Clifford Chance

Welcome to this month's global crypto round-up, summarising crypto regulatory developments that have happened around the world in February 2025 along with our Clifford Chance crypto publications and upcoming events. 

Details of these and previous developments can also be found on our Fintech Topic Guide on the Clifford Chance Financial Markets Toolkit.

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CLIFFORD CHANCE PUBLICATIONS & MATERIALS

• UK data reform: What you need to know about the Data (Use and Access) Act
• This sell-side regulatory horizon scanner provides a high-level overview of key ongoing and expected EU and UK regulatory developments relevant to banks and investment firms, including updates on key fintech regulation including the latest developments on the EU's Markets in Cryptoassets Regulation (MiCA) and Digital Operational Resilience Act (DORA), the developing UK cryptoassets regime and operational resilience requirements and payments updates including around PSD3.
• This buy-side regulatory horizon scanner provides a high-level overview of key ongoing and expected EU and UK regulatory developments relevant to investment managers, including updates on key fintech regulation including the latest developments on MiCA and DORA and the developing UK cryptoassets regime and operational resilience requirements.

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

INTERNATIONAL

• (31 Jul 2025) Global Blockchain Business Council (GBBC) and Oliver Wyman Proposed Risk Mitigation Framework for Non-Financial Risks of Blockchain Infrastructures, which is intended to give financial institutions guidelines to analyse and control the non-financial risks that arise when they use public blockchain infrastructure. | FAQs
• (24 Jul 2025) Global Digital Finance (GDF), Deloitte and Zodia Custody report on evolving the role of custody in the tokenisation of real-world assets.
• (14 Jul 2025) Letter from the new Financial Stability Board (FSB) Chair Andrew Bailey to G20 Finance Ministers and Central Bank Governors ahead of their July meeting, in which he identified the increasing role of stablecoins for payment and settlement purposes as one of the key risks to financial stability. | Press release

AMERICAS

Bolivia 

• (30 Jul 2025) The Central Bank of Bolivia has signed a memorandum of understanding with El Salvador's National Commission for Digital Assets on mutual cooperation in relation to the development of cryptoassets. | Press release (in Spanish).

US

• (31 Jul 2025) Securities and Exchange Commission (SEC) Chairman Paul S. Atkins has announced 'Project Crypto', which is intended to ensure American leadership in digital finance and will develop proposals to implement the recommendations of the Presidential Working Group on Digital Asset Markets. | Speech
• (31 Jul 2025) Letter from a group of Democrat US Senators to the Office of the Comptroller of the Currency (OCC) highlighting their concerns about conflicts of interest arising from President Trump's cryptocurrency business interests.
• (30 Jul 2025) The Presidential Working Group on Digital Asset Markets has published its report on strengthening American leadership in digital financial technology. Amongst other things, the report argues that: (i) a market structure framework is essential to support growth and innovation in the digital assets industry, (ii) bank capital rules should be aligned with the actual risks associated with digital assets, (iii) widespread adoption of dollar-backed stablecoins will modernise payments infrastructure and allow the United States to move away from costly and outdated legacy systems; and (iv) tax rules must align with new technologies and eliminate compliance hurdles for both individuals and businesses engaged in activities involving digital assets. | Fact Sheet | Webpage
• (29 Jul 2025) The SEC has voted to approve orders to permit in-kind creations and redemptions by authorised participants for cryptoasset exchange-traded product (ETP) shares. | Press release
• (29 Jul 2025) U.S. Senator Cynthia Lummis (R-WY) has introduced the 21stCentury Mortgage Act, which would direct the Federal National Mortgage Association (Fannie Mae) and the Federal Home Loan Mortgage Corporation (Freddie Mac) to include digital assets recorded on a cryptographically-secured distributed ledger as part of their mortgage risk assessments for single-family home loans. | Press release
• (22 Jul 2025) Republican leaders on the US Senate Banking Committee have published an initial discussion draft of digital asset market structure legislation alongside a request for information for stakeholders to submit feedback on the draft and on market structure legislation in general. | Press release
• (18 Jul 2025) President Donald Trump has signed the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, which provides for the regulation of payment stablecoins, into law. | Press release | Fact sheet
• (17 Jul 2025) The US House of Representatives has passed the Digital Asset Market Clarity Act of 2025, which establishes a regulatory framework for digital commodities.
• (14 Jul 2025) Statement by the OCC, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (FDIC) on cryptoasset safekeeping by banking organisations.
• (9 Jul 2025) Statement by SEC Commissioner Hester M. Peirce on the tokenisation of securities.
• (3 Jul 2025) Senator Cynthia Lummis has introduced a digital asset tax bill, which includes a USD 300 de minimis exclusion for digital asset gains or losses, as well as provisions relating to double taxation, digital asset lending, wash sales, and mark-to-market tax treatment. | Press release

