Global crypto regulation is entering a new phase, according to a new report from CertiK, with policymakers increasingly focused not on writing rules but on enforcing them. As digital assets move deeper into the financial mainstream, regulators across major economies are placing greater emphasis on operational compliance, cross-border investigations, anti-money laundering controls, and reserve verification. The report paints a picture of a fragmented but maturing global framework in which legal certainty, supervisory intensity, and market access increasingly vary by jurisdiction.
The European Union Sets the Pace With MiCA
CertiK identifies the European Union as the clearest example of a purpose-built regulatory regime for digital assets. Through the Markets in Crypto-Assets framework, or MiCA, the EU has introduced a dedicated structure for crypto-assets, issuers, and service providers rather than forcing the sector into legacy financial laws. That distinction matters because it gives companies a clearer legal map for compliance and expansion.
The report says this legal certainty has already had a noticeable market effect. Large exchanges are consolidating their European operations in jurisdictions viewed as both crypto-friendly and institutionally credible, particularly France and Ireland. In a global industry long shaped by uncertainty, MiCA is presented as a competitive advantage for the EU, helping it attract businesses that value predictability as much as market size.
Beyond market structure, MiCA also signals a broader policy direction: regulators are no longer content with aspirational compliance promises. They want firms to demonstrate that internal controls, governance processes, and consumer safeguards actually function in practice. That makes Europe not only a rule-setter, but increasingly a benchmark for implementation.
The United States Still Struggles With Fragmented Oversight
In contrast, the United States continues to be defined by what the report characterizes as an enforcement-led model. The longstanding jurisdictional tension between the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) remains unresolved, creating persistent uncertainty for companies trying to determine which assets fall under which regulatory category.
Recent court rulings have offered some clarification around what constitutes a security, but the report argues that the absence of a comprehensive federal legislative framework still pushes many US-based Web3 companies to consider more predictable jurisdictions abroad. That uncertainty does not only affect startups. It also complicates long-term planning for exchanges, custodians, stablecoin issuers, and institutional service providers.
Still, the report highlights one area that could become a turning point for the US market: stablecoin legislation. If lawmakers advance a coherent federal approach to stablecoins, it could provide a foundation for broader digital asset regulation and reduce some of the ambiguity that has defined the American market so far.
Asia Is Emerging as a Region of Sharp Contrasts
Asia, according to CertiK, offers some of the most divergent regulatory models in the world. Mainland China continues to maintain a strict ban on most crypto-related activities, preserving one of the most restrictive stances among major economies. At the same time, Hong Kong is actively positioning itself as a regulated virtual asset hub through a new licensing regime for retail trading platforms.
That contrast reflects a broader regional split between prohibition, controlled openness, and institutional specialization. The report also points to Singapore and Japan as leaders in stablecoin regulation. Singapore has built a reputation for focusing on institution-grade crypto services, creating an environment attractive to firms serving professional and large-scale market participants. Japan, meanwhile, moved early on consumer protection after suffering major exchange hacks in earlier market cycles.
As a result, both Singapore and Japan have become attractive destinations for digital asset custody and settlement services. Rather than racing to be permissive at all costs, these jurisdictions are trying to combine market development with safeguards that can support long-term legitimacy.
From Rulemaking to Results-Driven Supervision
One of the report’s central conclusions is that the global conversation is moving beyond whether regulation should exist. The new question is whether firms can prove that their compliance frameworks actually work. As regimes such as MiCA move into full application, supervisors are focusing less on policy documents and more on execution.
This means deeper audits of automated transaction monitoring systems, more direct scrutiny of proof-of-reserves claims, and growing pressure on firms to ensure that their operational reality matches their public disclosures. Regulators are no longer satisfied with paper-based compliance programs that fail when tested under real market conditions.
The report also notes an increase in joint investigations this year, with agencies sharing data in real time to track illicit fund flows across borders. That shift matters because crypto activity is inherently transnational, and fragmented enforcement can leave major gaps. More coordinated supervision suggests that regulators are adapting their methods to the structure of the market itself.
Enforcement Activity Is Rising Sharply in EMEA
The report provides one of its clearest indicators of this change through enforcement statistics in the EMEA region. According to CertiK, total fines in EMEA reached $168.2 million in the first half of 2025, a 767% increase from the previous year. The figures suggest that regulators are not merely expanding their powers on paper; they are using them more aggressively.
The UK Financial Conduct Authority led a series of major enforcement actions, including fines of £44 million against Nationwide Building Society, £39.3 million against Barclays, and £21.1 million against Monzo, all tied to anti-money laundering deficiencies. Separately, the Central Bank of Ireland fined Coinbase Europe €21 million for AML/CFT violations. CertiK says the activation of MiCA and the establishment of the EU’s Anti-Money Laundering Authority, or AMLA, are likely to reinforce this trajectory across the bloc.
These penalties underline a broader regulatory message: compliance expectations are no longer theoretical. Firms that fail to build and maintain effective controls are increasingly exposed to direct financial and reputational consequences.
Stablecoins, AML Standards, and DeFi Access Points Are Key Themes
CertiK says several policy themes are dominating the current agenda, beginning with stablecoin de-risking. Regulators are paying much closer attention to the reserves backing stablecoins and are increasingly inclined to treat these assets in ways similar to traditional money market funds. The stated goal is to reduce the chance that instability in one part of the market could spread more broadly through the financial system.
At the same time, AML compliance is entering a new phase as the Travel Rule gains wider global adoption. Implementation remains technically difficult for decentralized protocols, but the direction of travel is clear: authorities expect more traceability and more consistent identity-linked compliance standards across crypto transactions.
On decentralized finance, the report argues that purely decentralized systems remain harder to target directly. Instead, enforcement is increasingly focusing on centralized intermediaries that act as practical gateways for retail users, including website front ends and bridge operators. This reflects a pragmatic regulatory strategy: where protocols are hard to regulate at the base layer, authorities may target the access points users rely on most.
The Wait-and-See Era Is Over
CertiK’s overall conclusion is that the “wait and see” period in digital asset regulation has effectively ended. As central banks continue exploring CBDCs, the distinction between traditional finance and digital finance is expected to narrow further. In that environment, regulatory expectations will likely become more integrated, more continuous, and more demanding.
For market participants, the message is direct. Compliance is no longer an optional layer added after growth. It is becoming a prerequisite for long-term viability in the global financial system. Firms that can operate within increasingly rigorous standards may gain access to deeper pools of capital and more stable markets. Those that cannot may find themselves shut out, fined, or forced to relocate.
The report does not suggest that every region is converging on a single model. In fact, divergence remains one of its defining observations. But the trendline is unmistakable: wherever companies choose to operate, active supervision is replacing regulatory ambiguity as the dominant reality of the crypto market.