Recap: TRM Labs Quarterly Policy Roundtable, Q4 2025

Last week, TRM policy team's Ari Redbord and Angela Ang were joined by TRM’s EMEA Compliance Advisor Luke Dufour — and, in the spirit of year-end reflections, our festive holiday sweaters — for a review of what mattered most in global crypto policy in Q4 2025.

As jurisdictions around the world move from rule‑setting to execution, the discussion focused on how policy is being implemented in practice — from supervision and licensing to enforcement — and what that means for compliance teams navigating an increasingly complex regulatory landscape.

2025 in crypto policy: Toward regulatory clarity for institutional adoption

Angela opened the session with a look at TRM’s Global Crypto Policy Review & Outlook 2025/26, which set the frame for the discussion that followed. 

This year, TRM Labs reviewed crypto policy developments in 30 jurisdictions, representing over 70% of global crypto exposure, which revealed three trends:

• Stablecoins dominated policy agendas, with over 70% of jurisdictions progressing stablecoin regulation in 2025.
• Greater regulatory clarity created tailwinds for institutional adoption, with financial institutions in about 80% of jurisdictions announcing new digital asset initiatives.
• The impact of regulation on illicit finance remains clear. TRM analysis found that virtual asset service providers (VASPs), which are the most widely regulated segment of the crypto ecosystem, have significantly lower rates of illicit activity than the overall ecosystem.

Angela also noted a broader shift in tone. Led by the US, 2025 marked a turning point in global crypto policy, with noticeably friendlier attitudes toward crypto.

United States: From legislative momentum to agency-level execution

Ari agreed that 2025 had indeed been a watershed year for US crypto policy. And, Q4 reinforced that crypto policy momentum is no longer just about bills moving through Congress. Instead, regulators are increasingly using guidance, supervision, and enforcement to operationalize policy goals.

Ari pointed to growing expectations that agencies — including the SEC, CFTC, and Treasury — will continue to clarify crypto oversight through how they supervise firms and interpret existing mandates. While legislative debates over market structure continues, the practical reality for industry is being shaped now, through supervisory posture and enforcement signals.

However, crypto-friendly regulation does not mean enforcement against bad actors is neglected. On the contrary, the quarter saw arguably one of the largest enforcement actions in US history against Cambodian conglomerate Prince Group, which was running scam compounds across Southeast Asia.

EMEA: MiCA implementation and UK consultations

In Europe, Luke described 2025 as the year when MiCA decisively moved from text to execution. National competent authorities are implementing the regime, and firms are beginning to experience the practical implications of differences in supervisory approach, resourcing, and interpretation.

Some unevenness is expected at this stage. The challenge for regulators will be managing that through coordination and oversight — and for firms, navigating cross-border compliance in a live regulatory environment.

In the UK, policymakers continued to advance an ambitious consultation agenda, including significant work on stablecoin regulation. While directionally clear, the near-term task for firms is translating emerging stablecoin, custody, and prudential proposals into workable compliance builds that can scale as rules harden.

APAC: Implementation mode with new players in the arena

In APAC, implementation continues apace, but with a shift toward a more innovation forward tone in key jurisdictions  Notably, Australia released its long-awaited exposure draft for digital asset regulation with a notably more innovation-positive approach than earlier proposals. Hong Kong also continued to deliver on its ASPIRe roadmap, including steps this quarter that allow regulated VASPs to access global order books and expand products and services.

Alongside these mature regimes, new players are moving quickly into the regulatory arena. In 2025, Pakistan and Vietnam — ranked 3rd and 7th on TRM’s Country Crypto Adoption Index — advanced legislation to regulate digital assets, illustrating how decisively policy can move when governments act.

Stablecoins were also a major focus. JPYC, Japan’s first locally denominated stablecoin, went live this quarter, while Australia advanced draft stablecoin legislation and licensed issuers under existing frameworks. Looking ahead, the team is watching for Singapore’s draft stablecoin legislation, as well as how regulators — including in capital-control economies — balance stablecoin innovation with monetary policy considerations.

Stablecoins: Converging controls, diverging strategies

Stablecoins remained a consistent cross-regional theme in Q4, largely because regulators view them as the most payments-like crypto asset — and therefore one of the clearest bridges between traditional finance and blockchain-based systems. Rather than full convergence, the discussion highlighted an increasing focus on similar risk controls, particularly around reserves, redemption, governance, and AML.

At the same time, the group emphasized that stablecoin policy remains deeply shaped by domestic objectives, especially in jurisdictions with capital controls or strong monetary policy considerations. In those markets, the approach is more nuanced: regulators are actively exploring how to enable stablecoin innovation and utility without undermining financial stability or currency sovereignty. As a result, stablecoin frameworks are likely to remain selective and context-specific, reflecting both use cases and broader macroeconomic constraints.

Compliance and financial crime: Control design needs to match on-chain speed

The webinar also saw a number of questions from the audience around crypto compliance controls, and how financial institutions should be thinking about risk management for digital assets. Luke emphasized that effective crypto compliance increasingly requires dynamic, risk-based controls that reflect the speed and transparency of blockchain activity.

Static programs are no longer sufficient. Instead, regulators and law enforcement expect firms to demonstrate real-time awareness of risk, supported by blockchain intelligence and faster information-sharing across the ecosystem. Ari reinforced that enforcement outcomes will continue to test whether controls actually work under pressure.

What we’re watching in 2026

Looking ahead, Ari noted that a key question in the US is how regulators translate policy signals into concrete supervisory expectations, as agencies continue to shape markets through guidance, examinations, and enforcement.

Angela highlighted a packed first quarter of policy implementation for APAC — including Hong Kong’s expected first stablecoin licenses and Australia’s travel rule rollout — which should bring more clarity on how new rules operate in practice.

In EMEA, Luke emphasized the need for greater consistency in MiCA implementation, watching closely to see whether supervisory approaches converge as regimes mature. 

Across regions, the team agreed that financial crime resilience will remain central, with sanctions exposure, evolving typologies, and real-time on-chain interdiction continuing to drive regulatory focus.

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