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Navigating Global Crypto Regulations – a comparison of different crypto management systems

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With the rapid adoption of cryptocurrencies in today’s globalised world, different countries have set up different guidelines for the usage of crypto in their countries. Singapore is both contributing and influenced by major overseas developments in policy and legislation. These developments overseas set the ground for future policy changes by the Monetary Authority of Singapore (MAS), and also inform cross-border crypto transactions.

Europe

The EU’s Markets in Crypto-Assets (MiCA) establishes a unified regulatory framework for crypto-assets, addressing risks such as market abuse, financial instability, and consumer exploitation. The framework constructs uniform requirements within the European Union for offering crypto assets to the public, trading crypto assets, as well as crypto asset service providers around authorisation, operation, and supervision. MiCA focuses on three key areas:

Transparency

Under MiCA, companies have to adhere to strict disclosure and reporting obligations for crypto-asset issuers and service providers. White papers, financial statements, and operational details must be published in accordance with regulatory standards.

Stability

With a focus on stability, MiCA enforces strict requirements on asset-referenced tokens and e-money tokens (both of which are types of stablecoins), requiring them to maintain sufficient reserves, redemption mechanisms, and operational safeguards.

Consumer Protection

Crypto-Asset Service Providers are imposed strict accountability rules to shield investors from fraud, misinformation and operational risks. Furthermore, investors are guaranteed legal recourse in cases of misconduct.

As a result of MiCA’s requirements, there were significant shifts in the competitive landscape. For one, compliance costs and regulatory demands have created higher barriers of entry for smaller players, resulting in many exiting the market or merging with larger firms. This reduces market fragmentation and increases stability, but on the flip side, also reduces potential diversity and innovation. However, MiCA’s clear rules and focus on consumer protection have also increased the trust among investors, while elevating the role of stablecoins and crypto-asset providers.

UAE

The regulatory landscape within the UAE is structured at the federal and local emirate levels, as well as within two financial free zones. With a multi-layered regulatory approach, the UAE can ensure its competitiveness, while at the same time, not compromising on its security for digital asset activities.

The Securities and Commodities Authority (SCA) is the federal-level financial services regulator with respect to securities, commodities, and Virtual Assets Service Providers. While the overall federal authority rests with the SCA, it can delegate this authority to Local Licensing Authorities, which are entities designated to oversee virtual assets within their specific Emirates.

In terms of licensing, Virtual Asset Service Providers operating in or targeting Dubai must obtain a license from VARA, a body established under Law No. (4) of 2022 (Regulating Virtual Assets in the Emirate of Dubai). Once licensed by VARA,

With its comprehensive and multi-tiered framework, the UAE has established itself as a global hub for virtual assets, balancing security with competitiveness to create an ecosystem that encourages digital and blockchain innovation.

Hong Kong

On 1 August 2025, Hong Kong officially launched its comprehensive stablecoin regulatory regime, creating licensing and regulatory requirements for domestic stablecoin issuers administered by the Hong Kong Monetary Authority

Furthermore, reserve assets are mandated to be dominated in the same reference currency as the stablecoin For multi-currency stablecoins, reserve assets must match the referenced currency proportions.

The framework grants stablecoin holders an unconditional right to redeem their tokens at face value, with redemptions to be processed within one business day unless an extension is approved. Issuers are barred from charging unreasonable fees or placing excessive conditions on redemption. In the event of insolvency, holders are further protected through rights to a pro rata share of reserve assets and claims against issuers for any shortfall if reserves fall short. The rules also prohibit the promotion or issuance of stablecoins except through approved intermediaries, creating a tightly regulated, closed-loop system.

Singapore

The Monetary Authority of Singapore (MAS) has established a regulatory framework in hopes of maintaining the value stability of single-currency stablecoins. This framework applies to single-currency stablecoins pegged to the SGD or any G10 currency that is issued
 
in Singapore There are 4 main requirements of licensing under this framework, where (a) issuers must back their stable coins with adequate reserve assets that meet MAS-desired requirements, (b) issuers are to maintain a minimum level of capital and liquid assets to mitigate insolvency risks, (c) holders of MAS-regulated stablecoins must be able to redeem their tokens at face value within at most 5 business days of a redemption request, and (d) issuers must provide clear and comprehensive disclosure to users.

Singapore also has the Payment Services Act 2019, establishing a regulatory framework for all digital payment token providers in Singapore. The main objective of the act is for digital payment token providers to implement anti-money laundering (AML) and combatting finance of terrorists (CFT) procedures and policies. It also seeks to enforce public knowledge on the risk of crypto trading. Service providers must establish compliance management frameworks that, at a minimum, involve appointing a management-level AML/CFT compliance officer. They are also required to maintain an adequately resourced and independent audit function to regularly evaluate the effectiveness of internal policies, procedures, and controls, as well as overall regulatory compliance. In addition, firms must ensure that staff receive ongoing and suitable training on AML/CFT obligations and the organisation’s internal compliance measures.

Conclusion

Singapore is often seen as a financial hub, and thus it often references other countries’ regulatory systems to ensure that its policy is up to date, and compatible with other countries. This is especially important due to the globalised nature of cryptocurrency trading, where serving international customers requires adhering to many different jurisdictions. Navigating the different jurisdictions of countries is difficult, especially due to the situation-specific elements of law. If you require professional guidance in this regard, do contact the Advomi team, where we have a team of qualified lawyers to assist you in your operations.

Disclaimer: This article provides general information and does not constitute legal advice. Please seek professional advice for your specific situation.

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