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.

If you would like to receive future Round-ups directly to your inbox, please complete this preferences form. You can sign up for the Global Crypto Round-up under the 'Briefings and regular newsletters' heading. 

CLIFFORD CHANCE PUBLICATIONS & MATERIALS

The convergence of AI and Distributed Ledger Technology – opportunities and risks

Artificial intelligence (AI) and Distributed Ledger Technology (DLT) are transforming industries. Each of these technologies can offer benefits, but by combining the predictive and analytical capabilities of AI with the decentralised and resilient infrastructure of DLT, this synergy of "AIxDLT" has the potential to accelerate the transformation of a range of products, services and industries by enabling smarter, automated systems that operate with improved transparency, efficiency and trust. 

In this paper, developed in partnership with Deutsche Bank, we have brought together our resources and insights from our financial services and legal perspectives to further the conversation about AIxDLT, highlighting key practical considerations for its implementation and some of the legal, commercial and technical challenges that must be navigated.

Property Rights Law in Digital Assets Under International Standards

Alex Tollast, Counsel in our Global Financial Markets (GFM) Group, Paris, took part in this hour-long session as part of the Practising Law Institute (PLI) "Property Rights in Digital Assets" series. The session was with Chinedu Ezetah, a Director and Associate General Counsel in Citigroup’s Markets business segment. In the session Alex focused on the most important international standards in digital assets private law, exploring the main subjects addressed by UNIDROIT in its "Principles on Digital Assets and Private Law" in particular.  

Stablecoins – navigating the evolving global regulatory framework

New frameworks for stablecoins are emerging across global financial centres, including the US GENIUS Act for payment stablecoins, Hong Kong’s new regime for stablecoin issuers and a developing UK framework. You can now watch the recording from our recent webinar where panellists explored how different jurisdictions are approaching stablecoin oversight, including the lessons learned from more established regulatory frameworks such as the EU's Markets in Cryptoassets Regulation (MiCA), highlighted key compliance challenges, and looked at the future of stablecoin adoption.

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

INTERNATIONAL

• (30 Sep 2025) ISDA derivatiViews article on ISDA's work to identify and address certain legal, regulatory and operational challenges to enable the effective adoption of tokenization in the derivatives market.
• (19 Sep 2025) International Monetary Fund (IMF) working paper on optimal policy approaches for financial market tokenisation.
• (8 Sep 2025) Wolfsberg Group guidance on the provision of banking services to fiat-backed stablecoin issuers. | Press release
• (26 Aug 2025) The World Federation of Exchanges (WFE) has written to the Securities and Exchange Commission (SEC) Crypto Task Force, the International Organization of Securities Commissions (IOSCO)’s Fintech Task Force and the European Securities and Market Authority (ESMA), warning of growing investor protection risks linked to the third-party tokenisation of mostly US equities by unregulated brokers and cryptoasset trading platforms. | Press release

AMERICAS

US

• (23 Sep 2025) Commodity Futures Trading Commission (CFTC) Acting Chairman Caroline D. Pham has announced that the CFTC will launch an initiative for the use of tokenised collateral including stablecoins in derivatives markets. | Press release
• (22 Sep 2025) The US Treasury Secretary and the UK Chancellor of the Exchequer have announced the establishment of a Transatlantic Taskforce for Markets of the Future to enhance collaboration on capital markets, digital assets and other innovative financial activities. | Press release
• (18 Sep 2025) The Department of the Treasury has issued an Advance Notice of Proposed Rulemaking seeking public comments on its implementation of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. Deadline for comments: 20 October 2025. | Press release
• (17 Sep 2025) The Securities and Exchange Commission (SEC) has approved proposed rule changes by three national securities exchanges to adopt generic listing standards for exchange-traded products that hold spot commodities, including digital assets. As a result, the exchanges may list and trade Commodity-Based Trust Shares that meet the requirements of the approved generic listing standards without first submitting a proposed rule change to the SEC. | Press release
• (17 Sep 2025) New York State Department of Financial Services notice on the use of blockchain analytics for New York banking organisations.
• (10 Sep 2025) Speech by SEC Chairman Paul Atkins, in which he discussed "Project Crypto" and emphasised that providing certainty regarding the security status of cryptoassets was a priority for the SEC, noting that most crypto tokens are not securities. He also indicated that the SEC will work with other agencies so that a platform can offer trading in cryptoassets (whether or not they are securities), along with services like staking and lending, under a single regulatory umbrella.
• (5 Sep 2025) Joint statement by the SEC and CFTC which emphasises that harmonisation between US market regulators is essential to the viability of a range of innovative products. The two regulators have also announced a joint roundtable on regulatory harmonisation, to be held on 29 September 2025.
• (4 Sep 2025) The Office of Information and Regulatory Affairs has published the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, which sets out potential SEC rule proposals relating to the offer and sale of cryptoassets to help clarify the regulatory framework for cryptoassets and provide greater certainty to the market. | SEC statement
• (3 Sep 2025) The Federal Reserve Board has announced that it will be hosting a conference on payments innovation on 21 October 2025, which will feature panel discussions on several aspects of payments innovation, including the convergence of traditional and decentralised finance; emerging stablecoin use cases and business models; the intersection of AI and payments; and the tokenisation of financial products and services. | Press release.
• (2 Sep 2025) Joint CFTC and SEC statement which clarifies that SEC- or CFTC-registered exchanges are not prohibited from facilitating the trading of leveraged, margined, or financed spot retail commodity transactions on digital assets.

