The Crypto Expat’s Weekly Briefing: Navigating Global Shifts in Regulation, Tax, and Security (June 23-30, 2025)

Introduction: The Great Regulatory Divergence

This past week has marked a pivotal moment in the global crypto regulation landscape, defined by what can only be described as a “Great Divergence” in regulatory philosophies. As crypto investors and multinational corporations chart their course, the world is rapidly fracturing into distinct zones of opportunity and risk.

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North America: U.S. Crypto Policy Shift

In the U.S., the government is signaling a pro‑innovation pivot aimed at reclaiming America’s position as a premier hub for digital asset enterprise. A presidential executive order now elevates “responsible growth and use of digital assets” to a national priority, rescinding previous guidance. A new SEC Crypto Task Force, chaired by Commissioner Hester Peirce, is developing a comprehensive regulatory framework addressing token registrations, custody standards, and staking/lending rules, directly tackling the industry’s pain points.

Notably, the SEC has reversed SAB 121, enabling traditional banks to offer crypto custody, opening the floodgates for institutional adoption.

Legislative momentum is accelerating too. The GENIUS Act of 2025 passed the Senate on June 17, requiring stablecoins to be fully backed by liquid reserves, segregated from corporate assets, and verified monthly.

• A companion overview from Goodwin Law outlines issuer tiers, AML/CRA obligations, and federal regulatory roles.
• Reuters confirms Senate approval and details key compliance measures .

Despite broad support, there are critiques that it doesn’t fully address conflicts of interest, as discussed by New Yorker and AP .

Bottom line: The U.S. is replacing ambiguity with clear, comprehensive crypto regulation, featuring a tiered system under the SEC and CFTC, necessitating robust legal and compliance strategies.

1. The Regulatory Tsunami: Mapping the New Crypto Landscape

Global crypto regulation is shifting dramatically, creating three distinct regulatory blocs: the United States, the European Union, and an emerging Vietnam-led Asia hub. For crypto businesses, this new landscape demands careful jurisdictional due diligence.

1.1. U.S. Reopening for Crypto Business

• Policy Pivot: A presidential order reversing approach and establishing the SEC Crypto Task Force.
• Custody Expansion: Revocation of SAB 121 frees banks to hold crypto custody.
• Stablecoin Legislation: The GENIUS Act passed Senate, setting reserve and disclosure requirements.
• Regulatory Complexity: Dual-track oversight with the SEC tackling securities and the CFTC handling commodities requiring nuanced compliance investments.

This proactive U.S. crypto policy aims to position America as the global magnet for crypto capital and innovation, exerting competitive pressure on other regions especially the EU.

1.2. Europe’s MiCA Moment: The Great Compliance Deadline Arrives

As the U.S. tightens its embrace on crypto innovation, the EU ignited its MiCA regime on June 30, 2025, when all 27 member states submitted their national MiCA frameworks and penalty systems to ESMA, activating the regulation’s enforcement phase. Simultaneously, ESMA published its final market‑abuse guidelines, equipping NCAs with robust tools to combat insider trading, particularly in DeFi ecosystems and social media‑driven manipulation.

In a bid to simplify the overlap between frameworks, the European Banking Authority issued a no‑action opinion on June 10, clarifying that issuers of e‑money tokens (EMTs) should be regulated under MiCA rather than PSD2, though it advised awaiting formal updates via the upcoming PSD3/PSR legislative package.

Despite these efforts, implementation remains fragmented. Under MiCA’s grandfathering provisions, incumbents could opt for an 18‑month transition period, until July 1, 2026. France, Luxembourg, and Bulgaria embraced the full term, while the Netherlands and Poland truncated theirs to six months, creating a patchwork of regulatory timelines .

Hungary, however, jolted the bloc with a dramatic escalation: effective July 1, 2025, its new national law will criminalize unauthorized crypto‑asset transactions, imposing prison sentences of up to eight years for offenses over HUF 500 million (~€1.25M) . This sets a stark precedent, signaling that holding a MiCA passport no longer guarantees legal immunity, rigorous country‑by‑country compliance due diligence is now indispensable.

What’s emerging is a two‑tier EU crypto market: Tier 1 nations, like France and Germany, are implementing MiCA predictably, attracting institutional interest; Tier 2 nations, with harsher enforcement or truncated transitions like Hungary, are creating risky environments that could drive capital and firms elsewhere. Such fragmentation risks undermining MiCA’s goal of a consolidated digital single market, weakening the EU’s competitive position compared not only to a unified yet detailed U.S. regulatory framework but also to nimble Asian crypto hubs.

