Article · Technology

How Cryptocurrency Is Regulated Around the World: A Comparative Overview

Type
Article
Jurisdiction
National
Date
2026-04-30
Topic
Technology

A single crypto token can be a security, a commodity, money for transmission purposes, and taxable property all at once, and the answer changes with the token, the transaction, and the border. This article first defines blockchain and the crypto vocabulary in plain English, then maps the layered U.S. regime: the SEC and the Howey investment-contract test (through the split Ripple ruling, the contrary Terraform reasoning, and the pending exchange cases), the CFTC's commodity jurisdiction, FinCEN's Bank Secrecy Act obligations, fifty state money-transmission laws anchored by New York's BitLicense, and the IRS's property characterization. It then tours the wider world, from the EU's comprehensive MiCA framework and the distinct choices of the UK, Switzerland, Singapore, and Japan, to prohibition in China and El Salvador's abandoned legal-tender experiment. Two themes that reach the nature of money itself, stablecoins and central bank digital currencies, get their own treatment, including the 2025 GENIUS Act. Because U.S. law here moves quarter to quarter, the piece flags what is settled, what is contested, and what is genuinely in flux, and grounds each doctrine in worked hypotheticals a founder, investor, or compliance officer would actually face.

How Cryptocurrency Is Regulated Around the World: A Comparative Overview

Technology > Securities and Fintech | Published 30 April 2026 - Updated 6 May 2026 | UpLaw - uplaw.us

One token can be a security, a commodity, money, and property at the same time, in the same wallet, on the same afternoon. Which body of law governs it depends less on what the thing is than on what someone did with it and which regulator is asking. This is a map of that fractured territory, U.S. and global.

The full text of this document is available to Executive subscribers and above. See plans.