With Singapore retreating from its crypto-friendly stance and the U.S. stepping forward with bipartisan crypto bills and a presidential memecoin, global crypto regulation is at a crossroads. Who will lead the digital financial future?
As nations around the globe navigate the fast-moving world of digital finance, their divergent approaches to cryptocurrency regulation are beginning to shape a new global crypto order—one where the United States is suddenly at the helm.
While the U.S. moves swiftly to embrace crypto with broad bipartisan support behind two key legislative proposals—the Clarity Act and the Genius Act—other nations are retreating or recalibrating. Notably, Singapore, once a trailblazer in digital assets, is now pulling back.
On June 6, the Monetary Authority of Singapore (MAS) introduced stringent new licensing requirements for “digital token service providers” engaging with clients beyond its borders. These entities have been given until June 30 to comply, with the regulator stating that it “will not generally issue a license,” citing “money laundering risks are higher in such business models.”
Still, Chengyi Ong, head of Asia-Pacific policy at crypto analytics firm Chainalysis, downplayed the significance of the announcement. “The regulators imagine that only a small sliver of the ecosystem will be affected,” Ong explained. She noted that over 30 crypto companies, including major players such as Coinbase Global and Circle Internet Group, are already licensed in the city-state.
Others argue the tone behind Singapore’s move is what truly matters. “Singapore is signaling that crypto is not a strategic priority,” said Hagen Rooke, a partner at law firm Gibson, Dunn & Crutcher. “It’s mainly focused on all the risks.”
Singapore had initially adopted what Ong described as a “relatively light-touch regulatory regime,” when it introduced the Payment Services Act in 2020. However, the landscape changed after the tumultuous “crypto winter” of 2022, which left a significant mark on the nation. Singapore’s sovereign wealth fund Temasek Holdings suffered losses after investing in the now-defunct FTX, and the collapse of Singapore-based hedge fund Three Arrows Capital wiped out $10 billion in customer assets.
This regulatory pivot has opened the door for other crypto-friendly hubs to rise. The United Arab Emirates (UAE), particularly Dubai and Abu Dhabi, is emerging as a key rival. Dubai hosted the Token2049 conference last month, featuring Eric Trump and drawing over 10,000 attendees. Meanwhile, Abu Dhabi’s MGX wealth fund recently injected $2 billion into Binance, despite the firm’s failure to obtain a Singapore license.
“People are going back to the Middle East,” noted Sheila Warren, chief strategy officer at Project Liberty, which explores the impact of digital systems on society.
In Asia, Hong Kong remains a strong contender, while Japan is also inching forward. Tokyo recognized Bitcoin as legal tender as early as 2016 and plans to officially regulate digital assets in 2026. Still, high tax rates remain a stumbling block. “The main thing holding them back is taxation,” said Warren, noting that Japan currently treats crypto profits as “miscellaneous income,” taxing them at rates up to 55%. The ruling Liberal Democratic Party is pushing to bring this down to the capital gains standard of 20%.
All eyes are now on the United States, where industry momentum is rapidly building. “Our clients are falling all over each other to figure out how to enter the U.S.,” Rooke observed.
Ong believes U.S. regulation could ignite global adoption rather than divert it from smaller markets. “This is not a zero-sum game,” she said. “A pro-crypto posture in the U.S. is fueling interest around the world.”
Despite stark contrasts in tone—Singapore’s caution, Dubai’s enthusiasm—Ong argues that jurisdictions have learned from past missteps. “Jurisdictions are not trying to compete on the laxness of their regimes,” she emphasized.
Now, the global industry waits for Washington’s next move.
