The world’s major VASP (Virtual Asset Service Provider) regulations have converged into a 8 -pole structure: Japan (FSA + JVCEA two-layer) / Korea (FSC + FIU single) / Hong Kong (SFC VATP) / Singapore (MAS DPT) / EU (MiCA CASP) / US (federal + 50 -state fragmentation) / UAE (VARA alone) / UK (FCA-AML-centered + phased full implementation). This entry compares them side by side along 13 axes: legal source, license tiers, required capital, segregation (cold storage %), AML/Travel Rule, stablecoin regulation, cross-border, marketing, representative enforcement cases, disclosure, and carve-outs. For details on each pole, start from jp-vasp-regulatory-timeline / eu-mica-casp-regime-overview / us-crypto-licensing-multi-layer-system / hk-sfc-vasp-licensing-overview / sg-mas-dpt-licensing-overview.
Convergence of the 8 -pole structure: 2017 (Japan FSA registration system) → 2020 (Singapore PSA) → 2021 (Korea Act on Reporting and Use of Specific Financial Transaction Information) → 2023 (Hong Kong VATP / UK FCA promotion strengthening) → 2024 (EU MiCA CASP full implementation) → 2024-2025 (UAE VARA full operation), with the world’s major 8 poles completing the build-out of their VASP legal systems within 8 years •
The world’s strictest cold-storage ratio is Hong Kong (98%), followed by Japan’s JVCEA self-regulation (95%) •
A. Legal source / regulator / implementation timing
By state (NY BitLicense effectively a high surety bond + capital)
NY: customer assets backed in the same kind 100%
By state; NY DFS effectively requires cold dominant
UAE
By VASP category (Exchange from AED 1.5M〜)
Trust or segregated wallet
Risk-based provisions in the VARA Rulebook
UK
No provision (as it is currently MLR-based)
Not obligatory under the MLR; to be introduced with the FSMA 2026+ extension
No provision
E. Fit-and-proper / source of capital
Japan: Background screening of major shareholders / directors (anti-social forces, international sanctions, PEPs), proof of source of additional capital
Korea: Real-name-account banks conduct capital verification linked to KYC/CDD (bank 1:1 rule)
Hong Kong: SFC fit-and-proper test (the long-standing deeper test of character, background, financial condition, capability)
Singapore: MAS Notice on Fit and Proper Criteria (FSG-N16) applies
EU: MiCA Article 81 requires good repute of the management body + notification of large shareholders (qualifying holding)
US: NY BitLicense individually screens the Cybersecurity coordinator / Compliance Officer + background check
UAE: VARA requires senior management approval, with criminal-record / bankruptcy-record checks
UK: FCA Threshold Conditions + expanded application of the Senior Managers and Certification Regime (SMCR)
US: By state + SEC Reg BI / FINRA rule apply; influential persons require disclosure
UAE: VARA Marketing Regulations 2023-12 set detailed rules, with constraints even on the use of overseas influencers
UK: Financial Promotion Order + a cooling-off period of 24 hours (new customers must wait 24h after application), with risk-warning + appropriateness-assessment obligations
J. Representative enforcement cases (1-2 件 / pole)
Korea: Terra-Luna collapse (2022-05) → Do Kwon indicted by Korean prosecutors / arrested in Montenegro ; Korean prosecutor investigation expanded over FTX customer losses
Hong Kong: JPEX fraud (2023-09) → 11 名 arrests by Hong Kong police, losses over HK$15 億, a catalyst for improving the Hong Kong SFC warning list
Singapore: Three Arrows Capital failure (2022-06) → MAS banned 3AC from business for 9 years; Su Zhu/Kyle Davies in judicial cooperation with the US
EU: Binance France AMF warning (2023) → re-authorized in the 2024 SAS Société form ; BaFin’s individual approval of Coinbase Germany 2021-06
