How International Coordination Shapes Crypto Regulation

Crypto Regulation Coordination Explorer
FSB Framework
Risk-based, same-activity-same-regulation approach
2023UK-US Tech Deal
Innovation-friendly, cross-border sandbox
2025MiCA Regulation
Precautionary, consumer-focused
2025IOSCO Recommendations
Principles-based securities alignment
2023Initiative | Primary Lead | Philosophy | Scope | Timeline |
---|---|---|---|---|
FSB Recommendations | Financial Stability Board | Risk-based, same-activity-same-regulation | All crypto-assets, stablecoins | 2023 release, 2025 alignment goal |
UK-US Tech Propensity Deal | UK Treasury & US Treasury (SEC/CFTC) | Innovation-friendly, market-driven | Spot trading, DeFi, stablecoins | Signed 2025, sandbox pilots 2026 |
MiCA (EU) | European Commission | Precautionary, consumer-protective | Crypto-assets, stablecoins, service providers | Effective 2025, full compliance 2026-27 |
IOSCO Policy Recommendations | International Organization of Securities Commissions | Principles-based, securities-aligned | CASPs, token offerings | 2023 adoption, ongoing peer reviews |
- Stablecoins High Priority
- Cross-border Enforcement Moderate
- Consumer Protection High Priority
- DeFi Integration Emerging
Global Coordination Impact: By aligning regulatory philosophies, these initiatives aim to reduce regulatory arbitrage and provide clearer paths for market participants navigating cross-border crypto activities.
Quick Takeaways
- The Financial Stability Board (FSB) leads a global push for "same activity, same risk, same regulation" across 93% of its members.
- The UK‑US Tech Propensity Deal (2025) creates the first trans‑Atlantic template for crypto oversight.
- The EU’s MiCA regulation offers a more risk‑averse, consumer‑focused model that runs alongside other global efforts.
- US agencies (SEC, CFTC) are coordinating through joint statements and roundtables to close domestic gaps.
- Future progress hinges on cross‑border sandboxes, technical standards, and aligning CBDC and private‑crypto rules.
Why Global Coordination Matters
Crypto assets don’t respect borders. A stablecoin issued in one jurisdiction can be traded on an exchange in another, and a DeFi protocol can be accessed from anywhere with an internet connection. When regulators act in isolation, market participants face contradictory rules, compliance headaches, and the risk of regulatory arbitrage. International coordination aims to replace that patchwork with a clearer, more predictable framework, fostering innovation while protecting investors and financial stability.
Key International Bodies Setting the Stage
Financial Stability Board is a global standard‑setter that issued comprehensive recommendations on crypto‑assets and stablecoins in July2023. Its guiding principle-"same activity, same risk, same regulation"-provides a baseline for member jurisdictions to align their rules. As of October2024, 93% of FSB members have pledged to develop or revise crypto‑asset frameworks, and over half expect alignment by 2025.
International Organization of Securities Commissions (IOSCO) released eighteen policy recommendations in November2023, extending securities‑market standards to Crypto Asset Service Providers (CASPs). The recommendations dovetail with the FSB framework, reinforcing a cohesive global approach.
Financial Action Task Force (FATF) focuses on anti‑money‑laundering and counter‑terrorism financing. Its Recommendation15, updated through mid‑2025, obliges jurisdictions to enforce AML/KYC rules on crypto‑asset activities, ensuring that cross‑border flows remain under watch.
Bilateral Leadership: The UK‑US Tech Propensity Deal
On 18September2025, the United Kingdom and the United States announced the Tech Propensity Deal, a trans‑Atlantic partnership that sets out a joint regulatory roadmap for digital assets. The deal leverages the UK’s fintech ecosystem and the US’s deep capital markets to create a template that could influence global standards. Key outcomes include:
- Shared definitions for crypto‑assets, stablecoins, and DeFi products.
- Co‑ordinated supervision of cross‑border exchanges.
- Joint research on systemic risk and market integrity.
The partnership also proposes a cross‑border sandbox where firms can test innovations under a harmonized supervisory regime-a concept championed by SEC Commissioner Pierce.

European Counterpart: MiCA Regulation
The European Union’s Markets in Crypto‑Assets (MiCA) regulation, fully in effect by mid‑2025, takes a more precautionary stance. MiCA mandates:
- Licensing for crypto‑asset service providers operating in the EU.
- Strict capital and liquidity buffers for stablecoin issuers.
- Robust consumer‑protection disclosures and marketing limits.
While MiCA shares the FSB’s risk‑based philosophy, it imposes tighter compliance requirements, reflecting the EU’s emphasis on market integrity. The EU continues to monitor the UK‑US deal, ready to adjust its approach if the trans‑Atlantic model proves effective.
