Navigating global crypto regulations: A comparison of key regimes for fintech expansion
As fintech firms increasingly eye international markets, regulatory compliance remains a critical hurdle and opportunity. Expanding into new jurisdictions means grappling with diverse crypto regulatory frameworks, particularly for stablecoins and broader crypto-assets, which are pivotal for payments, DeFi, and cross-border transactions.
This article compares five key regulatory regimes: the GENIUS Act in the United States, the CRYPTOPRU regime in the United Kingdom, MiCA in the European Union, Singapore’s stablecoin framework, and Hong Kong’s Stablecoins Ordinance. The focus is on stablecoins and related activities, reflecting their increasing significance in fintech innovation. It examines the scope, applicability, covered activities, prudential requirements, and exemptions within each framework, while offering deeper insights into the implications for fintech firms seeking to expand into these jurisdictions. The discussion also considers which regime may be most suitable for different types of firm expansion objectives.
Overview of the Regulatory Regimes
US: GENIUS Act (Generating Excellence in New Innovative Utility Services Act)
Signed into law in July 2025, the GENIUS Act is the first federal US legislation specifically targeting stablecoins. It aims to provide clarity for issuers while emphasizing consumer protection and financial stability. Effective from January 2027, it mandates 1:1 backing with USD or low-risk assets and integrates stablecoins into existing anti-money laundering (AML) frameworks under the Bank Secrecy Act. It allows banks to issue tokenized deposits and custody stablecoins, fostering innovation in payments.
UK: CP25/14: Stablecoin issuance and cryptoasset custody
Published by the Financial Conduct Authority (FCA) in 2025, CP25/14 outlines the proposed prudential framework for cryptoasset firms issuing qualifying stablecoins and safeguarding digital assets. The consultation expands on previous regulatory obligations under the Financial Services and Markets Act, providing detailed capital, liquidity, and risk management requirements. Aimed at firms operating in or targeting the UK, the proposals are designed to ensure financial stability, protect consumers, and promote trust in regulated crypto markets. CP25/14 serves as the foundation for the FCA’s CRYPTOPRU regime.
EU: MiCA (Markets in Crypto-Assets Regulation)
Fully effective since December 2024, MiCA is a comprehensive EU-wide framework regulating crypto-assets, including stablecoins (classified as asset-referenced tokens or e-money tokens). It harmonizes rules across member states, covering issuance, trading, and custody, with strong emphases on market integrity, AML, and investor safeguards. MiCA licenses Crypto-Asset Service Providers (CASPs) and includes a market abuse regime.
Singapore: Stablecoin Framework (MAS Regulatory Framework)
Finalized in August 2023 following a 2022 consultation and response to feedback, the Monetary Authority of Singapore (MAS) framework regulates single-currency stablecoins (SCS) pegged to the Singapore Dollar or G10 currencies and issued in Singapore. It introduces "Stablecoin Issuance Service" as a regulated activity under the Payment Services Act (PS Act). Non-bank issuers with SCS in circulation exceeding SGD 5 million must comply with requirements for reserves, capital, redemption, and disclosures to ensure value stability. Compliant SCS can be labelled "MAS-regulated stablecoins", distinguishing them from unregulated tokens. Broader crypto activities fall under digital payment token (DPT) services licensing.
Hong Kong: Stablecoins Ordinance (HKMA and SFC Framework)
Effective from August 1, 2025, the Stablecoins Ordinance introduces a licensing regime for issuers of fiat-referenced stablecoins (FRS) under the Hong Kong Monetary Authority (HKMA). It emphasizes reserve backing, licensing, AML/CFT (Counter-Terrorist Funding) compliance, and investor protection to position Hong Kong as a regulated crypto hub. The Securities and Futures Commission (SFC) regulates virtual asset service providers (VASPs), including trading platforms, complementing the stablecoin rules.
Comparison and Contrast
To facilitate a clear analysis, we've structured the comparison in a table focusing on the specified dimensions. Note that while the GENIUS Act is stablecoin-specific, others encompass broader crypto-assets but include stablecoin provisions. Below the table, we delve into what these differences mean for fintech firms expanding internationally.
| Theme | US (GENIUS Act) | UK CP25/14 (FCA framework) | EU (MiCA) | Singapore (MAS framework) | Hong Kong (Stablecoins Ordinance) |
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| Prudential requirements |
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Implications for Fintech Firms Expanding to These Jurisdictions
The contrasts in these regimes have significant practical implications for fintech expansion strategies.