1.3. Asia’s New Powerhouse: Why All Eyes Are on Vietnam

On June 14, 2025, Vietnam’s National Assembly passed the landmark Law on Digital Technology Industry, establishing for the first time a clear legal foundation for crypto assets in Vietnam. The law, which will come into force on January 1, 2026, marks a decisive shift as the country steps out of regulatory ambiguity to position itself as one of the most promising and strategically aligned crypto jurisdictions in Asia.

This transformation comes in a market that already boasts one of the highest crypto adoption rates in the world, with recent estimates suggesting that between 17% and 27% of the Vietnamese population owns digital assets, placing it ahead of the U.S., Japan, or Germany in terms of per-capita usage. With a national market value exceeding $100 billion, the demand for regulatory clarity was urgent.

The new law introduces a clear taxonomy distinguishing crypto assets (financial instruments like tokens) from virtual assets (non-financial assets such as game tokens), while explicitly excluding CBDCs and securities to avoid jurisdictional conflicts. It mandates that all crypto exchanges operating in Vietnam must secure a local license, establish a physical presence, meet minimum capital thresholds, and comply with strict AML/CFT regulations aligned with FATF standards, a direct response to Vietnam’s 2023 inclusion on the FATF grey list.

But Vietnam’s strategy extends well beyond compliance. The legislation is bundled with high-impact economic incentives aimed at attracting both foreign and domestic crypto innovation:

• Long-term corporate tax incentives of up to 15 years with rates as low as 10%.
• Full exemptions from import duties and land lease fees for eligible crypto and AI startups.
• Generous R&D subsidies and workforce training programs for blockchain development.
• A fast-track blockchain visa program for skilled foreign professionals and entrepreneurs.

These features place Vietnam in what many analysts now describe as a “regulatory Goldilocks zone“—not too permissive, not too strict. It blends the licensing discipline of MiCA with the pro-growth incentives seen in the recent U.S. crypto pivot, creating a hybrid model that’s uniquely competitive in the Southeast Asian region.

What sets Vietnam apart, however, is the integration of crypto policy into a broader national digital agenda. Alongside crypto, the state is aggressively promoting semiconductor manufacturing, AI development, and advanced digital infrastructure, creating a synergistic ecosystem few jurisdictions can match. For crypto firms, this means Vietnam is not merely a tax-efficient location, but a strategic base embedded in an emerging digital technology supply chain.

Unlike traditional crypto tax havens, Vietnam is building a future-proofed digital economy, positioning itself as the central node of Southeast Asia’s blockchain revolution.

Section 2: The Global Tax Maze: Finding Shelter in a Transparent World

As regulatory frameworks solidify, tax authorities worldwide are intensifying their focus on the digital asset class. For investors and companies, navigating the complex and divergent tax policies is as critical as regulatory compliance. This week saw key developments in the US, while the map of tax-friendly jurisdictions continues to evolve.

2.1. US Tax Update: IRS Extends a Cautious Olive Branch to Brokers

On June 12, 2025, the IRS issued Notice 2025‑33, which extends transitional relief for Form 1099‑DA broker reporting requirements through December 31, 2027. This means that while brokers must still issue 1099‑DA forms starting in 2025, penalties for backup withholding failures and TIN mismatches are suspended if brokers verify payee TINs using the IRS TIN Matching Program. Additionally, withholding on crypto‑for‑crypto trades in 2027 is capped at 24 % of the value at liquidation, not the transaction’s initial value.

However, this narrow relief applies only to centralized exchange brokers—DeFi protocols, non-custodial wallets, and miners remain excluded, with future IRS guidance expected . The underlying principle that crypto is treated as property for U.S. tax purposes remains unchanged: any disposal, be it selling, swapping crypto, or paying for goods, triggers capital gains tax, while activities like staking, mining, or receiving airdrops count as ordinary income .

For U.S. citizens abroad, worldwide taxation still applies: all crypto gains, even if realized in a low-tax country like Germany, are subject to U.S. tax. The annual choice between using the Foreign Earned Income Exclusion (FEIE) or the Foreign Tax Credit (FTC) remains a vital strategic decision for expats .