US Domestic Coordination: SEC&CFTC Joint Actions
Within the United States, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have moved from rivalry to collaboration in 2025. Their joint statements in August and September clarified that exchanges regulated by either agency may list certain spot commodity products, reducing uncertainty for market participants.
The September29,2025 roundtable tackled practical issues-trading‑hours extensions, perpetual contracts, shared margining, and DeFi innovation exemptions. These discussions feed into the SEC’s Regulatory Flexibility Agenda, which currently lists crypto‑related rule proposals at the “proposed rule” stage.
Although the SEC‑FINRA joint statement on crypto assets was withdrawn in May2025, the agencies continue public engagement through roundtables running through December2025, gathering industry feedback to shape forthcoming regulations.
Cross‑Border Challenges That Remain
Even with high‑level agreements, several friction points persist:
- Legal heterogeneity: Civil‑law jurisdictions (EU) and common‑law jurisdictions (US, UK) interpret risk and consumer‑protection concepts differently.
- Off‑shore compliance gaps: Many issuers base operations in low‑regulation jurisdictions, evading supervisory reach.
- Stablecoin stability: No universal reserve‑backing standard exists, leaving issuers vulnerable to runs.
- CBDC interaction: With 91% of central banks exploring CBDCs, aligning public and private digital‑asset rules adds technical and policy complexity.
Addressing these gaps will require more than policy statements; concrete mechanisms for information sharing, joint enforcement actions, and interoperable technical standards are essential.
Comparison of Major Coordination Initiatives
Initiative | Primary Lead | Regulatory Philosophy | Scope (Assets) | Implementation Timeline |
---|---|---|---|---|
FSB Recommendations | Financial Stability Board | Risk‑based, same‑activity‑same‑regulation | All crypto‑assets, stablecoins | 2023release, 2025alignment goal |
UK‑US Tech Propensity Deal | UK Treasury & US Treasury (SEC/CFTC) | Innovation‑friendly, market‑driven | Spot trading, DeFi, stablecoins | Signed2025, sandbox pilots 2026 |
MiCA (EU) | European Commission | Precautionary, consumer‑protective | Crypto‑assets, stablecoins, service providers | Effective2025, full compliance2026‑27 |
IOSCO Policy Recommendations | International Organization of Securities Commissions | Principles‑based, securities‑aligned | CASPs, token offerings | 2023adoption, ongoing peer reviews |
Looking Ahead: What Will Shape the Next Wave?
Three trends are likely to drive the next phase of coordination:
- Technical standardization: Interoperability protocols for cross‑chain transfers and stablecoin reserves will need global consensus, perhaps through a new ISO working group.
- Cross‑border enforcement hubs: The FSB is considering a centralized information‑sharing platform that would enable rapid joint investigations.
- Sandbox expansion: Successful UK‑US sandbox pilots could inspire a multilateral sandbox network, allowing firms to test compliance under multiple regulators simultaneously.
Ultimately, the success of international coordination will be judged by two metrics: the reduction of regulatory arbitrage opportunities and the clarity investors receive when navigating crypto markets. If the current momentum continues, we may see a de‑facto global baseline for crypto regulation by the early 2020s, even if regional nuances remain.

Frequently Asked Questions
How does the FSB framework differ from the EU’s MiCA?
The FSB focuses on a risk‑based, principles‑first approach that allows jurisdictions flexibility in implementation. MiCA, by contrast, spells out detailed licensing, capital, and consumer‑protection rules, offering less flexibility but greater certainty for market participants operating in the EU.
What is the Tech Propensity Deal?
Signed on 18September2025, the Tech Propensity Deal is a UK‑US agreement that sets a joint roadmap for regulating digital assets, including shared definitions, coordinated supervision of cross‑border exchanges, and a planned trans‑Atlantic sandbox for innovation.
Why are stablecoins a particular focus for regulators?
Stablecoins can act like digital cash, so a loss of confidence can trigger rapid runs on the issuer’s reserves, creating systemic risk. Regulators therefore demand clear reserve‑backing, liquidity requirements, and consumer‑protection measures.
How are the SEC and CFTC coordinating in 2025?
They have issued joint statements clarifying jurisdiction over spot commodity products, held a roundtable on harmonizing market structure, and are collaborating on rule proposals that cover DeFi and perpetual contracts.
What role does FATF play in global crypto oversight?
FATF sets anti‑money‑laundering standards, notably Recommendation15, which obliges member countries to apply AML/KYC rules to crypto‑asset service providers. Its peer‑review process drives consistent enforcement worldwide.
24 Comments
They’re hiding the true agenda behind the FSB, and nobody notices.
