Other Jurisdictions
Digital asset legislation from South Korea, India, Australia, Brazil, Germany, France, Liechtenstein, Bahrain, and beyond.
Digital asset legislation is not a story of five or six major centres. South Korea’s comprehensive VASP framework, Australia’s licensing reform consultation, Brazil’s central bank digital currency programme, Liechtenstein’s blockchain act — one of Europe’s most permissive — and Bahrain’s CBB-administered crypto rules each represent distinct regulatory philosophies with direct implications for market structure. India and the United States are both notable non-signatories to the OECD’s CARF framework, underscoring that the most consequential jurisdictions do not always move fastest. This section tracks legislative developments across the full universe of tokenisation-relevant markets beyond the primary coverage areas.
Australia's Crypto Regulation: Token Mapping, Licensing Reform, and the Long Wait for Clarity
Australia conducted a comprehensive 'token mapping' exercise in 2023 and proposed a licensing framework for digital asset exchanges — but implementation has been slow, leaving the industry in prolonged regulatory uncertainty.
Bahrain's Crypto Regulation: The Gulf Pioneer and CBB's Pragmatic Framework
Bahrain became one of the first Gulf states to regulate cryptocurrency exchanges when the Central Bank of Bahrain issued its crypto asset module in 2019 — positioning the island kingdom as a Gulf FinTech hub.
Brazil's Virtual Assets Act: Latin America's Most Advanced Crypto Framework
Brazil's Virtual Assets Act (Law 14,478), signed December 2022, created a licensing framework for Virtual Asset Service Providers — making Brazil the most advanced crypto regulatory jurisdiction in Latin America.
France's PSAN Regime: Optional Licensing, Optional MiCA, and the AMF's Pragmatic Approach
France's PSAN (Prestataires de Services sur Actifs Numériques) regime created an optional licensing framework for crypto service providers — and became one of the first EU member states to invite early MiCA adoption.
Germany's Electronic Securities Act: Digitalising the Bund
Germany's Electronic Securities Act (eWpG), in force since 2021, allows securities to be issued as electronic records — a significant legal modernisation that enables tokenized securities without requiring traditional paper certificates.
India's Crypto Tax: The 30% Flat Rate and Its Chilling Effect
India imposed a 30% flat tax on crypto gains and 1% TDS on transactions in 2022 — one of the world's most restrictive crypto tax frameworks, reflecting the Reserve Bank of India's continued skepticism of digital assets.
Liechtenstein's Token Act: The World's First Comprehensive Token Economy Law
Liechtenstein's Token and Trusted Technology Service Provider Act (TVTG), in force since 2020, created the world's first comprehensive legal framework for token economies — a remarkable achievement for a microstate of 39,000 people.
South Korea's Virtual Asset User Protection Act: Consumer-First Crypto Regulation
South Korea's Virtual Asset User Protection Act, effective July 2024, focuses on protecting retail investors — requiring exchanges to segregate customer assets, maintain insurance, and meet transparency standards.