APAC

Australia

• (25 Sep 2025) The UK and Australia have held their first Joint Financial Regulatory Forum, at which they discussed priority areas including regulatory reform and digital assets, including their respective cryptoasset and stablecoin regulatory developments. | Joint statement
• (24 Sep 2025) Australian Treasury exposure draft of proposed legislation amending the Corporations Act 2001 to capture digital asset platforms and tokenised custody platforms by introducing each as new financial products. Deadline for comments: 24 October 2025. | Consultation page | Explanatory materials | Fact sheet | Consultation questions
• (18 Sep 2025) The Australian Securities and Investments Commission (ASIC) has granted class relief for intermediaries engaging in the secondary distribution of stablecoins issued by an Australian financial services (AFS) licensed issuer. The relief exempts intermediaries from the requirement to hold separate AFS, Australian market, or clearing and settlement facility licences when providing services related to stablecoins issued by an AFS licensee. As and when more issuers of eligible stablecoins obtain an AFS licence, ASIC will consider extending the above relief to intermediaries distributing those stablecoins. | Press release

Singapore

• (25 Sep 2025) Monetary Authority of Singapore (MAS) guide on responsible financial content creation and guidelines on standards of conduct for digital advertising activities, which are both intended to promote responsible online financial content sharing and advertising. | Press release

New Zealand

• (4 Sep 2025) Financial Markets Authority (FMA) discussion paper on the current use and future potential of tokenisation in New Zealand’s financial markets. Deadline for comments: 31 October 2025.  | Press release

Republic of Korea

• (5 Sep 2025) Financial Services Commission (FSC) guidelines (in Korean) for virtual asset lending by virtual asset service providers.

EUROPE

EU

• (29 Sep 2025) Speech by European Central Bank (ECB) Executive Board member Piero Cipollone on how the digital euro will bolster Europe’s unity, safeguard its autonomy and strengthen its resilience.
• (26 Sep 2025) Speech by Piero Cipollone on the role of research and innovation in preparing the future of payments and money.
• (26 Sep 2025) ECB report on the outcome of the pioneers and visionaries workstreams of the digital euro innovation platform. | Press release | Digital euro innovation platform webpage
• (24 Sep 2025) Association for Financial Markets in Europe (AFME) report on enabling digital innovation in European capital markets, which calls for a simplification of EU digital rules to unlock innovation and boost competitiveness. | Webpage | Press release
• (22 Sep 2025) The European Fund and Asset Management Association (EFAMA) has published two papers setting out recommendations for reform of the digital assets framework, covering the DLT Pilot Regime and existing regulatory frameworks and enabling DLT payments & investments | Press release
• (19 Sep 2025) The European Securities and Markets Authority (ESMA) has updated its list of links for complaints-handling under Article 108 of the Markets in Cryptoassets Regulation (MiCA). The list provides hyperlinks to the sections of the websites of the competent authorities relating to their MiCA complaints-handling procedures.
• (17 Sep 2025) Slides on central bank money for the digital era and the ECB's strategy in response to digitalisation and fragmentation used by ECB Executive Board Member Piero Cipollone at the Associazione Bancaria Italiana's Executive Committee meeting.
• (16 Sep 2025) Speech by Piero Cipollone on the digital euro and ensuring resilience and inclusion in digital payments.
• (16 Sep 2025) ECB working paper on central bank money as a catalyst for fungibility – the case of stablecoins.
• (15 Sep 2025) The French Autorité des Marchés Financiers (AMF), the Austrian Finanzmarktaufsichtsbehörde (FMA) and the Italian Commissione Nazionale per le Società e la Borsa (CONSOB) have put forward proposals aimed at ensuring a more effective supervision of cryptoasset markets, strengthening the competitiveness of European market participants and providing better investor protection. The three authorities believe that the first few months of application of MiCA have revealed major differences in how crypto markets are being supervised by national authorities. | Press release
• (15 Sep 2025) Commission Delegated Regulation (EU) 2025/1125 setting out regulatory technical standards (RTS) under MiCA specifying the information to be included in an application for authorisation to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading and Commission Implementing Regulation (EU) 2025/1126 setting out implementing technical standards (ITS) on the standard forms, templates and procedures for that information have been published in the Official Journal. Entry into force: 4 October 2025.
• (4 Sep 2025) Essay on the digital euro by ECB Executive Board Member Philip R. Lane, in which he argues that a digital euro will minimise the likelihood of adverse economic outcomes in the future and ensure the resilience of the monetary system in an increasingly digital world, while also unifying fragmented markets.
• (4 Sep 2025) Speech by Piero Cipollone, in which he discussed the digital euro and the need to ensure resilience and inclusion in digital payments.
• (3 Sep 2025) Speech by ECB President Christine Lagarde, in which she argued that multi-issuance schemes where an EU entity and a non-EU entity jointly issue fungible stablecoins should not be allowed to operate in the EU, unless they are supported by robust equivalence regimes in other jurisdictions and safeguards relating to the transfer of assets between the EU and non-EU entities.