Oh, the grand tapestry of international crypto regulation – it reads like a science‑fiction novel penned by a committee that thinks “risk‑based” is a secret code for “let’s keep everyone guessing.” The FSB’s “same‑activity‑same‑regulation” mantra sounds noble until you realize it gives each jurisdiction a free pass to interpret “same activity” however they please. Meanwhile, the UK‑US Tech Propensity Deal boasts of “innovation‑friendly” sandbox environments, yet those sandboxes often feel like back‑alley poker tables where only the well‑funded get a seat. MiCA’s consumer‑protective stance is commendable, but its prescriptive licensing regime could drown startups in paperwork faster than a shark in a bathtub. IOSCO’s principles‑based approach is a breath of fresh air – if you can actually breathe through the dense legal jargon that accompanies it. The FATF’s AML/KYC thrust is essential, but it often ends up as a bureaucratic maze that criminal actors simply bypass by hopping to offshore havens. Cross‑border enforcement remains a patchwork quilt, each piece stitched by different time zones and political will. Stablecoins, the darling of regulators, continue to wobble without a universal reserve‑backing standard – a recipe for systemic risk that no one wants to admit. The rise of DeFi integration is exciting, yet it also opens a Pandora’s box of untested protocols that regulators scramble to categorize. CBDC interactions add another layer of complexity, as sovereign digital currencies begin to intersect with private crypto assets in ways that no textbook covered. The whole ecosystem feels like a high‑stakes juggling act where the balls are on fire and the juggler keeps adding more. Yet, the coordinated sandbox pilots slated for 2026 could serve as a proof‑of‑concept for truly harmonized oversight, provided they’re not bogged down by endless inter‑agency memorandums. Technical standardization, especially for cross‑chain transfers, remains an Achilles’ heel that no global body has fully addressed. Information‑sharing platforms proposed by the FSB could revolutionize joint investigations, but only if member states agree to real‑time data exchange without sovereignty concerns. In short, while the momentum toward a de‑facto global baseline is palpable, the devil remains in the details – and those details are scattered across continents, time zones, and relentless regulatory agendas.
One might contemplate the ontological ramifications of a "risk‑based" paradigm when applied to assets untethered from nation‑states. The epistemic scaffolding of the FSB is, in effect, an attempt to impose a metaphysical order upon a digital ether that resists such codification. Yet, therein lies the dialectic: regulation must both illuminate and constrain. :) It is, perhaps, a Sisyphean endeavor, but one that begets a certain aesthetic of disciplined innovation.
Interesting overview, very thorough, and I appreciate the nuanced breakdown, especially the sections on cross‑border enforcement, which often gets sidelined, yet remains crucial, for creating a cohesive regulatory environment, and the emphasis on stablecoin reserves, which is a timely reminder, of the systemic risks involved.
Wow, look how the US and the UK are suddenly the poster children for “innovation‑friendly” regulation-like nothing else matters but our two‑nation friendship. It’s almost comical how the rest of the world is expected to bend to the whims of a trans‑Atlantic sandbox while we pretend it’s all about protecting consumers. The whole thing smacks of techno‑nationalism, where the narrative is: if you’re not American or British, you’re just a regulator waiting to be left behind. The irony is palpable, given that most of the real crypto activity happens in places that don’t speak English. And yet, here we are, patting ourselves on the back for a deal that barely scratches the surface of global coordination.
Great synthesis! For anyone looking to dive deeper, the IOSCO recommendations are a solid starting point-they’re less about heavy‑handed rules and more about guiding principles that can adapt to local contexts. Also, the upcoming FSB information‑sharing platform could be a game‑changer for enforcement across borders. Happy to answer any follow‑up questions you might have.
I’m glad to see the article highlight the sandbox pilots; they could really lower the entry barrier for smaller innovators. That said, the success will hinge on clear metrics and transparent reporting, otherwise it’s just another bureaucratic experiment. It’ll be interesting to watch how the EU’s MiCA adapts once the sandbox data starts flowing in.
The jargon overload in these coordination frameworks is staggering-risk‑based, principle‑based, AML/KYC, CBDC… It’s a veritable lexicon of regulatory buzzwords that mask the underlying operational challenges. Without concrete technical standards for cross‑chain liquidity, we’re left with a house of cards that could collapse under market stress. The real work begins when these bodies move from policy statements to enforceable protocols.
Loving the clarity of the quick takeaways. The bullet points really help cut through the noise.
Thats a big miss.
I think it’s worth noting that the FSB’s alignment goal for 2025 still feels optimistic. Many member jurisdictions are still drafting their own domestic frameworks, which could lead to inconsistencies. Still, the collaborative spirit is a step in the right direction.