This extension isn’t a retreat, it’s a tactical enforcement strategy. By granting brokers time to build compliance systems while mandating basic taxpayer identifiers, the IRS aims to strengthen future tax enforcement. It also deepens the CeFi vs. DeFi compliance divide, signaling that operating a centralized exchange in the U.S. will be more compliance-heavy but legally clearer, while DeFi users may face higher future scrutiny.

2.2. The Expat’s Guide to Crypto-Friendly Jurisdictions in 2025

For high-net-worth investors and mobile entrepreneurs, the allure of crypto tax havens and jurisdictions with clear, favorable regulations remains a powerful driver for expatriation. As of mid-2025, a handful of countries stand out for their combination of tax incentives, regulatory clarity, and pathways to residency. The key to unlocking these benefits is establishing legitimate tax residency, a process that typically involves obtaining a residence permit and spending a significant portion of the year (often 183 days or more) in the country.  

Leading destinations include the United Arab Emirates, Switzerland, Portugal, and Malta, each offering a distinct value proposition. The following table provides a comparative analysis to aid in strategic decision-making.

Jurisdiction	Corporate Tax on Crypto	Personal Capital Gains Tax (Long-Term)	Personal Capital Gains Tax (Short-Term)	Residency/Citizenship Pathway	Key Regulatory Framework	Strategic Notes
UAE (Dubai/Abu Dhabi)	0%	0%	0%	Golden Visa (real estate/business investment)	VARA (Dubai), ADGM (Abu Dhabi)	A premier hub for businesses and high-net-worth individuals. Offers tax-free crypto free zones (e.g., DMCC) and a clear, business-friendly regulatory environment. Strong link between real estate investment and residency.
Switzerland	Varies by canton	0% (for personal investment)	0% (for personal investment)	Lump-sum taxation for residency	FINMA guidelines	The original “Crypto Valley” remains a top-tier destination for privacy, security, and regulatory maturity. Best for long-term holders; professional trading may be taxed as business income.
Portugal	Standard corporate rates	0% (if held >1 year)	28% (if held <1 year)	Golden Visa (investment), D7 Visa (passive income)	MiCA compliant	No longer a zero-tax haven, but still highly attractive for long-term investors. The distinction between short-term and long-term gains is now critical.
Malta	35% (refunds can lower effective rate)	0% (for long-term investment)	Taxed as business income for frequent traders	Residency/Citizenship by Investment	MiCA compliant	The “Blockchain Island” offers a special tax regime for residents. Best for buy-and-hold investors rather than active, professional traders.
Panama	0% (on foreign-sourced income)	0%	0%	Friendly Nations Visa, other residency options	Developing framework	A growing hub with a territorial tax system, meaning foreign-sourced crypto gains are not taxed. Regulatory clarity is still evolving.
El Salvador	0% (for foreign investors)	0% (on Bitcoin gains)	0% (on Bitcoin gains)	Citizenship by investment (Bitcoin-focused)	Bitcoin Law	The pioneering nation for Bitcoin as legal tender. Offers complete tax exemption on Bitcoin gains but faces infrastructure and economic challenges.
Vietnam	As low as 10% for 15 years (for qualifying tech firms)	To be determined	To be determined	Special visas for tech investors/talent	Law on Digital Technology Industry (effective 2026)	The rising star. While personal tax rules are pending, the extremely low corporate tax and strategic tech incentives make it a top future destination for crypto companies.

Section 3: Fortifying the Fort: Security, Compliance, and a Crackdown on Crime

As the crypto industry matures, operational resilience and regulatory compliance have become non-negotiable pillars for success. This week’s events underscore a global tightening of financial crime prevention standards and a coordinated international effort to pursue illicit actors, leaving no corner of the digital world untouched.

3.1. The Travel Rule and AML: The New Global Standard

In 2025, the FATF Travel Rule has become a global compliance baseline, transforming crypto operations into mirror images of traditional banking AML practices. Under FATF Recommendation 16, Crypto-Asset Service Providers (CASPs), including exchanges, brokers, and custodial wallets, must now collect, verify, and transmit sender and recipient data with every transaction.

3.1.1 Europe: Transfer of Funds Regulation (TFR)

In the European Union, this has crystallized in the EU Transfer of Funds Regulation (TFR), which fully integrates the Travel Rule into MiCA. Since December 30, 2024, all crypto transfers, regardless of amount, must be accompanied by detailed originator and beneficiary information. There is no de minimis threshold or grace period, meaning even micro-transfers trigger compliance obligations.