For instance, MiCA gives fintechs a single EU-wide license to operate across 27 countries, making cross-border scaling easier. The trade-off is strict prudential rules—governance, reserve quality, and detailed disclosures—that can push up costs for smaller firms. In contrast, the US GENIUS Act focuses on payment stablecoins, offering fast federal clarity and strong oversight for USD-backed tokens, but it leaves other crypto activities exposed to additional state rules. Meanwhile, the UK’s CP25/24 and CRYPTOPRU regime establishes requirements intended to allow firms to continue to operate in times of stress and enable innovation, ideal for established firms with robust risk management, but potentially tough for smaller entrants in competitive retail entrants.
Singapore’s MAS framework lets non-bank issuers with over SGD 5 million in circulation pilot “MAS-regulated stablecoins,” combining flexibility with credibility, though operational restrictions may require careful structuring for global expansion. Hong Kong’s Stablecoins Ordinance, effective August 2025, sets licensing, governance, and strict AML/CFT rules for fiat-backed tokens, positioning the city as a gateway to Asia. Its newness adds uncertainty, favouring firms with strong compliance infrastructure and tech-ready operations.
Overall, these differences highlight the need for tailored strategies: broad regimes like MiCA favour large-scale operators, while targeted frameworks such as the GENIUS Act or Singapore’s MAS regime offer lower entry barriers for niche players, though with potential limits on growth.
Insights: Regime Suitability for Different Fintech Expansion Goals
Selecting a regime depends on your firm's size, activities, and strategic objectives. Here's how each aligns with specific expansion goals:
EU (MiCA): Best suited for large fintechs aiming for pan-European scale and diversified crypto services (e.g., trading, custody alongside stablecoins). The passporting feature supports rapid multi-country expansion, building trust through strong investor protections—ideal if your goal is market dominance in a mature, unified region, though high compliance costs suit well-funded firms.
Singapore (MAS Framework): Optimal for innovative startups or mid-sized fintechs targeting Asia-Pacific experimentation with stablecoins. The proportionate requirements (e.g., exemptions below SGD 5M) and "MAS-regulated" label enable quick pilots and credibility, perfect for goals like testing DeFi or payments in a pro-innovation hub, with lower barriers than the EU but restrictions on high-risk activities.
Hong Kong (Stablecoins Ordinance): Suited for firms seeking a bridge to Asian markets with a focus on regulated stablecoin issuance. Its licensing and reserve rules support goals like cross-border payments or VA integration, especially for established players leveraging HK's hub status, but strict ID rules may complicate user onboarding for retail-oriented expansions.
US (GENIUS Act): Ideal for payment-centric fintechs pursuing US market entry and bank partnerships. The federal focus on stablecoins facilitates goals like tokenized deposits for efficient remittances, benefiting firms with USD exposure, but limited scope means it's less suitable for broad crypto ambitions without navigating patchwork state regs.
UK (CP25/14): Fits mature fintechs with retail consumer goals, emphasizing stability through prudential rules. It's great for expansion into a sophisticated financial centre with investment attraction, but burdensome requirements like own-funds calculations make it better for firms prioritizing risk mitigation over speed.
Companies undergoing an expansion process might view a multi-jurisdictional approach as the best course of action – however, firms should conduct a regulatory analysis to determine the jurisdiction and regulator that best aligns with their objectives taking into account time and resource constraints Increasingly, we are seeing greater harmonisation of regulations across regions, providing clearer rule interpretation and enabling the creation of robust, replicable frameworks.
Additional Considerations
Beyond the core comparison, fintechs should weigh these factors for informed expansion:
Enforcement and Penalties: The EU's market abuse regime enables swift cross-border enforcement, deterring misconduct but increasing liability; contrast with the US's SEC/CFTC overlaps, which can lead to dual investigations for non-compliant firms.
Innovation Support: Singapore and Hong Kong provide sandboxes for testing, accelerating product launches; MiCA's pilot for tokenized securities suits DeFi innovators, unlike the UK's more conservative prudential focus.
Cross-Border Harmonisation: MiCA's passporting minimises barriers within the EU, ideal for regional growth; potential US-UK alignments provide some harmonisation for transatlantic operations, but as with other jurisdictions all require a local presence to be established.
How FXp can help
Regulatory landscapes are quickly evolving. For fintechs planning to expand, a clear understanding of licensing and compliance requirements can be the catalyst to reducing friction, avoiding costly delays, and seizing market opportunities.
At Braithwate, we help fintechs turn regulatory complexity into a competitive advantage. Through our expert advisory services and our one-stop platform for international expansion - FintechXpndr - we guide you from initial jurisdiction analysis to full market entry with clarity and confidence.
If you’re preparing to scale across borders, contact us today for a free consultation on tailoring your expansion strategy to the latest regulatory frameworks.
This article is for informational purposes only and does not constitute legal advice.