The article does a decent job of mapping out the major players, but it glosses over the political tug‑of‑war behind each initiative. The EU’s precautionary stance, for example, is as much about market control as consumer safety. Likewise, the US‑UK deal is driven by a desire to stay ahead of China’s digital currency ambitions.
One cannot help but marvel at the choreography of these global bodies, each stepping onto the stage with a different rhythm, yet pretending to waltz together. The FSB’s risk‑based hymn, the IOSCO’s principle‑laden aria, and MiCA’s operatic caution-all converge in a cacophonous symphony that nevertheless manages to keep the audience-i.e., the market-on its toes.
It’s clear that aligning definitions is critical. Without a shared language, enforcement becomes a game of telephone.
While the drive toward coordination is commendable, it tacitly assumes that all jurisdictions share the same moral compass when it comes to consumer protection. This overlooks the fact that some regimes prioritize sovereign revenue over investor safety. Moreover, the emphasis on stablecoins as a “systemic risk” metric ignores the innovative potential they hold for financial inclusion. The narrative also fails to address how emerging markets will be forced to adopt standards that may be ill‑suited to their infrastructural realities. In short, the optimism should be tempered with a realistic assessment of geopolitical power dynamics.
Let’s be real: the tech deal sounds shiny, but it’s basically a marketing ploy to sell the West’s regulatory model. The jargon about “shared definitions” is just code for “we’ll dictate the terms.” If you ask me, the real innovation will happen in the shadows, away from the prying eyes of these committees.
It is incumbent upon the scholarly community to scrutinize the procedural rigor of these initiatives with a level of formality befitting their gravitas. The FSB’s risk‑based schema, while ostensibly comprehensive, lacks explicit quantification metrics, thereby rendering its implementation susceptible to interpretative variance. Likewise, the IOSCO recommendations, though principle‑oriented, suffer from a paucity of enforceable deterrents, which may engender regulatory arbitrariness. The EU’s MiCA, conversely, exemplifies a prescriptive approach, yet its stringent licensing requisites risk stifling nascent enterprise. In sum, the dialectic between flexibility and rigidity persists, and only through meticulous empiricism shall an equilibrium be attained.
Sure, coordination sounds great, but have you considered how many meetings it takes to agree on a single definition? It’s like watching a room full of cats trying to decide on a nap spot. The sarcastic charm of the UK‑US deal is that it pretends to be efficient while actually adding another layer of bureaucracy.
Exciting times ahead! I’m hopeful this global effort will finally give us clear guidance.
Looks like another endless compliance checklist. I doubt many startups will survive the paperwork.
Another policy update that probably won’t affect the average user.
For anyone navigating these frameworks, the key is to focus on the core consumer‑protection principles-they’re the common thread across all initiatives. Also, keep an eye on the upcoming sandbox pilots; they’ll offer practical insights not found in the policy documents.
Ah, the drama unfolds! First, we have the FSB waving its risqué "risk‑based" banner like a flamboyant peacock, demanding that every jurisdiction bow to its glorious decree of "same‑activity‑same‑regulation." Then, like a thunderclap, the UK‑US Tech Propensity Deal strides onto the stage, brandishing a glittering banner of "innovation‑friendly" sandbox, as if such a phrase could mask the inevitable bureaucratic quagmire that follows. Meanwhile, the EU’s MiCA, ever the solemn guardian, clutches its heavy tomes of licensing requirements, shouting, "Consume at your own risk!" – a proclamation that would make any aspiring startup shiver in terror. IOSCO attempts to play the diplomatic peacemaker, tossing around vague principles like confetti at a parade, hoping no one notices the lack of teeth behind the glitter. And let us not forget the FATF, ever the omnipresent watchdog, sniffing around with its AML/KYC hounds, reminding us that even in this brave new digital world, the old guardians of money‑laundering still prowls. The stablecoin saga continues, with each jurisdiction polishing its own version of a "reserve‑backed" promise, yet none can agree on a single, universally accepted definition – a true odyssey of contradictions. Cross‑border enforcement remains a patchwork quilt, each square sewn by different nations, each thread fraying under the weight of political will. The promise of sandbox pilots in 2026? Ah, dear reader, it sounds like a utopian garden awaiting the first frost. Technical standardization, the holy grail, remains elusive, as elusive as a unicorn in a blockchain. Information‑sharing platforms, touted as the future, may merely become echo chambers for the already‑in‑the‑know. In short, while the chorus of coordination sings a hopeful melody, the underlying orchestra is still tuning its instruments, and the audience – the market – watches with bated breath, hoping the performance doesn’t devolve into a cacophony of discord.
Spot on! The enthusiasm around the sandbox pilots is infectious, and the collaborative spirit highlighted by the FSB information‑sharing platform could truly transform enforcement. Let’s keep this momentum going, and maybe even host a joint workshop to share best practices across regions.