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.
DORA put EU regulators directly over Amazon, Microsoft and Google in 2026. How the EU, UK and US split on overseeing the cloud the financial system runs on.
The CFTC cleared Coinbase to offer US clients crypto perpetuals while the EU caps them, the UK bans them for retail and Singapore gates them. The split explained.
MiCA's July 1, 2026 cutoff and the GENIUS Act's July 18 rulemaking deadline lock in incompatible stablecoin regimes, forcing issuers into region-specific coins.
The FCA reopened retail access to crypto ETNs on Oct 8, 2025, charting a third UK path between the US spot-ETF model and the EU’s MiCA-governed market.
The CLARITY Act would give the CFTC spot digital-commodity markets and leave investment-contract assets with the SEC, diverging from MiCA, the UK and Singapore.
EMIR 3.0's active account requirement forces EU firms to clear euro rate derivatives at EU CCPs from 2026, targeting the 80% that still sits at London's LCH.
From June 30, 2026 Germany's PFOF carve-out expires, making the EU a uniform no-PFOF bloc — and splitting it from the UK ban and the US disclosure regime.
Japan's FIEA amendment reclassifies crypto as financial instruments, importing insider-dealing bans and a flat 20% tax — and diverging from MiCA and the US.
From July 2027 the EU's AMLR and Frankfurt-based AMLA replace 27 national AML regimes with one rulebook and direct supervision — diverging from the US and UK.
Basel's SCO60 crypto capital standard took effect Jan 1, 2026 with a 1,250% risk weight - but the EU, UK and US are implementing it three different ways.
SEC August 2025 statement clears $66bn liquid staking market; MiCA, FCA, MAS and VARA still split. Cross-jurisdictional rulebook diverges on CASP authorisation.
CySEC's RAA 270/2025 capped non-major commodity and index CFDs at 10:1 in September 2025; ESMA's CSA 2026 now adds inspections on conflicts of interest.
Hong Kong's FSTB/SFC publish consultation conclusions on VA dealing and custodian licensing — a four-jurisdiction read alongside MAS, VARA, and the SEC.
FATF Travel Rule coverage reached 85 of 163 jurisdictions in 2026, but ~59% have yet to issue enforcement actions — concentrating risk in FCA, FinCEN, MAS and EU TFR perimeters.
SEC Commissioner Peirce clarified on May 21 that the tokenized-stocks innovation exemption will permit digital twins of NMS shares, not synthetics — and how EU, UK, and Swiss regimes diverge.
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