United Kingdom vs United States of America: crypto regulation compared

Side-by-side across all nine dimensions, each value linked to its primary government source.

Dimension	United Kingdom	United States of America
CBDC status	Research cbdctracker.org ↗	Pilot cbdctracker.org ↗
Legal status	Legal, with restrictions Financial Conduct Authority (FCA) ↗	Legal, with restrictions IRS, U.S. Treasury ↗
VASP licensing	Registration only Financial Conduct Authority (FCA) ↗	Registration only Financial Crimes Enforcement Network (FinCEN), U.S. Department of the Treasury ↗
Stablecoin rules	Pending HM Treasury ↗	In force Office of the Comptroller of the Currency (OCC) — GENIUS Act ↗
Tax treatment	CARF reporting HMRC — Cryptoasset Reporting Framework ↗	Capital gains Internal Revenue Service (IRS) ↗
DeFi treatment	Addressed Bank of England ↗	Addressed U.S. Department of the Treasury ↗
NFT classification	Addressed HM Revenue & Customs (HMRC) ↗	Addressed Internal Revenue Service (IRS) ↗
Mining policy	Addressed HM Revenue & Customs (HMRC), Government of the United Kingdom ↗	Restricted New York State – Chapter 58 of the Laws of 2022 (Senate Bill S6486D) ↗
Enforcement intensity	High Financial Conduct Authority (FCA) ↗	High U.S. Securities and Exchange Commission (SEC) ↗