全球加密资产监管实践及潜在影响

Core Viewpoint - The article discusses the evolving regulatory landscape for cryptocurrency assets globally, highlighting a trend towards more lenient regulations, particularly in the United States under Trump's administration, which is expected to influence other economies [1][18][22]. Group 1: Definition and Classification of Cryptocurrency Assets - There is no unified definition of cryptocurrency assets globally; terms like "cryptocurrency," "crypto assets," "virtual assets," and "digital assets" are often used interchangeably. The Financial Stability Board (FSB) defines crypto assets as private sector digital assets primarily relying on cryptography and distributed ledger technology (DLT) [2][6]. - Cryptocurrency assets are categorized into three main types: cryptocurrencies (e.g., Bitcoin, Ethereum), stablecoins (which have value stabilization mechanisms), and asset tokenization (where off-chain assets are represented on the blockchain) [5][6]. Group 2: Regulatory Positions of Major Economies - Regulatory stances on cryptocurrency assets can be classified into three categories: prohibition (e.g., China, Bangladesh), open attitude with minimal regulation (e.g., Switzerland, UAE), and regulated environments (e.g., the US, EU, Japan, UK) [7][8]. - The US lacks a unified federal regulatory framework, with 32 states being friendly towards crypto assets and 18 states imposing strict regulations. The EU's MiCA regulation, effective from June 30, 2023, is the most comprehensive framework to date [8][9]. Group 3: Specific Regulatory Developments - The US is moving towards a more supportive regulatory framework for cryptocurrency assets, with Trump signing an executive order to establish a digital asset market working group and develop a federal regulatory framework within 180 days [11][12]. - The EU's MiCA requires crypto asset issuers to disclose project information, maintain sufficient reserve assets, and meet minimum capital requirements, while also mandating licensing for service providers [12][13]. - Japan is considering easing tax requirements on crypto assets and aligning them with existing financial product regulations, while the UK plans to introduce a comprehensive regulatory framework by 2026 [14]. Group 4: International Regulatory Standards - International standard-setting bodies are working to create global regulatory benchmarks to avoid fragmentation and regulatory gaps in cryptocurrency asset oversight. The FSB has issued high-level recommendations for regulating crypto assets and global stablecoins [15][17]. Group 5: Dynamic Regulatory Landscape - The global regulatory environment for cryptocurrency assets is shifting towards leniency, influenced by the US government's supportive stance, which may encourage other countries to follow suit. This trend is evident as countries like Russia and several Middle Eastern nations are relaxing their regulations [18][21][23].