Sort out the specific regulatory policies of the global encryption market and understand the future evolution trend

Fun coin 2021-08-05 17:06:56 阅读数:970

sort specific regulatory policies global

In the near future , Encryption market regulatory It has become one of the most concerned topics inside and outside the encryption industry , Many countries represented by the United States have strengthened the supervision of the encryption market . For now , National regulation will play an increasingly important role in the encryption industry .

therefore , Chain catcher combed a number of countries around the world with clear encryption market regulatory policies , From the nature of cryptocurrency and the corresponding regulatory policies 、 Exchange supervision system 、 Tax policy, etc , I hope it will be helpful for practitioners in the encryption market and industry followers to further strengthen policy awareness .

Original title :《 Understand the specific policies and evolution trend of global encryption market supervision 》

Arrangement :Richard Lee、 Bran

The United States

As the most developed country in the global financial market , The U.S. regulation of the encryption market is very detailed , Several administrative agencies are developing specific regulatory rules based on the nature of cryptocurrency , For example, the U.S. Securities Commission SEC Treat some tokens as negotiable securities , The commodity and Futures Trading Commission calls it goods , The IRS regards it as property .

ICO Usually vulnerable to regulation by the securities and Exchange Commission . according to 《 Federal securities law 》, If encrypted assets are identified as securities , The issuer must report to SEC Register the securities or provide them under an exemption from registration requirements . In terms of whether tokens are recognized as securities ,SEC There's always room , Call it Depending on the characteristics and purpose of the particular asset . But overall ,SEC Prefer to think of cryptocurrencies as securities , At the same time, the securities law is fully applicable to digital wallet , It also affects exchanges and investors .

2017 year 12 month , then SEC The chairman issued a statement on cryptocurrency and ICO Statement of , Potential buyers are said to be sold because of the potential of token appreciation 、 Be able to lock in these value-added by reselling tokens in the secondary market or profit from tokens based on the efforts of others , These are the key symbols of securities and securities issuance . therefore , The chairman said , Overall speaking , The first token issue structure seen involves the issuance and sale of Securities , For violations 《 Federal securities law 》 Of ICO Behavior , from SEC Take law enforcement action .

Cryptocurrency exchange , Mainly by the U.S. financial crime enforcement network (FinCEN) Supervision , Focus on fund transfer and anti money laundering (AML). according to 《 Bank secrecy law 》,FinCEN Supervise money service enterprises (MSB).2013 year 3 month ,FinCEN Release guide , Determine the cryptocurrency transaction service provider as MSB. Under this framework , Cryptocurrency trading platform must obtain FINCEN The license , Implement a comprehensive anti money laundering risk assessment and reporting mechanism .

last year 12 month ,FinCEN It is proposed to add... To cryptocurrency transaction providers KYC Wait for new data collection requirements . According to the proposed rule , Banks and money service companies will be required to submit reports 、 Keep records and verify customer identity , Private digital wallets hosted by non-financial institutions are also included . The proposal has caused great controversy ,FinCEN This year, 1 In June, it announced to extend the time for soliciting opinions , At present, there is no latest trend .

In terms of encrypted derivatives , The commodity and Futures Trading Commission (CFTC) Treat cryptocurrency as a commodity , according to 《 Commodity trading law 》, Cryptocurrency futures 、 Options and other derivative contracts must be traded at CTFC Publicly traded on regulated exchanges . at present , The Chicago options exchange and the Chicago Mercantile Exchange offer futures trading linked to bitcoin prices .

In terms of encryption investment tax , The IRS taxes cryptocurrency as property . For citizens personally , Hold cryptocurrency as a capital asset for more than one year 、 And realized income , Are subject to capital gains tax ; Holding for less than one year and earning , Pay ordinary income tax .

In addition to the aforementioned decentralized regulation at the federal level , State governments may make specific rules and regulations within their jurisdiction .

New York State in 2015 year 8 In June, it took the lead in proposing a comprehensive regulatory framework for the encryption market BitLicense, This is also the most influential license in the encryption industry .BitLicense Including key consumer protection 、 Anti money laundering compliance and cyber security guidelines , The regulation provides for any company or individual living in New York that uses cryptocurrency , Companies dealing with virtual currency business are required to apply for a license . at present ,Circle、Ripple etc. 20 Several companies have obtained BitLicense License plate .

Besides , The state of New York has also introduced a trust charter for cryptocurrency custody companies (Charter), at present Paxos、Gemini、NYDIG、Coinbase、Bakkt、Fidelity Digital Asset Nearly equal 10 The company won the Charter .