3.1.2 Operational and Market Impacts

Implementing the Travel Rule demands significant investments in data platforms, identity verification, and encrypted messaging systems. These compliance costs are driving industry consolidation: well-funded players are acquiring smaller CASPs, while others are exiting the market. Although this streamlines regulatory oversight and reduces fragmentation, it may stifle innovation by sidelining nimble, startup players.

3.1.3 Compliance as Competitive Differentiator

In today’s crypto ecosystem, scalable compliance frameworks have replaced user experience and token variety as key differentiation points. Firms capable of building global AML infrastructure, in tandem with advanced blockchain analytics and legal teams, are positioned to excel. This shift has also accelerated growth in RegTech, with KYC vendors, transaction monitoring solutions, and Travel Rule interoperability tools becoming as essential as the exchanges themselves. 

3.2. Enforcement Spotlight: The Long Arm of the Law

A major international enforcement action on June 25, 2025, laid bare the reality of cross-border cryptocurrency crime. Spanish authorities, coordinated with Europol and agencies in Estonia, France, and the U.S., dismantled a massive crypto investment fraud ring, arresting five suspects. The network was responsible for defrauding over 5,000 victims globally and laundering approximately €460 million through a sophisticated structure involving cash withdrawals, bank wires, and crypto transactions across multiple exchanges.

This operation reinforces the findings in Europol’s 2025 SOCTA report, which warns that online financial crime, accelerated by AI-driven social engineering, is a growing threat. Such coordinated strikes showcase that illicit crypto activities, even those headquartered in lax jurisdictions, are vulnerable to highly integrated enforcement mechanisms across multiple continents .

In the U.S., enforcement focuses sharply on criminal AML violations, even amid a more lenient regulatory landscape for token classifications. A prime example is the February 2025 OKX guilty plea, when Aux Cayes FinTech Co. (OKX) admitted to running an unlicensed money-transmitting business, resulting in over $500 million in fines and forfeitures. U.S. Attorney Matthew Podolsky made it clear that there would be serious “consequences for financial institutions that avail themselves of the U.S. markets but violate the law”.

What This Means for Crypto Firms

Strategic advice: Operating legally is not enough, companies must be proactive, integrating multi-jurisdictional compliance layers to avoid becoming targets in international investigations.

Borderless law enforcement: The Spain/Europol bust proves that jurisdictional arbitrage is increasingly ineffective, geographic location offers no safe cover if your platform touches regulated markets.

Compliance is now non-negotiable: Even with more lenient token regulations, skirting basic AML and KYC laws can lead to criminal prosecution and massive penalties.

Section 4: Strategic Relocation: Visas, Havens, and Red Flags

For crypto entrepreneurs and investors, the decision of where to domicile themselves and their businesses is a complex equation of regulatory stability, tax efficiency, and personal liability. This week’s developments have brought both attractive opportunities and serious new risks into sharp focus.

4.1. The Golden Ticket: Leveraging Visas for Crypto Wealth

Programs like Golden Visas and Digital Nomad visas have become essential tools for crypto investors seeking tax-efficient residency. These legal pathways establish the foundation required to access favorable tax regimes, but require real integration with the host country.

In the Gulf, the Dubai Golden Visa stands out. By investing at least AED 2 million in property—frequently purchased with crypto funds—investors can qualify for a renewable 10-year visa, with privileges for sponsoring family members and traveling freely in and out of the UAE. UAE authorities, including the Abu Dhabi Residents Office, are aggressively promoting these programs to attract high-net-worth talent and capital, particularly from the digital asset space, alongside booming adoption of digital real estate acquisitions.

Europe also remains a top destination. Portugal’s Golden Visa and its D7 Passive Income Visa offer pathways to benefit from the country’s favorable crypto capital gains tax policy, where profits from crypto held for over 365 days are entirely tax-exempt. Meanwhile, Malta’s citizenship-by-investment programs similarly attract investors by offering access to its special tax regime.

However, securing residency is just the gateway. Investors must then prove genuine domicile—meeting the 183-day physical presence requirement, navigating local banking systems often cautious of crypto-linked funds, and mastering the local tax code’s exceptions and thresholds. Residency alone doesn’t guarantee benefits—it must be backed by real integration and compliance.

A powerful trend is emerging at the intersection of crypto wealth and real estate investment. In Dubai and Lisbon, wealthy crypto investors are deploying capital into brick-and-mortar properties, forming a powerful synergy: physical assets used to secure visas, which then provide access to favorable tax environments. This strategy isn’t just for lifestyle, it’s a central element of sophisticated tax and legal optimization strategies. Early indicators suggest this will continue to drive up property values in these elite crypto hubs and cement their reputation as emerging digital asset residency centers.

