The CFTC brought crypto perpetual futures onshore in 2026 while the UK bans them for retail and the EU caps leverage at 2:1 — a five-jurisdiction split.
The CLARITY Act (H.R.3633) would split US crypto between the SEC and CFTC — a model that diverges from MiCA, the UK's FCA and Singapore. Analysis and outlook.
MiCA's Article 143(3) grandfathering ends July 1, 2026 with no extension. With only ~204 CASPs authorised, thousands of EU crypto firms must license or exit.
In 2026, 85 jurisdictions have adopted the FATF Travel Rule but most don't enforce it. How the EU, UK, US and Singapore diverge — and the sunrise problem it leaves.
A five-agency FinCEN rule makes US stablecoin issuers BSA financial institutions, but the KYC duty stops at the issuer — leaving the secondary market open.
Retail FX leverage caps hold at 30:1 across the EU, UK and Australia, but 2026 enforcement targets the offshore funnel — CySEC's FXNET and SquaredFinancial cases.
The Bank of England's £40bn stablecoin cap and 70/30 reserve rule diverge from MiCA and the GENIUS Act, leaving issuers with three incompatible regimes.
As tokenised real-world assets pass $20bn, the EU, UK, US and Singapore are diverging on tokenised-securities rules — creating real regulatory-arbitrage risk.
Best execution returns to FX supervision in 2026: ESMA's new RTS repeals RTS 27/28, the FCA scrapped them in 2021, and the US keeps a prescriptive duty.
MiCA Title VI bans crypto insider dealing and manipulation EU-wide from 2024, forcing CASP surveillance and STORs — while the UK's MARC waits until 2027 and the US relies on anti-fraud law.