Wyoming is a region where the United States is more friendly to cryptocurrency , More than a dozen relevant bills have been promulgated . One of the most influential is 2018 year 3 Passed by the month HB70《 Open blockchain token exemption 》 bill , It puts forward similar Utility tokens Asset classes for . According to the act , If the issued token is not used as an investment , For consumption purposes only , Such as exchange 、 Used to receive goods and services, etc , May be exempted from 《 Federal securities law 》 Constraints .

thereafter ,Ripple And Cardano Development Company IOHK And other well-known encryption enterprises have migrated to Wyoming .2020 year 9 Month so far ,Kraken、Avanti etc. 3 The company has also been approved by Wyoming regulators , According to SPDI The law authorizes the establishment of encrypted banks , Provide commercial banking and custody services for token assets and digital currencies .

This year, 5 month , The United States SEC Said Congress had been urged to legislate , To give SEC Yes Digital assets More regulatory authority . meanwhile ,SEC It is also committed to leading the establishment of a broad regulatory framework for encrypted assets , So that many American regulators clearly divide the scope of market supervision and then perform their respective duties , Even all digital assets are under supervision .

In the near future , The United States SEC Start to focus on DeFi The direction is tilted ,SEC The chairman also said that any person who provided token services in the nature of securities DeFi All projects are in SEC Within the scope of Supervision , Any stock token or crypto token that provides exposure to underlying securities is subject to the Securities Act , It has caused great controversy in the encryption market .


Maybe by Mt.Gox The impact of the exchange bankruptcy , Japan is currently the leading country in the world in the regulatory system of cryptocurrency exchanges .

2016 year 5 In June, the Japanese parliament passed a bill to amend 《 Capital settlement method 》 And in 17 year 4 Officially effective in , This adds... To the law Virtual currency chapter , Define virtual currency as a kind of settlement 、 Means of payment , And has property value . meanwhile , The act also clearly introduces the regulatory mechanism of encrypted asset exchange , Only at the Japan financial agency / Only enterprises registered with the Finance Bureau can provide cryptocurrency exchange services in the country .

according to the understanding of , Registration requirements generally include : The minimum capital is 1000 More than ten thousand yen ; Provide transaction asset information to customers 、 Contract details, etc ; Separate management of user property and operator property ;KYC Confirmation, etc .

2017 year , The Japan finance agency will report to 16 A cryptocurrency exchange is licensed , But because of Coincheck18 Stolen at the beginning of the year and lost nearly 5 Billion dollars , The financial services agency of Japan suspended the issuance of licenses during the year , At the same time, it has settled in major registered exchanges in Japan for a period of time 2-6 Weekly inspection , Range from financial statements 、 Anti money laundering system 、 Employee background checks , To the system version of each computer 、 Password and employee attendance , Since then, a number of unqualified exchanges have been rectified and warned 、 Fines and even closures .

Since then, the Japan finance agency has reopened the license issuance , By 2021 year 6 month , So far 31 An encryption enterprise has registered , Include bitFlyer、Coincheck And this year 6 Recently approved in June Coinbase etc. . The official website of Japan's financial agency will also publish the list of companies that are not registered to engage in encrypted asset trading in the country from time to time , Among them, Qian an 、Bybit When recently warned .

In encrypted asset trading and management 、 Margin trading and STO aspect ,2020 year 5 Implemented since June 《 Capital liquidation law 》 and 《 Financial Instrument Trading Act 》 The amendment and recent decrees put forward more specific provisions :

Encrypted asset transactions and management , In dealing with the risk of crypto asset disclosure , For user assets managed by hot wallet , Force enterprises to retain the same number and type of encrypted assets as repayment resources ; Transaction risk investigation , The exchange needs to create and maintain transaction records , And inform the authorities of suspicious transactions ; On the protection of users' rights and interests , The regulations require the exchange to give priority to returning the escrow encrypted assets to users in case of bankruptcy ; Encrypted asset custody , Relevant service providers also need to obtain the cryptocurrency transaction license from the regulatory authorities .

Cryptocurrency derivatives transactions , Relevant operators need to register as cryptocurrency exchange and primary financial instrument operators at the same time . meanwhile , Japan limits the leverage ratio to double .

Securitized tokens , Japan in 《 Financial instruments and transaction law 》 It also defines the relevant regulatory mechanism . This year, 3 month , Sumitomo Mitsui bank and securitized token platform Securitize The first asset-backed Securities tokens , This is also the first one that meets 《 Financial instruments and transaction law 》 Security token .

