
| UAE | Complete | Complete | Gaps | Complete | Partial | Complete | Partial |
| Bahrain | Complete | Complete | Gaps | Partial | Partial | Partial | Gaps |
| Nigeria | Complete | Complete | Partial | Partial | Gaps | Complete | Partial |
Key: Complete = matrix verifies comprehensive data; Partial = some data with NOT VERIFIED gaps; Gaps/None = significant missing data or no framework.
10. Reading Guide
How to Use These Tables
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Licensing (Table 1): Compare regulatory approaches and entry costs for firms evaluating market entry. Capital requirements, regulator identity, and passporting availability are the key differentiators.
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Stablecoins (Table 2): Identify which jurisdictions offer viable pathways for stablecoin issuance. Reserve requirements, redemption rights, and approved issuers indicate framework maturity.
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Taxation (Table 3): Assess the fiscal environment for crypto payment businesses and their customers. Holding-period incentives, loss-offset rules, and VAT/GST treatment are critical for business-model viability.
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AML/Travel Rule (Table 4): Evaluate FATF compliance posture. Travel Rule thresholds and unhosted-wallet rules are the key operational variables for compliance teams.
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Consumer Protection (Table 5): Assess the regulatory burden and risk profile for consumer-facing services. Cold-wallet mandates, asset segregation, and marketing restrictions directly affect operational design.
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Enforcement (Table 6): Gauge regulatory credibility and risk. Maximum penalties and notable enforcement actions indicate whether the framework is actively enforced.
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Cross-Border (Table 7): Evaluate international scalability. Passporting availability, settlement-finality frameworks, and CBDC status affect cross-border payment viability.
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Regulatory Model (Table 8): Understand the institutional architecture. Single-regulator versus multi-agency models have significant implications for compliance complexity and regulatory coherence.
Cross-Referencing
Each jurisdiction slug in the tables (e.g., Singapore) links to the full regulation file for that jurisdiction, where detailed analysis, sources, and verification notes can be found. For cross-domain context, see stablecoin regulations, CBDC frameworks, and digital-asset taxation.
11. Key Comparative Insights
11.1 Licensing Cost Spectrum
The cost of regulatory entry varies by more than three orders of magnitude across the 19 jurisdictions:
| Cost Tier | Jurisdictions | Approximate Entry Cost |
|---|---|---|
| Ultra-low | El Salvador (BSP/DASP) | $2,000 minimum capital |
| Low | Bahrain (Cat 1), Liechtenstein (TVTG), EU / France / Germany (CASP Class 1) | ~$50,000-$75,000 |
| Moderate | EU (CASP Class 2/3), Singapore (SPI/MPI), Liechtenstein (top TVTG), Bahrain (Cat 4) | ~$125,000-$795,000 |
| High | Switzerland (FinTech CHF 300K), Hong Kong (VATP HKD 5-10M), Brazil (SPSAV R$10.8M-R$37.2M), UAE (ADGM exchanges min USD 2M) | ~$300,000-$7M |
| Ultra-high | US (nationwide MTL aggregate), Japan (practical CAESP JPY 1B+), El Salvador (Investment Bank/PSAD $50M), Switzerland (Banking CHF 10M) | $500,000-$50M+ |
The EU's CASP framework provides the best cost-to-market-access ratio: EUR 50,000-150,000 in capital for access to 27+ markets via passporting (with ~199 CASPs authorised across 23 countries as of 12 April 2026). The US offers the worst ratio: ~$1M-$2M state net-worth aggregate across a 49-state patchwork (Montana excepted) with no federal passporting. El Salvador straddles the extremes — $2,000 for a retail BSP/DASP but $50,000,000 for the institutional investment-bank/PSAD track.
11.2 Stablecoin Framework Maturity
Three tiers of stablecoin regulatory maturity are observable from Table 2:
Tier 1 — Operational frameworks with approved issuers: EU (MiCA EMT/ART: Circle USDC/EURC, SG-Forge EURCV), France (EURCV — first MiCA-compliant EMT; USDCV from 15 Apr 2026), Singapore (SCS policy: Paxos USDG, StraitsX XSGD/XUSD), US (GENIUS Act enacted, rules in proposed stage), Hong Kong (Stablecoins Ordinance — first two licences 10 Apr 2026: Anchorpoint, HSBC), UAE (PTSR — USDU approved Jan 2026, DDSC final approval Feb 2026), Bahrain (SIO — AX Coin first licence 3 Jun 2026), Japan (EPI — JPYC first yen issuer Oct 2025), Nigeria (cNGN — Africa's first regulated stablecoin, Feb 2025).
