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.
Crypto staking is regulated four ways across the US, EU, UK and Hong Kong. From the Kraken reversal to MiCA's July 1 deadline and the FCA's new regime.
From July 10, 2027 the EU's AMLR single rulebook and Frankfurt's AMLA centralise AML supervision over banks, crypto and FX firms — diverging from the US and UK.
From June 30, 2026, MiFIR Article 39a bans payment for order flow across the EU as Germany's exemption expires — while the US keeps PFOF legal under disclosure.
Basel's SCO60 imposes a 1,250% capital charge on crypto from January 1, 2026 — but the US rejected it, the UK held back, and only the EU is transposing it in full.
After the Van Loon ruling forced the Tornado Cash delisting, the US, EU and UK are diverging on sanctioning crypto code and developer liability in 2026.
Hong Kong's first stablecoin licences complete a five-jurisdiction map where HK, Singapore, Japan, the US and EU agree on reserves but split on who can issue.
The EU's MiCA review consultation reopens the crypto rulebook 18 months in — DeFi, staking, perps and the stablecoin ban that pushed out USDT all on the table.
The EU, UK and Switzerland move to T+1 on October 11, 2027 — ESMA wants the build done by Q4 2026. Why FX funding, CLS cut-offs and prefunding are the risk.
FSMA, CONSOB and the Czech National Bank are pushing funded-trader firms towards MiFID II just as the CFTC's My Forex Funds case collapsed in sanctions.
Kalshi v. Flaherty: the Third Circuit rules CFTC jurisdiction preempts state gambling law for event contracts — while the UK and Ontario draw the opposite line.
The FATF Travel Rule now covers 85 of 117 jurisdictions, but uneven enforcement and a €0-to-$3,000 threshold split leave a sunrise gap that VASPs must bridge across the EU, US and Asia.