Japan also attaches great importance to the role of industry associations in the encryption market ,《 Financial instruments and transaction law 》 Japan virtual currency exchange business association and Japan STO The association certifies cryptocurrency transactions and ST Independent regulatory organizations in the field , To carry out specific operations related to the law , And formulate specific rules and guidelines for the industry .

Besides , Japan has also developed a tax mechanism for cryptocurrency transactions , The annual salary income exceeds 2000 Million yen or non salary income exceeds 20 An individual of 10000 yen needs to declare his cryptocurrency trading profit income , The tax rate shall be 15% To 55% Unequal .


Singapore is one of the more friendly countries to the encryption market in the world , Detailed regulatory policies have been issued , Therefore, it is favored by many encryption enterprises , At the same time, the country's sovereign wealth fund GIC And Temasek, a state-owned investment company, have invested hundreds of millions of dollars in encryption .

Monetary authority of Singapore (MAS) It is the main agency responsible for supervising the encryption market in Singapore , Its officials are 2018 Nian once said MAS Divide tokens into application tokens 、 Payment tokens and securities tokens .MAS It is not intended to regulate applied tokens , However, the payment bill applicable to payment tokens will be enacted at the end of the year , Securities tokens are applicable to the existing Singapore securities and Futures Act .

Explain according to the official website documents ,MAS The definition of digital payment token is a digital representation of any value , They are not denominated in any currency 、 Not linked to any currency , Can be transferred electronically 、 Store or trade , Intended to be a medium of exchange accepted by the public or part of the public , As a means of paying for goods or services or paying off debts , Such as bitcoin and Ethereum .

As early as 2017 year ,MAS It has been released 《 Digital token issuance guidelines 》, Guide and supervise the issuance of digital tokens in this country , Since then, it has been modified many times and published in 19 The latest version was launched in , It also proposes 11 A specific case .

According to the guidelines , When it comes to issuing tokens of the nature of Securities , The issuer needs to obtain a capital market service license ; When it comes to tokens of the nature of trading securities , The trading platform is certified as a capital market operator (RMO) License plate ; When it comes to providing token related financial advisory services , The company needs to obtain a financial adviser licence . meanwhile , All relevant business operators shall comply with the provisions of relevant laws on anti money laundering and anti terrorist financing .

MAS stay 2019 Launched in 2013 《 Payment services act 》 And take effect the following year , The act requires enterprises engaged in specific payment services to obtain licenses to carry out business activities , These include digital payment token Services , Specific refers to Buy or sell digital payment tokens (DPT)( Commonly known as cryptocurrency ), Or offer to allow people to exchange DPT The platform of ., This is widely regarded as a license for cryptocurrency exchanges .

But so far , Singapore has not yet issued a license to encryption companies , However, some encryption companies have obtained license exemptions for encrypted payment services for a specific period of time , These include Paxos 、Coinbase、Genesis Wait at least 20 companies . meanwhile ,MAS To require cryptographic payment service providers to take strong control measures , For example, fulfill the obligations of customer due diligence and transaction monitoring 、 To the Department of commercial affairs (CAD) Submit suspicious transaction reports , To detect and prevent the flow of illegal funds through Singapore's financial system .

meanwhile ,MAS still 2019 The regulatory sandbox mechanism was launched in , Enable financial institutions and fintech participants to test innovative financial products or services in a real environment but within a clearly defined space and duration , Bond exchange BondEvalue、 Securitized token platform ISTOX Wait until at least two encryption companies are shortlisted .

2020 year 2 month ,MAS Formal approval ISTOX Public listing operation , Provide issuance of securitized tokens 、 Settlement 、 Services such as custody and secondary transactions .2020 year 10 month ,MAS Formal approval BondEvalue For market operators (RMO), Provide blockchain based bond trading services for institutional investors .

The British

The UK financial conduct authority, the main body responsible for the regulation of the encryption market in the UK (FCA), The regulatory purpose is only for anti money laundering and anti terrorist financing .2020 year 1 month ,FCA Gain regulatory authority to oversee how crypto asset companies manage money laundering and counter-terrorism financing risks , Since then, UK crypto asset companies must comply with 《 Money laundering regulations 》(MLR) And to FCA register .

at present , The encryption enterprises that have completed registration are Ziglu、Gemini、Archax、Fibermode、Digivault. Besides , More than 80 Encryption enterprises are on the provisional registration list , Can be found in 2022 year 3 month 31 Temporary operation recently , These include Wintermute、Revolut、Galaxy Digital、Fidelity Digital、eToro、Huobi etc. .