Tier 2 — Frameworks enacted but not yet in force / no approved issuers: Canada (Stablecoin Act, Royal Assent 26 Mar 2026, in force expected 2027), UK (dual FCA + BoE FSMA framework — not in force until 25 Oct 2027), Switzerland (proposed Regulated Stablecoins — Oct 2025 consultation closed 6 Feb 2026), Liechtenstein (MiCA via EEA — no significant domestic issuance yet).
Tier 3 — No dedicated framework in force: India (none; RBI prefers CBDCs), South Korea (Digital Asset Basic Act pending, not enacted), Australia (captured by overlapping AUSTRAC/ASIC/RBA frameworks), El Salvador (CNAD oversight under LEAD but reserve rules NOT VERIFIED), Brazil (no dedicated issuer regime — stablecoins regulated as FX under Resolution 521).
11.3 Travel Rule Implementation Gap
Significant threshold divergence persists across jurisdictions, even where the Travel Rule is fully implemented:
- No threshold (strictest): UK (all transfers, stricter than FATF $1,000), EU / France / Germany (no de minimis for CASP-to-CASP), Japan (Section 7: no threshold), Hong Kong (FATF-aligned, no HK threshold cited).
- Below FATF $1,000-equivalent recommendation: Switzerland (CHF 1,000), South Korea (KRW 1,000,000 ~USD 842), Singapore (S$1,500 for enhanced PII), UAE (AED 3,500 ~USD 953).
- At or near FATF recommendation: Canada (C$1,000), EU (EUR 1,000 for unhosted-wallet verification).
- Above FATF recommendation: US ($3,000 — three times the FATF-recommended threshold).
- Phased / deferred / emerging: Brazil (phased Feb 2026-Feb 2028; threshold NOT VERIFIED), Australia (deferred to 1 Jul 2026), India (tightened from Jan 2026; threshold NOT VERIFIED), Nigeria (CBN pilot from Apr 2026), El Salvador (Travel Rule NOT VERIFIED), Bahrain (required; threshold NOT VERIFIED).
The US threshold of $3,000 remains notably above the FATF-recommended $1,000, leaving a transparency gap for transfers between $1,000 and $3,000. By contrast, the UK, EU/France/Germany, and Japan impose no de minimis at all for VASP-to-VASP transfers.
11.4 Settlement Finality — The Universal Gap
No jurisdiction among the 19 studied has designated a blockchain-based payment system under a statutory settlement-finality framework. This remains the single most consistent finding across all comparison dimensions. Partial solutions exist but none constitutes settlement finality in the traditional sense:
- Switzerland: DLT Act ledger-based securities (CO Art. 973d-973i) and bankruptcy segregation for custodied crypto; SDX licensed as exchange + CSD.
- US: UCC Article 12 (controllable electronic records) adopted in 34 jurisdictions, with a qualifying-purchaser take-free rule, but no federal finality statute.
- EU: SFD 98/26/EC applies only to designated systems — no blockchain payment system designated as of March 2026 — while the DLT Pilot Regime (EU 2022/858) permits CBM/CoBM/EMT settlement only in a sandbox.
- Germany: eWpG (Electronic Securities Act, in force 10 Jun 2021) enables electronic bearer bonds and a DLT-based crypto-securities register, but for securities rather than general payments.
- UK: FSMA 2023 DSAs and the Digital Securities Sandbox provide finality via contractual protections (Gate 2), but stablecoins/e-money are excluded as settlement assets.
- Japan: the Act on Book-Entry Transfer covers tokenised securities only; EPI stablecoins gain only contractual finality via the redeem-at-par obligation.
Eleven of the 19 jurisdictions mark settlement-finality law NOT VERIFIED or "No framework," confirming that on-chain payments still lack statutory finality almost everywhere.
