EU MiCA (Markets in Crypto-Assets Regulation)

  • Requires mandatory licensing for crypto-asset service providers (CASPs).
  • Enforces capital requirements, insurance policies, and reserve mechanisms to ensure solvency.
  • Strong consumer protection standards: transparent risk disclosures, clear service terms, and anti-fraud measures.
  • Pan-European harmonization — unified rules across all EU member states under ESMA and EBA supervision.

AU APRA (Australian Prudential Regulation Authority)

  • Oversees banks, insurers, and pension funds.
  • Imposes capital adequacy and risk assessment requirements related to crypto-asset exposure.
  • Requires stress testing and management of third-party risks.

AU ASIC (Australian Securities and Investments Commission)

Regulates crypto services as financial products:

  • Requires an AFSL (Australian Financial Services Licence)
  • Enforces custody standards, fair pricing, and audit rules for crypto ETFs and asset managers.

CA Canadian Regulatory Framework

OSFI — Supervises banks and insurers, ensuring deposit protection and capital stability.
IIROC — Regulates investment brokers and traders, ensuring transparency and client protection.
CSA (via provincial regulators) — Requires crypto platforms to:

  • Register and disclose risks
  • Undergo regular audits and maintain robust security practices
  • Segregate client funds