APAC

Australia

• (10 Jul 2025) The Reserve Bank of Australia (RBA) and the Digital Finance Cooperative Research Centre (DFCRC) have selected a number of industry participants to explore how innovations in digital money and existing settlement infrastructure might support the development of Australian wholesale tokenised asset markets as part of Project Acacia. | Press release.

Hong Kong

• (29 Jul 2025) The Hong Kong Monetary Authority (HKMA) has published the following documents for the implementation of the regulatory regime for stablecoin issuers, which will come into effect on 1 August 2025: the consultation conclusions on the guideline on supervision of licensed stablecoin issuers and the finalised guideline; the consultation conclusions on the guideline on anti-money laundering and counter-financing of terrorism (for licensed stablecoin issuers) and the finalised guideline; an explanatory note on licensing of stablecoin issuers on various aspects of the licensing regime and application process; and
• an explanatory note on transitional provisions for pre-existing stablecoin issuers.
• (23 Jul 2025) HKMA blog post on the next steps for implementing the Stablecoins Ordinance.
• (11 Jul 2025) The Hong Kong Government has gazetted the following amendment rules: Banking (Capital) (Amendment) Rules 2025, which amend the Banking (Capital) Rules;  Banking (Disclosure) (Amendment) Rules 2025, which amend Banking (Disclosure) Rules; and  Banking (Exposure Limits) (Amendment) Rules 2025, which amend Banking (Exposure Limits) Rules.
• The amendments implement the capital standards and the associated requirements on disclosure and exposure limits issued by the Basel Committee on Banking Supervision (BCBS) in relation to the prudential treatment of cryptoasset exposures. The Government has also taken the opportunity to revise certain provisions, mainly to better align with international practices and to enhance clarity or consistency within Hong Kong's regulatory framework. | Press release

New Zealand

• (9 Jul 2025) The New Zealand Government has announced that it will ban crypto ATMs as part of its overhaul of the AML/CFT regime. | Press release

Singapore

• (3 Jul 2025) The Guardian Foreign Exchange Industry Group has published a report on the use of tokenised bank liabilities for transaction banking. The report illustrates how tokenised bank liabilities, underpinned by shared ledger infrastructures, can enable 24/7 real-time settlement across borders and help optimise liquidity management in transaction banking. | Project Guardian webpage

EUROPE

EU

• (28 Jul 2025) European Central Bank (ECB) blog post on what stablecoins mean for Europe.
• (28 Jul 2025) The European Banking Authority (EBA) has published its latest opinion on money laundering and terrorist financing risks affecting the EU’s financial sector. The EBA notes that the rapid evolution of financial technologies and new financial products such as cryptoassets, and the growing interconnection of financial products and services across sectors, have introduced new vulnerabilities.
• (26 Jul 2025) Interview with ECB Executive Board member Piero Cipollone, in which he discussed the case for a digital euro.
• (22 Jul 2025) European Securities and Markets Authority (ESMA) list of grandfathering periods decided by Member States under Article 143 of the Markets in Cryptoassets Regulation (MiCA).
• (16 Jul 2025) ESMA overview table of Level 2 and Level 3 measures under MiCA. | Webpage
• (15 Jul 2025) The Eurosystem has invited financial market stakeholders to express their formal interest in participating in the Pontes market contact group, which will support and facilitate a dialogue with the market regarding the Pontes project to enable distributed ledger technology (DLT) transactions to be settled in euro using central bank money. | Press release
• (15 Jul 2025) Recording of an ECB Focus Session on advancing TARGET services with DLT transactions in central bank money and the accompanying slides on:  Findings from the exploratory work;  Short-term track: Pontes; and  Long-term track: Appia.
• (11 Jul 2025) ESMA has published its final guidelines specifying the criteria for assessing the knowledge and competence of staff at cryptoasset service providers (CASPs) who provide information or advice on cryptoassets and services under MiCA. | Press release
• (11 Jul 2025) ESMA statement warning investors of the ‘halo effect’ that can lead to overlooking risk when authorised CASPs offer both regulated and unregulated products and/or services. | Press release
• (10 Jul 2025) ESMA has published the results of a peer review looking at the authorisation of CASPs in Malta under MiCA. The peer review recommends that all national competent authorities (NCAs) currently in the process of authorising CASPs pay particular attention to certain areas of risk, including business growth, conflicts of interests, governance and intragroup arrangements, ICT architecture, Web3, decentralised products, and the promotion of unregulated services. | Press release
• (10 Jul 2025) Speech by ECB Executive Board Member Piero Cipollone on the challenges presented by the current digital transition in payments and how the digital euro offers opportunities to address them.
• (9 Jul 2025) ESMA's guidelines on supervisory practices for competent authorities to prevent and detect market abuse under MiCA have been translated into the official EU languages.
• (1 Jul 2025) ECB report on the Eurosystem’s exploratory work on new technologies for wholesale central bank money settlement. | Press release
• (1 Jul 2025) ESMA article on maximal extractable value implications for crypto markets. | Webpage.