11.5 CBDC Competition
Fourteen of the 19 jurisdictions have an active CBDC programme at some stage; five do not (US retail, El Salvador, Canada, Liechtenstein, Bahrain — the latter three NOT VERIFIED / no active programme):
| Stage | Jurisdictions |
|---|---|
| Live / advanced pilot | India (digital rupee ~10M users, 16 banks; circulation down ~24% YoY), Hong Kong (e-HKD Phase 2), Singapore (wholesale CBDC live trial, Nov 2025), Nigeria (eNaira live since Oct 2021, modest adoption), UAE (Digital Dirham wholesale + retail; mBridge operational) |
| Pilot / development | EU (digital euro: pilot Q3 2026/late 2027), Brazil (Drex, pivoted off blockchain, 2026 target), Switzerland (Project Helvetia III wholesale on SDX to mid-2027), South Korea (large-scale digital won tests) |
| Research / consultation | UK (digital pound; RTGS atomic settlement targeted 2028), Japan (digital yen — not launched), Australia (CFR/RBA examining, no retail commitment) |
| No active programme | US (no retail CBDC; GENIUS gives stablecoin issuers Fedwire/FedNow access), El Salvador (dollarized, no digital-dollar plans), Canada (NOT VERIFIED), Liechtenstein (not specified), Bahrain (NOT VERIFIED) |
CBDC development remains particularly relevant for crypto payment regulation because central banks consistently position CBDCs as public-sector alternatives to private stablecoins — explicit in India (RBI prefers CBDCs over stablecoins), the EU (digital euro as a public alternative coexisting with MiCA EMTs), South Korea (digital won as a sovereign alternative), and Brazil (Drex positioned as complementary, not a stablecoin replacement). The EU's non-EUR stablecoin usage caps (1M tx / EUR 200M daily) are the clearest instance of CBDC/monetary-sovereignty policy shaping stablecoin rules.
Verification Notes
- Source of truth: Every cell in Tables 1–8 mirrors
.claude/crypto-payment-regulation-fact-matrix.json(fields t1–t8 respectively) as of the 4 June 2026 refresh. No fact has been introduced that is not in the matrix; cells the matrix marks "NOT VERIFIED" are reproduced as such. - Corrections applied this pass:
- US market-structure bill corrected to the Digital Asset Market Clarity Act (CLARITY Act, H.R. 3633) — advanced by the Senate Banking Committee 14 May 2026, still not enacted (previously mislabelled FIT21).
- Roman Storm convicted (Aug 2025) on the 18 U.S.C. 1960 unlicensed money-transmitting count; jury deadlocked on money-laundering/sanctions counts; DOJ seeks an October 2026 retrial (Table 6).
- Brazil: MP 1303's flat 17.5% crypto tax was rejected (251-193) and expired in October 2025 — never in force; the progressive 15%-22.5% regime with the R$35,000 monthly exemption remains (Table 3).
- El Salvador: Bitcoin is no longer legal tender — a voluntary payment method since 29 January 2025 (Decree 199), reflecting the post-IMF status exactly as the matrix states it (Tables 3, 7, 8).
- Japan: PSA amendment recognising qualifying foreign trust-type stablecoins as EPIs, and the 2025 PSA ECISBO intermediary regime, take effect 1 June 2026 (Tables 1, 2).
- US GENIUS Act implementing NPRMs: six of seven federal regulators have issued proposed rules (Fed Board pending), advanced April–May 2026 (Table 2).
- Aggregates re-derived from the matrix (derivation, not new facts): 19 jurisdictions total; ~199 EU CASPs across 23 countries; 13 HK VATPs; 36 Singapore MPI-for-DPT licences; 29 Liechtenstein TT service providers; ~53 German CASPs; ~51 UK FCA-registered firms; EUR 540M+ aggregate EU MiCA penalties; settlement-finality designated in 0 of 19; active CBDC programmes in 14 of 19.
- Tagging: Only canonical region/ stance/ dimension/ type/ payment/ tags are used in the frontmatter.
- Citations: No Wikipedia, Reddit, Quora, X/Twitter, or Medium sources are cited anywhere in this file. Cross-domain references use the
deep-research/wikilink path prefix.