US: SEC v. Coinbase (filed 2023-06 → dismissed in part 2024-03 ) ; SEC v. Binance.US (2023-06) ; FTX failure → SBF 25 -year prison sentence (2024-03)
UAE: Bybit (UAE-headquartered) / withdrawal from the Japanese market (2026-03) ; OKX US settlement over FIU violations 2025
UK: Binance UK FCA warning → withdrawal 2024 ; Copper.co accelerating expansion after authorization
K. Disclosure / financial reporting / proof-of-reserves
Japan: Monthly submission of customer-asset-segregation status to JVCEA + annual financial-results disclosure (submitted to the FSA)
Korea: Monthly STR reporting to the FIU + annual KISA ISMS renewal audit
Hong Kong: Monthly returns to the SFC + annual IFRS audited financials + monthly client asset attestation
Singapore: Annual financial statement + assurance report to MAS (monthly customer asset report for large MPIs)
UAE: VARA Rulebook mandates a monthly proof-of-reserves attestation obligation (one of the world’s strictest frequencies)
UK: Disclosure is limited under the MLR → to become full-scale with the FSMA extension
L. Notable carve-outs / exceptions
Japan: NFTs are in principle outside the VASP scope (judged individually by function) ; banks / trust banks fall under a separate framework for stablecoin issuance
Korea: The User Protection Act fully bans retail derivatives → even CME-affiliated overseas underwriting including institutional is restricted
Hong Kong: HKMA stablecoin runs parallel to the SFC VATP, dual supervision
Singapore: DBS Digital Exchange is by individual MAS approval (separate from the PSA), institution-only
EU: Existing NCA-authorized operators get a 18 -month transitional period (2024-12-30 → 2026-07-01) to migrate to MiCA
US: The OCC Federal Trust Charter fully exempts 50 -state MTL (Anchorage Digital was the first to obtain it 2021-01 , Circle obtained it 2025 )
UAE: DIFC is outside VARA’s jurisdiction (DFSA alone), ADGM is FSRA-independent (with 3 systems coexisting within the UAE)
UK: MLR registration is an AML obligation only; market-conduct regulation depends on the FSMA (a two-stage structure)
Integrated type (single-passport regime)
EU MiCA: 1 license → passporting to 27 countries (the world’s widest)
Japan: FSA single registration, but two-layer with JVCEA self-regulation
Korea: FSC + FIU single, further concentrated by the bank 1:1 rule
Singapore / Hong Kong: Single supervision within the city-state / SAR
Fragmented type (multi-layer regime)
US: Federal (FinCEN/SEC/CFTC/OCC) + state (50 -state MTL + NY BitLicense), the world’s most complex
UAE: VARA + DFSA + ADGM-FSRA + federal SCA + Central Bank, with 5 systems coexisting
Phased build-out type (phased regime)
UK: MLR 2017 (AML-centered, current) → FSMA 2023 extension (2026-2027 phased) to shift to full-scale regulation
Korea: Specific-Financial-Transaction-Information Act (2021) → User Protection Act (2024) → stablecoin regulation (planned 2026 ), added in phases
3. Implications for global CEX strategy
MiCA passporting intensified the competition to acquire EU bases from 2024-2025 → confirming the configuration of Coinbase EU (Luxembourg) / Kraken EU (Ireland) / Crypto.com EU (Malta) / Binance France
US state-by-state MTL costs reach the tens of millions of dollars for nationwide deployment, resulting in ecosystem concentration among a handful of major players
UAE VARA’s low corporate tax + full-stack license + retail unbanning provides a “floor of global trust” → the headquarters-relocation trend of Bybit / OKX / Crypto.com
APAC three-city division of labor: the role-sharing of Singapore (institution-oriented) / Hong Kong (retail unbanned, limited to large names) / Japan (retail-permitted, strict whitelist) has become entrenched
US GENIUS Act 2025 + the OCC Trust route push the US back up to the world’s largest stablecoin-issuance hub (Circle / Paxos / USD bank via OCC)