数字资产监管（英）

Digital Assets Regulation: Insights from Jurisdictional ApproachesI N S I G H T R E P O R TO C T O B E R 2 0 2 4Images: Getty ImagesDisclaimer This document is published by the World Economic Forum as a contribution to a project, insight area or interaction. The findings, interpretations and conclusions expressed herein are a result of a collaborative process facilitated and endorsed by the World Economic Forum but whose results do not necessarily represent the views of the World Economic Forum, nor the entirety of its Members, Partners or other stakeholders.© 2024 World Economic Forum. All rights reserved. No part of this publication may be reproduced or transmitted in any form or by any means, including photocopying and recording, or by any information storage and retrieval system.ContentsPreface 3Executive summary 4Introduction 51 Regulatory approaches, outcomes and unintended consequences 71.1 European Union 91.2 Gibraltar 111.3 Hong Kong SAR, China 121.4 Japan 141.5 Singapore 161.6 Switzerland 181.7 United Arab Emirates 201.8 United Kingdom 221.9 United States of America 232 Recommendations 262.1 Anti-money laundering (AML) and know your customer 27 (KYC) recommendations 2.2 Regulatory and technical sandbox recommendations 282.3 Decentralized finance (DeFi) recommendations 292.4 Privacy and security policy recommendations 30Conclusion 31Contributors 32Endnotes 35Digital Assets Regulation: Insights from Jurisdictional Approaches2As the adoption of digital assets continues, 2024 marks a pivotal moment for the global landscape of digital asset regulation. As of early September 2024, the total market capitalization of cryptocurrencies, one type of digital asset, was valued at $2.01 trillion and stablecoins comprised 8.5% of this market, amounting to $171 billion.1 When it comes to the status of regulation globally, according to a recent Bank for International Settlements (BIS) survey, two-thirds of the 86 jurisdictions surveyed were or will soon be regulating digital assets.2 The main goals of implementing regulation are to protect investors and consumers and maintain financial stability.As regulatory developments continue, countries such as Australia, the United Kingdom, Brazil and South Korea have this year committed to unveiling new regulatory frameworks. In addition, the full rollout of the European Union’s Markets in Crypto-Assets (MiCA) regulation is poised to set a precedent for comprehensive digital asset oversight.Although there has been recent progress in digital asset regulation, countries are taking divergent approaches and have established different timelines for creation and implementation. Each jurisdiction is developing regulations based on unique goals and objectives, which risks a lack of coordination globally.With these varying approaches, it is imperative that stakeholders collaborate to forge a secure and equitable regulatory environment. This necessitates the sharing of learnings from global regulatory e