Global Perspectives on Crypto Regulation: A Comparative Analysis of Legal Frameworks in Different Countries!

Astra Protocol
4 min readApr 20, 2023


The increasing popularity and rapid growth of cryptocurrencies have led regulators and governments worldwide to take a closer look at the implications of digital assets. This has resulted in various legal frameworks emerging to address the unique challenges posed by these new financial tools.

This article explores the crypto regulatory landscape across different countries to determine similarities and differences in their approaches to digital assets. The diverse range of regulatory systems for cryptocurrencies highlights the complexity of managing digital assets worldwide. As the adoption of cryptocurrencies continues to grow, governments and regulators are looking into collaborating and adapting new legal frameworks to ensure a balanced approach — fostering innovation while protecting investors and maintaining financial stability. It is crucial for policymakers to closely monitor the developments in other jurisdictions and learn from their experiences to create a robust and effective global regulatory framework.


The United States has a complex regulatory environment for cryptocurrencies, with multiple agencies overseeing different aspects. The Securities and Exchange Commission (SEC) treats specific cryptocurrencies as securities, while the Commodity Futures Trading Commission (CFTC) considers them commodities. The Financial Crimes Enforcement Network requires crypto exchanges to implement AML and KYC procedures. Despite this divide and regulatory fragmentation, there is a growing demand to create a more balanced approach to cryptocurrency regulation in the US.


The European Union has taken a more unified approach to cryptocurrency regulation. The Fifth Anti-Money Laundering Directive (5AMLD) and the upcoming Markets in Crypto Assets (MiCA) regulation provide a comprehensive framework for digital assets. The 5AMLD requires crypto exchanges and wallet providers to implement AML and KYC measures, while MiCA aims to create a single market for crypto assets and ensure investor protection. The European Central Bank is also exploring the possibility of a digital euro, furthering the influence on crypto regulation in the region.


With a more restrictive stance on cryptocurrencies, the People’s Bank of China (PBOC) banned initial coin offerings (ICOs) in 2017, marking a decline in crypto trading, mining, and exchanges. However, China has been actively exploring blockchain technology and has introduced the digital yuan, a central bank digital currency (CBDC), to strengthen its control over financial transactions.


Japan has been a forerunner for crypto regulation, declaring Bitcoin a legal payment method in 2017. Overseen by the Financial Services Agency, the country’s regulatory framework requires crypto exchanges to register and adhere to strict AML and KYC requirements. Today, thanks to its progressive approach, Japan is considered a hub for digital asset innovation.

South Korea

South Korea has implemented a robust regulatory framework due to its significant surge in cryptocurrency adoption. The country’s Financial Services Commission (FSC) oversees crypto exchanges, requiring them to register and comply with AML and KYC measures. Additionally, South Korea has introduced a 20% capital gains tax on crypto transactions, signaling its intent to treat cryptocurrencies as a credible asset class.


India’s stance on cryptocurrency regulation has been uncertain. In 2018, the Reserve Bank of India (RBI) imposed a banking ban on crypto, but it was subsequently overturned by the Supreme Court two years later. The government is now considering a new bill regulating cryptocurrencies and potentially creating a national digital currency. India’s evolving regulatory landscape reflects the challenges emerging markets and developing countries face in addressing the implications of digital assets.

Astra’s Contribution to Crypto-regulation Worldwide

Astra Protocol is revolutionizing crypto regulation worldwide as the only globally patented decentralized KYC solution for Web3. It brings major legal and audit companies on-chain with its Decentralized Legal Network (DLN), like KPMG. Astra Protocol has positioned itself as a critical player in the global effort to build a secure, transparent, and regulated cryptocurrency ecosystem by seamlessly integrating legal and compliance requirements into blockchain platforms.

This innovative platform brings financial regulatory standards for over 155 countries and 300+ sanctions, offering a simple plug-in technology that ensures compliance with AML and KYC standards. With the backing of major global firms, Astra provides faster and more cost-effective KYC that surpasses what centralized services offer, affirming decentralization.

Moreover, Astra Protocol’s impact on crypto-regulation extends to enhancing cross-border collaboration. By providing a standard regulatory framework that can be tailored to the specific needs of individual jurisdictions, Astra Protocol fosters cooperation among regulators. This technology facilitates the sharing of best practices in digital asset regulation. This leads to greater global consistency in regulatory standards and encourages innovation and growth in the cryptocurrency industry.

Astra Protocol has built an impressive advisory board that includes members of the UK Parliament and US Administration to ensure compliance and adherence to laws and regulations that impact the financial infrastructure on a global scale. Its commendable approach to regulating cryptocurrencies and digital assets worldwide has significantly advanced the global effort to build a more transparent and trustworthy cryptocurrency ecosystem. Astra Protocol will play a pivotal role in shaping the future of crypto-regulation as the industry continues to evolve.

Astra: KYC for Web3

Astra’s mission is to provide a range of regulatory compliance tools for crypto applications, ensuring that financial compliance standards can be met across the Web3 industry.

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Astra Protocol

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