If the encryption enterprise is not on the temporary registration list , It is not allowed to carry out any encryption business activities ,FCA It also published the list of hundreds of unregistered encryption enterprises on the official website , Including the recently warned currency security .

On the official website ,FCA Indicates a serious warning for users to invest in encrypted assets , If the user purchases encrypted assets and has problems , It will be unlikely to have access to the services of the Financial Ombudsman or the financial services compensation scheme , Crypto assets are considered very risky speculative purchases . If you buy encrypted assets , You should be ready to lose all your money .

FCA It does not supervise specific encryption assets and related businesses , But it will still regulate crypto asset derivatives ( For example, futures contracts 、 Contracts for differences and options ), And encrypted assets that are considered Securities ( Securities tokens ). Due to concerns about the volatility and valuation of encrypted assets ,FCA The sale of crypto asset derivatives to retail customers has been prohibited .

stay FCA It seems , Security tokens are tokens that provide certain rights , Including ownership status 、 Repayment of a specified amount 、 The right to share future profits, etc , All the rules involved in traditional securities apply to securities tokens .

at present , The British government is still consulting on the use of stable currency as a means of payment . If the government's proposal is adopted ,FCA Consultations will be held on the application of the proposed rules . This means that the stable currency used for payments and services will be regulated in the future , Protect consumers according to the rules .

Besides ,FCA It has also issued e-money to a number of encryption enterprises (AEMI) The license , These include Circle、Coinbase、Wirex、、 The license enables these enterprises to distribute and create e-wallets on behalf of customers 、 Mobile payment 、 Global remittance and other businesses , And opening separate accounts to store customers' funds .

Hong Kong

The SFC is the main regulator of encrypted assets in Hong Kong , Over the years, it has mainly supervised securities tokens , There are no clear regulatory policies for other types of encrypted assets and trading platforms , So far FTX、BitMEX、Bitfinex And other well-known cryptocurrency exchanges .

2017 year 、2019 year , The SFC of Hong Kong will issue the first token respectively (ICO) And securities tokens (STO) Make a statement , Clearly representative of shares 、 Cryptocurrencies for interests such as debentures and collective investment plans are considered to be negotiable securities , Transactions related to securities tokens 、 consulting 、 Fund management 、 Distribution activities will be affected by Hong Kong 《 Securities and Futures Ordinance 》 Supervision of . Relevant institutions must be licensed or registered with the SFC . And not belong to negotiable securities or Futures contracts Encrypted assets within the scope of legal definition , According to the SFC 2018 year 11 Regulatory framework statement issued in June , Its market is unregulated .

2019 year 3 month 《 Statement on the issue of security token 》 It's also clear , Securities tokens can only be sold to professional investors ( In Hong Kong , Individual professional investors are those who own 800 Investors with current assets of HK $million and rich investment records in the past year ).

Trading platform supervision , Hong Kong from 2018 The exploration period of the regulatory framework began in , Recently, there has been a tightening trend . all the time , Hong Kong has not legislated or amended laws specifically for encrypted assets and their related businesses , Regulators can only introduce regulatory policies within the existing legal framework , Regulatory power and space are relatively limited .

2019 year 11 month , Hong Kong SFC Release 《 Position paper on supervision of virtual asset trading platform 》, The trading platform licensing system has been formulated , And publish the specific licensing terms and conditions . The system is only for Provide at least one platform for securities based virtual asset trading service .

The licensing conditions mainly include : The platform party can only provide services to professional investors , Develop criteria for strict inclusion of assets and provide services only to customers who are fully aware of virtual assets , Run the external market monitoring system , And ensure that the insurance related to the risk of hosting encrypted assets takes effect at any time .

Under this mechanism ,2020 year 12 month 15 Japan , Hong Kong Securities Regulatory Commission to the first encrypted asset trading platform OSL Licensing . The listed company BC Technology Group's digital asset trading platform OSL get SFC Chapter II under the regulatory framework 1 Class and 7 Class license plate , Separately licensed to operate securities trading ( Brokerage services ) And provide automated trading services .

thus , Under the current regulatory regulations , Non securities crypto assets and their financial activities have been in an unregulated state . until 2020 end of the year , The financial services and the Treasury Bureau of the HKSAR government issued a legislative consultation document , It is proposed in 《 Anti money laundering and terrorist financing regulations 》 All encrypted asset trading platforms will be fully implemented Compulsory licensing system .