Spain

• (28 Jul 2025) Spanish Ministry of Finance consultation (in Spanish) on a Draft Royal Decree transposing Directive (EU) 2023/2226 (DAC 8) into Spanish law and establishing due diligence, registration and tax reporting obligations for certain cryptoasset service providers and operators. Deadline for comments: 16 September 2025.

UK

• (31 Jul 2025) The deadline for responding to the Financial Conduct Authority (FCA)'s two consultation papers on stablecoin issuance and cryptoasset custody (CP25/14) and a prudential regime for cryptoasset firms (CP25/15) has now ended. Responses published to date include: CP25/14 BBA | CryptoUK | IA | ICAEW and CP25/15 CryptoUK
• (22 Jul 2025) The House of Commons Treasury Select Committee has held an oral evidence session on financial stability, hearing from Bank of England Governor Andrew Bailey and two External Members of the Financial Policy Committee. Amongst other things, they were asked about the implications of stablecoins for financial stability as well as the Bank's own plans for a digital pound. Bailey indicated that the Bank is currently focusing on working with the market to develop digital technology in the commercial bank payment systems and that, if this work is successful, he would "need a lot of convincing" that the use case for a retail central bank digital currency was made. | Meeting webpage | Parliament TV recording of the session – section on stablecoins and digital pound
• (21 Jul 2025) Office of Financial Sanctions Implementation/HM Treasury threat assessment report on sanctions compliance in the cryptoasset sector. | Webpage
• (15 Jul 2025) The Chancellor of the Exchequer, Rachel Reeves, has announced the 'Leeds Reforms' to financial services and launched the Government's Financial Services Growth and Competitiveness Strategy, setting out a ten-year plan to drive the growth and competitiveness of financial services in the UK. Amongst other things, the package of measures includes: the National Payments Vision, which responds to the findings of the independent Future of Payments Review 2023, led by Joe Garner;  a Wholesale Financial Markets Digital Strategy, setting out the Government’s approach to digitalising the UK’s wholesale financial markets;  the Digitisation Taskforce's final report, which recommends a staged approach to removing paper share certificates and ultimately moving to a fully intermediated system of shareholding in the UK – the Government has accepted these recommendations; and an update on the Digital Gilt Instrument (DIGIT) pilot.
• (11 Jul 2025) House of Commons briefing paper on the Property (Digital Assets etc) Bill. | Webpage
• (7 Jul 2025) The deadline for responding to the FCA's proposal in CP25/16 to lift the ban on retail access to certain cryptoasset exchange traded notes (cETNs) has now passed. Responses published to date include those from: CryptoUK | GBBC | GDF | IA | 21Shares
• (4 Jul 2025) UK Finance blog post entitled 'FCA and MAS stablecoin frameworks: a comparative view'.
• (1 Jul 2025) Speech by Bank of England (BoE) Executive Director Victoria Cleland on the Bank's plans for a synchronised settlement and programme of experiments in wholesale payments.