MiCA vs UK, US and Dubai: A Crypto Compliance Map for Global Operators
A crypto compliance map for global operators: MiCA in the EU, the FCA regime in the UK, SEC, CFTC and state licences in the US, MAS in Singapore and VARA and ADGM in the Gulf.
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Crypto is global, but crypto regulation is not. A business that wants to operate across the EU, UK, US and the Gulf faces four very different rulebooks. This article maps the major crypto compliance regimes so global operators can see where MiCA fits and what changes when they cross a border.
It is a high-level map, not legal advice. Licensing in any jurisdiction must be confirmed with local counsel. For the EU build, see our MiCA compliance software development.
European Union – MiCA
MiCA is the first comprehensive crypto framework in a major economy. One authorisation as a crypto-asset service provider passports across all 27 member states, supervised by the national competent authority where you are authorised. Rules for asset-referenced and e-money tokens applied from 30 June 2024 and rules for CASPs from 30 December 2024.
United Kingdom – the FCA cryptoasset regime
The UK regulates cryptoasset firms for anti-money-laundering through FCA registration, and applies financial-promotion rules to crypto marketing. A broader regulatory regime bringing more crypto activities into FCA authorisation is being developed. For now, the entry requirement is AML registration plus promotion compliance.
United States – SEC, CFTC and state licences
The US has no single federal crypto law. The SEC treats many tokens as securities, the CFTC treats others as commodities, and money transmission is licensed state by state, including New York’s BitLicense. Operating nationally can mean securities analysis plus dozens of state money-transmitter licences.
Singapore – MAS
Singapore regulates digital payment token services under the Payment Services Act, supervised by the Monetary Authority of Singapore, with licensing, AML and consumer-protection requirements.
Dubai and Abu Dhabi – VARA and ADGM
Dubai has a dedicated Virtual Assets Regulatory Authority (VARA) with activity-based licences. Abu Dhabi Global Market regulates virtual-asset activities through its Financial Services Regulatory Authority. Both are built specifically for crypto businesses.
The regimes at a glance
| Regime | Region | What it means |
|---|---|---|
| MiCA | EU (27 states) | One authorisation passports EU-wide |
| FCA cryptoasset regime | United Kingdom | AML registration plus financial-promotion rules |
| SEC, CFTC and state MTL | United States | Securities analysis plus state money-transmitter licences |
| MAS, Payment Services Act | Singapore | Digital payment token licensing |
| VARA and ADGM | Dubai and Abu Dhabi | Activity-based virtual-asset licences |
Building for multi-jurisdiction
The winning pattern is one compliance core, configured per regime. KYC, AML, monitoring, reporting and audit trails are common to every jurisdiction; what changes is the Travel Rule protocol, the reporting format and the licensing evidence. Build the core once, keep the jurisdiction-specific rules as configuration, and you can add a market without rebuilding.
Pharos Production builds MiCA compliance software with a configurable core that extends beyond the EU. See the cost breakdown, the compliance checklist, or request a gap assessment. We are not a law firm: licensing in each jurisdiction must be confirmed with local counsel.
FAQ
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Yes. A single CASP authorisation passports across all 27 EU member states.
You are supervised by the national competent authority where you are authorised, and you can serve clients EU-wide without a separate licence per country.
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MiCA is one harmonised regime with a single passportable authorisation. The US is fragmented: the SEC treats many tokens as securities, the CFTC treats others as commodities, and money transmission is licensed state by state.
Operating across the US is far more complex than a single MiCA authorisation.
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Yes. The UK is outside the EU, so a MiCA authorisation does not cover it.
UK crypto firms register with the FCA for anti-money-laundering and must follow financial-promotion rules, with a broader regime being developed.
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Dubai has a dedicated Virtual Assets Regulatory Authority (VARA) that issues activity-based licences. Abu Dhabi Global Market regulates virtual-asset activities through its Financial Services Regulatory Authority.
Confirm the specific licence with local counsel.
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Yes, with the right architecture. Build one compliance core for KYC, AML, monitoring and reporting, and keep jurisdiction-specific rules such as the Travel Rule protocol and reporting format as configuration.
That lets you add a market without rebuilding.
Role: Founder and CTO, Pharos Production
Focus: Architecture, Web3 products, smart contract security, high-load systems
Experience: 23 years in production delivery
