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Matiashvili G.N. An analysis of approaches to cryptocurrency regulation using the US, EU, and China as examples. Cognitive Sciences in the Information Society. 2025; 5(3). Available at: https://knio.ru/PDF/04KN325.pdf (in Russian).

An analysis of approaches to cryptocurrency regulation using the US, EU, and China as examples

Matiashvili Georgy Nugzarovich
State University of Education, Moscow, Russia
E-mail: geo.matiashvili@gmail.com

Abstract. The article is devoted to a comparative analysis of regulatory approaches to the cryptocurrency markets in the leading economic centers — the United States, the European Union and the People’s Republic of China. The regulatory landscape of the cryptocurrency market demonstrates significant inter-regional differences. The multi-level supervision system in the United States, implemented through the federal agencies SEC, FinCEN and CFTC in combination with state legislation, generates complex licensing requirements. On the contrary, the European Union is moving towards the unification of the regulatory framework through the MiCA regulation, striving to ensure an optimal balance between consumer protection and stimulating innovative development. Chinese regulators have taken a radical approach, banning transactions with decentralized crypto assets while simultaneously introducing the state-owned digital currency e-CNY as a tool to strengthen monetary control and maintain macroeconomic stability. The researchers note the formation by the mid-2010s of an alternative approach to the American approach, characterized by the creation of specialized regulatory frameworks instead of adapting existing legislation. This regulatory model is being implemented in Germany, Luxembourg, France, as well as in Switzerland, which, while not an EU member, is integrated into the pan-European context. An analysis of the positive effects of regulatory measures indicates increased counteraction to financial offenses, increased investor protection, and the promotion of technological progress. At the same time, the identified negative consequences include a reduction in the investment potential of the industry, excessive regulation and possible infringement of the economic interests of market participants. The study of regulatory mechanisms demonstrates the variability of approaches: from point-by-point modification of existing legislation in the United States to comprehensive EU directives and the radical prohibitive course of the PRC. Achieving an optimal balance between ensuring public safety and supporting the innovative development of blockchain technologies is considered to be a key factor in the effectiveness of regulation.

Keywords: cryptocurrencies; nature of crypto assets; securities; Crypto-Currency Act of 2020; EU MiCA regulation; digital yuan; blockchain technologies

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