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10 Gibraltar International www.gibraltarinternational.comguarantees. Whitepaper disclosures are now mandatory, and exchanges and custodians must meet strict operational and security criteria.%u201cMiCA signals the end of regulatory ambiguity in Europe and sets the stage for a new wave of responsible innovation,%u201d said Verena Ross, Chair of the European Securities and Markets Authority (ESMA).Projects operating across the EU now benefit from passporting rights, enabling them to access all member states through a single regulatory licence - a major efficiency gain for the sector.The UK%u2019s Post-Brexit approachThe UK has opted for a bespoke regulatory model, aligning crypto oversight with traditional financial services under the Financial Services and Markets Act (FSMA). The FCA is expanding its supervisory role, requiring digital asset platforms to meet anti-money laundering (AML), consumer protection, and operational resilience standards.While the UK%u2019s approach is more incremental than the EU%u2019s, it is firmly principled. Stablecoins used for payments will be regulated under e-money rules, and broader crypto regulation will follow a phased implementation.%u201cWe%u2019re aiming to build one of the most open, well-regulated, and technologically advanced capital markets in the world,%u201d said Andrew Griffith MP, former Economic Secretary to the Treasury, in a 2024 policy speech.The US Regulatory patchworkIn contrast, the United States continues to grapple with a fragmented regulatory approach. The Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) are competing for jurisdiction, leading to confusion and legal challenges.High-profile enforcement actions have rocked the industry. Several major exchanges have faced lawsuits over alleged unregistered securities offerings. However, legislative proposals like the Financial Innovation and Technology for the 21st Century Act suggest that bipartisan appetite for a clearer framework is building.Until such laws are passed, US firms must navigate complex state-by-state licensing schemes and inconsistent federal oversight - a stark contrast to the relative clarity emerging in Europe.Gibraltar, a proven, principles-based frameworkWhile newer regimes are only now taking shape, Gibraltar has been regulating cryptoasset businesses since 2018 under its DLT Regulatory Framework, making it one of the earliest jurisdictions to adopt bespoke legislation for blockchain companies.Regulated by the Gibraltar Financial Services Commission (GFSC), the framework is based on 10 core principles, including risk management, security, and governance. Importantly, the regime allows for flexibility and innovation, while maintaining a clear emphasis on consumer protection and market integrity.Gibraltar took a forward-looking approach - balancing innovation with robust oversight. Gibraltar remains a jurisdiction that welcomes serious operators who want to be regulated.This pioneering approach has attracted several leading firms in blockchain finance, who value regulatory clarity as a long-term competitive advantage.The push for global standardsAs crypto matures, so too does the conversation around global coordination. Bodies such as the Financial Stability Board (FSB) and the International Organisation of Securities Commissions (IOSCO) are developing frameworks for cross-border supervision and risk management.This push is essential: without common standards, regulatory arbitrage remains a risk, and fragmented rules can stifle global innovation. %u201cWe need regulation that is coordinated, consistent, and technologyneutral. Fragmentation helps no one,%u201d said Kristalina Georgieva, Managing Director of the International Monetary Fund (IMF) at the 2025 Davos summit.Compliance as catalystWith regulation now a key determinant of long-term success, compliance is no longer seen as a barrier but as a strategic asset. Crypto firms that proactively align with regulatory expectations are not only future-proofing themselves but also earning the trust of institutional investors, banks, and end-users. Whether under MiCA in Europe, the FCA%u2019s evolving UK framework, or Gibraltar%u2019s early and mature DLT regime, the message is clear: the age of regulatory uncertainty is coming to an end. The next phase of the crypto industry will be defined not just by innovation, but also by its ability to integrate responsibly into the broader financial system.Gibraltar Finance ReportContinued from p8www.gibraltarfinance.giWe%u2019re aiming to build one of the most open, well-regulated, and technologically advanced capital markets in the world