4.2. Jurisdictional Risk Assessment: Where Not to Go in 2025

Identifying growth opportunities is essential—but so is escaping jurisdictional risk, which now goes beyond outright crypto bans to include political volatility, regulatory unpredictability, and harsh personal liability regimes.

4.2.1 Hungary: Criminal Penalties & FDI Overreach

From July 1, 2025, Hungary’s new criminalization of unauthorized crypto-asset exchanges imposes up to 2 years imprisonment for significant transactions (HUF 5–50 million) and up to 8 years in more serious cases. Further, a June 24 amendment to its FDI screening law, grants the state a right of pre-emption over private deals within up to 90 business days. Together, these measures expose foreign crypto investors to both criminal jeopardy and political control.

4.2.2 U.S. State-Level Crypto Risk: Connecticut & California

Even with federal support for digital assets, state policies can still pose unexpected barriers:

• Connecticut’s HB 7082, effective October 1, bans state and municipal governments from accepting, holding, investing in, or creating virtual currency reserves. The law also tightens money transmission licensing rules, including mandatory 1:1 asset backing and enhanced consumer protection.
• In California, the DFPI’s implementation of the Digital Financial Assets Law (DFAL) has been delayed until July 1, 2026, due to a projected $193 million funding shortfall in the Financial Protection Fund. This delay introduces significant regulatory uncertainty in one of the world’s most tech-centric markets.

4.2.3 The Rise of the Political Risk Premium

Crypto leaders now must evaluate a “political risk premium”, assessing not just laws, but broader geopolitical trajectories. Hungary’s departure from the International Criminal Court (ICC) signals a trend toward legal isolationism, which could presage further aggressive crypto regulations. These shifts demand geopolitical due diligence that goes beyond standard compliance and legal vetting.

Key Takeaways for Crypto Stakeholders

• Criminal liability matters: Even within the EU, Hungary’s new laws pose real jail risk.
• State law overrides federal tone: Federal crypto friendliness won’t shield against restrictive state actions like Connecticut’s ban.
• Budget woes delay implementation: California’s DFAL may be slow to roll out, creating compliance limbo.
• Geopolitical shifts signal crypto risk: Monitor international positioning, like ICC withdrawal, for signs of regulatory hostility.

Conclusion & Forward Outlook: Actionable Insights for the Week Ahead

The global crypto landscape has irrevocably split into three camps:

• United States, re-emerging as a pro-innovation, TradFi-integrated hub, focused on regulatory clarity to attract capital.
• European Union, a high-compliance zone, offering scale but challenged by inconsistent national enforcement and political outliers.
• Asia (e.g., Vietnam), rising as a strategic crypto hub, blending regulatory certainty with economic incentives.

For crypto leaders, the path forward demands swift and strategic action tailored to each region’s unique risk‑reward framework.

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Actionable Recommendations

1. For Crypto Companies

It’s time to reassess your global strategy in light of the US/EU regulatory divergence. The assumption of a uniform “Western” approach is obsolete.

• Begin an Asia-Pacific strategy review, with Vietnam at the center, its policy merges crypto regulation with broader digital economy incentives, a rare opportunity.
• In the EU, conduct jurisdictional risk mapping, paying special attention to extreme liability zones like Hungary’s criminal crypto law .

2. For High‑Net‑Worth Investors

Now is the time to re-evaluate tax residency strategies.

• The benefits of crypto‑friendly jurisdictions like the UAE and Switzerland are becoming more tangible.
• U.S. expats must consult advisors on the impact of IRS Notice 2025‑33’s broker reporting extension and the unwavering requirement for worldwide taxation.

What to Watch Next

• SEC Crypto Task Force updates: Look for upcoming policy recommendations under Commissioner Peirce to enhance clarity on classification, custody, and disclosure paths.
• MiCA enforcement actions: The first penalty frameworks under MiCA’s activated enforcement regime will set the tone for EU compliance.
• Vietnam’s sub‑decrees: The coming regulations on DeFi, licensing, and taxation will complete the operational picture of its January 2026 crypto regime.

The Great Divergence is not abstract, it’s here, and it demands decisive positioning. The choices made today will define who the winners and losers are in tomorrow’s crypto economy.