Crypto Regulation in 2025: Comparing the US, UK & UAE Legal Landscape
May 14, 2025
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Crypto Regulation in 2025: Comparing the US, UK & UAE Legal Landscape

By 
Ben Mendelson - Senior Associate & Crypto Specialist

Crypto Regulation in 2025: How the US, UK, and UAE Stack Up

The world of crypto regulation is heating up, and 2025 is already shaping up to be a pivotal year. PwC recently released a very large Global Crypto Regulation Report, packed with insights on how countries are shaping digital asset policy. To save you the time (and the scroll), we’ve broken down their key findings for the United States, United Kingdom, and United Arab Emirates so you can quickly understand where the most crypto-friendly environments are for businesses, investors, and startups alike.

🇬🇧 United Kingdom: A Roadmap in the Making

Over in the UK, the government has made a bold statement "cryptoassets are here to stay." The Financial Conduct Authority (FCA) is leading the charge with a full crypto regulatory framework planned by 2026.

In the meantime, the Financial Services and Markets Act 2023 (FSMA) has already laid the foundation. It provides the FCA with powers to regulate activities like:

  • Crypto trading platforms
  • Custody of digital assets
  • Stablecoin issuance and payment systems
  • Consumer protection and financial crime compliance

The UK is also preparing for the potential launch of a retail Central Bank Digital Currency (CBDC), aka the digital pound, with the Bank of England targeting a 2025 design decision.

Other key areas include:

  • Strict marketing rules under the Financial Promotions Order
  • New registration rules for foreign crypto firms serving UK clients
  • AML regulations tied to the Travel Rule

The bottom line: The UK is positioning itself as a global leader in digital asset regulation, but it’s still in a transition phase. It's a promising space, just not the fastest-moving.

🇦🇪 United Arab Emirates: Innovation with a Green Light

And then we have the United Arab Emirates, arguably the most crypto-friendly country in 2025.

The UAE has rolled out a clear, forward-thinking crypto asset regulatory framework through authorities like:

  • Dubai’s Virtual Asset Regulatory Authority (VARA)
  • Abu Dhabi’s Financial Services Regulatory Authority (FSRA)
  • Central Bank of the UAE (CBUAE)

What makes the UAE stand out? It offers:

  • A unified and detailed licensing process for VASPs
  • Multiple activity-specific rules for custody, exchanges, lending, and issuance
  • Clear restrictions on anonymity-enhanced cryptocurrencies
  • A fast-growing stablecoin regulation framework for AED-pegged tokens
  • Full alignment with FATF standards on AML/CFT compliance

VARA has introduced updated Marketing Regulations, making it one of the few jurisdictions to formally regulate crypto promotions and advertising. And yes, even social media influencers need to follow the rules.

Meanwhile, the CBUAE is leading the charge on CBDCs with the Digital Dirham. Phase 1 of the mBridge project has already launched, with cross-border testing involving India and China, and Phase 2 now underway.

Add to this the RAK Digital Oasis Free Zone, which is tailored for Web3, NFTs, DAOs, and metaverse ventures, and you’ve got a full-stack regulatory system with global ambition.

The bottom line: The UAE is not just crypto-friendly, it’s crypto-ready.

🇺🇸 United States: Progress… with a Side of Complexity

The US crypto regulation landscape remains one of the most complex in the world. While the U.S. continues to be a powerhouse in crypto innovation, regulatory uncertainty has long been a barrier to entry for crypto startups.

But in 2025, there's hope on the horizon. With a new administration and greater focus on innovation, agencies like the Securities and Exchange Commission (SEC) are shifting from aggressive enforcement to greater regulatory clarity. The SEC's newly formed Task Force is focusing on resolving issues like crypto asset classification and pathways to registration.

Key legislative proposals like the Market Structure Act and FIT 21 (Financial Innovation and Technology for the 21st Century Act) are gaining traction. These bills aim to clearly define the roles of the CFTC and SEC, and better distinguish between crypto securities and commodities.

Other 2025 developments include:

  • Introduction of IRS Form 1099-DA for crypto tax reporting.
  • FASB guidance requiring fair value accounting for digital assets like Bitcoin.
  • Ongoing debate over stablecoin regulation, with USDC oversight involving the Federal Reserve and FSOC.

However, the US still lacks a federal licensing framework for crypto, leaving firms to pursue state licenses like the BitLicense in New York. This fragmented system continues to pose challenges, especially for foreign firms seeking entry.

The Bottom line: The US is evolving, but regulatory complexity remains a hurdle for scaling in 2025.

🚀 So, Where’s the Best Place to Start or Grow a Crypto Business in 2025?

If you're looking for:

  • Regulatory clarity
  • Fast licensing
  • A welcoming attitude toward crypto startups
  • Robust rules without regulatory chaos

...then the UAE is your best bet in 2025.

  • The USA has momentum but remains fragmented.
  • The UK is building a strong framework, but it's not fully in place yet.
  • The UAE offers an established, investor-friendly environment with global leadership in crypto regulation and digital asset innovation.

Thinking of launching or expanding your crypto venture in 2025? Drop us a line hello@founders-law.co.uk or contact@founders-aw.ae

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