2.1 Indonesia
2.1.1 Legal and Regulatory Framework
Indonesia classifies cryptocurrencies as commodities, regulated under the Commodity Futures Trading Regulatory Agency (BAPPEBTI). This classification permits crypto trading on registered exchanges but explicitly prohibits cryptocurrencies as payment instruments in transactions
[Indonesia and Cryptocurrency]
[Crypto Regulations in Indonesia—All You Need to Know in 2024].
In 2023, regulatory oversight began shifting from BAPPEBTI to the Financial Services Authority (OJK), which traditionally supervises banking and capital markets. This move aims to consolidate financial regulation and enhance consumer protection, though it introduces uncertainty for crypto startups regarding compliance and licensing under the new regime
[Indonesia Shifts Crypto Oversight to OJK Under New Regulation].
2.1.2 Licensing and Compliance Requirements
Crypto exchanges in Indonesia must obtain licenses from BAPPEBTI, which require compliance with operational standards, capital requirements, and AML/KYC protocols. Exchanges must implement robust customer identification processes and report suspicious transactions to prevent illicit activities
[Indonesia and Cryptocurrency].
The licensing framework emphasizes market integrity and consumer protection but is less comprehensive than Singapore’s Payment Services Act (PSA), which covers a broader range of payment services and imposes stricter technology risk management and consumer safeguards
[Regulatory Framework for Cryptocurrency: A Comparative Analysis of Malaysia, Indonesia and Singapore].
2.1.3 Taxation
Indonesia imposes taxes on cryptocurrency transactions, including capital gains tax and value-added tax (VAT). The crypto sector has advocated for tax reforms to remain competitive globally, arguing that current tax policies may hinder innovation and market growth
[Indonesia's crypto sector seeks tax reforms to compete globally].
2.1.4 Market Conditions
Indonesia’s crypto market has experienced increasing trading volumes, driven by retail and institutional investors. However, liquidity remains uneven across different tokens and exchanges, partly due to regulatory constraints and market fragmentation
[Investment Behavior and Strategy in Cryptocurrency in Indonesia].
New rules introduced by the Indonesia Stock Exchange (IDX) for liquidity providers aim to improve market depth and reduce volatility, indirectly benefiting crypto markets by fostering a more stable investment environment
[Indonesia Implements New Rules for Liquidity Providers].
Investor confidence in Indonesia’s crypto market is influenced by regulatory clarity and enforcement. The mandatory KYC and AML measures have increased trust among investors, although some perceive the regulatory environment as restrictive, especially for startups and smaller exchanges
[Investment Behavior and Strategy in Cryptocurrency in Indonesia].
Volatility remains a significant characteristic of the market, affected by global crypto trends and domestic regulatory announcements. Indonesian investors tend to be risk-tolerant but cautious, often adjusting their strategies in response to regulatory changes
[Reinvestment intentions in cryptocurrency: Examining the dynamics of risks and investor risk tolerance].
2.1.5 Historical Evolution of Regulations
Indonesia’s approach to cryptocurrency regulation has evolved from an initial absence of clear rules to a structured framework under BAPPEBTI. Early regulatory efforts focused on banning crypto as a payment method while permitting trading as commodities. Over time, the government introduced licensing, AML, and KYC requirements to address fraud and money laundering risks
[Indonesia and Cryptocurrency].
The recent transfer of oversight to OJK marks a significant shift, potentially signaling tighter integration of crypto within the broader financial system and more rigorous regulatory scrutiny
[Indonesia Shifts Crypto Oversight to OJK Under New Regulation].
2.2 United States
2.2.1 Enhanced Regulatory Clarity and Enforcement
In 2025, U.S. regulators have intensified efforts to clarify the classification of cryptocurrencies, particularly Bitcoin, under securities laws. The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have delineated jurisdictional boundaries, with Bitcoin generally recognized as a commodity, while many altcoins and tokens fall under securities regulation
[Crypto Regulations in the US—A Complete Guide (2025)].
AML regulations have been strengthened, requiring cryptocurrency exchanges and wallet providers to implement rigorous Know Your Customer (KYC) protocols and report suspicious activities more proactively. The Financial Crimes Enforcement Network (FinCEN) has expanded its oversight, mandating enhanced transparency for decentralized finance (DeFi) platforms and stablecoin issuers
[US Financial Regulators Chart New Path Forward for the Crypto Industry | BakerHostetler].
2.2.2 Taxation and Reporting
The Internal Revenue Service (IRS) has updated guidance to improve tax compliance, including clearer rules on capital gains reporting and the treatment of staking rewards and airdrops. Cryptocurrency transactions exceeding certain thresholds must be reported with greater detail, increasing compliance burdens for investors and exchanges
[Crypto Regulations in the US—A Complete Guide (2025)].
2.3 European Union
2.3.1 Implementation of MiCA and Consumer Protections
The EU’s Markets in Crypto-Assets (MiCA) regulation has come into force in 2025, establishing a unified regulatory framework for crypto-assets across member states. MiCA introduces licensing requirements for crypto-asset service providers, mandates transparency in stablecoin issuance, and enforces strict consumer protection measures, including clear disclosure of risks
[The 2025 crypto policy landscape: Looming EU and US divergences?].
AML directives have been harmonized, requiring exchanges and custodians to conduct enhanced due diligence and report suspicious transactions to national Financial Intelligence Units (FIUs). The EU also emphasizes environmental sustainability, encouraging crypto projects to disclose energy consumption metrics
[2025 Crypto Policy Outlook | Grant Thornton].
2.3.2 Tax Harmonization Efforts
While taxation remains largely a national competence, the EU is working toward greater harmonization of crypto tax policies to reduce arbitrage and improve compliance. Several member states have introduced digital asset-specific tax regimes, including capital gains taxes and VAT clarifications
[Cryptocurrency Regulation Tracker].
2.4 China
2.4.1 Continued Ban on Cryptocurrencies and Focus on CBDC
China maintains its strict ban on cryptocurrency trading, mining, and initial coin offerings (ICOs), citing financial stability and fraud concerns. Enforcement actions against illicit crypto activities have intensified, with authorities targeting underground exchanges and peer-to-peer trading networks
[A Global Overview of Cryptocurrency Regulations in 2025].
Simultaneously, China is aggressively promoting its digital yuan (e-CNY), positioning it as a state-controlled digital currency to replace cash and enhance monetary policy control. The government’s focus on CBDC development contrasts sharply with its stance on decentralized cryptocurrencies
[Recent Developments Raise Significant Questions about the Future of Regulation and Enforcement of Cryptocurrency].
2.5 Emerging Markets: India and Brazil
2.5.1 India’s Regulatory Balancing Act
India has adopted a cautious but evolving regulatory approach. The government has implemented a 30% tax on crypto gains and a 1% tax deducted at source (TDS) on transactions to improve transparency and revenue collection. Regulatory authorities are working on a comprehensive framework that aims to regulate crypto exchanges and enforce AML standards without stifling innovation
[PwC: Global crypto regulation trends for 2025].
2.5.2 Brazil’s Progressive Regulatory Environment
Brazil has emerged as a crypto-friendly jurisdiction with clear regulations for exchanges, custodians, and token issuers. The Central Bank of Brazil and the Securities and Exchange Commission of Brazil (CVM) have issued guidelines on AML compliance and consumer protection. Brazil is also exploring the issuance of a digital real CBDC to complement its crypto ecosystem
[PwC: Global crypto regulation trends for 2025].