France

• (19 Sep 2025) The AMF has announced its compliance with ESMA's guidelines on the detection and prevention of market abuse under MiCA. | Press release (in French)
• (12 Sep 2025) AMAFI-AFPDB-FBF response (in French) to the Autorité des marchés financiers (AMF) consultation on the marketing of crypto exchange traded notes.
• (Sep 2025) Paris Europlace Cryptoassets Regulation Working Group position paper on Europe’s response to the rise of dollar stablecoins, which provides an initial analysis of the potential implications for the competitiveness of the financial sector, the autonomy of monetary policy, the protection of savings and the sound financing of businesses.

Germany

• (29 Sep 2025) German Federal Financial Supervisory Authority (BaFin) consultation (in German) on a draft Crypto Markets Notification Ordinance, which is intended to establish clear and consistent requirements for notifications under the Crypto Markets Supervision Act. Deadline for responses: 29 October 2025. | Press release (in German)

Switzerland

• (16 Sep 2025) The Swiss Bankers Association (SBA), in collaboration with PostFinance, Sygnum Bank, and UBS, has published a report on a proof of concept to evaluate the feasibility of a blockchain-based deposit token. | Press release

UK

• (26 Sep 2025) UK Finance has launched a collaborative industry pilot project to deliver the first UK live transactions of tokenised sterling deposits. The pilot will run until mid-2026. | Press release
• (25 Sep 2025) The UK and Australia have held their first Joint Financial Regulatory Forum, at which they discussed priority areas including regulatory reform and digital assets, including their respective cryptoasset and stablecoin regulatory developments. | Joint statement
• (22 Sep 2025) The Chancellor of the Exchequer and the US Treasury Secretary have announced the establishment of a Transatlantic Taskforce for Markets of the Future to enhance collaboration on capital markets, digital assets and other innovative financial activities. | Press release
• (17 Sep 2025) Speech by FCA Chief Data, Information and Intelligence Officer Jessica Rusu on the future of fintech.
• (17 Sep 2025) Minutes from the Bank of England (BoE)'s CBDC Academic Advisory Group meeting on 12 March 2025.
• (17 Sep 2025) FCA consultation (CP25/25) on the proposed application of existing FCA Handbook rules to firms conducting regulated cryptoasset activities. The consultation sets out how existing FCA Handbook rules will apply to firms, including High Level Standards such as the Senior Management Arrangements, Systems and Controls (SYSC) Sourcebook (including governance, Senior Managers and Certification Regime, financial crime and operational resilience), and Business Standards (specifically the Environmental, Social and Governance Sourcebook). The FCA has also opened a discussion on how the Consumer Duty should apply to crypto and on how complaints should be managed, including whether consumers should be able to refer them to the Financial Ombudsman Service. The FCA has invited comments on the discussion proposals (chapters 6-7) by 15 October 2025 and feedback on the consultation proposals (chapters 1-5) by 12 November 2025. | Webpage | Press release
• (9 Sep 20205) UK Finance blog post providing a comparative view of the FCA and GENIUS stablecoin frameworks.
• (8 Sep 2025) The deadline for responding to the Law Commission's consultation on digital assets and electronic trade documents in private international law has now passed. Responses published to date include those from: CLLS | FMLC | GBBC | GDF
• (3 Sep 2025) Speech by BoE Deputy Governor Sarah Breeden setting out her vision for a 'multi-money' system where different forms of money including traditional and tokenised commercial bank deposits, stablecoins and central bank money are freely exchangeable.
• (3 Sep 2025) BoE guidance on the process for requesting waivers and modifications to the Digital Securities Sandbox (DSS) rules.
• (2 Sep 2025) HM Treasury has published the draft Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations 2025 and an accompanying policy note to launch a technical consultation on the practical operability, clarity, and effectiveness of the SI, including changes to customer due diligence, pooled client accounts, cryptoasset regulation, and trust registration. Deadline for comments: 30 September 2025. | Webpage
• (28 Aug 2025) Information Commissioner's Office (ICO) consultation on draft guidance on distributed ledger technologies. Deadline for Comments: 7 November 2025.

MIDDLE EAST

UAE

• (9 Sep 2025) The Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) has published Consultation Paper No. 9 of 2025, proposing several enhancements to the regulatory framework governing regulated activities involving fiat-referenced tokens (FRTs). The proposals build on the existing FRTs issuance framework introduced in December 2024 and reflect the FSRA’s evolving approach to digital assets. FRTs are defined as stablecoins pegged to a fixed amount of a single fiat currency and backed by high-quality, liquid assets in that same currency. Deadline for comments: 7 October 2025.