The USA, UAE and EU have a common goal — to make the digital asset market safer and clearer. But the paths to this goal differ drastically. Looking at the map of global cryptocurrency regulation from above, three strategies can be seen:

The USA has focused exclusively on payment stablecoins, creating a clear but very narrow corridor of rules for them. Other crypto assets remain in a zone of uncertainty under outdated securities and commodities laws.

The UAE has built a comprehensive oversight system covering the full range of virtual assets. But this comes at the cost of a complex multi-layered structure with federal regulators, local authorities, and free zones — each with its own requirements.

The European Union has embarked on the most ambitious experiment: a single set of rules for absolutely everything — from utility tokens to systemically important stablecoins. In return, companies receive a "European passport" that opens access to 27 national markets at once.

Stablecoin Regulation in the USA, UAE and EU

The philosophy of stablecoin provision in the three jurisdictions reflects their general approaches to financial sovereignty:

The USA: Stablecoin Reserve Requirements

The GENIUS Act establishes banking standards for payment tokens:

• Reserves must be strictly 1:1 only in highly liquid assets (HQLA)

• Permitted assets: cash USD, insured bank deposits, short-term treasury bills (up to 93 days), overnight repo for treasury securities

• Categorical prohibition of rehypothecation — reserves cannot be pledged or loaned

• Monthly reporting signed by CEO and CFO

The UAE: Regulation of Payment Token Reserves

The UAE Central Bank requires full territorial control:

• Dirham token reserves — 100% in cash AED in an escrow account at a local bank

• The custodial bank cannot be part of the issuing group

• Bank subsidiaries can hold up to 50% of the reserves in UAE government bonds

• Foreign stablecoins are registered, but not issued

The EU: MiCA and Token Reserve Rules

MiCA distinguishes requirements by token types:

• ART (asset-backed tokens): a diversified pool of assets with strict concentration limits

• EMT (e-money tokens): requirements similar to traditional e-money

• Mandatory storage of reserves in credit institutions in the EU

The main difference: The USA and EU bet on the quality and liquidity of reserve assets, while the UAE focuses on their physical presence under the jurisdiction of the country.

Cryptocurrency Licensing in the USA, UAE and EU

The range of permitted cryptocurrency services and licensing requirements differ dramatically:

The USA: Cryptocurrency Service Licenses

GENIUS creates clear frameworks only for payment stablecoins:

• Federal non-bank issuers are licensed by the OCC

• Bank subsidiaries operate under the supervision of the primary banking regulator

• State licenses are limited to a volume of $10 billion

• Other crypto services are regulated under outdated SEC and CFTC rules

The UAE: Cryptocurrency Licensing System

A multi-agency system covers the full range of services:

• CBUAE: payment tokens (issuance, storage, conversion)

• SCA: all other virtual assets onshore

• VARA: the full range of services in Dubai

• DIFC and ADGM: specific regimes in financial zones

• Mandatory physical presence and a minimum capital of 15 million dirhams

The EU: CASP License under MiCA

MiCA offers the widest coverage of services:

• Single CASP license for custody, trading, exchanging, advising, managing portfolios

• "European passport" — one license for operation in 27 countries

• National regulators issue licenses, EBA and ESMA oversee systemically important players

Practical takeaway: The EU wins in terms of access scale, the UAE — in crypto hub attractiveness, the USA offers maximum certainty, but only for stablecoins.

Crypto Investor Protection in the USA, UAE and EU

The level of protection for crypto investors is a key indicator of the maturity of the regulatory regime:

The USA: Investor Protection under the GENIUS Act

Focused protection for stablecoin holders:

• Priority right to reserve assets in the event of issuer bankruptcy

• Monthly public reporting on reserve structure

• Independent audits for large issuers (over $50 billion)

• Weak point: no special regime against market manipulation and insider trading

The UAE: Investor Protection through VARA and the Central Bank

Basic protection with a focus on transparency:

• Explicit right of token holders to redemption at par

• Liability for issuers for providing false information

• VARA establishes market behaviour rules and prohibits manipulations

• Mandatory risk disclosure

The EU: Crypto Investor Protection under MiCA

The most comprehensive protection regime among all jurisdictions:

• Dual liability: issuers and their management personally liable for the accuracy of the whitepaper

• Custodial service guarantees: CASP reimburse customer losses due to hacks and technical failures

• Total ban: insider trading and market manipulation equated to similar violations in traditional markets

• Business conduct standards: honesty, fair pricing, absence of conflicts of interest, best execution of orders

Best Jurisdiction for Crypto Business: USA, UAE or EU

For stablecoin projects: The USA offers maximum legal certainty, but only for payment tokens pegged to the dollar.

For crypto exchanges and custodians: The EU provides unmatched scale advantages — one license for half a billion potential clients.

For DeFi protocols: The UAE is currently the most lenient towards decentralized solutions, while MiCA may force protocols to centralize.

For institutional investors: The EU offers the highest level of protection, comparable to traditional financial markets.

Conclusion: There is no universally best jurisdiction. The choice depends on the type of business, target audience, and willingness to comply with various levels of regulatory requirements.