2021 year 5 month 21 Japan , The Hong Kong Finance Bureau issued the legislative consultation summary . This file shows , Most respondents supported the development of the licensing system . The above amendment to the anti money laundering regulations is considered to plug the regulatory loophole of non securities token transactions . At present, the regulation is still in the revision stage , The bill will be introduced in 2021-2022 It will be submitted to the Legislative Council of Hong Kong for deliberation in the legislative year .

South Korea

South Korea is one of the countries with active cryptocurrency trading market , Due to the high enthusiasm of cryptocurrency investors in the country , The bitcoin price market of the country's exchange is higher than that of other exchanges in the world , go by the name of Kimchi premium . In recent years , South Korean regulators have gradually strengthened the supervision of the encryption market , At present, it has become one of the countries with the most clear regulatory mechanism in the encryption market .

2017 year 9 month , Responsible for managing and supervising digital assets, Korean Financial Services Commission (FSC) Means that all forms of... Are prohibited ICO Behavior , But there is no regulatory policy for cryptocurrency exchanges , The implementation of self-regulation is mainly promoted by the Korean blockchain Association , thereafter Bithumb、Upbit When the Korean exchange develops rapidly .

2020 year 3 month , The Korean government approved the revised 《 Reporting and using information on specific financial transactions 》 And this year 3 Effective month , According to the law , All virtual asset service providers ( This includes the custodian 、 Exchanges and brokerage firms ) Must be in 9 month 25 Registered with the Korean Financial Intelligence Center before the th , Regularly report transaction data , Otherwise, they will be severely punished .

meanwhile , Virtual asset service providers also need to obtain information security management systems (ISMS) Management Certificate , And open a real name account under the guidance of the bank , To prevent money laundering . At present, only Korbit、Bithumb、Coinone and Upbit Such as the exchange meets the real name trading regulations .

Due to the above strict regulatory rules ,OKEx South Korea and other exchanges have decided to withdraw from the South Korean market before the new regulations take effect . meanwhile ,10 More than exchanges in operation began to take a large number of high-risk currencies off the shelves .

at present , The Korean government has not recognized cryptocurrency as a financial asset , But it's already in 2020 year 12 In June, it announced that a tax would be imposed on investors' income , If investors use encrypted assets such as bitcoin to earn more than 250 All the won ( about 2200 dollar ), You must pay 20% The tax rate of .

This year, 6 month , The South Korean parliament began to discuss legislation on encrypted assets , Enter the encryption asset industry, develop and protect investors .


Thailand is also one of the countries with a relatively perfect regulatory system for encrypted assets in the world , since 2018 Since, a number of clear licensing mechanisms have been launched to regulate the development of the domestic encryption industry .

2018 year 5 month , Thailand SEC Official release 《 Digital assets act 》, To encourage technological innovation , Provide various financing tools to enterprises in a position to do so , At the same time, ensure the purchase of digital assets 、 Sale or exchange is fair 、 Transparent and responsible , And establish a mechanism to maintain the national financial system and macroeconomic stability .

According to the law , Digital assets are divided into cryptocurrencies (Cryptocurrency) And digital tokens (Digital Token), The first type of digital assets is used as common money to exchange goods and services or as a medium of exchange , The second category of digital assets is according to the regulations of the securities and Exchange Regulatory Commission , For the project / Invest in business and exchange goods / service / Any other interest .

meanwhile , The law divides digital asset business operators in Thailand into digital asset exchanges 、 Digital asset brokers 、 Digital asset dealers , Operators of each type of business need to apply for corresponding licenses to operate relevant businesses . Besides , Thailand SEC Also for publishing ICO The information of ICO The portal has set up a license mechanism .

Up to now , Thailand SEC Already directed Upbit、Huobi、BITKUB etc. 8 Companies have issued digital asset exchange licenses , towards Upbit etc. 6 Companies have issued digital asset dealer licenses , towards Longroot etc. 4 The company issued ICO Portal license .

Thailand SEC It also formulates the corresponding tax mechanism for digital asset transactions , Individual investors should pay for their digital asset transactions 7% VAT and 15% Return capital gains tax .

However, under these relatively complete encrypted asset supervision mechanisms , Thailand SEC It still maintains a strict regulatory attitude towards the development of the domestic encryption industry , For example, in DeFi aspect , This year, 5 In June, the Thai licensed exchange Bitkub For its DeFi platform Tuktuk Finance Issue tokens , But soon SEC Warn them , Weigh and DeFi Relevant activities may require permission from financial regulators in the future .

