Japan’s Financial Services Agency has published a commissioned study on overseas financial regulatory systems, a 609-page report prepared by Japanese law firm Atsumi & Sakai. The document covers eight countries and regions, including the United States, the United Kingdom, the European Union, China, and Hong Kong, and is intended to serve as a reference for Japan’s financial system planning and legislative work. The report reviews regulatory frameworks for crypto asset exchanges, stablecoins, and real-world asset tokenization across those jurisdictions. It specifically references the U.S. GENIUS Act, the European Union’s Markets in Crypto-Assets regulation, the U.K.’s stablecoin regulatory framework, and rules issued by China in February 2026 covering virtual currencies and RWA-related activity. According to the report, China’s current rules generally prohibit domestic issuance, trading, and related services for RWA tokenization, except for business that has obtained approval from competent authorities and operates through designated financial market infrastructure. The study also discusses Hong Kong’s move to expand the scope of tokenized securities trading and the related market oversight arrangements.
Japan’s Financial Services Agency (FSA) has released a commissioned study on overseas financial regulatory systems, a 609-page report prepared by Japanese law firm Atsumi & Sakai. The study covers eight countries and regions, including the United States, the United Kingdom, the European Union, China, and Hong Kong, and is meant to inform Japan’s financial system planning and legislative work.
The report focuses on regulatory frameworks for crypto asset exchanges, stablecoins, and real-world asset (RWA) tokenization. It reviews the U.S. GENIUS Act, the European Union’s Markets in Crypto-Assets (MiCA) regulation, the U.K.’s stablecoin regulatory framework, and rules issued by China in February 2026 on virtual currencies and RWA-related activity.
According to the report, China’s current rules generally prohibit domestic issuance, trading, and related services tied to RWA tokenization, with an exception for business that has obtained approval from competent authorities and relies on specific financial infrastructure.
The report also covers Hong Kong’s expansion of the scope of tokenized securities trading and the related market regulatory arrangements.
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