In 2010, we witnessed the very first transaction of cryptocurrency in exchange for something physical. A software developer, Laszlo Hanyecz, paid 10,000 Bitcoin for two Papa John’s pizzas giving the coins a value of around $41¹. Crypto has come a long way from the fringe concept it was then, and today those 10,000 Bitcoin would be worth around $1.1bn!
The increasing value of crypto has led governments and individuals around the world to start taking the currency seriously. However, what exactly that looks like varies quite dramatically from one country to the next. While some, such as the USA, adopt supportive crypto regulations, others are playing catch up or adopting a more cautious approach, such as Australia and the UK respectively.
Crypto rules here in the UK
The regulations surrounding crypto in the UK take a mildly cautious approach and there has been recent changes to make things clearer for those looking to invest. Rule changes aim to grow the industry in the UK as part of the current government’s Plan for Change scheme, which aims to ‘kickstart economic growth’. The government wants to balance promoting growth with ‘protecting millions of people across Britain’, especially given that around 12% of UK adults either currently own or have owned crypto².
New regulations would see crypto exchanges and dealers brought under the same legislation that stock exchanges and other financial institutions follow. Although they haven’t been fully formed yet, there will also be new rules surrounding transparency and consumer protection to ensure individuals understand the risk of crypto before they invest. The Property Assets Bill, first proposed in 2024 and currently stalled in the final stages, would formally recognise crypto as a property asset, with the goal of providing greater protection for consumers³.
The Financial Conduct Authority
Since 2020, crypto assets have been managed by the Financial Conduct Authority, which also regulates other financial trade throughout the country. The FCA has introduced stricter rules on collecting and verifying information when trading crypto and other assets to prohibit false advertising. Although policy relating to crypto has been in development since November 2023, specific changes have been slow moving.
The basic picture
The overall picture for crypto regulation in the UK remains a murky one. There are lots of proposed changes to make trading clearer and more secure, but details are sparse. At the moment, trading crypto is legal and protected in a similar way to other assets. You’ll need to pay Capital Gains Tax if you make a profit when selling crypto and provide your name, address and birth date when trading.
What are the rules like down under?
In recent months, there have been changes in Australia aimed at making trading crypto a much simpler and more accessible process. From the 18th of September 2025, those who trade stablecoins issued by firms who have an Australian Financial Services license no longer need to obtain separate licenses. This change makes the regulation surrounding trading cryptocurrency much clearer. It followed guidance provided by experts who estimated that cutting duplicate licenses could reduce the operating costs of mid-tier exchanges by 30% ⁴.
While cryptocurrency is completely legal in Australia, it’s not viewed as legal tender, so businesses are not required to accept it as payment. Similarly to the UK, crypto providers must ensure customers complete identity verification when purchasing crypto to help prevent money laundering. Aside from that, and despite almost a third of Aussies owning crypto, it remains a largely unregulated market⁵.
Who regulates crypto in Australia?
The Australian Securities and Investments Commission (ASIC) is responsible for regulating activities which involve financial products such as crypto. However, not all digital assets meet the criteria to qualify as a financial product, so they only manage certain types of stablecoins and tokens. Anyone who trades these financial products must hold an Australian Financial Services License.
Digital assets that don’t fall under ASIC’s remit are managed by the Australian Transaction Reports and Analysis Centre (AUSTRAC), which regulates these assets according to the Anti-Money Laundering and Counter-Terrorism Act of 2006. As a result, only digital currency exchange providers currently need to register with AUSTRAC; however, this is set to change following the streamlining of licensing, so all digital asset providers will need to register with AUSTRAC by the 31st of March. The government aims to tackle money laundering and fraud through this process, in addition to making regulation clearer.
Recent and upcoming changes
One change we’re more likely to see is a ban on crypto ATMs, which Minister for Home Affairs Tony Burke says pose an ‘unacceptable risk of money laundering’. The ATMs allow users to turn their cash into digital currency in minutes and have been flagged as a money laundering and fraud concern for a while. Australia is home to 2,000 crypto ATMs, which AUSTRAC estimates have around $275m passing through annually⁶.
In an experiment conducted by law enforcement, it was found that 90% of the biggest crypto ATM users in the country were either scam victims or money mules who were tricked into moving money around. They were also found to disproportionately target those aged between 50 and 70, who are at the highest risk for scams.
Making USA the ‘Crypto Capital of the World’
President Donald Trump has been a vocal supporter of cryptocurrency. He has his own cryptocurrency $TRUMP, his family owns a $5bn stake in the crypto firm World Liberty Financial and highlighted throughout his campaign an aim to make the USA the ‘crypto capital of the world’⁷. Since taking office on the 20th of January 2025, Trump has supported the growth of crypto in the US through supportive legislation, including allowing investment in it into 401ks and the introduction of the GENIUS Act.
A close look at the US crypto regulations
At the start of August, Trump published an executive order to make it easier for retirement savings, which are called 401ks in the US, to include investments in cryptocurrency. Instead of a pension like we have here in the UK, American employees are offered the opportunity to contribute to an investment plan that their employer can also pay into. Usually, these are separately managed by a financial firm that controls where the money goes and the level of risk. Following the executive order, employees will now be able to elect that their payments go towards digital currency investments.
Although the full details of the GENIUS Act are not yet clear, we do know that it will focus on making cryptocurrency regulation more consistent. It’s the first piece of national legislation that will consolidate how crypto is managed throughout the country. It will also back stablecoins one-to-one with US dollars, which should help to support their value.
Easing of regulations
A big focus for the Trump administration has been on making it easier for individuals to trade cryptocurrency. Another way they’ve aimed to do this is by disbanding the Crypto Enforcement Team and redirecting those resources to focus on terrorism and drug crime. Trump accused former President Joe Biden’s administration of a reckless path of regulation through prosecution. The Enforcement Team was dedicated to monitoring crypto for fraud. Their closure signals a move away from prosecution.
What do crypto regulations look like around the world?
The monumental rise of cryptocurrency has caught some countries off guard and left the likes of Australia trailing behind when it comes to regulations. Confusion over which regulations and rules apply to different assets has made trading inaccessible and confusing for some individuals. Now, legislation such as the GENIUS Act, the Plan for Change and the AUSTRAC consolidation should change that. Although the restrictiveness of regulations varies across the world, the movement is towards support and clarity.
⁵ The Future of Crypto Regulation in Australia, Written by Johanna Leggatt, Published by Forbes.
