While the European Union and United Kingdom push forward with cautious crypto frameworks, the United States is suddenly emerging as a front-runner in global digital asset policy thanks to a blitz of legislation, political momentum and massive ETF inflows.
In the latest episode of Byte-Sized Insight, Cointelegraph head of podcasts Savannah Fortis is joined by Mark Jennings, head of Europe at Gemini, to break down how the US, EU and UK are approaching crypto regulation and what it means for innovation, adoption and investment across the West.
The US and EU advantage
“We’ve seen the administration push legislation very quickly as it’s come in this year,” said Jennings. “It became a topic of conversation during the presidential election, and I think it highlights the importance of crypto globally, that it becomes a talking point at that level.”
“[A] positive move the administration has made by providing legislation very quickly. It allows companies to grow, to scale, to innovate because they have the ability to allocate capital and understand what that investment will look like.”
The US still has a way to go before getting some important bills set in stone. Additionally, it may also face regulatory fragmentation at the state level, similar to the situation in Europe, where 30 national regulators are now tasked with implementing the EU’s MiCA regulation.
MiCA, adopted in 2023, is widely considered the world’s most comprehensive crypto regulatory framework. “Where we get to now with MiCA, it’s built a full infrastructure that views cryptocurrency as another asset class,” Jennings said.
“It allows us to operate once we’ve received the license in every European jurisdiction… and it allows us to properly scale.”
Related: Bybit, OKX expand crypto services in Europe under MiCA
The UK’s crypto push
Meanwhile, the UK’s post-Brexit approach is lagging. Though it recently lifted a ban on crypto ETNs, a full regulatory framework remains a work in progress. Jennings said the country is taking a more deliberate route.
“I think the UK has taken a wait-and-see approach,” he said.
“They want to understand how this framework plays out… They may benefit from that second mover advantage to see what happens with MiCA, what happens with US legislation, and take the best parts of both.”
Still, Jennings cautions that innovation moves fast and regulators need to keep pace. “Sometimes you’ve got to wait and see… but also see what happens in other jurisdictions and maybe be somewhat reactive and somewhat proactive,” he said.
“To me, that’s a more measured approach and focuses on the benefits of cryptocurrency and blockchain technology, rather than potentially stifling innovation.”
Listen to the full episode of Byte-Sized Insight for the complete interview on Cointelegraph’s Podcasts page, Apple Podcasts or Spotify. And don’t forget to check out Cointelegraph’s full lineup of other shows!
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