This year, 6 month , Thailand SEC It also announced that the exchange is prohibited from providing trading services for the following types of encrypted assets :(1)Meme Tokens, : Having no clear objective or substance or basis , Its price moves with social media trends ;(2) Fan token (Fan Token): Monetized by the popularity of wanghong ;(3) Irreplaceable tokens (NFT): A digital creation , Used to declare the ownership or right of an object or the grant of specific rights ;(4) Digital tokens issued by digital asset exchange or related personnel for blockchain transactions .

thereafter , Thailand SEC One after another asked Huo coin Thailand to stop its operation 、 Sue Qian an , And issued an announcement urging listed companies to be particularly cautious when purchasing digital assets , It is also suggested that listed companies with relevant plans take the initiative to cooperate with SEC communication .

Other countries

2020 year 1 month , Germany implements 《 EU No 4 Money laundering directive No 》 The government's draft came into force , The law means that encrypted assets do not have the legal status of money or money , However, it can be accepted by natural or legal persons as the method of payment , Or for investment purposes , By 《 German banking law 》 As a financial instrument . meanwhile , All encryption custody enterprises that manage digital keys for investors are subject to the supervision of the German federal financial regulatory authority ,Coinbase It is the first enterprise to obtain the license .

This year, 8 month 2 The date of , Germany's new 《 Fund positioning method 》 For the first time, some institutional level funds will be allowed to invest in cryptocurrency assets on a large scale , The highest proportion of the portfolio is no more than 20%.

2020 year 6 month , Canada 《 Proceeds of crime ( Money laundering ) And the terrorist financing act 》 The amendment to the Convention entered into force , One of the amendments confirms the asset attributes of cryptocurrencies such as bitcoin , Exchange cryptocurrency 、 Payment processors and other cryptocurrency companies are legally recognized as money service businesses (MSB) And then incorporated into the regulation .

2021 year 1 month , Russia 《 Digital financial assets law 》 In force , The law requires Russian officials or individuals holding public office to disclose their digital assets , And the digital assets of their spouses and children . meanwhile , The law prohibits certain Russian officials from holding any cryptocurrency , For example, the board of directors of the Central Bank of Russia 、 Employees of listed companies owned by the Russian Federation .

2021 year 6 month , Australian Securities and Investment Commission (ASIC) Said it would seek market opinions on a series of encryption market supervision proposals , Plan pricing for these encrypted assets 、 hold 、 Establish a code of conduct for risk management and information disclosure , To protect retail investors and maintain fair market behavior . before , Australia only requires the cryptocurrency exchange to be regulated by the Australian Financial Intelligence Agency , And fulfill the anti money laundering and anti terrorist financing compliance and reporting obligations .



According to the Financial Action Task Force (FATF) This year, 7 Monthly data , at present 128 In... Jurisdictions 58 Indicates that the revised... Has been implemented FATF standard , among 52 Regulatory virtual asset service providers in multiple jurisdictions , 6 Three jurisdictions prohibit the operation of virtual asset service providers .

In the near future , Many governments have issued warnings to some cryptocurrency exchanges , The main reason is the provision of derivatives trading and not registered in the country , It also reflects that more and more countries are no longer laissez faire to cryptocurrency transactions , Start to take the initiative .

For now , Crypto assets are playing an increasingly important role in global financial markets , Therefore, more and more countries are developing corresponding regulatory mechanisms , However, at present, most countries mainly carry out corresponding supervision for the defensive purpose of anti money laundering and anti-terrorism financing risk , Instead of supervision for the main purpose of promoting the progress of the industry .

In some countries with clear regulatory mechanisms , Encrypted assets are usually clearly divided into different types of tokens , For example, it is divided into practical tokens 、 Payment tokens and security tokens , It also requires securities tokens to be managed in accordance with the relevant requirements of the securities law , Other types of tokens are less regulated .

Besides , Japan 、 Singapore 、 South Korea 、 The British 、 Germany and New York state of the United States have launched license systems for encryption enterprises , Among them, Singapore 、 Hong Kong 、 Japan and other Asian regions are the most friendly , Attract many encryption enterprises to establish business locally and even move their headquarters , Become the center of the current encryption market .

With DeFi、NFT And the rapid development of new things , The problem of encryption market supervision faced by countries and regions around the world is becoming more and more complex , How to deal with the balance between the inclusiveness of market innovation and the risk of financial stability , In particular, it will test the of governments Governance capacity and Strategic vision .

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